{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Complex index methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps for synthetic replication, which introduces counterparty risk and complexity. While the index is broadly based, its ESG screening methodology adds complexity. The use of derivatives for index tracking (not just risk management) and the potential for tracking error due to swap pricing spreads contribute to the classification. The PRIIPs KID confirms swap usage and counterparty risk, while the fact sheet highlights the synthetic replication method. The risk category 6 (out of 7) also suggests higher complexity. The ESG screening criteria and exclusion of certain sectors/issuers further complicate the investment strategy beyond a simple index tracker.",
    "confidence": 90
}