{
    "fund_name": "Invesco FTSE All Share Screened & Tilted UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the FTSE All-Share ex Investment Trusts ESG Climate Select Index, holding the underlying securities directly. While derivatives are permitted for efficient portfolio management (EPM) such as hedging or reducing costs, there is no indication of extensive or complex derivative usage that would materially alter the risk profile. The fund is UCITS-compliant, has a clear investment objective, and follows a straightforward index-tracking strategy. The risk profile (category 6) is primarily due to equity market exposure rather than structural complexity. The ESG screening and tilting methodology, while sophisticated, does not introduce complexity in the MiFID II sense, as it remains transparent and rules-based.",
    "confidence": 95,
    "risk_level": 6,
    "counter_argument": "Some might argue that the ESG tilting methodology or the use of derivatives for EPM could introduce complexity. However, the derivatives are used in a limited and controlled manner for risk management rather than as a core strategy, and the ESG methodology is clearly disclosed and systematic. The fund's physical replication and lack of leverage or inverse strategies support the non-complex classification."
}