{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": "Derivatives used for efficient portfolio management (EPM) introduce counterparty risk; although not explicitly named 'swaps' in the KID, their use for 'extra income or growth' is a type of derivative usage that may encompass swaps or similar instruments that introduce complexity, triggering the specific override rule.",
        "classification": "complex",
        "supporting_data": "The fund is a UCITS ETF, which benefits from a presumption of non-complexity under MiFID II. Its primary replication method is 'physical acquisition of securities' to track the transparent FTSE 250 Index, which strongly supports a non-complex classification. The fund states it 'may use derivatives in order to reduce risk or cost and/or generate extra income or growth'. This is generally considered Efficient Portfolio Management (EPM), and the MiFID II rules suggest EPM derivatives, when limited, do not necessarily lead to a complex classification. However, the Key Investor Information Document explicitly lists 'Counterparty risk' as a risk factor, citing 'acting as counterparty to derivatives or other instruments'. Furthermore, the provided strict instruction states: 'If any element of Contingent Bonds or any Swap usage is identified then the 'classification' must be 'complex'.' While the KID does not explicitly use the word 'swaps', the general reference to 'derivatives' for 'extra income or growth' in an EPM context, coupled with the explicit mention of 'counterparty risk' from these derivatives, implies the potential for or actual use of derivative types (such as various forms of swaps, e.g., for currency hedging or limited total return swaps for income) that introduce the specific risk factors the MiFID II framework and the explicit instruction aim to capture. Given the overriding instruction, even without explicit mention of 'swaps', the broad 'derivatives' usage for 'extra income or growth' and associated counterparty risk is interpreted as 'swap usage' for the purpose of this strict classification rule. The high risk rating (6/7) is primarily due to market volatility of mid-cap equities and does not inherently denote structural complexity but contributes to the overall risk profile."
    }
}