{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Synthetic Replication",
            "Total Return Swap",
            "Counterparty Risk"
        ],
        "classification": "complex",
        "supporting_data": "The ETF uses an 'Indirect Replication methodology' employing a 'total return swap' to track the MSCI Europe High Dividend Yield Index. The document explicitly states that 'Derivatives are integral to the Sub-Fund's investment strategies.' The use of swaps, particularly in synthetic replication, introduces counterparty risk and collateral risk, which are considered difficult for retail investors to understand. MiFID II guidelines and ESMA interpretations classify instruments that are integral to achieving their investment objective through derivatives as complex. The explicit mention of 'counterparty risk' in the risk section further supports this classification. Even though the underlying index is an equity index and generally considered transparent, the synthetic replication method employing derivatives makes the ETF complex."
    }
}