{
    "complexity_assessment": {
        "type": "ETF",
        "ucits": true,
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": null,
        "classification": "non-complex",
        "supporting_data": "The ETF is a physically replicated, UCITS-compliant fund that primarily invests in emerging market equities with an ESG focus. It uses derivatives only for efficient portfolio management (EPM), not as a core strategy, and does not employ leverage, swaps, or inverse strategies. The fund's risk profile (SRRI 6) is driven by its exposure to emerging markets rather than structural complexity. The KIID and factsheet confirm straightforward index-tracking with active management for outperformance, but no complex instruments or strategies are employed.",
        "confidence": 95,
        "counter_argument_consideration": "While the fund has a high SRRI rating (6) due to emerging market volatility, this alone does not indicate complexity under MiFID II. The use of derivatives for EPM is explicitly permitted under non-complex classifications, provided they are not used to create leverage or materially alter the risk profile. The fund's transparency, liquidity, and straightforward investment approach support its non-complex designation."
    }
}