{
    "fund_name": "Invesco Global Active Defensive ESG Equity UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF is physically replicated, uses derivatives only for efficient portfolio management (EPM) such as risk management and cost reduction, and does not employ leverage or inverse strategies. It is UCITS-compliant, has a clear investment objective of tracking global equities with ESG criteria, and maintains a straightforward risk profile (risk category 6, but this is based on market volatility rather than structural complexity). The use of derivatives is limited to EPM, and there are no indications of synthetic replication, complex underlying assets, or capital protection mechanisms. The fund's active management and ESG focus do not introduce complexity under MiFID II rules.",
    "confidence": 95,
    "risk_level": 6,
    "counter_argument": "Some might argue that the active management and quantitative investment model could introduce complexity. However, these are standard practices in many ETFs and do not inherently make the product complex under MiFID II, as the risks remain transparent and the fund does not employ sophisticated strategies like leverage or synthetic replication.",
    "final_decision_reasoning": "The fund is classified as non-complex because it uses physical replication, employs derivatives only for EPM, and avoids leverage, inverse strategies, or synthetic structures. The ESG and active management aspects do not introduce MiFID II complexity."
}