{
    "success": true,
    "data": {
        "type": "ETF",
        "ucits": true,
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Index complexity"
        ],
        "classification": "non-complex",
        "supporting_data": "The ETF tracks the STOXX Global Breakthrough Healthcare Index. While the index focuses on 'healthcare innovation' which might imply a degree of sector-specific complexity, the underlying securities are equity securities. The document states the ETF aims to invest in equity securities that make up the index. There is no mention of derivatives being used as part of the replication strategy. The index methodology requires companies to generate significant revenues from healthcare innovation, which could be seen as a complex filter, but the core investment is in equities. The risk profile is rated six, but this is attributed to investment risk concentrated in specific sectors, countries, currencies or companies, and market volatility, not structural complexity. The fund is passively managed and uses 'optimising techniques' which may include strategic selection of securities or use of Financial Derivative Instruments (FDIs) for direct investment purposes. However, the primary aim is to invest in equity securities of the index. Given that UCITS ETFs are generally presumed non-complex and the primary investment is in equities with no explicit mention of complex derivatives or structures being integral to its strategy or replication, it leans towards non-complex. The 'optimising techniques' and potential indirect exposure through FDIs are mentioned, but the core intent is physical replication of an equity index. The information does not suggest the use of derivatives integral to the strategy or complex underlying instruments that would inherently make it difficult for a retail investor to understand. The 'complexity' in the index selection criteria does not automatically translate to the ETF's complexity under MiFID II if the underlying assets and replication method are straightforward."
    }
}