{
    "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",
        "Indirect replication methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps to achieve exposure to the S&P 500 Index, which introduces counterparty risk and makes the investment strategy more complex than physical replication. While the fund does not use leverage or inverse strategies, the reliance on derivatives for core exposure and the indirect replication methodology are key factors that trigger the 'complex' classification under MiFID II. The KIID explicitly mentions counterparty risk and hedging risk, which are typical concerns for synthetic ETFs. The fact that derivatives are 'integral to the Sub-Fund's investment strategy' further supports this classification. The PRIIPs KID and factsheet confirm the synthetic replication approach, reinforcing the complexity determination.",
    "confidence": 90
}