{
    "complex": false,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "OTC Swap with counterparty risk",
        "Physical replication with derivative exposure"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication as its primary method (confirmed in the factsheet) and tracks a straightforward equity index (FTSE Italia PMI PIR Net Tax Index). While it does use an OTC swap with counterparties (Morgan Stanley and Societe Generale), the exposure is capped at 10% of assets, and the swap is likely used for efficient portfolio management rather than leverage or complex strategies. The risk profile is rated as 'lower risk' (SRRI 1-3), and the fund's documentation emphasizes transparency and liquidity. The presence of derivatives does not automatically trigger complexity under MiFID II if they are used for simple replication or hedging purposes. The ETF is UCITS-compliant, which typically aligns with non-complex classification unless specific complexity triggers are present. The factsheet and KIID do not indicate leverage, inverse exposure, or capital protection features. The primary complexity factor is the counterparty risk from the swap, but this is mitigated by UCITS limits and the fund's overall straightforward structure.",
    "confidence": 85
}