{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivative usage for direct investment purposes"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses financial derivative instruments (FDIs) for direct investment purposes, which is explicitly stated in the KIID. While it primarily employs physical replication, the use of derivatives for purposes beyond efficient portfolio management (EPM) introduces complexity. The KIID mentions that FDIs may be used for direct investment, which could imply more sophisticated strategies than simple hedging or replication. Additionally, the presence of counterparty risk due to derivative usage further supports the classification as complex. The risk indicator of 4 and the mention of counterparty risk in the risk disclosures also contribute to this assessment.",
    "confidence": 85
}