{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Complex Indices",
            "Potential derivative use with counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF that uses physical replication, which are characteristics of a non-complex instrument, the presumption of non-complexity is overturned. The primary driver for the 'complex' classification is the nature of the underlying index: the 'MSCI EMU Universal Low Carbon Select 5% Issuer Capped Index'. This is not a standard market-capitalization-weighted index. Its rules-based methodology, which involves 'tilting away from free-float market cap weights' based on ESG profiles and trends, is not straightforward and requires more than basic financial knowledge to understand how performance is generated. Furthermore, the KIID states the fund 'may use derivatives' and explicitly warns of 'potential loss due to failure of counterparty.' While derivatives may be used for efficient portfolio management, the introduction of counterparty risk is a concept that is difficult for the average retail investor to understand and is a key indicator of complexity under MiFID II. The combination of a complex index strategy and the potential for derivative use with counterparty risk makes the ETF difficult to understand, thus classifying it as complex."
    }
}