{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Active Management",
            "Complex Index"
        ],
        "classification": "complex",
        "supporting_data": "The fund is classified as complex. Although it is a UCITS ETF using physical replication and only uses derivatives for Efficient Portfolio Management (EPM), its investment strategy is the primary driver of complexity. The fund is explicitly 'actively-managed' and follows a 'research enhanced' strategy with the objective to 'achieve a long-term return in excess of' its benchmark. This introduces a discretionary, 'black box' element, as the performance depends on the investment manager's active security selection (overweighting/underweighting) rather than simply tracking an index. An average retail investor cannot easily understand or predict the drivers of this active strategy. Furthermore, the benchmark itself, the 'MSCI Europe SRI EU PAB Overlay ESG Custom Index', is inherently complex. The 'Custom', 'SRI', 'PAB', and 'ESG' components signify multiple layers of screening and a non-standard construction methodology that is difficult for a typical retail investor to comprehend. The combination of an opaque active management strategy and a complex custom benchmark makes the product difficult to understand, thus overriding the non-complex presumption for UCITS ETFs."
    }
}