{
    "ucits": true,
    "type": "ETF",
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "leverage": 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[1]. The ETF tracks the MSCI Europe SRI Low Carbon Select 5% Issuer Capped Index primarily through direct investments in the underlying securities and/or limited use of derivatives for efficient portfolio management, not as an inherent part of the investment strategy[extracted text]. The ETF does not engage in securities lending, does not use significant leverage beyond UCITS limits, and does not embed derivatives such as swaps or structured products that would introduce complexity[extracted text]. The replication method is physical or optimized physical, which is transparent and straightforward for retail investors to understand[extracted text][2]. The risk profile is moderate to high due to equity market volatility but this reflects market risk, not structural complexity[extracted text]. The ETF promotes environmental and social characteristics but does not have a sustainable investment objective that would add complexity[extracted text]. There is no indication of embedded derivatives, leverage, inverse strategies, or complex index structures such as those involving CLOs or structured products. 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[2][3][4]. Therefore, the ETF is classified as non-complex under MiFID II."
}