{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Contingent Convertible Bonds (CoCos)",
        "Total Return Swaps",
        "Optimisation Technique"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex under MiFID II due to several factors: 1) It may invest up to 30% in total return swaps, which introduces counterparty risk and derivative exposure. 2) The fund holds Contingent Convertible Bonds (CoCos), which are complex instruments with potential for principal loss and conversion to equity. 3) The use of an optimisation technique for replication, while not inherently complex, adds a layer of strategy that may not be easily understood by retail investors. 4) The fund's risk disclosures mention significant risks associated with derivatives, leverage, and emerging markets. While the fund uses physical replication as its primary method, the combination of swap exposure, CoCo bonds, and optimisation techniques elevates its complexity beyond typical ETFs. The PRIIPs KID and monthly factsheet confirm these exposures and strategies.",
    "confidence": 85
}