{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Active Management",
            "Complex Indices"
        ],
        "classification": "complex",
        "supporting_data": "Although the fund is a UCITS ETF that uses physical holdings and only employs derivatives for Efficient Portfolio Management (EPM), its classification is 'complex' due to its investment strategy and benchmark. The fund is actively managed, meaning its performance relies on the discretionary decisions of the Investment Manager to overweight or underweight securities, which introduces a layer of opaqueness and strategy risk that is difficult for a retail investor to assess. Furthermore, the fund's performance is measured against a highly bespoke benchmark: the 'MSCI Europe SRI EU PAB Overlay ESG Custom Index'. The use of a 'Custom' index with an 'Overlay' and specific Paris-Aligned Benchmark (PAB) and SRI criteria makes it structurally complex and not easily understandable for an average retail investor. According to MiFID II rules, if the structure, risks, or the underlying index are difficult to understand, the asset is deemed complex. The combination of an active strategy with a non-standard, complex benchmark overrides the presumption of non-complexity for a UCITS ETF."
    }
}