{
    "fund_name": "HSBC EMERGING MARKET SUSTAINABLE EQUITY UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Limited swap usage (up to 10%)",
        "Emerging market exposure",
        "ESG screening complexity"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication to track the FTSE Emerging ESG Low Carbon Select Index. While it may use swaps (up to 10%) and derivatives for efficient portfolio management, these are not the primary investment strategy and are limited in scope. The fund's risk profile (category 6) is driven by emerging market exposure rather than structural complexity. The ESG screening adds some complexity but remains within standard UCITS parameters. The fund's documentation emphasizes transparency and liquidity, with no leverage or inverse strategies.",
    "confidence": 85,
    "counter_argument": "The presence of swaps and derivatives could suggest complexity, but their limited use (up to 10%) and purpose (efficient portfolio management) align with standard UCITS practices. The ESG criteria add some complexity, but the overall structure remains straightforward for retail investors.",
    "risk_level": 6,
    "additional_notes": "The fund's classification as non-complex is supported by its physical replication method, UCITS compliance, and the limited, clearly disclosed use of derivatives. The emerging market focus and ESG criteria are the primary risk drivers, not structural complexity."
}