{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Total Return Swaps",
        "Contracts for Difference"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its use of total return swaps and contracts for difference, which introduce counterparty risk and derivative exposure. Although the primary replication method is physical, the allowance for up to 10% of assets in swaps and derivatives, combined with the potential for securities lending (up to 30%), adds layers of complexity. The KIID explicitly mentions derivative-related risks, including tracking error and counterparty risk, which are not typical of non-complex instruments. The risk profile (category 6) and the warning that the fund may not be suitable for investors with a short-term horizon further support this classification. While the ETF does not employ leverage or inverse strategies, the derivative usage for purposes beyond efficient portfolio management (e.g., gaining exposure to index constituents) and the potential for significant tracking error due to these instruments justify the 'complex' designation under MiFID II.",
    "confidence": 85
}