{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "ESG screening",
        "Emerging market bonds",
        "Counterparty risk from derivatives"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication as its primary method and employs derivatives only for efficient portfolio management (EPM) and not for leverage or complex strategies. The underlying assets are emerging market bonds with ESG criteria, which, while carrying higher credit risk, are not inherently complex instruments. The risk level is rated 5, but this is due to the nature of emerging market debt rather than structural complexity. The use of derivatives is limited and does not introduce significant additional risk or require specialist knowledge to understand.",
    "confidence": 85,
    "counter_argument": "Some might argue that the ESG screening and emerging market exposure add complexity, but these factors relate to the underlying asset class rather than the structure of the ETF itself. The derivatives are used in a straightforward manner for EPM, not for leverage or sophisticated strategies, which keeps the ETF within non-complex classification under MiFID II.",
    "risk_level": 5,
    "benchmark_complexity": "The benchmark is a standard ESG-filtered emerging market bond index, which is not considered complex in itself."
}