{
    "complex": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Contingent Convertible Bonds"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its investment in Contingent Convertible Bonds (CoCos), which are hybrid debt securities with complex conversion and write-down mechanisms. While the ETF uses physical replication, the underlying assets (CoCos) are inherently complex instruments that may convert into equity or suffer principal write-downs under certain conditions. The risk profile is high (SRRI 6), and the KIID explicitly states that CoCos are 'relatively new and complex instruments' with untested behavior in stressed financial markets. The PRIIPs KID does not contain a comprehension alert, but the detailed risk disclosures in both documents highlight the complexity of CoCos, including discretionary coupons, potential capital loss, and lack of maturity. The ETF's focus on AT1 CoCos, which are designed to absorb bank losses, further contributes to its complexity. While the replication method is physical, the underlying assets' complexity drives the classification.",
    "confidence": 90
}