{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for direct investment",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "The asset is classified as complex. Although it is a UCITS ETF using physical replication to track a standard equity index (MSCI EM Asia), which typically points to a non-complex classification, its investment policy contains a critical feature that introduces complexity. The Key Investor Information Document (KIID) explicitly states, 'The investment manager may use financial derivative instruments (FDIs) ... for direct investment purposes.' This permission extends beyond the use of derivatives for simple Efficient Portfolio Management (EPM), such as hedging or managing cash flows. Using derivatives for 'direct investment' means they can be integral to achieving the investment objective, which introduces structural complexity and risks not easily understood by the average retail investor. The KIID reinforces this by listing 'Counterparty Risk' as a particular risk, noting that the insolvency of a counterparty to derivatives could expose the Share Class to financial loss. Under the MiFID II framework, the introduction of such risks and the use of derivatives as a core part of the investment strategy, even if only potential, are sufficient to overturn the non-complex presumption for a UCITS product. The fund also engages in securities lending, which further contributes to counterparty risk."
    }
}