{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Derivatives for investment purposes",
            "Leverage"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF which primarily uses physical replication, the classification is 'complex' due to several key factors outlined in the KIID. The fund's investment policy explicitly states it 'may invest up to 10% of its assets in total return swaps and contracts for difference' for 'investment purposes'. The use of swaps, even if potential or limited, is a definitive trigger for a complex classification under MiFID II rules as it introduces counterparty risk and a structure that is difficult for a retail investor to understand. Furthermore, the KIID identifies 'Investment Leverage Risk' as a material risk, noting that leverage can occur when derivatives are used. This, combined with the specific mention of 'Derivatives Risk' and 'Counterparty Risk', confirms that the fund's structure and risk profile go beyond that of a non-complex instrument, thereby overturning the baseline UCITS presumption. The potential use of total return swaps is the most critical factor leading to the 'complex' determination."
    }
}