{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives",
        "Swaps",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The HSBC Japan Sustainable Equity UCITS ETF is classified as complex primarily due to its use of derivatives and swaps, even though it employs physical replication. The KIID explicitly states that the fund may invest up to 10% in total return swaps and contracts for difference, which introduces counterparty risk and potential tracking error. Additionally, the fund may use derivatives for investment purposes beyond efficient portfolio management, which adds complexity. The presence of counterparty risk and the potential for unexpected behavior of derivatives further support this classification. While the fund is UCITS-compliant and uses physical replication, the derivative usage and swap exposure make it complex under MiFID II rules.",
    "confidence": 85
}