{
    "fund_name": "First Trust Global Capital Strength ESG Leaders UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Complex ESG screening methodology",
        "Active management with discretionary adjustments",
        "Restricted investment universe due to ESG criteria"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication and does not employ leverage, inverse strategies, or swaps. It invests in a diversified portfolio of global equities with an ESG focus, using an active management approach that applies proprietary 'capital strength' criteria. While the ESG screening and active management add some complexity, the underlying investments are straightforward equities, and the risk profile is clearly communicated as mid-to-high risk (SRRI 6). The fund's transparency, UCITS compliance, and lack of derivative usage make it suitable for retail investors under MiFID II.",
    "confidence": 90,
    "counter_argument": "Some might argue that the active management and ESG screening add complexity, but these factors do not meet MiFID II's criteria for 'complex' instruments. The fund's transparency and lack of derivative usage outweigh these considerations.",
    "risk_level": "6 (mid-to-high risk)"
}