{
    "success": true,
    "data": {
        "type": "ETF",
        "ucits": true,
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": [
            "Integral use of Financial Derivative Instruments (FDIs) for direct investment purposes to achieve the investment objective",
            "Explicit mention of Counterparty Risk as a particular risk not adequately captured by the risk indicator",
            "Securities lending activity introducing additional counterparty risk",
            "Complexity of the underlying index methodology (factor-based, ESG optimization, carbon reduction targets)"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF, which typically benefits from a presumption of non-complexity. However, this presumption is overturned by several features. The Key Investor Information Document (KIID) states that Financial Derivative Instruments (FDIs) 'may be used for direct investment purposes' to help achieve the Fund's investment objective. This indicates that derivatives are integral to the strategy beyond efficient portfolio management (EPM), which, according to the provided rules, renders an ETF complex. Furthermore, 'Counterparty Risk' is explicitly listed under 'Particular risks not adequately captured by the risk indicator', confirming the presence of complex structural risks that are difficult for retail investors to understand. While the Fund uses physical replication, which typically supports a non-complex classification, the integral use of derivatives for direct investment and the associated counterparty risk override this. The Fund also engages in securities lending, which, although not automatically making an ETF complex, introduces additional counterparty risk and contributes to the overall complexity. Lastly, the benchmark index, the 'MSCI World Quality ESG Reduced Carbon Target Select Index', is not a simple market-capitalization index but involves an 'optimisation methodology' based on a 'quality factor' and ESG screening, adding a layer of complexity to its performance drivers that may be challenging for an average retail investor to fully grasp."
    }
}