{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Machine learning-based ESG screening"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps, which introduces counterparty risk and complexity beyond physical replication. While it does not employ leverage or inverse strategies, the use of swaps for performance delivery and the machine learning-based ESG screening process make the investment strategy less transparent and more complex for retail investors. The risk profile (level 5) and the mention of derivative and counterparty risks in the KIID further support the classification as complex. The PRIIPs KID and factsheet confirm the synthetic replication method and the active management approach, which adds to the complexity.",
    "confidence": 85
}