{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": [
            "Total return swaps usage",
            "Contracts for difference usage",
            "Counterparty risk from derivatives",
            "Securities lending counterparty risk",
            "Potential for investment leverage via derivatives"
        ],
        "classification": "complex",
        "supporting_data": "The ETF is classified as 'complex' despite being a UCITS fund, which are generally presumed non-complex. This presumption is overturned primarily due to the explicit mention of total return swaps in its investment policy. The Key Investor Information Document states that 'The Fund may invest up to 15% of its assets in total return swaps and contracts for difference. However, this is not expected to exceed 5%.' The provided MiFID II complexity assessment rules explicitly state: 'If any element of ... any Swap usage is identified then the 'classification' must be 'complex'.' This specific instruction takes precedence.While the Fund primarily uses physical replication by investing in the underlying shares, its policy also states that if it 'cannot invest directly in the companies that constitute the Index, it may gain exposure by using other investments such as ... derivatives'. This indicates that derivatives, including total return swaps, are integral to achieving its investment objective under certain circumstances and not solely for efficient portfolio management (EPM). The use of swaps introduces risks like counterparty risk and collateral risk, which are typically difficult for retail investors with basic knowledge to understand, contributing to the complexity assessment as per the rules.Furthermore, the ETF may engage in securities lending for up to 25% of its assets (expected). Although securities lending does not automatically classify an ETF as complex, it introduces additional counterparty risk. The KII also mentions 'Investment Leverage Risk' arising from the use of derivatives, indicating that while the fund itself may not employ direct leverage beyond UCITS limits, the use of derivatives can lead to economic exposure greater than the amount invested.Even though the underlying index (FTSE Asia Pacific ex Japan ESG Low Carbon Select Index) appears transparent and the fund's risk profile (6/7) primarily reflects market volatility, the presence and potential use of total return swaps and contracts for difference for investment purposes are the decisive factors for its 'complex' classification under MiFID II guidance."
    }
}