{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives for EPM",
        "Total Return Swaps",
        "Contracts for Difference"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but is permitted to use derivatives, including total return swaps and contracts for difference (CFDs), up to 10% of its assets. While the primary replication method is physical, the use of derivatives beyond simple hedging (e.g., for investment purposes) introduces complexity. The KIID explicitly mentions derivative risks, including volatility divergence and counterparty risks, which are hallmarks of complex instruments under MiFID II. Additionally, the fund's risk profile is categorized as level 6, indicating higher volatility and potential complexity. The presence of swap agreements and CFDs, even if limited, suggests a layer of complexity that may not be easily understood by retail investors.",
    "confidence": 85,
    "counter_argument": "The fund is primarily physically replicated and has a straightforward climate-aligned index-tracking objective. The derivative usage is limited (up to 10%) and framed as a contingency for when direct investment is impractical. However, the explicit mention of derivative risks and the potential for tracking error due to derivative usage outweighs this argument, as MiFID II tends to classify instruments with any material derivative exposure as complex, especially when such exposure is not purely for hedging.",
    "risk_level": 6
}