{
    "fund_name": "WisdomTree Global Quality Growth UCITS ETF - USD Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the WisdomTree Global Quality Growth UCITS Index, holding the underlying securities directly. There is no mention of synthetic replication, leverage, inverse strategies, or complex derivatives. The risk profile (SRRI 6) is primarily due to equity market exposure rather than structural complexity. The fund's use of derivatives is limited to efficient portfolio management (e.g., stock lending and repurchase agreements), which does not trigger complexity under MiFID II. The index is rule-based and transparent, with no indications of hard-to-value assets or complex structures.",
    "confidence": 95,
    "risk_level": 6,
    "counter_argument": "While the SRRI of 6 suggests higher risk, this is attributed to equity market volatility rather than structural complexity. The fund's use of derivatives for EPM (e.g., stock lending) is explicitly permitted under MiFID II without classifying the product as complex, provided it does not materially alter the risk profile. The absence of leverage, inverse strategies, or synthetic replication supports the non-complex classification.",
    "additional_notes": "The ETF is UCITS-compliant, physically replicated, and accumulates income, with no capital protection features or embedded derivatives beyond standard EPM practices. The index methodology is transparent and based on liquid, large-cap equities."
}