{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Total Return Swaps",
        "Contracts for Difference"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but is permitted to use derivatives, including total return swaps and contracts for difference (CFDs), up to 10% of its assets (though typically not exceeding 5%). While the fund is UCITS-compliant and follows a straightforward index-tracking strategy, the use of swaps and CFDs introduces counterparty risk and potential complexity in tracking performance. The KIID explicitly mentions these instruments, and their inclusion, even at low levels, can classify the ETF as complex under MiFID II due to the additional risks they introduce. The fund's risk profile is categorized as level 6, indicating higher volatility, which aligns with the potential complexity introduced by derivative usage. Additionally, the fund's exposure to emerging markets and potential tracking error further supports the classification as complex.",
    "confidence": 85
}