{
    "fund_name": "RIZE GLOBAL SUSTAINABLE INFRASTRUCTURE UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivative usage for non-EPM purposes",
        "Exposure to micro/small-cap companies",
        "Emerging market risks"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but permits the use of financial derivative instruments (FDIs) for purposes beyond efficient portfolio management (EPM). The KIID explicitly mentions the use of FDIs based on companies in the Index, which introduces complexity. Additionally, the fund's exposure to micro and small-cap companies, along with emerging market risks, contributes to its complexity. The risk rating of 6 and extensive risk disclosures further support this classification.",
    "confidence": 85,
    "counter_argument": "The ETF could be argued as non-complex due to its primary use of physical replication and lack of leverage or inverse strategies. However, the explicit mention of derivative usage beyond simple tracking and the high-risk profile override this argument.",
    "risk_level": 6,
    "additional_notes": "The PRIIPs KID and factsheet did not provide additional complexity indicators beyond what was already identified in the KIID. The fund's UCITS compliance and physical replication method are positive factors, but the derivative usage and risk profile necessitate a 'complex' classification under MiFID II."
}