{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Swaps",
        "Synthetic Replication",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via a total return swap, which is a derivative instrument integral to its investment strategy. This introduces counterparty risk and requires understanding of swap mechanics, making it complex under MiFID II. The KIID explicitly mentions 'total return swap' and 'derivative instruments' as part of the fund's methodology, confirming its reliance on derivatives beyond simple efficient portfolio management. The presence of significant counterparty risk disclosures further supports the complexity classification.",
    "confidence": 95
}