{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives for Currency Hedging",
            "Counterparty Risk"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF, which establishes a presumption of being non-complex. It uses an optimised physical replication method to track its benchmark index, which also supports a non-complex classification. However, this presumption is overturned by several key factors. This specific share class is currency-hedged ('GBP Hedged'), and the KIID explicitly states that 'FDIs, including FX forward contracts, will be used for currency hedging purposes.' The use of derivatives is therefore integral to the investment strategy of this specific share class. Furthermore, the KIID states that 'FDIs may be used for direct investment purposes,' which goes beyond simple Efficient Portfolio Management (EPM). Most importantly, the document explicitly identifies 'Counterparty Risk' as a particular risk not captured by the main risk indicator, stating that the insolvency of a counterparty to derivatives may expose the Share Class to financial loss. The need for a retail investor to understand the mechanics of FX forwards, the nuances of a hedging strategy that 'may not completely eliminate currency risk', and the concept of counterparty risk makes the product's structure and risk profile difficult to understand. In line with MiFID II rules, where derivative use is central to the strategy and introduces complex risks like counterparty risk, the ETF is classified as complex."
    }
}