{
    "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",
            "Complex index methodology"
        ],
        "classification": "complex",
        "supporting_data": "Although the asset is a UCITS ETF, which carries a presumption of being non-complex, this presumption is overturned by several factors. The Key Investor Information Document (KIID) states that the fund may use financial derivative instruments (FDIs) for 'direct investment purposes'. This goes beyond simple Efficient Portfolio Management (EPM) and means derivatives are integral to achieving the investment objective, introducing complexities and risks, such as the explicitly mentioned 'Counterparty Risk', which are difficult for a retail investor to understand. Furthermore, the underlying benchmark index, the 'MSCI Europe High Dividend Yield Advanced Select', employs a complex 'optimisation process' that targets multiple factors including dividend yield, quality characteristics, and ESG scores. This complex index methodology adds a layer of opacity that makes it difficult for an average retail investor to easily grasp how the fund's performance is achieved. The combination of using derivatives for direct investment and tracking a complex, optimised index leads to the classification of this ETF as complex under MiFID II."
    }
}