{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Use of derivatives for replication",
        "Potential counterparty risk from swaps",
        "Complex index composition (foreign bonds with ESG overlay)"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses a stratified sampling strategy with potential derivative usage for replication, which introduces counterparty risk. While the primary replication method is physical, the KIID mentions the possibility of using derivatives to achieve proportionate exposure. The index tracks foreign bonds with ESG characteristics, which may add complexity in understanding the underlying assets. The risk profile is moderate (risk level 4), but the combination of derivative usage and the nature of the underlying assets (foreign bonds) suggests this ETF may be considered complex under MiFID II.",
    "confidence": 85
}