{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for direct investment purposes",
            "Counterparty risk from derivatives"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF using an optimised physical replication method, which would typically support a non-complex classification. However, the Key Investor Information document explicitly states that Financial Derivative Instruments (FDIs) 'may be used for direct investment purposes'. This phrasing is crucial as it signifies that derivatives can be used as an integral part of the investment strategy to achieve its objective, going beyond simple Efficient Portfolio Management (EPM) like hedging or managing cash flows. This use of derivatives introduces a layer of structural complexity and specific risks that are difficult for an average retail investor to understand. The document reinforces this by listing 'Counterparty Risk' as a particular risk, noting that the insolvency of a counterparty to derivatives could expose the Share Class to financial loss. According to the MiFID II framework and ESMA guidance (e.g., ESMA35-36-1640), the use of derivatives that are central to the investment strategy and introduce difficult-to-understand risks like counterparty risk is a primary indicator of complexity. Therefore, despite being a UCITS with physical replication, the ability to use derivatives for direct investment purposes overrides the presumption of non-complexity.",
        "final_assessment": "Complex"
    }
}