{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Counterparty Risk"
        ],
        "classification": "complex",
        "supporting_data": "The ETF's investment policy explicitly states that it 'can use total return swaps with the objective of delivering synthetically the performance of a portfolio of equities'. This directly indicates the use of derivatives as a core part of the investment strategy, which is a primary indicator of complexity under MiFID II. The document also highlights 'counterparty risk' associated with these swaps, further reinforcing the complex classification. While the ETF is UCITS compliant, the use of synthetic replication via total return swaps means that the ETF's assets do not directly mirror the underlying index. This introduces risks such as counterparty default, which are not easily understood by retail investors, thus making the instrument complex according to MiFID II regulations.  The risk and reward profile also notes 'Derivative and Counterparty risk' as materially relevant and not adequately captured by the synthetic indicator, emphasizing the inherent complexity."
    }
}