{
    "success": true,
    "response": "```json{  'leverage': false,  'derivatives': false,  'swaps': false,  'inverse': false,  'replication_method': 'physical',  'ucits': true,  'type': 'ETF',  'complex_factors': [],  'classification': 'non-complex',  'supporting_data': 'The Vanguard FTSE Emerging Markets UCITS ETF is classified as non-complex primarily due to its UCITS status and physical replication method. The MiFID II rules and ESMA guidance (CESR/09-295, Annex I) explicitly state that UCITS are generally presumed non-complex, and the use of derivatives for efficient portfolio management (EPM) does not automatically render a UCITS complex. The fund tracks a transparent equity index by holding underlying securities (physical replication) and states that derivatives are used 'to reduce risk or cost and/or generate extra income or growth', which aligns with EPM. While counterparty risk from derivative use and securities lending is noted, these are secondary features and do not represent a 'structured UCITS' or embedded derivatives that create complex, algorithm-based payoffs, which would trigger a complex classification under the ESMA MiFID II Supervisory briefing (ESMA35-36-1640, Para 19, footnote 12). There are no indications of significant leverage, synthetic replication as a core strategy, or complex underlying indices or bonds that would make its structure or risks difficult for an average retail investor to understand beyond standard market volatility and tracking error associated with an equity index fund.'}```**Non-Complex**",
    "note": "Response was not in expected JSON format"
}