{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Swaps",
            "ESG screening criteria leading to complex index construction"
        ],
        "classification": "complex",
        "supporting_data": "The ETF is classified as complex primarily because it uses derivatives to achieve its investment objective. Specifically, the KIID states, 'To achieve the aim, the fund will invest in transferable securities and enter into financial contracts (derivatives) with one or more swap counterparties relating to the transferable securities and the index, in order to obtain the return on the index.' MiFID II and related guidance (CESR/09-295 and ESMA35-36-1640) clearly indicate that the use of derivatives, particularly swaps for replication purposes, introduces counterparty risk and complexity that is not easily understood by retail investors, thus leading to a complex classification. The underlying index methodology, which involves ESG screening and carbon exposure criteria, further adds to the complexity of understanding the fund's investment strategy and underlying holdings."
    }
}