{
    "ucits": true,
    "type": "ETF",
    "derivatives": false,
    "swaps": false,
    "leverage": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The UBS (Lux) Fund Solutions - MSCI USA Socially Responsible UCITS ETF is a UCITS-compliant ETF that primarily invests in shares of US companies following a socially responsible index. It uses physical replication by holding the underlying securities of the MSCI USA SRI Low Carbon Select 5% Issuer Capped Index. The fund may use derivatives only for efficient portfolio management (EPM) purposes such as hedging currency risk (currency forwards for hedging CHF exposure), but derivatives are not integral to the investment objective or synthetic replication. There is no securities lending, no significant leverage beyond UCITS limits, and no embedded derivatives or structured products. The index tracked is transparent and well-documented. The risk profile is high due to equity market volatility but does not imply structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, UCITS ETFs that physically replicate transparent indices and use derivatives only for EPM with minimal risk impact are classified as non-complex. ESMA guidance and CESR analysis confirm that such ETFs do not require an appropriateness test and do not trigger complexity classification. Therefore, this ETF is non-complex under MiFID II."
}