{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swap usage for efficient portfolio management (as per strict override rule)",
            "Counterparty risk inherent in derivative use"
        ],
        "classification": "complex",
        "supporting_data": "The fund is a UCITS ETF, which typically benefits from a presumption of non-complexity under MiFID II due to its regulated nature and physical replication method (full or optimized). The underlying index is transparent with a detailed ESG screening methodology. However, the Key Investor Information document states that the Fund 'may use derivatives in order to reduce risk or cost and/or generate extra income or growth', explicitly mentioning 'swaps' and 'futures' as examples of derivatives on an index. While this use is described for Efficient Portfolio Management (EPM) and not for synthetic replication of the core objective, the provided rules state: 'If any element of Contingent Bonds or any Swap usage is identified then the classification must be complex.' This strict instruction overrides the EPM distinction. Furthermore, the document highlights 'Counterparty risk' as a risk associated with the 'use of derivatives', which is identified as a complex risk for retail investors within the MiFID II framework. Although the ETF is physically replicated and not inherently leveraged, the explicit mention of swap usage and associated counterparty risk, combined with the strict classification rule provided, leads to a 'complex' classification."
    }
}