{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Leverage",
            "Derivatives for investment purposes",
            "Quantitative models"
        ],
        "classification": "complex",
        "supporting_data": "Although the Fund is a UCITS ETF, which creates a presumption of non-complexity, this is overturned by several key factors outlined in its investment policy. The Fund is classified as complex primarily because it uses financial derivative instruments (FDIs) not just for efficient portfolio management, but explicitly 'for investment purposes in order to achieve the investment objective'. More critically, the policy states the Fund 'may, via FDIs, generate varying amounts of market leverage (i.e. where the Fund gains market exposure in excess of the value of its assets)'. The use of derivatives to generate leverage is a definitive characteristic of a complex financial instrument under MiFID II, as it introduces risks and a payoff structure that are difficult for an average retail investor to understand. The strategy also relies on 'quantitative (i.e. mathematical or statistical) models' for stock selection, adding another layer of structural complexity. The KID also explicitly lists 'Counterparty Risk' as a particular risk, which is directly associated with the use of derivatives. These features combined make the Fund's structure and risk profile opaque and not easily understandable, leading to a 'complex' classification."
    }
}