{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "inverse": false,
    "derivatives": false,
    "swaps": false,
    "complex_factors": [
        "High yield bonds",
        "Complex index methodology",
        "ESG screening complexity"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication with minimal derivative usage (only for direct investment purposes and expected to be limited). The index tracks high-yield fallen angel bonds with ESG and climate alignment criteria, which adds complexity to the underlying assets but does not trigger MiFID II complexity classification. The fund does not use leverage, inverse strategies, or synthetic replication. The risk profile (category 4) is moderate and clearly disclosed. The primary complexity factors are the high-yield bond focus and the sophisticated index methodology, but these do not meet MiFID II's complexity thresholds for retail investors.",
    "confidence": 85
}