{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Complex index tracking"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps for synthetic replication, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions 'unfunded swaps' and 'swap agreements,' which are key indicators of complexity under MiFID II. Additionally, the fund's reliance on derivatives for index tracking and the potential for tracking error due to counterparty performance further support the classification as complex. The PRIIPs KID and factsheet confirm the synthetic replication method and swap usage, reinforcing the complexity determination. While the fund is UCITS-compliant and tracks a straightforward healthcare sector index, the use of derivatives for replication rather than direct investment in underlying securities is a primary driver of the complex classification.",
    "confidence": 90
}