{
    "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 synthetic replication complexity. The KIID explicitly states that the Fund will use unfunded swaps to exchange the performance of a basket of equities for the performance of the S&P Select Sector Capped 20% Energy Index. This synthetic replication method, combined with the reliance on counterparties, makes the product complex under MiFID II. Additionally, the risk category is 7, indicating higher risk, and the extensive disclosures about derivative-related risks further support the complexity classification. The PRIIPs KID and factsheet reinforce these points, particularly the emphasis on counterparty risk and the synthetic nature of the replication.",
    "confidence": 95
}