{
    "complex": false,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Use of total return swaps (up to 10%)",
        "Potential for tracking error due to index replication",
        "Complex ESG screening methodology"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication as its primary method (as confirmed in the fact sheet) and only uses derivatives (up to 10% in total return swaps) for efficient portfolio management rather than as an inherent part of its strategy. The derivatives usage is limited and transparent, with no leverage or inverse exposure. The fund's risk profile (category 6) is clearly disclosed, and the underlying index is a standard equity index with ESG screening. While the ESG criteria add some complexity, this is typical for sustainable funds and doesn't make the product inherently complex under MiFID II. The fund is UCITS-compliant and provides adequate public information.",
    "confidence": 90
}