{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivative usage for non-EPM purposes",
        "Counterparty risk from FDIs"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication to track the FTSE All Share ex IT ex CW ex TC ex REITS Dividend Growth with Quality Net Tax Index. While it mentions the use of financial derivative instruments (FDIs), these appear to be used for efficient portfolio management rather than as a core strategy. The KIID and factsheet indicate no leverage, inverse exposure, or synthetic replication. The risk profile is rated 6-7, but this is primarily due to equity market risks rather than structural complexity. The ETF is UCITS-compliant, promotes ESG characteristics, and has a straightforward dividend-focused strategy.",
    "confidence": 90,
    "counter_argument": "The presence of FDIs could suggest complexity, but the documentation clarifies these are used for managing risk rather than as an inherent element of the strategy. The ETF's physical replication method and lack of leverage or synthetic exposure outweigh the derivative usage in this context.",
    "risk_level": 6
}