{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for direct investment",
            "Holds complex bonds with bail-in risk",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF which is presumed non-complex, the classification is 'complex' for two primary reasons. First, the investment policy states that financial derivative instruments (FDIs) 'may be used for direct investment purposes.' This goes beyond simple efficient portfolio management (EPM) and introduces a layer of structural complexity and counterparty risk that is difficult for a retail investor to understand. Second, the 'Risk and Reward Profile' explicitly highlights 'bail-in' risk, stating that a financial institution's assets may be 'subject to a write down in value or converted'. This indicates the fund holds complex forms of securitised debt, such as subordinated or convertible bonds from financial institutions, which are not easily understood. As per the provided rules, the use of derivatives integral to the strategy and the inclusion of structurally complex underlying assets overturn the UCITS non-complex presumption.",
        "final_assessment": "Complex"
    }
}