{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Use of up to 10% in total return swaps",
        "Potential for up to 35% single issuer exposure",
        "Complex ESG and value factor indexing methodology"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication (as confirmed in the factsheet) and derivatives are limited to 10% for efficient portfolio management (not for leverage or inverse exposure). The risk profile is straightforward (category 6) and the fund tracks a complex but transparent index. While swaps are permitted, their usage appears limited and for EPM purposes. The ETF is UCITS-compliant and has a clear, liquid structure suitable for retail investors. The main complexity factors are the ESG/value factor methodology and potential single issuer concentration, but these don't meet MiFID II's complexity thresholds.",
    "confidence": 85
}