{
    "fund_name": "Franklin Future of Food UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Franklin Future of Food UCITS ETF is a physically replicated ETF that seeks to track the Solactive Sustainable Food Index-NR. The KIID and factsheet indicate that the fund primarily uses full replication or optimization methodology to hold the underlying securities of the index. While the fund mentions the use of derivatives for efficient portfolio management (EPM), this is a common practice for UCITS-compliant ETFs and does not inherently make the fund complex under MiFID II. The fund does not employ leverage, inverse strategies, or synthetic replication. The risk profile is moderate, with a risk rating of 4 out of 7, and the fund provides clear and transparent information about its holdings, strategy, and risks. The absence of complex features such as leverage, synthetic replication, or capital protection mechanisms supports the classification as non-complex.",
    "confidence": 95,
    "counter_argument": "Some might argue that the use of derivatives for EPM could introduce complexity. However, under MiFID II, derivatives used solely for EPM purposes do not classify an ETF as complex, provided they are used in a straightforward manner and do not materially alter the risk profile or require specialist knowledge to understand. The fund's transparency and straightforward replication strategy further support its non-complex classification.",
    "risk_level": "moderate"
}