{
    "fund_name": "Ossiam US ESG Low Carbon Equity Factors UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track a selection of US equities based on ESG and factor-based criteria. It does not employ leverage, inverse strategies, or synthetic replication. The investment process is systematic and rules-based, focusing on ESG screening and factor exposure without reliance on complex financial instruments. The risk indicator is level 6, which is high but not necessarily indicative of complexity under MiFID II, as it reflects equity market volatility rather than structural complexity. The KIID and factsheet do not mention the use of derivatives, swaps, or other complex instruments. The fund is UCITS-compliant, which generally aligns with non-complex classifications under MiFID II. The absence of counterparty risk, leverage, or structured features further supports the non-complex classification.",
    "confidence": 95,
    "risk_level": 6,
    "counter_argument": "The risk level of 6 might suggest higher complexity due to volatility, but this is inherent to equity markets and not due to structural complexity. The ESG and factor-based methodology, while sophisticated, does not introduce complexity in the MiFID II sense, as it does not involve derivatives or leverage.",
    "final_decision": "The ETF is classified as non-complex because it uses physical replication, does not employ derivatives or leverage, and adheres to UCITS standards, making it suitable for retail investors under MiFID II."
}