{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Complex index methodology (ESG screening, carbon reduction, multiple exclusion criteria)",
        "Potential derivative usage (up to 10% in swaps/CFDs, though not expected to exceed 5%)",
        "Risk profile classified as category 6 (highest risk level)"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication as its primary method (confirmed in both KIID and fact sheet) and does not employ leverage or inverse strategies. While it has permissions to use derivatives (up to 10% in swaps/CFDs), the fact sheet indicates this is not expected to exceed 5% and is likely for efficient portfolio management rather than core strategy. The index methodology is complex (ESG screening, carbon reduction, multiple exclusions), but this does not automatically trigger complexity classification under MiFID II. The risk profile is high (category 6), but this reflects market volatility rather than structural complexity. The fund is UCITS-compliant and has transparent holdings. The potential derivative usage is within typical EPM (efficient portfolio management) limits and does not appear to create materially different risk characteristics from the underlying assets. The fact sheet confirms no actual swap usage as of the latest reporting date.",
    "confidence": 85
}