{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using total return swaps",
        "Counterparty risk exposure from swap agreements",
        "Indirect replication methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps to achieve exposure to the TOPIX index, which introduces counterparty risk and makes the investment strategy more complex. While the fund is UCITS-compliant and has a straightforward equity index objective, the use of derivatives for replication rather than physical holding of securities triggers the MiFID II complexity classification. The KIID explicitly mentions 'derivatives are integral to the Sub-Fund's investment strategies' and highlights counterparty risk, which are key complexity indicators. The PRIIPs KID and factsheet confirm the synthetic replication approach, reinforcing the complexity determination.",
    "confidence": 90
}