{
    "name": "iShares Dow Jones Global Leaders Screened 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 Dow Jones Global Best-In-Class Index, which consists of equity securities selected based on ESG criteria. While the KIID mentions the potential use of financial derivative instruments (FDIs) for direct investment purposes, there is no indication of extensive or complex derivative usage, leverage, or synthetic replication. The risk profile is rated 6, but this is primarily due to equity market risks rather than structural complexity. The ETF is UCITS-compliant, which imposes strict regulatory safeguards, and the underlying assets are liquid, transparent equities. The absence of leverage, inverse strategies, or complex underlying assets further supports the non-complex classification.",
    "confidence": 95,
    "risk_level": "The ETF has a risk rating of 6, which is relatively high but typical for equity-based funds. The primary risks are market-related (equity volatility, ESG screening impacts) rather than structural complexity. Counterparty risk is mentioned but is standard for UCITS funds and does not indicate complexity under MiFID II.",
    "counter_argument": "Some might argue that the use of derivatives (even for EPM) could introduce complexity. However, the KIID and factsheet do not suggest that derivatives are used beyond standard efficient portfolio management, nor do they create material additional risk or require specialist knowledge. The physical replication method and straightforward equity holdings outweigh this concern."
}