{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Active management, use of derivatives for risk management, ESG screening, securities lending, currency hedging",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is actively managed and invests primarily in other UCITS funds and ETFs, with at least 80% of assets in funds tracking ESG-compliant indices. The fund may use derivatives for risk management, cost reduction, and currency hedging, but not as a core strategy. Securities lending is permitted but is a secondary feature, managed within UCITS rules. The fund does not use significant leverage, synthetic replication, or embedded derivatives. The structure, risks, and objectives are transparent and described in the KID. The fund is UCITS-compliant, which under MiFID II Article 25(4)(a)(iv) generally presumes non-complex status, unless it is a 'structured UCITS'u2014which this fund is not, as it does not employ algorithm-based payoffs or complex portfolio techniques that would make the risk profile difficult for a retail investor to understand. The use of derivatives is limited to efficient portfolio management (EPM) and hedging, not integral to the investment objective, and does not introduce material counterparty or collateral risk that would override the UCITS presumption. Therefore, despite some derivative use and active management, the fund remains non-complex under MiFID II."
}