{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Swaps",
        "Synthetic Replication",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and reliance on derivative agreements. The KIID explicitly mentions the use of swaps and the associated risks, including the potential insolvency of counterparties. The synthetic replication method, combined with the use of derivatives for index tracking, makes the product complex under MiFID II rules. Additionally, the risk category is 7, indicating higher risk and complexity. The presence of swap agreements and the reliance on counterparties for performance delivery are key factors in this classification.",
    "confidence": 95
}