{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for hedging, not central to strategy; no embedded derivatives, swaps, or leverage; no complex indices or structured products; no securities lending; no contingent convertible bonds; no roll costs, contango, or backwardation effects; transparent index; high market risk but not structural complexity",
    "supporting_data": "The ETF is a UCITS-compliant, physically replicating fund tracking a transparent, ESG-screened equity index. It may use derivatives for efficient portfolio management (EPM), specifically for currency hedging, but derivatives are not central to the investment objective. There is no securities lending, no embedded derivatives, no swaps, no leverage beyond UCITS limits, and no exposure to complex indices or structured products. The fund's risk profile is high due to equity market volatility, but this reflects market risk, not structural complexity. The structure, risks, and payoff are straightforward for a retail investor with basic knowledge. The use of derivatives is limited to risk reduction and does not introduce significant counterparty or collateral risk. The index is transparent and well-documented. All these factors support a non-complex classification under MiFID II, as the derivative use is ancillary and the product's risks are easily understood.",
    "classification": "non-complex"
}