{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Contracts for Difference (CFDs)",
            "Derivatives for exposure",
            "Leverage"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF which is presumed non-complex and primarily uses physical replication, its classification is 'complex' due to several key factors outlined in the KIID. The fund's investment policy explicitly states it may invest up to 10% of its assets in Total Return Swaps and Contracts for Difference (CFDs). This use of derivatives goes beyond simple Efficient Portfolio Management (EPM) as it is intended to 'gain exposure' to the index, making the derivatives integral to the investment strategy. The use of such instruments introduces risks that are difficult for a typical retail investor to understand, including 'Counterparty Risk' and 'Investment Leverage Risk', which are specifically highlighted in the KIID as material risks. According to MiFID II rules and ESMA guidance, the use of swaps and CFDs, which are listed as complex instruments (MiFID Annex I, Section C, points 4-10), automatically triggers a complex classification. The explicit ability to use swaps makes the 'complex' classification mandatory as per the assessment rules."
    }
}