{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None identified",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which is automatically non-complex under MiFID II unless it is a structured UCITS or fails Article 57 criteria[1]. The ETF tracks the S&P Developed ESG Elite Dividend Aristocrats Index using physical replication, holding at least 90% of its assets in index constituents. While the fund may use derivatives for efficient portfolio management (EPM) in exceptional circumstances, such use is not central to the investment strategy and is not for synthetic replication or to achieve leverage. The fund does not engage in securities lending, does not use significant leverage, and does not hold complex bonds or structured products. The index is transparent and the fundu2019s structure, risks, and objectives are straightforward and disclosed in the KID. There is no evidence of embedded derivatives, contingent convertible bonds, or other features that would introduce complexity beyond standard equity market risk. Therefore, the fund meets all criteria for non-complex classification under MiFID II[1]."
}