{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Contingent Convertible Bonds",
        "Derivative Usage Beyond EPM"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its exposure to Contingent Convertible Bonds (CoCos), which are inherently complex instruments with trigger mechanisms that can lead to significant losses or conversion into equity. Additionally, while the ETF uses derivatives for efficient portfolio management (EPM), the presence of CoCos and the potential for material deviations from the benchmark due to active management introduce complexity that may not be easily understood by retail investors. The risk profile (category 4) and the extensive disclosures around counterparty and derivative risks further support this classification.",
    "confidence": 90
}