{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The UBS (Irl) ETF plc - S&P 500 ESG ELITE UCITS ETF is a UCITS-compliant ETF that seeks to track the S&P 500 ESG ELITE Index using a physical replication method. The fund is passively managed, invests primarily in equities of 500 leading US companies meeting sustainability criteria, and does not engage in securities lending or significant leverage. While it may use derivatives for currency hedging and efficient portfolio management, these are limited and do not form an integral part of the investment strategy. The ETF's structure, risks (market volatility, tracking error), and payoff are straightforward and transparent to retail investors with basic knowledge. The index tracked is a broad-based, market-cap weighted equity index with publicly available methodology, supporting non-complexity. There is no indication of embedded derivatives, synthetic replication, leverage beyond UCITS limits, or complex features such as structured products or contingent convertible bonds. According to MiFID II Article 254, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, such a UCITS ETF with physical replication, limited derivative use for EPM, and transparent structure is classified as non-complex. This aligns with the general presumption that UCITS ETFs are non-complex unless specific complex features are present. Therefore, no appropriateness assessment beyond standard disclosure is required for retail investors under MiFID II."
}