{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swap usage (total return swaps)",
            "Derivatives used for investment purposes (not solely EPM)",
            "Potential for synthetic replication when direct investment is not possible",
            "Explicit mention of Counterparty Risk as a material risk",
            "High securities lending exposure (up to 30%) contributing to counterparty risk",
            "The underlying index ('FTSE EPRA Nareit Developed Green EU PAB Index') incorporates complex, multi-faceted ESG and climate-aligned methodologies (e.g., GHG emissions intensity reduction, Green certificate increase, energy consumption reduction targets) that require more than basic knowledge to fully understand."
        ],
        "classification": "complex",
        "supporting_data": "The fund is a UCITS ETF, which initially presumes it to be non-complex. However, this presumption is overturned by several factors as per the MiFID II rules and ESMA guidance. The Key Investor Information Document (KID) explicitly states that 'The Fund may invest up to 10% of its assets in total return swaps and contracts for difference.' The provided rules clearly state: 'If any element of [...] any Swap usage is identified then the 'classification' must be 'complex'.' This alone triggers a complex classification. Furthermore, derivatives are stated to be used for 'investment purposes' in addition to 'efficient portfolio management', implying they are integral to achieving the investment objective, especially when direct investment in index constituents is not possible, which can lead to a partially synthetic replication approach. The KID also lists 'Counterparty Risk' and 'Investment Leverage Risk' (due to derivative use) as material risks, which are often associated with complex instruments and structures. The fund's ability to engage in securities lending for up to 30% of its assets further introduces counterparty risk. While the underlying 'FTSE EPRA Nareit Developed Green EU PAB Index' is transparent, its specific and quantitative ESG and climate alignment criteria (e.g., GHG emissions reduction, green certificate increase) add a layer of complexity beyond a standard, simple equity index, requiring a deeper understanding from a retail investor. Therefore, due to the explicit use of total return swaps for investment purposes and the associated risks, the fund is classified as complex."
    }
}