{
    "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 (iShares MSCI Europe Industrials Sector EUR (Acc)) that aims to replicate the MSCI Europe Industrials 20/35 Capped Index by holding the underlying equity securities physically in similar proportions. The ETF uses derivatives only for limited purposes such as efficient portfolio management (e.g., short-term securities lending) and not as an integral part of the investment strategy. There is no indication of synthetic replication, embedded derivatives, leverage beyond UCITS limits, or complex structured products like CLOs. The index tracked is transparent and based on large and mid-cap equities in developed European markets, with clear methodology and quarterly rebalancing. The risk profile reflects market volatility typical of equity ETFs but does not imply structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, UCITS ETFs that physically replicate transparent indices and use derivatives only for EPM with minimal risk impact are classified as non-complex. ESMA and CESR guidance confirm that such ETFs do not require an appropriateness assessment for non-advised sales. Therefore, this ETF is classified as non-complex under MiFID II."
}