{
    "fund_name": "HSBC Bloomberg Global Sustainable Aggregate 1-3 Year Bond UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Total Return Swaps",
        "Derivative Usage for Investment Purposes"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses total return swaps (up to 30%) and derivatives for both efficient portfolio management and investment purposes. While it primarily employs physical replication, the inclusion of swaps and derivatives for investment purposes introduces complexity. The KIID explicitly mentions the use of derivatives for investment purposes, which goes beyond simple hedging or efficient portfolio management (EPM). Additionally, the fund's exposure to securities lending (up to 30%) and potential counterparty risks associated with swaps contribute to its complexity. The risk profile (category 3) and the presence of derivative-related risks 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 straightforward bond index-tracking objective. However, the explicit mention of derivatives for investment purposes and the allowance for significant swap usage (up to 30%) override this argument, as these features introduce additional risks and require a higher level of investor understanding.",
    "risk_level": "Medium (Category 3)"
}