{
    "fund_name": "Global X CleanTech UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Unfunded OTC swaps",
        "Potential for significant counterparty risk",
        "High concentration in CleanTech sector (risk category 7)",
        "Potential for complex index tracking risks"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded OTC swaps and exchange-traded equity futures for investment purposes, which introduces counterparty risk and potential complexity. While it primarily uses physical replication, the use of derivatives for investment purposes (not just efficient portfolio management) and the high risk category (7) suggest complexity. The CleanTech sector focus also introduces concentration risk that may not be easily understood by retail investors. The PRIIPs KID would need to be reviewed for any comprehension warnings that might further support this classification.",
    "confidence": 85,
    "counter_argument": "The ETF is UCITS-compliant and primarily uses physical replication, which typically suggests non-complex status. The derivatives usage might be argued as minimal for efficient portfolio management.",
    "overriding_reason": "The explicit mention of unfunded OTC swaps for investment purposes (not just hedging) and the high risk category (7) outweigh the physical replication method in determining complexity under MiFID II."
}