{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives for investment purposes",
        "Total return swaps",
        "Contracts for difference"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses derivatives for both efficient portfolio management and investment purposes, including total return swaps and contracts for difference (up to 10% of assets). While it primarily employs physical replication, the use of derivatives beyond simple hedging or efficient portfolio management (EPM) introduces complexity. The presence of swap agreements and the potential for counterparty risk, as well as the explicit mention of investment leverage risk in the KIID, contribute to the classification as complex. The risk level (category 6) and the disclosure of derivative-related risks further support this assessment.",
    "confidence": 85,
    "counter_argument": "The ETF is UCITS-compliant, physically replicated, and has a straightforward investment objective tracking a well-defined index. The derivative usage is limited (up to 10%) and primarily for risk management. However, the explicit allowance for investment purposes and the presence of swaps and CFDs, which introduce counterparty risk and potential tracking error, outweigh these factors, leading to a 'complex' classification under MiFID II.",
    "risk_level": 6
}