{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of Total Return Swaps for investment purposes/gaining exposure",
            "Use of Contracts for Difference for investment purposes/gaining exposure",
            "Explicit Counterparty Risk due to derivative usage",
            "Investment Leverage Risk associated with derivative use"
        ],
        "classification": "complex",
        "supporting_data": "The Fund is a UCITS ETF, which initially benefits from a presumption of non-complexity. However, this presumption is overturned by the Fund's explicit investment policy which states it 'may invest up to 10% of its assets in total return swaps and contracts for difference' and that it 'may also invest in derivatives for efficient portfolio management purposes (such as to manage risk and costs, or to generate additional capital or income) and for investment purposes'. The critical point is the use of 'total return swaps and contracts for difference' for 'investment purposes' or 'gaining exposure' (if direct investment is not possible), which makes the derivatives integral to the investment objective rather than solely for efficient portfolio management (EPM). MiFID II rules, as per the provided guidance, stipulate that 'If any element of Contingent Bonds or any Swap usage is identified then the 'classification' must be 'complex''. The KII explicitly lists 'Counterparty Risk' as a material risk not fully captured by the Risk and Reward Indicator, which directly arises from derivative exposure and is considered difficult for retail investors to understand. Furthermore, the KII mentions 'Investment Leverage Risk' arising from derivative use. While the primary replication method is physical, the allowance for and explicit use of total return swaps to gain exposure introduces a synthetic element and associated risks (like counterparty risk) that are inherently complex for a retail investor. The CESR guidance (CESR/09-295, paragraph 7 and Annex I) reinforces that derivatives are generally assumed to be complex and that instruments involving them for their core valuation or exposure are complex."
    }
}