{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Rules-based index with ESG screening"
        ],
        "classification": "non-complex",
        "supporting_data": "The assessment is 'non-complex' based on the MiFID II framework. The asset is a UCITS ETF, which establishes a presumption of non-complexity. This presumption is upheld by several key factors identified in the KIID. The replication method is physical ('by buying all or a substantial number of the securities in the index'), which is straightforward and transparent for an investor to understand. While the fund may use derivatives, the KIID states this is 'in order to manage risk, reduce costs and improve results', which aligns with Efficient Portfolio Management (EPM) rather than being integral to the investment strategy. According to the rules, this does not trigger a complex classification. The fund does not use swaps, leverage, or inverse strategies. The underlying index, MSCI EMU Select Screened Index, is a rules-based equity index; its screening criteria (ESG, carbon) do not introduce structural complexity that would be difficult for a retail investor to understand. The high risk rating of 6/7 reflects market volatility of the underlying equities, not structural complexity. The presence of securities lending is a secondary feature for income generation and is managed within UCITS rules, so it does not make the ETF complex. The fund clearly meets the criteria for a non-complex instrument under MiFID II and ESMA guidelines, as its structure and risks are easily understandable.",
        "final_assessment": "Non-Complex"
    }
}