{
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Contingent Convertible Bonds",
        "Total Return Swaps",
        "Complex Indices"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex under MiFID II due to several factors: 1) It uses synthetic replication via total return swaps (up to 30% of assets), which introduces counterparty risk and requires specialist understanding. 2) The fund invests in contingent convertible bonds (CoCos), which are complex structured products with loss-absorbing features that can convert to equity under certain conditions. 3) The Bloomberg Global Aggregate Bond Index includes a diverse range of bonds (government, corporate, securitized) across developed and emerging markets, some with below-investment-grade ratings (Ba1/BB+), adding complexity. 4) While the risk profile is rated 3/7, the use of derivatives for hedging and the potential for significant tracking error (due to optimization techniques) adds layers of complexity. 5) The fund's exposure to emerging markets and ABS/MBS securities introduces additional risks that may not be easily understood by retail investors. The monthly factsheet confirms swap usage is currently at 0%, but the permission to use up to 30% in swaps remains a complexity factor. The PRIIPs KID would likely contain a comprehension alert, further supporting the complex classification.",
    "confidence": 90
}