{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "complex_factors": [
            "Swaps",
            "Derivatives"
        ],
        "classification": "complex",
        "supporting_data": "The UCITS ETF has an 'actively managed' investment policy. It states that it will 'seek to obtain market exposure to the securities in which it primarily invests by entering into a series of purchase and sale contracts or by using other investment techniques (such as buy backs)'. It also explicitly mentions that 'The fund may use forwards or forward settling contracts. The return is linked to movements in the underlying assets.' Furthermore, under 'Derivatives and Counterparty Risk', it states, 'The use of certain derivatives could result in the fund having a greater or more volatile exposure to the underlying assets and an increased exposure to counterparty risk.' The document also states, 'In order to reach its investment objective, the fund may use swaps, including futures and forwards.' MiFID II regulations, specifically Delegated Regulation EU 2017/565 Article 57 and ESMA guidelines, classify instruments that use derivatives as integral to achieving their investment objective, or that introduce counterparty or collateral risk, as complex. The explicit mention of swaps and the potential for greater or more volatile exposure due to derivatives, along with the risk of counterparty default, triggers a complex classification. Even though it is a UCITS, the use of derivatives for replication or achieving the investment objective overrides the default non-complex presumption.",
        "complex": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false
    }
}