{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Contingent Convertible Bonds"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its exposure to contingent convertible bonds (CoCos), which are inherently complex instruments with trigger mechanisms that can lead to principal write-downs or conversion to equity. While the ETF uses physical replication and does not employ leverage or synthetic replication, the inclusion of CoCos introduces significant complexity in terms of risk assessment and potential outcomes. The KIID explicitly mentions the risks associated with CoCos, including potential write-downs, coupon deferrals, and conversion to equity at discounted prices, which are not typical features of standard corporate bonds. Additionally, the ETF's use of ESG screening and active management, while not inherently complex, adds layers of decision-making that may not be fully transparent to retail investors. The risk profile is rated at level 4, indicating medium volatility, which aligns with the complexity introduced by CoCos. Although the ETF is UCITS-compliant and physically replicated, the presence of CoCos and the active management approach justify the 'complex' classification under MiFID II.",
    "confidence": 85
}