{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and complexity. The KIID explicitly states that the Fund will use swaps to exchange the performance of securities not in the index for the performance of the reference index, indicating synthetic replication. The risk profile is categorized as level 6, which is relatively high, and the document highlights risks associated with derivatives and counterparty exposure. The presence of swap agreements and the synthetic replication method are key indicators of complexity under MiFID II.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "comprehension_warning": false,
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the use of swaps and synthetic replication inherently introduces complexity due to the reliance on counterparties and the potential for tracking error. The high risk level (6) and the explicit mention of derivative-related risks further support the classification as complex."
}