{
    "success": true,
    "data": {
        "complex": false,
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for replication, specifically a swap agreement, indicating potential counterparty and collateral risks, which are beyond the understanding of retail investors with basic knowledge.  While the fund is passively managed and uses physical replication, the use of a swap introduces complexity that might not be immediately apparent."
        ],
        "classification": "complex",
        "supporting_data": "The fund replicates the Stoxxu00ae China A 900 Minimum Variance Index physically. However, the fund uses a derivative agreement (Swap Agreement) with a swap counterparty for achieving this objective.  This introduces a level of complexity relating to derivatives, specifically swap agreements, which retail investors might find challenging to understand.  The fact that the fund might utilize derivatives in the future to achieve performance in part, raises concern over the level of transparency and potential understanding required from the retail investor when making an investment decision. The fund's objective of replicating the index's performance physically, and the usage of derivative instruments in managing risk suggests a complex structure.  The use of derivatives for replication, even with physical replication as the primary method, is a key factor in the MiFID II complexity assessment.  The regulatory documents highlight that complexity is determined by the structure, not just the risk, of an instrument, and the use of swaps falls within that category. The use of the Swap Agreement is presented in the KID as being necessary to replicate the index performance, which suggests a structural reliance on the agreement that is complex for a retail investor."
    }
}