{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Complex Index Methodology"
        ],
        "classification": "complex",
        "supporting_data": "The fund is a UCITS ETF, which initially presumes it to be non-complex under MiFID II. Its primary replication method is physical, investing directly in the underlying companies, which supports a non-complex classification. The fund states it 'may also invest in... financial derivative instruments (FDIs) which are investments the prices of which are based on the companies contained in the Index'. Given its primary physical replication strategy, this use of derivatives is interpreted as supplementary or for efficient portfolio management (EPM), rather than being integral to its core strategy or embedding complex structured products. Therefore, according to the provided rules ('If the asset may use derivative instruments for managing risk rather than as an inherent element of the strategy then make 'derivatives' = false'), 'derivatives' is set to false.However, the classification leans towards 'complex' due to the nature of its benchmark index. The Foxberry SMS USA Environmental Impact USD Net Total Return Index 'utilises a unique thematic classification and scoring system pursuant to which companies must derive at least 50% of their revenues from the sub-sectors of the u201cEnvironmental Impact Opportunitiesu201d thematic classification used by the Index and are primarily weighted according to their respective forward-looking Environmental Impact Scores'. This 'unique thematic classification and scoring system' and the use of 'forward-looking Environmental Impact Scores' introduce a level of methodological complexity that goes beyond a straightforward, transparent market-capitalization or traditional sector index. A retail investor with basic knowledge may find it difficult to fully understand how these scores are derived, how they influence the index's composition and weighting, and the implications for the ETF's performance. As per the provided MiFID II rules, if the 'index itself is complex or opaque... this can make the ETF complex', and if its 'structure or risks are opaque or require advanced knowledge to understand', it is classified as complex. While the fund's direct holdings are transparent, the underlying index's dynamic and proprietary methodology adds significant opacity to the 'ease of understanding' for an average retail investor. The high-risk rating (7/7) primarily reflects market volatility associated with its thematic focus on innovative and smaller companies, rather than structural complexity, but it reinforces the need for thorough investor comprehension."
    }
}