{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Complex Index Tracking"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses physical replication but acknowledges the use of OTC swaps with counterparties like Morgan Stanley and Societe Generale, which introduces counterparty risk. The factsheet explicitly mentions 'COUNTERPARTY RISK' due to swap agreements, and while the exposure is limited to 10% of total assets per UCITS guidelines, this still qualifies as a complex feature under MiFID II. Additionally, the underlying index (S&P Eurozone LargeMidCap Net Zero 2050 Paris-Aligned ESG Index) is highly specialized with a complex methodology involving decarbonization targets, climate risk adjustments, and ESG criteria, which may not be easily understood by retail investors. The presence of swaps and the complexity of the benchmark index justify the 'complex' classification despite the ETF being UCITS-compliant and primarily physically replicated.",
    "confidence": 85
}