{
    "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)",
        "Potential exposure to illiquid securities"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication through financial derivative instruments, which is a key complexity indicator under MiFID II. While it doesn't use leverage or inverse strategies, the use of swaps for replication purposes triggers complexity. Additionally, the fund may invest in Contingent Convertible Bonds (CoCos) and other complex securities, which further increases the complexity. The risk profile includes exposure to illiquid securities and emerging markets, which may not be easily understood by retail investors. The fact that the ETF is UCITS-compliant does not automatically make it non-complex, as UCITS funds can still use derivatives and complex strategies. The combination of synthetic replication and potential exposure to complex underlying assets leads to the classification as a complex financial instrument.",
    "confidence": 85
}