{
    "complex": false,
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The HSBC NASDAQ Global Climate Tech UCITS ETF primarily uses physical replication to track its underlying index, with derivatives only permitted for efficient portfolio management (EPM) purposes, such as risk management or cost reduction. While the KIID mentions the potential use of derivatives (up to 10% in total return swaps and contracts for difference, though not expected to exceed 5%), this is not a primary strategy and does not introduce significant complexity. The fund does not employ leverage, inverse strategies, or synthetic replication, and its risk profile (category 6) is driven by market volatility rather than structural complexity. The underlying index is transparent, and the fund's holdings are disclosed, making it suitable for retail investors under MiFID II. The absence of capital protection mechanisms, structured features, or illiquid assets further supports the non-complex classification.",
    "confidence": 90,
    "counter_argument": "Some might argue that the potential use of derivatives (even for EPM) could introduce complexity. However, the fund's primary replication method is physical, and derivatives are not a core part of its strategy. The fund's transparency, liquidity, and straightforward investment objective outweigh this concern.",
    "risk_level": 6
}