{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for investment purposes",
            "Active management strategy",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "The Franklin Sustainable Euro Green Bond UCITS ETF is classified as 'complex' despite being a UCITS vehicle that physically holds bonds. The primary reason for this classification is that its investment policy explicitly permits the use of derivatives not only for efficient portfolio management (EPM) but also for 'investment purposes'.Under MiFID II, using derivatives as an integral part of the investment strategy to generate returns, rather than solely for risk mitigation like hedging, makes a product complex. This is because it introduces risks and structures that are difficult for a typical retail investor to understand. The Key Investor Information document reinforces this by specifically highlighting 'Counterparty risk' as a material risk, defining it as 'the risk of failure of financial institutions or agents (when serving as a counterparty to financial contracts) to perform their obligations'. This directly links to the use of derivatives.Furthermore, the fund is actively managed and may deviate materially from its benchmark. While active management itself is not a direct trigger, when combined with the authority to use derivatives for investment objectives, it increases the product's structural complexity. An investor cannot simply assume the fund's performance will mirror a straightforward index; they must also comprehend the potential impact of the manager's derivative strategies. This combination of factors overturns the default non-complex presumption for UCITS ETFs.",
        "final_assessment": "Complex"
    }
}