{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "None identified",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers Global Infrastructure ESG UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent, ESG-screened equity index. It is passively managed and aims to hold all or a substantial number of the index constituents, with no indication of synthetic replication, embedded derivatives, or complex structured products. While the fund may use derivatives for efficient portfolio management (EPM), such use is explicitly described as limited to risk management, cost reduction, or improving results, not as a core strategy or for leverage. The fund's risk profile (category 6) reflects market volatility of the underlying equities, not structural complexity. The index is administered by S&P Dow Jones Indices LLC, is reviewed and rebalanced at least quarterly, and full portfolio disclosure is available. There is no evidence of contingent convertible bonds, swaps, complex indices, or other features that would make the fund's structure or risks difficult for a retail investor with basic knowledge to understand. The fund meets all Article 57 criteria for non-complex UCITS ETFs under MiFID II: it does not embed derivatives as a core strategy, there are frequent opportunities to dispose of shares, no liability exceeds the cost of acquisition, no clauses fundamentally alter risk or payout, no exit charges render it illiquid, and comprehensive, understandable information is publicly available. Therefore, the fund is classified as non-complex."
}