{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Investment in complex underlying assets (Contingent Convertible Bonds)",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via financial derivative instruments (including swaps) to gain exposure to underlying assets. While it does not employ leverage or inverse strategies, the use of derivatives for replication and the potential investment in complex securities like Contingent Convertible Bonds (CoCos) triggers MiFID II complexity classification. The KIID and factsheet confirm the use of derivatives and reference counterparty risk, which are key complexity indicators. Additionally, the ETF's active management strategy and exposure to less liquid or structured securities (e.g., ABS/MBS) further support the complex classification. The PRIIPs KID does not contain a comprehension warning, but the derivative usage and underlying asset complexity are sufficient to classify it as complex under MiFID II.",
    "confidence": 90
}