{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Contingent Convertible Bonds",
        "Financial Derivative Instruments"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses financial derivative instruments (FDI) for investment purposes and efficient portfolio management, which introduces complexity. Additionally, the presence of contingent convertible bonds (CoCos) in the portfolio, as indicated in the risk disclosures, further contributes to the complexity. The ETF's risk profile includes exposure to derivative-related risks and counterparty risks, which are typical indicators of complexity under MiFID II. The use of derivatives, even if not for leverage, and the inclusion of complex instruments like CoCos, make this ETF complex.",
    "confidence": 85,
    "risk_level": 4
}