{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via a total return swap to track the S&P Global Luxury Index, which introduces counterparty risk and derivative exposure. The KIID explicitly states that derivatives are integral to the investment strategy, and the presence of an unfunded swap structure (implied by the lack of collateral details) further supports the complexity classification. While the ETF does not employ leverage or inverse strategies, the reliance on derivatives for replication and the associated counterparty risks make it complex under MiFID II rules. The risk profile (SRRI 4) and the disclosure of counterparty risk in the KIID reinforce this assessment.",
    "confidence": 9
}