{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Contingent Convertible Bonds"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its exposure to contingent convertible bonds (CoCos), which are inherently complex instruments with trigger mechanisms that can lead to principal write-downs or conversion to equity. While the fund uses derivatives only for efficient portfolio management (EPM) and follows a physical replication strategy, the inclusion of CoCos introduces significant complexity. The KIID explicitly warns about the risks associated with CoCos, including potential write-downs, coupon deferrals, and conversion to equity at discounted prices. These features require specialized knowledge to understand fully, aligning with MiFID II's criteria for complex instruments. Additionally, the fund's active management approach and ESG screening, while not inherently complex, add layers of decision-making that may not be immediately transparent to retail investors.",
    "confidence": 0.9
}