{
    "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, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency. The ETF described invests predominantly in shares of the MSCI Emerging Markets SRI Low Carbon Select 5% Issuer Capped Index using a sampling strategy (portfolio optimization), which is a form of physical replication. The fund explicitly states it will not enter into securities lending and only uses derivatives potentially for risk reduction, which is minimal and consistent with efficient portfolio management (EPM). There is no indication of synthetic replication, embedded derivatives, leverage beyond UCITS limits, or complex structured products such as CLOs. The risk profile is high due to market volatility typical of emerging markets equities, but this does not imply structural complexity. The index tracked is transparent and well-documented. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, UCITS ETFs that do not embed derivatives as a core strategy and use physical replication are non-complex. ESMA and CESR guidance confirm that structured UCITS or those using synthetic replication or complex derivatives would be complex, but this ETF does not fall into those categories. Therefore, the classification is non-complex."
}