{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The fund is explicitly identified as a UCITS ETF, which is generally presumed non-complex under MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, and confirmed by ESMA guidelines (CESR/09-295, Section 3, paragraph 69 and Annex I). The ESMA guidance explicitly states that 'All investments in UCITS are non-complex instruments by definition, for the purposes of the appropriateness requirements, regardless of the underlying instruments in which the UCITS invests. Nothing in MiFID Art.19(6) requires a person to look through to the underlying investments of the UCITS for these purposes.' and 'The fact that an undertaking invests in derivatives will not automatically make it u2018complexu2019 for these purposes.'.The fund employs a 'physical acquisition of securities' replication method, which is considered transparent and straightforward, strongly supporting a non-complex classification. While the fund 'may use derivatives in order to reduce risk or cost and/or generate extra income or growth' (Efficient Portfolio Management - EPM), this use is not integral to its primary investment objective (physical index replication) and falls within the permissible activities for UCITS without triggering a complex classification. The mention of 'counterparty risk' in the KIID is a standard risk for EPM activities like securities lending or derivative use, but as per the ESMA guidance, it does not automatically classify the UCITS as complex if used for EPM rather than as an inherent element of a complex strategy or structure. The fund also states it 'may engage in short term secured lending of its investments', which, while introducing counterparty risk, is typically a secondary EPM feature within UCITS rules and does not automatically lead to complexity. There is no indication of significant leverage, use of total return swaps for replication, embedded derivatives (like those in structured products or complex bonds), or that it tracks complex indices with features like roll costs or contango/backwardation. The index (FTSE All-World High Dividend Yield Index) is transparent. The risk rating of 6/7 on the SRRI scale reflects market volatility, not structural complexity, which is consistent with the provided rules."
    }
}