{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Factor-based index"
        ],
        "classification": "non-complex",
        "supporting_data": "The asset is classified as non-complex based on the MiFID II framework. It is a UCITS ETF, which establishes a presumption of non-complexity. The fund uses physical replication, stating it 'intends to replicate the Index by holding the equity securities which make up the Index'. This method is transparent and straightforward for a retail investor to understand. While the KIID notes that the fund 'may use financial derivative instruments (u201cFDIsu201c)... for direct investment purposes to produce a similar return to its Index', this is not the primary replication strategy and is not indicative of synthetic replication (e.g., using swaps). Following the provided rules, as this use is for optimizing the physical portfolio rather than being an inherent part of the strategy, it does not trigger a complex classification. The fund does engage in securities lending, but this is a secondary activity managed within UCITS rules and does not make the ETF complex. The benchmark index, while using a 'factor' strategy (quality), is based on transparent and understandable company characteristics (earnings, debt) and does not involve derivatives, leverage, or opaque methodologies. The fund does not use swaps, leverage, or hold complex bonds like CoCos. Therefore, despite a high market risk rating (6/7), its structure and risks are considered understandable by an average retail investor, and it is classified as non-complex."
    }
}