{
    "complex": false,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Use of total return swaps (up to 15%)",
        "Investment in other funds (up to 10%)",
        "Complex ESG index methodology",
        "Emerging market exposure"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication (as confirmed in the factsheet) and only uses derivatives (total return swaps up to 15%) for efficient portfolio management, not for leverage or inverse strategies. The replication method is physical-full, and the fund tracks a complex ESG index but does not exhibit characteristics that would make it complex under MiFID II. The use of derivatives is within standard EPM (Efficient Portfolio Management) practices and does not create significant additional risk. The fund is UCITS-compliant, has a straightforward investment objective, and the risks are clearly disclosed. The fact that it is classified in risk category 6 is due to the underlying index's volatility, not the fund's structure. The ETF is suitable for retail investors as it provides transparency and liquidity.",
    "confidence": 90
}