{
    "complex": false,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Derivative usage (up to 10% in total return swaps)",
        "Potential counterparty risk from derivative exposure",
        "Complex ESG screening methodology in index"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication (as confirmed in the factsheet) with up to 10% derivative exposure for efficient portfolio management, which is within typical UCITS ETF parameters. While derivatives are used, they are not for leverage or inverse strategies, and the overall structure remains transparent with clear risk disclosures. The ESG-focused index tracking adds some complexity but does not cross into MiFID II's 'complex' threshold. The fund's UCITS compliance and straightforward equity exposure further support the non-complex classification.",
    "confidence": 90
}