{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Swaps",
            "Synthetic Replication"
        ],
        "classification": "complex",
        "supporting_data": "The ETF utilizes an 'Indirect Replication methodology' employing a 'total return swap (financial derivative instrument)' to gain exposure to the MSCI Europe Value Index. MiFID II regulations, as highlighted in ESMA guidelines, classify the use of derivatives integral to achieving an investment objective, such as swaps for index replication, as complex. This complexity arises from the associated risks like counterparty risk and collateral risk, which are not easily understood by retail investors. The document explicitly states 'Derivatives are integral to the Sub-Fund's investment strategies', directly leading to a complex classification. Although the ETF is a UCITS, which generally presumes non-complexity, the reliance on synthetic replication through swaps overrides this presumption."
    }
}