{
    "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 (UBS MSCI Japan Socially Responsible UCITS ETF) uses physical replication of a transparent equity index (MSCI Japan SRI Low Carbon Select 5% Issuer Capped Index), which is straightforward and easily understood by retail investors. The fund does not engage in securities lending, does not use significant leverage, and derivatives, if used, are only for efficient portfolio management with minimal impact on risk-return profile. There is no indication of embedded derivatives or complex structured products such as CLOs. The risk profile is high due to market volatility but this does not imply structural complexity. The ETF's structure and risks are transparent and suitable for retail investors with basic knowledge. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, such UCITS ETFs are non-complex unless they embed derivatives integral to the strategy or have complex features, which is not the case here. Therefore, no appropriateness assessment is required for execution-only sales, and no comprehension alert is mandated."
}