{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency. The ETF tracks the S&P 500 ESG ELITE Index using physical replication, holding underlying securities rather than synthetic replication with derivatives. Although the fund may use derivatives for risk reduction or cost management, these are limited to efficient portfolio management (EPM) purposes and do not form an integral part of the investment strategy, so derivatives are not considered inherent to the product's complexity. The fund does not engage in securities lending, does not use significant leverage, and does not embed complex derivatives or structured products such as CLOs. The underlying index is transparent and well-documented. The risk profile reflects market volatility typical of equity investments but does not imply structural complexity. Therefore, the ETF meets all criteria for non-complex classification under MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, and no comprehension alert is required in the PRIIPs KID. This assessment aligns with ESMA guidance and CESR technical advice that UCITS ETFs with physical replication and limited derivative use for EPM are non-complex. Hence, the classification is non-complex."
}