{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives for investment purposes",
        "Total return swaps",
        "Contracts for difference"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses derivatives not only for efficient portfolio management but also for investment purposes, including total return swaps and contracts for difference, which introduces additional complexity. While the primary replication method is physical, the use of derivatives beyond simple hedging or efficient portfolio management (EPM) triggers complexity under MiFID II. The KIID explicitly mentions the use of derivatives for investment purposes, which is a key indicator of complexity. Additionally, the presence of counterparty risk and the potential for tracking error further contribute to the classification as complex.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": true,
    "tracking_error_risk": true,
    "currency_risk": true,
    "investment_leverage_risk": true,
    "operational_risk": true,
    "additional_notes": "Although the ETF is UCITS compliant and primarily uses physical replication, the explicit mention of derivatives for investment purposes and the potential for significant tracking error due to derivative usage justify the classification as complex. The risk level of 6 also aligns with a higher complexity profile."
}