{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "optimized",
        "complex_factors": [
            "Use of derivatives including Total Return Swaps",
            "Optimized replication instead of full physical replication",
            "Exposure to small cap companies",
            "Securities lending",
            "ESG screening introduces complexity in tracking the index"
        ],
        "classification": "complex",
        "supporting_data": "The ETF is a UCITS ETF, but its complexity arises from several factors.  Firstly, it uses an optimized replication method instead of full physical replication which can introduce tracking error and make it less directly correlated to the underlying index. Secondly, it utilizes derivatives, including total return swaps (up to 10%, expected to be around 5%). While derivatives can be used for efficient portfolio management (EPM), their integral use introduces counterparty risk and collateral risk, making it more complex.  Thirdly, the ETF is exposed to small cap companies, which are generally more volatile and less liquid than large cap stocks. Fourthly, the ETF engages in securities lending which introduces counterparty risk. Finally, the ETF integrates ESG metrics, which introduces complexity into the selection process of companies. The underlying index also excludes certain companies based on ESG criteria, further complicating the investment strategy and increasing potential tracking error and introducing sector risk. Taken together these factors would make it difficult for an average retail client to understand this product.",
        "complex": true,
        "non_complex": false
    }
}