{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": "The ETF tracks an index of corporate bonds, with ESG criteria, which introduces market risk due to bond characteristics. While the ETF may use a sampling strategy or engage in securities lending (secondary features), the primary focus is on physical replication of a corporate bond index, thus deemed non-complex. The KID shows the index as consistent with environmental, social and governance characteristics. The main risk factors are market risk and the risks linked to ESG methodologies and ESG score computation. The KID states the minimum recommended holding term is 3 years. The index methodology is well-documented and available to the public, supporting non-complexity. The fund seeks to achieve its objective via a direct replication, by investing primarily in the securities comprising the Benchmark Index. The fund is not leveraged.",
        "classification": "non-complex",
        "supporting_data": "This UCITS ETF is assessed as non-complex under MiFID II because it primarily uses physical replication to track a corporate bond index. The index's methodology is transparent, and the ETF's structure and risks (market volatility, ESG criteria) are readily understandable for retail investors with basic knowledge. The ESMA guidelines note the need for a firm to distinguish between complex and non-complex investment products. The fund may engage in securities lending, which is well-managed within UCITS rules. There is no significant leverage or embedded derivatives, no swaps identified, and the replication method is direct, all supporting a non-complex classification. As stated in the KID the main risks are linked to market volatility. While the use of a sampling strategy can introduce some complexity, it's not central to the strategy. The fund promotes among other characteristics ESG characteristics pursuant to Article 8 of the Disclosure Regulation, so this feature is considered. The KID describes the ESG rating methodology. The lack of use of derivatives, and the clear structure supports a non-complex classification. The absence of any swaps use is identified. The ESMA briefing emphasizes that firms will need processes to distinguish between complex and non-complex investment products. As the use of swaps and leverage are not identifed, the fund meets the conditions to be considered non-complex. The ESMA guidelines emphasize that firms must have a system to identify which products are complex. The asset falls under the non-complex catagory, by the absence of the complex factors."
    }
}