{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for efficient portfolio management, not central to strategy; no synthetic replication, no leverage, no securities lending, no embedded derivatives, no complex index, no contingent convertible bonds, no swaps, no inverse or leveraged features.",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is passively managed and invests at least 90% of its assets in the constituents of a transparent, ESG-screened equity index (MSCI USA Prime Value Advanced Target Select Index). Derivatives may be used for efficient portfolio management (EPM), such as managing inflows/outflows or hedging, but are not central to the investment strategy. The fund does not engage in securities lending, does not use synthetic replication, and does not employ leverage beyond UCITS limits. The structure, risks (primarily market volatility), and investment objective are straightforward and disclosed in the Key Investor Information Document (KIID). The use of derivatives introduces some counterparty risk, but this is mitigated by the fund's collateral policy and is not a dominant feature. There is no evidence of embedded derivatives, complex indices, or other features that would make the product difficult for a retail investor with basic knowledge to understand. The fund is UCITS-compliant, which under MiFID II generally presumes non-complexity unless specific complex features are present[1]. Here, such features are absent, and derivative use is limited and well-disclosed, supporting a non-complex classification."
}