{
    "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",
        "Derivative instruments"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an over-the-counter swap contract (FDI) to track the STOXX Europe 600 Telecommunications Index. While the fund is UCITS-compliant and has a straightforward equity focus, the use of derivatives (specifically swaps) introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions 'financial derivative instruments' and 'counterparty risk,' which are key indicators of complexity under MiFID II. The fact sheet confirms the replication method is 'synthetic,' further supporting this classification. The risk profile is relatively low (SRRI 3), but the derivative usage and counterparty exposure make it complex for retail investors to fully understand.",
    "confidence": 90
}