{
    "complex": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Contingent Convertible Bonds",
        "Complex Underlying Assets"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its investment in Contingent Convertible Bonds (CoCos), which are inherently complex instruments with features such as principal write-downs or conversion to equity upon predefined triggers. Additionally, the underlying index tracks a niche segment of the bond market (AT1 bonds) with specific regulatory and structural complexities. While the ETF uses physical replication and does not employ leverage or derivatives for investment purposes, the nature of the underlying assets and their risk characteristics (e.g., credit risk, liquidity risk, and regulatory triggers) make the product difficult for retail investors to fully understand without specialized knowledge. The PRIIPs document reinforces this by stating the product is not considered appropriate for retail investors by the CNMV in Spain, further supporting the complex classification.",
    "confidence": 90
}