{
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Unfunded swap structure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via unfunded swaps to track the S&P Select Sector Capped 20% Industrials Index, 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. While the ETF is UCITS-compliant and tracks a straightforward equity index, the reliance on derivatives for replication (rather than direct investment in underlying securities) and the associated counterparty risk elevate its classification to 'complex.' The PRIIPs KID and factsheet confirm the synthetic replication method and swap usage, reinforcing the complexity determination. The risk profile (category 6) and disclosures about counterparty risk further support this classification.",
    "confidence": 90
}