{
    "fund_name": "HSBC MSCI EMERGING MARKETS UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives for efficient portfolio management",
        "Total return swaps (up to 10%)",
        "Contracts for difference",
        "Securities lending (up to 30%)"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication to track the MSCI Emerging Markets Index. While it may use derivatives (up to 10% in total return swaps and contracts for difference) and securities lending (up to 30%), these are for efficient portfolio management and not for leverage or complex strategies. The risk profile is transparent, and the fund is UCITS-compliant, which generally indicates a non-complex structure. The KIID and factsheet do not indicate the use of leverage, inverse strategies, or complex underlying assets.",
    "confidence": 90,
    "risk_level": 6,
    "counter_argument": "The use of derivatives and swaps could be seen as a complexity indicator. However, the limited exposure (up to 10%) and the clear disclosure of their use for efficient portfolio management rather than leverage or speculative purposes support the non-complex classification. The fund's physical replication method and UCITS compliance further reinforce this assessment.",
    "additional_notes": "The fund's risk level is rated 6, which is relatively high, but this is due to the inherent volatility of emerging markets rather than structural complexity. The fund's transparency, liquidity, and straightforward investment objective align with non-complex characteristics under MiFID II."
}