{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for direct investment",
            "Counterparty risk",
            "Securities lending"
        ],
        "classification": "complex",
        "supporting_data": "The asset is classified as 'complex' despite being a UCITS ETF with a physical replication method. The primary reason is the fund's policy on Financial Derivative Instruments (FDIs). The KIID states, 'The Fund invests in financial derivative instruments (FDIs)... FDIs may be used for direct investment purposes.' Under the MiFID II framework, using derivatives as part of the core strategy to gain investment exposure, rather than strictly for efficient portfolio management (EPM) like hedging, renders an asset complex. This introduces risks such as 'Counterparty Risk,' which the KIID explicitly highlights as a particular risk and is considered difficult for a typical retail investor to understand. Furthermore, the fund engages in securities lending, which adds another layer of counterparty risk. The use of American and Global Depositary Receipts (ADRs/GDRs) also contributes to structural complexity, as these are not automatically considered non-complex like direct shares. These factors combined are sufficient to overturn the baseline UCITS presumption of non-complexity."
    }
}