{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "The fund tracks a rules-based climate index which has a more complex methodology than a standard market-cap index."
        ],
        "classification": "non-complex",
        "supporting_data": "The asset is classified as non-complex based on the MiFID II framework. It is a UCITS ETF, which establishes a presumption of non-complexity. The fund employs a physical replication strategy, holding the underlying securities of the index, which is a transparent and straightforward method. The KIID confirms this, stating the portfolio will be a 'near mirror-image of the components of the Index'. There is no use of swaps, leverage, or inverse strategies. While the KIID mentions that derivative instruments may be used, it specifies their purpose is for 'reducing risk, reducing costs of generating additional capital or income' (i.e., Efficient Portfolio Management - EPM). This use is not integral to the investment strategy of tracking the index, and thus does not trigger a complex classification under the provided rules. The fund does not engage in securities lending. The index, while having a specific climate-focused methodology, is an equity index and does not appear to have features like embedded derivatives or opaque structures that would render it complex. The high risk rating (6/7) is due to the market volatility of the underlying equities, not structural complexity. Therefore, the product's structure and risks are considered easy for a retail investor to understand."
    }
}