{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives Usage",
        "Counterparty Risk",
        "High Yield Bonds"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses derivatives (futures, options, and swaps) for replication and risk management, which introduces counterparty risk and potential volatility. While it primarily uses physical replication, the inclusion of derivatives and exposure to high-yield bonds (non-investment grade securities) adds complexity. The KIID explicitly mentions derivative and counterparty risks, which are key indicators of complexity under MiFID II. Additionally, the underlying index includes below-investment-grade corporate debt, which may be harder for retail investors to assess.",
    "confidence": 85,
    "risk_level": "medium",
    "counterparty_risk": true,
    "illiquid_assets": false,
    "structured_products": false,
    "capital_protection": false,
    "benchmark_complexity": "moderate",
    "additional_notes": "Although the ETF is UCITS-compliant and primarily uses physical replication, the use of derivatives for non-EPM purposes and exposure to high-yield bonds (which carry higher credit and liquidity risks) justify the 'complex' classification. The KIID's explicit warnings about derivative and counterparty risks further support this determination."
}