{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "FLEX Options",
        "Target Outcome Strategy",
        "Customized Derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses FLEX Options, which are customized derivative instruments, to achieve its target outcome strategy. This involves complex structures like caps and buffers that require sophisticated understanding. The strategy resets annually with new derivative contracts, adding to the complexity. While it is UCITS-compliant, the use of non-standard derivatives and the structured outcome approach make it complex under MiFID II.",
    "confidence": 90,
    "risk_level": 5,
    "additional_notes": "The ETF's use of FLEX Options and its target outcome strategy, which involves caps and buffers, introduces complexity beyond standard derivative usage. The fact that it requires holding through specific periods to achieve outcomes further complicates its suitability assessment for retail investors. The PRIIPs KID and factsheet reinforce this complexity with detailed disclosures about the derivative mechanics and outcome-based risks."
}