{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives for replication",
        "OTC derivatives with counterparty risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses derivatives, including OTC derivatives, for replication purposes when direct investment is impractical. This introduces counterparty risk, which is mitigated but not eliminated. The KIID explicitly mentions the use of derivatives and the associated risks, including potential losses due to counterparty failure. While the primary replication method is physical, the use of derivatives for replication in certain circumstances and the exposure to OTC derivatives with counterparty risk elevate the complexity. The fund's risk category of 7 also indicates high volatility and risk, which, combined with derivative usage, supports the classification as complex under MiFID II.",
    "confidence": 85
}