{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "FLEX Options usage",
        "Customised equity options",
        "Buffer and cap mechanisms",
        "Complex index tracking"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses FLEX Options (customised equity options) to achieve its investment objective, which involves a buffer against the first 15% of index losses and a predetermined upside cap. This structure is inherently complex due to the customised nature of the options, the buffer/cap mechanism, and the active management required to reset the strategy annually. While the ETF is UCITS-compliant and does not use leverage or inverse exposure, the use of derivatives (FLEX Options) for the core investment strategy, rather than just efficient portfolio management, triggers the 'complex' classification under MiFID II. The risk profile (category 5) and the requirement for investors to hold shares for the entire Target Outcome Period (approximately one year) further support this classification. The PRIIPs KID and fact sheet confirm the extensive use of derivatives and the structured nature of the investment strategy.",
    "confidence": 90
}