{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Active management with a complex proprietary screening methodology"
        ],
        "classification": "complex",
        "supporting_data": "The asset is classified as 'complex' despite being a UCITS-compliant, physically-replicated equity ETF with no apparent use of derivatives or leverage. The baseline presumption of non-complexity for a UCITS ETF is overturned by its actively managed nature and the complexity of its investment strategy. The fund does not simply track a standard index; instead, it employs a multi-stage, proprietary 'capital strength' screening methodology on an initial universe of ESG-screened stocks. This process involves multiple quantitative criteria (trading volume, cash, debt-to-market-cap, return on equity, volatility) and discretionary adjustments by the investment manager. According to MiFID II rules, an asset is complex if its structure, risks, or payoff are difficult for a retail investor with basic knowledge to understand. The intricate, rules-based yet discretionary selection process makes it difficult for an average retail investor to grasp how the portfolio is constructed and why it will perform in a certain way, separating it from a straightforward, transparent index-tracking ETF. This strategic complexity, rather than the use of complex instruments, is the key driver for the 'complex' classification."
    }
}