{
    "fund_name": "HSBC JAPAN SCREENED EQUITY UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives for investment purposes",
        "Total return swaps",
        "Counterparty risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex due to its use of derivatives for investment purposes beyond efficient portfolio management (EPM), including total return swaps and contracts for difference (up to 10% of assets). While it primarily uses physical replication, the potential use of derivatives for investment purposes and the explicit mention of counterparty risk introduce complexity. The KIID highlights risks such as 'Derivatives Risk' and 'Investment Leverage Risk,' which are not typical for non-complex ETFs. Additionally, the fund's risk profile is categorized as level 6, indicating higher volatility and complexity. The presence of securities lending (up to 30%) and the potential for tracking error further contribute to the complexity assessment.",
    "confidence": 90,
    "counter_argument": "The ETF could be argued as non-complex due to its primary use of physical replication and low ongoing charges (0.18%). However, the explicit allowance for derivatives beyond EPM and the associated risks (e.g., counterparty risk) outweigh this argument, as MiFID II emphasizes the potential for significant additional risks or the need for specialist knowledge to understand the product.",
    "risk_level": 6
}