{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Swaps",
        "Derivative Usage"
    ],
    "classification": "complex",
    "supporting_data": "The VanEck S&P Global Mining UCITS ETF is classified as 'complex' under MiFID II due to its use of financial derivative instruments, including swaps (e.g., index swaps and equity swaps), currency forwards, and non-deliverable forwards. Although the primary replication method is physical, the KIID explicitly states that the fund may use derivatives related to the index or its constituents. The presence of swaps and other derivatives introduces counterparty risk and complexity beyond simple physical replication. Additionally, the fund's high risk rating (7 out of 7) and exposure to emerging markets and natural resources companies further contribute to its complexity. While the fund does not use leverage or inverse strategies, the derivative usage for purposes beyond efficient portfolio management (EPM) triggers the 'complex' classification.",
    "confidence": 85
}