{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives for direct investment",
            "Complex index methodology"
        ],
        "classification": "complex",
        "supporting_data": "Although the fund is a UCITS ETF and primarily uses physical replication, which would typically suggest a non-complex classification, the Key Investor Information document contains a critical provision that leads to a 'complex' determination. The document states, 'The investment manager may use financial derivative instruments (u201cFDIsu201c) for direct investment purposes to produce a similar return to its Index.' This statement signifies that derivatives are not limited to Efficient Portfolio Management (EPM) like hedging but can be used as a core part of the investment strategy. This introduces structural complexity and specific risks, such as the explicitly mentioned 'Counterparty Risk,' which are difficult for an average retail investor to fully comprehend, as per MiFID II guidelines. The permission to use derivatives for the main investment objective is a key trigger for a complex classification. Additionally, the index methodology, which involves multi-layered ESG and climate transition screening, is more intricate than a standard market-capitalisation index, further reducing the ease of understanding for a retail client."
    }
}