{
    "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 reliance on derivative instruments. The KIID explicitly states the use of swaps and highlights risks associated with synthetic replication, including potential financial loss due to counterparty insolvency. The risk category is 6, indicating higher risk, and the fund's performance is dependent on the counterparty's ability to deliver the benchmark performance. The PRIIPs KID and factsheet reinforce the synthetic replication method and the associated risks, confirming the use of derivatives and swaps.",
    "confidence": 90,
    "counter_argument": "The ETF is UCITS-compliant and tracks a well-known index, which might suggest it is non-complex. However, the use of swaps and the synthetic replication method, along with the high risk category and explicit warnings about counterparty risk, outweigh this argument. The complexity arises from the derivative exposure and the potential for significant tracking error or financial loss due to counterparty failure.",
    "risk_level": 6
}