{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Contingent Convertible Bonds",
            "Convertible Bonds",
            "Callable Bonds"
        ],
        "classification": "complex",
        "supporting_data": "Although the fund is a UCITS ETF and uses derivatives only for Efficient Portfolio Management (EPM) and currency hedging, its classification is 'complex' due to its investment policy allowing it to hold structurally complex instruments. The Key Investor Information document explicitly lists 'Contingent convertible debt securities' (CoCos), 'Convertible bonds', and 'Subordinated debt securities' which may be 'callable' as potential investments and material risks. These instruments introduce complexities that are difficult for a retail investor to understand, such as trigger events leading to value write-downs or conversion to equity, and embedded options (call features). According to MiFID II guidelines and the provided ESMA guidance (e.g., CESR/09-295), instruments with embedded derivatives like convertible and callable bonds are considered complex. The presence of CoCos, with their potential for sudden capital loss based on triggers, is a significant factor driving the complex classification, overriding the general non-complex presumption for UCITS.",
        "final_assessment": "Complex"
    }
}