{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The UBS (Irl) ETF plc - MSCI Australia UCITS ETF is a physically replicated ETF that tracks the MSCI Australia 100% hedged to EUR Index. The KIID and factsheet indicate that the fund uses physical replication to hold all or nearly all of the securities in the index. While the KIID mentions that the fund may use derivative instruments for risk reduction, cost reduction, or generating additional capital or income, this is explicitly stated as an ancillary activity rather than a core strategy. The fund does not employ leverage, inverse strategies, or synthetic replication. The risk profile is categorized as level 6 due to the volatility of equities, but this is typical for equity ETFs and does not indicate complexity under MiFID II. The fund is UCITS-compliant, which generally aligns with non-complex classifications. The factsheet confirms physical replication and does not reveal any additional complexity factors such as swap usage or complex underlying assets.",
    "confidence": 95,
    "counter_argument": "Some might argue that the use of derivatives for any purpose could trigger complexity. However, MiFID II guidelines allow for derivatives to be used for efficient portfolio management (EPM) without classifying the instrument as complex, provided they are not used for leverage or to create a materially different risk profile. The fund's derivative usage is clearly secondary and for risk management, not a primary strategy.",
    "risk_level": 6
}