{
    "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 tracks the EURO STOXX 50 ESG Index primarily through direct investments in the underlying securities, i.e., physical replication, which is straightforward and transparent. Although the ETF may use derivatives, these are limited to efficient portfolio management (EPM) purposes, such as managing inflows/outflows or hedging currency risk, with minimal impact on the risk-return profile. The fund explicitly states it will not engage in securities lending, and there is no indication of significant leverage or embedded derivatives. The index tracked is transparent and well-documented. The risk profile is elevated due to market volatility (risk category 5/7), which does not imply structural complexity. The ETF's structure and risks are understandable by retail investors with basic knowledge. Therefore, it meets the criteria under MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation for non-complex classification. No features such as synthetic replication, significant leverage, embedded derivatives, or opaque structures are present to trigger a complex classification."
}