{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "complex_factors": "Currency hedging via forwards, potential use of derivatives for efficient portfolio management, high volatility due to equity exposure",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is authorized in Luxembourg and regulated under the UCITS Directive, which generally presumes non-complex status for UCITS funds[1]. The ETF tracks the MSCI EMU SRI Low Carbon Select 5% Issuer Capped 100% hedged to CHF Index (Net Return) primarily through physical replication, holding the underlying securities of the index. The fund may use derivatives, but only for efficient portfolio management (EPM)u2014specifically, to hedge currency risk between the reference currency (EUR) and the share class currency (CHF) using one-month currency forwards. The prospectus states that derivatives may also be used where direct replication is not possible or practical, but there is no indication that derivatives are central to the investment strategy or that synthetic replication (e.g., total return swaps) is employed. The fund does not engage in securities lending, does not use significant leverage beyond UCITS limits, and does not hold complex bonds or structured products like CLOs. The index is transparent and well-documented, and the fundu2019s structure and risks (market volatility, currency risk, tracking error) are clearly disclosed. While the risk category is high (6/7), this reflects equity market volatility, not structural complexity. The use of derivatives for currency hedging is a common, limited EPM activity under UCITS rules and does not, by itself, trigger a complex classification under MiFID II, provided the risks are well-disclosed and the strategy remains straightforward[1]. There is no evidence of embedded derivatives, contingent convertible bonds, or other features that would make the product difficult for a retail investor with basic knowledge to understand. Therefore, despite the potential for derivative use and currency hedging, the ETF remains non-complex under MiFID II[1]."
}