{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Derivative usage (up to 10% in total return swaps)",
        "Counterparty risk from derivative exposure",
        "Emerging market complexity",
        "Potential tracking error from index replication"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication (as confirmed in the fact sheet) and only uses derivatives for efficient portfolio management (up to 10% in total return swaps). While there is some derivative exposure, it is limited and not the core strategy. The fund tracks a complex emerging market ESG index, but the replication method is straightforward physical replication. The risk profile (category 6) reflects emerging market volatility rather than product complexity. The derivative usage is within typical ETF parameters for efficient portfolio management and does not create materially different risk characteristics. The fund is UCITS-compliant, which typically indicates non-complex status unless specific complexity factors are present.",
    "confidence": 85
}