{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via swap agreements",
        "Counterparty risk exposure",
        "Use of derivatives for index exposure",
        "Emerging markets exposure with ESG and low carbon screening"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is a UCITS-compliant fund that uses synthetic replication through swap agreements to achieve its investment objective, as explicitly stated in the KIID and factsheet. The fund does not invest directly in the underlying securities but enters into financial contracts (derivatives) with one or more swap counterparties to obtain the return on the MSCI EM Latin America Low Carbon SRI Selection Capped Index. The factsheet confirms the use of indirect replication (swap) and highlights counterparty risk as a key risk factor. There is no leverage or inverse exposure. The risk profile is high (category 7 in KIID, 5 in PRIIPs), reflecting volatility and derivative-related risks. The fund invests in emerging market equities with ESG and low carbon criteria, which adds complexity due to the nature of the index and the underlying market risks. The use of swaps and derivatives as an inherent part of the investment strategy, combined with counterparty risk and emerging market exposure, drives the classification as complex under MiFID II. No capital protection or structured features are present, and costs are straightforward with no performance fees. However, the synthetic replication and swap usage are decisive complexity factors."
}