{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "supporting_data": "This UCITS ETF is physically replicated, tracking a transparent equity index (MSCI Europe Sector Neutral Quality Index). It uses derivatives only for efficient portfolio management (EPM), not as a core part of its investment strategy. The ETF does not use leverage, swaps, or inverse strategies. The structure, risks, and payoff are straightforward and easily understood by retail investors with basic knowledge. The ETF is UCITS-compliant, which generally presumes non-complexity under MiFID II, and there are no features (e.g., embedded derivatives, contingent convertible bonds, complex indices, or significant securities lending) that would override this presumption. The index methodology is transparent, and the risks disclosed (market risk, factor focus risk, counterparty risk from ancillary services) are typical for equity ETFs and do not introduce structural complexity.",
    "classification": "non-complex"
}