{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives for investment purposes",
            "Potential holdings of complex securitised debt"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF, which creates a presumption of being non-complex. However, this presumption is overturned by several key factors identified in the KIID. 1.  **Use of Derivatives**: The investment policy states the Fund may use derivatives not only for hedging and efficient portfolio management but also for 'investment purposes'. The use of derivatives as a core part of the investment strategy, rather than purely for risk mitigation, introduces a layer of complexity and associated counterparty risk that is difficult for a retail investor to understand.2.  **Potential for Complex Holdings**: The KIID contains a specific risk warning for 'Securitisation risk', describing 'investment in securities which generate return from various underlying groups of assets such as mortgages, loans or other assets'. This indicates the Fund may hold Asset Backed Securities (ABS) or similar structured finance products. According to ESMA guidance (CESR/09-295), such instruments are considered complex because their value is derived from underlying assets in a way that makes their structure and risk profile difficult to understand. While the Fund uses physical replication and is not leveraged, the combination of using derivatives for investment purposes and the potential to hold complex securitised debt makes its structure and risk profile opaque and not easily understandable for the average retail investor. Therefore, it is classified as a complex instrument under MiFID II."
    }
}