{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Invesco Quantitative Strategies ESG Global Equity Multi-Factor UCITS ETF is an actively managed ETF that invests in global equities based on ESG criteria and quantitative factors (Value, Quality, Momentum). The KIID and factsheet indicate physical replication with no mention of synthetic replication, swaps, or leverage. Derivatives are only used for risk management, not as a core strategy. The fund has a clear investment objective, straightforward risk profile (risk category 6 due to equity market exposure), and no complex underlying assets. The ESG screening and quantitative model are transparent and do not introduce complexity beyond standard equity investing. The fund is UCITS-compliant, further supporting its non-complex classification.",
    "confidence": 95,
    "counter_argument": "Some might argue that the quantitative investment model or ESG screening adds complexity. However, these are standard practices in modern equity investing and do not materially alter the fund's risk-return profile or require specialist knowledge to understand. The use of derivatives for risk management is explicitly permitted under MiFID II for non-complex instruments, provided they are not used for leverage or speculative purposes.",
    "risk_level": 6
}