{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but acknowledges the use of financial derivatives and swap agreements with counterparties like Morgan Stanley Bank AG and Societe Generale. While the replication method is physical, the presence of swap agreements and counterparty risk introduces complexity. The KIID and factsheet mention 'Financial Derivatives Instruments' and 'OTC Swap' exposure, which, despite being within UCITS limits, adds a layer of complexity due to counterparty risk and potential tracking error. The risk profile is relatively low (SRRI 3), but the use of derivatives for purposes beyond efficient portfolio management (EPM) and the explicit mention of counterparty risk warrant a 'complex' classification under MiFID II.",
    "confidence": 0.85
}