{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Swaps",
        "Derivatives for investment purposes"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its use of total return swaps and derivatives for investment purposes, despite being physically replicated. The KIID states the fund may invest up to 15% in total return swaps and contracts for difference, though not expected to exceed 5%. Additionally, derivatives are used not just for efficient portfolio management but also for investment purposes, which introduces additional complexity. The fund also mentions potential counterparty risk and operational risks associated with derivatives. While the primary replication method is physical, the use of swaps and derivatives beyond simple hedging or efficient portfolio management triggers the complex classification under MiFID II.",
    "confidence": 85,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": true,
    "tracking_error_risk": true,
    "emerging_markets_risk": true,
    "currency_risk": true,
    "esg_focus": true,
    "sustainability_characteristics": "Article 8 SFDR",
    "benchmark_complexity": "FTSE Asia Pacific ex Japan ESG Low Carbon Select Index, which applies multiple ESG exclusionary criteria and seeks to improve ESG ratings",
    "additional_notes": "While the fund is physically replicated and has a straightforward investment objective, the use of swaps and derivatives for investment purposes, along with the potential for significant counterparty risk and operational risks, leads to the classification as complex. The fund's risk level of 6 also supports this classification, as higher risk levels often correlate with complexity under MiFID II."
}