{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using unfunded swaps",
        "Counterparty risk exposure",
        "Complex index tracking via derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication with unfunded swaps, which introduces counterparty risk and complexity beyond simple physical replication. The KIID explicitly mentions 'unfunded swaps' and 'counterparty risk,' which are key complexity indicators under MiFID II. While the underlying index (EURO STOXX 50) is relatively straightforward, the use of derivatives for tracking introduces additional layers of risk that may not be easily understood by retail investors. The PRIIPs KID and factsheet confirm the synthetic replication method and swap usage, reinforcing the complexity classification. The risk category of 6 (out of 7) also suggests a higher complexity profile.",
    "confidence": 90
}