{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an over-the-counter swap contract (FDI) with counterparties like Morgan Stanley Bank AG and Societe Generale, exposing investors to counterparty risk. The KIID explicitly mentions financial derivative instruments (FDIs) and the risks associated with them, including leverage risk and high volatility. The factsheet confirms the synthetic replication method and highlights counterparty risk as a key concern. While the ETF does not employ leverage or inverse strategies, the use of swaps and the synthetic replication method inherently introduce complexity due to counterparty exposure and the need for investors to understand the mechanics of swap agreements and collateral management.",
    "confidence": 90,
    "risk_level": 4,
    "counter_argument": "The ETF could be argued as non-complex due to its straightforward objective of tracking a well-known healthcare index and its UCITS compliance, which imposes strict risk limits. However, the synthetic replication and explicit counterparty risk warnings in the KIID and factsheet override this argument, as MiFID II explicitly flags synthetic replication and significant counterparty exposure as complexity indicators.",
    "additional_notes": "The ETF's risk level (SRRI 4) and the presence of operational and liquidity risks further support the complexity classification. The factsheet's emphasis on counterparty risk and the use of swaps align with MiFID II's criteria for complex instruments."
}