{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives for investment purposes",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "The fund is classified as complex based on its potential use of derivatives. The Key Investor Information document states, 'The Fund may use derivatives for hedging, efficient portfolio management and investment purposes.' While use for hedging and EPM can be consistent with a non-complex classification, the inclusion of 'investment purposes' indicates that derivatives may be used as an integral part of the strategy to 'maximise total returns', not just for risk mitigation. This introduces a layer of structural complexity and specific risks, such as the explicitly mentioned 'Counterparty risk', which are difficult for an average retail investor to understand. According to MiFID II Delegated Regulation (EU) 2017/565 Article 57, a key factor for non-complexity is the ease of understanding the risks involved. The use of derivatives for investment objectives and the associated counterparty risk moves this fund beyond the non-complex presumption typically afforded to UCITS ETFs, thus warranting a 'complex' classification."
    }
}