{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "complex_factors": [
            "Swaps",
            "Counterparty risk",
            "Collateral risk"
        ],
        "classification": "complex",
        "supporting_data": "The ETF's investment objective is to track the SG Global Quality Income NTR Index using **indirect replication by entering into an over-the-counter swap contract (financial derivative instrument)**. This reliance on OTC swaps means the ETF is classified as complex. The KIID explicitly mentions 'Counterparty risk' and 'Risk of Financial derivative Instruments' as risks, highlighting the complexity introduced by these instruments.  MiFID II and ESMA guidelines clearly state that the use of derivatives, particularly for replication purposes (like swaps), central to the strategy, introduces risks (counterparty risk, collateral risk) that are difficult for retail investors to understand, thus leading to a complex classification. While the ETF's objective is to track an index, the method of synthetic replication via swaps makes it complex. The 'minimum recommended holding term is 5 years' is standard for ETFs and does not influence the complexity classification. The reference to 'unlevered performance' in the objective refers to the index itself, not the ETF's structure which uses derivatives. Even though it is a UCITS ETF, the use of synthetic replication via swaps overrides the general UCITS presumption of being non-complex."
    }
}