{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Use of derivatives for replication",
        "Counterparty risk from OTC derivatives",
        "Complex index methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses derivatives for replication purposes, which introduces counterparty risk and complexity beyond simple physical replication. While the KIID states 'physical replication' in the factsheet, the prospectus mentions potential use of derivatives where direct replication is not possible. The MSCI China Universal Low Carbon Select 5% Issuer Capped Index involves complex ESG screening and issuer capping, adding to the complexity. The use of OTC derivatives for replication creates counterparty risk, which is a MiFID II complexity factor. While the fund is UCITS-compliant and uses derivatives for efficient replication rather than leverage or inverse exposure, the combination of derivative usage and complex index methodology makes it complex under MiFID II.",
    "confidence": 85
}