{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Potential use of derivatives",
            "Active quantitative strategy"
        ],
        "classification": "complex",
        "supporting_data": "The assessment begins with the baseline presumption that as a UCITS ETF, the fund is non-complex. However, this presumption is overturned by several factors. The Key Investor Information document explicitly states the fund 'may use financial derivatives' and lists 'counterparty risk' as a material risk, noting that 'A derivative counterparty may fail to fulfill its obligations which could result in a loss.' According to MiFID II rules and ESMA guidelines, the introduction of risks such as counterparty risk, which are difficult for a typical retail investor to understand, is a primary driver for a complex classification, even if derivatives are used for efficient portfolio management rather than for replication. Furthermore, the fund is actively managed using a 'proprietary quantitative stock-ranking model'. The opaque nature of such a quantitative strategy makes it difficult for a retail investor with basic knowledge to understand how investment decisions are made and the specific risks involved, further supporting a complex classification. While the fund uses physical replication by investing in stocks, the combination of an opaque active strategy and the potential use of derivatives with associated counterparty risk renders the product difficult to understand in its entirety."
    }
}