{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Complex Index Methodology",
            "Derivatives for Direct Investment",
            "Counterparty Risk"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF, which is presumed non-complex, several factors lead to a 'complex' classification under MiFID II. The primary driver is the complexity of the benchmark index itself, the 'STOXX Developed World Equity Factor Screened'. This index uses a quantitative 'risk model' and an 'optimisation process' to maximise exposure to five distinct investment factors (Momentum, Quality, Value, Low Volatility, Size). This structure is not straightforward and requires more than basic knowledge to understand, as highlighted by the KIID's specific warnings on 'Index Methodology Risk' and 'Multi-Factor Focus Risk'. Secondly, the fund's policy explicitly states that financial derivative instruments (FDIs) 'may be used for direct investment purposes'. This goes beyond simple efficient portfolio management (EPM) and introduces a layer of structural complexity and risk that is difficult for a typical retail investor to assess. Finally, the fund engages in securities lending and explicitly lists 'Counterparty Risk' as a key risk. According to ESMA guidelines, counterparty risk is a concept that is not easily understood by retail investors. The combination of a complex, model-driven index and the use of derivatives for direct investment purposes makes the ETF's structure and risk profile difficult to understand, thus overriding the non-complex presumption.",
        "assessment": "Complex"
    }
}