{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthethic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of unfunded swaps (Swaps) to replicate the index's performance.",
            "Exposure to the Bloomberg Commodity Carbon Tilted Indexu00ae, which is a complex index applying GHG emissions criteria.",
            "Synthetic ETF risk as the fund enters into swap agreements with counterparties."
        ],
        "classification": "complex",
        "supporting_data": "This UCITS ETF is classified as complex due to its use of unfunded swaps for replication, which introduces counterparty risk and opacity. The fund's objective to achieve the total return of the Bloomberg Commodity Carbon Tilted Indexu00ae further adds to the complexity, as the index itself is based on a variant of the Bloomberg Commodity Index and applies environmental costs based on GHG emissions associated with the underlying commodity futures contracts, creating a structure that is difficult for the average retail investor to understand. The use of swaps falls under ESMAu2019s broad definition that considers even EPM use as complex, and therefore it requires comprehension alerts. (See MiFID II Complexity Assessment Rules, 2., Nuance). The index's complex structure and its use of futures contracts also contribute to complexity. Additionally, the fact that the fund is a synthetic ETF means it purchases securities not contained in the reference index and enter into swap agreements to exchange the performance of those securities for the performance of the reference index which also increases complexity (See MiFID II Complexity Assessment Rules, 3.)  The risk profile of the fund is high (risk category 6/7), also adding to the need for a comprehension alert in the KID. (See MiFID II Complexity Assessment Rules, 5.) The PRIIPs Key Information Document (KID) must include a comprehension alert (e.g., 'You are about to purchase a product that is not simple and may be difficult to understandu2019)."
    }
}