{
    "complex": false,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The RIZE USA Environmental Impact UCITS ETF is a physically replicated, UCITS-compliant ETF that tracks the Foxberry SMS USA Environmental Impact USD Net Total Return Index. The KIID and factsheet indicate that the fund uses full physical replication, does not employ leverage or inverse strategies, and does not rely on synthetic replication or swaps. While the fund may use financial derivative instruments (FDIs) for efficient portfolio management, these are not used in a way that introduces complexity or significant additional risk. The fund's risk profile is transparent, with a risk rating of 7 primarily due to the nature of its underlying investments (small and micro-cap companies in the environmental sector) rather than structural complexity. The fund is Article 9 under SFDR, further indicating a straightforward, transparent investment approach.",
    "confidence": 95,
    "counter_argument": "Some might argue that the use of derivatives (FDIs) could introduce complexity. However, the KIID and factsheet clarify that these are used for efficient portfolio management rather than as a core strategy, and the fund's overall structure remains simple and transparent. The physical replication method and lack of leverage or synthetic exposure further support the non-complex classification."
}