{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Derivatives",
            "Index Complexity"
        ],
        "classification": "complex",
        "supporting_data": "The ETF aims to track the Solactive Global SuperDividendu00ae v2 Index. While the primary replication method is physical investment in equity securities, the KIID explicitly states that the Fund may invest in 'financial derivative instruments (u201cFDIsu201d), namely, total return u201cunfundedu201d OTC swaps and exchange-traded equity futures for investment purposes.' The use of OTC swaps, even for investment purposes, combined with the mention of exchange-traded equity futures, indicates derivative usage. According to MiFID II, the use of derivatives, especially if integral to achieving the investment objective or for purposes beyond simple efficient portfolio management, can classify an instrument as complex due to the inherent risks (counterparty risk, collateral risk) that are difficult for retail investors to understand. The KIID also mentions that 'the Fund may attempt to use FDIs to hedge against negative currency movements, however there is no guarantee that any attempts at hedging will be successful.' This further confirms derivative use. While physical replication is generally non-complex, the explicit mention of derivatives, particularly OTC swaps, triggers complexity. The KIID also states, 'Derivatives are subject to counterparty risk...and are highly sensitive to underlying price movements, interest rates and market volatility and therefore come with a greater risk.' This reinforces the rationale for classification as complex. Although the document doesn't explicitly mention 'embedded derivatives' in the structured product sense, the use of derivatives for investment and hedging purposes as stated is sufficient to classify the ETF as complex under MiFID II rules, as the nature and risks associated with these derivatives are not easily understood by a retail investor.",
        "esma_guideline_references": [
            "ESMA35-36-1640, Section 2.1, Determining situations where the appropriateness assessment is required, where it notes that firms need processes to distinguish between 'complex' and 'non-complex' investment products, and that shares embedding a derivative would be complex. The KIID explicitly states derivative use.",
            "CESR/09-295, Summary list of MiFID complex/non-complex financial instruments, which lists 'all derivatives' as complex and notes that instruments embedding a derivative are complex. The KIID states the fund may use FDIs including swaps."
        ]
    }
}