{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swap usage (total return swaps) for gaining exposure to the index, beyond efficient portfolio management, introduces inherent complexity.",
            "Potential for investment leverage arising from the use of derivatives.",
            "Associated Counterparty Risk and Derivatives Risk, explicitly highlighted in the KID as material risks, which are difficult for retail investors with basic knowledge to understand."
        ],
        "classification": "complex",
        "supporting_data": "The HSBC Emerging Market Screened Equity UCITS ETF is classified as a UCITS fund. While its primary investment policy indicates passive management by investing directly in the shares of the underlying index constituents (suggesting physical replication), the fund's investment policy explicitly states it 'may gain exposure by using other investments such as ... derivatives' including 'up to 10% of its assets in total return swaps and contracts for difference'. This use of total return swaps for achieving investment exposure, rather than solely for efficient portfolio management (EPM), is a key factor triggering a complex classification under MiFID II. The provided rules state that if derivatives are integral to achieving the investment objective, or if 'any Swap usage is identified', the asset must be classified as complex. The fund's Key Investor Information Document also highlights 'Counterparty Risk' and 'Derivatives Risk' as material risks, alongside 'Investment Leverage Risk' which occurs when derivatives are used. These types of risks and the mechanisms involved (e.g., total return swaps) are considered opaque and difficult for retail investors with basic knowledge to fully comprehend, despite the fund's UCITS status and intention for primary physical replication. The presence of these derivative-based investment tools, even if not the primary method or for a limited percentage, fundamentally alters the ease of understanding for a retail investor and leads to the complex classification."
    }
}