{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Synthetic replication using total return swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via a total return swap, which introduces counterparty risk and derivative exposure as integral parts of its investment strategy. The KIID explicitly states that derivatives are integral to the fund's strategy, and the factsheet confirms the synthetic replication method. While the fund does not employ leverage or inverse strategies, the use of swaps and the associated counterparty risk make it complex under MiFID II rules. The fund's risk profile (SRRI 4) and the presence of hedging risks further support this classification.",
    "confidence": 90
}