{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Complex index tracking methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication through swap agreements to track the Shiller Barclays CAPE Europe Sector Value Net TR Index, which introduces counterparty risk. The KIID explicitly mentions 'swap agreements' and 'derivative instruments' as part of its investment strategy. Additionally, the index itself is complex, involving dynamic sector selection based on CAPE ratios and price variations, which may not be easily understood by retail investors. The risk profile is rated 6 out of 7, indicating higher risk and complexity. The presence of significant derivative-related risk disclosures and the synthetic replication method are key factors in classifying this ETF as complex under MiFID II.",
    "confidence": 90
}