{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Counterparty Risk from Swaps",
        "Securities Lending"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but engages in securities lending and has counterparty risk exposure from OTC swaps with Morgan Stanley Bank AG and Societe Generale. While the replication method is physical, the use of swaps and securities lending introduces complexity. The KIID and factsheet disclose counterparty risk and operational risks associated with these activities. The SRRI risk level is not explicitly high, but the presence of derivative instruments (swaps) and the associated risks make it complex under MiFID II rules. The factsheet explicitly mentions 'counterparty risk' due to OTC swaps, which is a key complexity indicator.",
    "confidence": 85,
    "risk_level": "medium",
    "counter_argument": "The ETF could be argued as non-complex due to its primary physical replication strategy and straightforward equity exposure. However, the use of swaps and securities lending, even if limited, introduces elements that require additional investor understanding, thus meeting the threshold for complexity under MiFID II."
}