{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Active Management",
            "Derivatives for hedging",
            "High-yield and unrated bonds"
        ],
        "classification": "complex",
        "supporting_data": "The fund is classified as 'complex' despite its UCITS status. The presumption of non-complexity is overturned by several factors. Firstly, the fund is actively managed with no benchmark, meaning its performance is dependent on the manager's discretion within a broad and opaque universe, rather than a transparent index. This makes it difficult for a retail investor to understand the drivers of risk and return. Secondly, the fund uses currency derivatives for hedging, which explicitly introduces Counterparty Risk as noted in the KIID. According to MiFID II guidelines, the introduction of counterparty risk, even for EPM purposes, is a significant indicator of complexity. Finally, and most importantly, the investment policy allows for an unlimited portion of the fund to be invested in 'below investment grade' (high-yield) and unrated debt securities. The KIID itself describes these as 'largely speculative'. Such assets are inherently difficult for a retail investor to understand and assess, a key criterion for complexity under MiFID II. The combination of an opaque active strategy, derivative use with counterparty risk, and significant exposure to speculative debt renders the ETF complex."
    }
}