{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is passively managed and aims to track the MSCI EMU Small Cap ESG Broad CTB Select Net EUR Index using direct (physical) replication, primarily by holding the underlying securities. While the prospectus states that derivatives may be used for efficient portfolio management (EPM) to handle inflows/outflows or to gain better exposure to index constituents, such use is ancillary and not central to the investment strategy. There is no indication of synthetic replication, embedded derivatives, structured products, or significant leverage. The ETFu2019s structure, risks (market, liquidity, counterparty, operational), and investment objective are transparent and straightforward, consistent with typical non-complex UCITS ETFs[1][2]. Securities lending is permitted but is a secondary feature, well within UCITS rules, and does not dominate the risk profile. The index tracked is a transparent, publicly documented equity index. All these factors support a non-complex classification under MiFID II Article 25(4) and Delegated Regulation Article 57, as the product does not embed complex features, does not rely on derivatives for its core strategy, and is easily understood by retail investors with basic knowledge[1][2]."
}