{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Derivatives for investment purposes",
            "Investment Leverage Risk"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF that primarily uses physical replication, its classification is 'complex' based on several key factors identified in the KIID. The fund's investment policy explicitly states it may use derivatives not only for efficient portfolio management (EPM) but also for 'investment purposes'. Critically, it discloses that it 'may invest up to 10% of its assets in total return swaps and contracts for difference'. The use of swaps for investment purposes, even as a minority part of the strategy, introduces counterparty risk and a level of structural complexity that is considered difficult for a typical retail investor to understand. This is a decisive factor, as any use of swaps for achieving the investment objective points towards a complex classification. Furthermore, the KIID lists 'Derivatives Risk', 'Counterparty Risk', and 'Investment Leverage Risk' as material risks, confirming that the fund's structure incorporates mechanisms beyond simple market risk. The potential for leverage through derivatives is explicitly noted. According to the MiFID II framework and ESMA guidelines, the use of swaps and the associated complex risks overturn the initial non-complex presumption for a UCITS ETF.",
        "final_assessment": "Complex"
    }
}