{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives used for efficient portfolio management (EPM)",
            "Counterparty risk",
            "Collateral risk",
            "Complex Index"
        ],
        "classification": "complex",
        "supporting_data": "The ETF aims to reflect the performance of the Solactive ISS ESG Total Return Net Emerging Markets Net Zero Pathway Index. While the primary replication method is physical, the KIID explicitly states that 'The fund may employ techniques and instruments in order to manage risk, reduce costs and improve results. These techniques and instruments may include the use of financial contracts (derivatives). Further, the 'Risk and reward profile' section notes that 'DERIVATIVES RISK: The fund may use derivatives to try to manage its investments more efficiently. This may not always be successful and may result in greater fluctuations in the value of the fund.' Although the use of derivatives is stated as being for EPM, the explicit mention of derivatives risk and the potential for greater fluctuations suggests that their use, even if limited, introduces elements of complexity that may be difficult for a retail investor to fully grasp. Additionally, the index itself is ESG-focused and uses specific screening and weighting methodologies based on 'Science-based targets', 'Climate disclosure standards', and 'Green revenue', which can be considered a complex index. The KIID also mentions 'Transaction costs and taxes, unexpected fund costs and market conditions such as volatility or liquidity issues may affect the ability of the fund to track the index,' and states the anticipated tracking error is 2%. The risk and reward profile rates the fund as category 6, indicating high potential for gains and losses due to strong fluctuations. While not explicitly mentioning swaps, the general 'use of financial contracts (derivatives)' and 'derivatives risk' implies the potential use of instruments like swaps which introduce counterparty and collateral risks, making the structure less straightforward for a retail investor. The nuances provided in the MiFID II rules, particularly concerning derivative use for EPM, highlight that even limited use can be flagged as complex if it introduces counterparty risk, which is implied here. Furthermore, the KIID states the fund aims to align with 'EU Paris-aligned Benchmark (EU PAB) standards and certain net zero frameworks,' indicating the complexity of the underlying index methodology."
    }
}