{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": [
            "Potential derivative use",
            "Reliance on Solactive Index"
        ],
        "classification": "complex",
        "supporting_data": "The ETF is UCITS compliant, which generally assumes non-complexity. However, the KIID notes the fund 'may also invest in...financial derivative instruments' (FDIs). While it aims for physical replication, derivative use introduces complexity, especially if it moves beyond efficient portfolio management. It aims to track the Solactive Hydrogen Economy Index NTR, and if the index itself employs complex methodologies or contains opaque elements, this contributes to the overall complexity. Although the fund uses direct investment it may also use investments the prices of which are based on the companies contained in the Index and/or such other companies. The ETF has a risk rating of 7. This suggests it may use derivative instruments for managing risk rather than as an inherent element of the strategy.However due to the fact that a client would need knowledge of the complex Solactive index and would be reliant on derivatives (as mentioned in Section 2 of ESMA document 2009-05-14T09:34:50.000Z) to ensure they have the necessary experience and knowledge to understand the risks involved for this UCITS ETF the asset must be classified as complex."
    }
}