{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of swaps for index replication",
            "Potential for synthetic replication as an alternative to physical method",
            "Associated counterparty and collateral risks from derivative use"
        ],
        "classification": "complex",
        "supporting_data": "The Fund is a UCITS ETF, which are generally presumed non-complex. However, this presumption is overturned by specific features identified in the Key Investor Information Document. While the Fund states it will 'normally use a replication strategy by investing directly in the underlying equity securities' (physical replication), it explicitly notes that it 'may also (or alternatively) invest in financial derivative instruments (FDIs) which relate to the Index or constituents of the Index'. Crucially, the listed FDIs include 'swaps (including equity swaps and swaps on the Index)'. According to the provided MiFID II complexity assessment rules, if 'derivatives are integral to achieving its investment objective, such as using swaps or futures to replicate the index's performance', the ETF is classified as complex. The instruction further clarifies: 'If any element of ... any Swap usage is identified then the classification must be complex'. The fund's ability to use swaps for index exposure, even as an alternative, introduces synthetic replication capabilities and associated risks (e.g., counterparty risk, collateral risk) that are difficult for retail investors with basic knowledge to understand. Although the underlying MVIS Global Future Healthcare ESG Index is transparent, the potential for complex replication methods involving swaps overrides the presumption of non-complexity for a UCITS ETF. The high-risk rating (7/7) primarily reflects market volatility, not structural complexity, but the use of swaps is the determining factor for structural complexity."
    }
}