{
    "fund_name": "iShares EUR Green Bond UCITS ETF EUR (Acc)",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivative usage for direct investment purposes"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication to track the Bloomberg Barclays MSCI Euro Green Bond SRI including Nuclear Power Index. While it mentions the use of financial derivative instruments (FDIs) for direct investment purposes, this appears to be for efficient portfolio management rather than as a core strategy. The fund does not exhibit leverage, inverse exposure, or synthetic replication. The risk profile is moderate (risk level 4), and the underlying assets are investment-grade green bonds, which are relatively straightforward. The derivative usage is not extensive or complex enough to warrant a 'complex' classification under MiFID II.",
    "confidence": 85,
    "counter_argument": "The use of derivatives could be seen as a complexity factor. However, the derivatives are used for direct investment purposes and not for leverage or synthetic replication, which are key triggers for complexity. The overall structure and risk profile remain transparent and suitable for retail investors.",
    "risk_level": 4,
    "additional_notes": "The ETF is UCITS-compliant and physically replicates its index, which are strong indicators of non-complexity. The derivative usage is limited and does not introduce significant additional risk or complexity."
}