{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Use of swaps for efficient portfolio management",
        "Counterparty risk exposure",
        "Complex index methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses physical replication but mentions the use of financial derivatives (futures) and swaps with counterparties (Morgan Stanley, Societe Generale) for efficient portfolio management. While the primary replication method is physical, the presence of swaps and counterparty risk, along with the complex index methodology (Solactive EUR USD IG Corporate Green Bond TR Index), contributes to the classification as complex under MiFID II. The index involves a multi-step screening process for green bonds, which may not be easily understood by retail investors. Additionally, the fact sheet mentions counterparty risk and replication risk, which are factors that can increase complexity. The ETF is UCITS-compliant, but the use of derivatives and counterparty exposure, even if for efficient portfolio management, can trigger a complex classification under MiFID II.",
    "confidence": 85
}