{
    "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",
        "Complex index methodology (CAPE-based selection)"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication through swap agreements with Barclays, which introduces counterparty risk. While there is no leverage or inverse exposure, the use of derivatives for replication and the complex index methodology (based on CAPE ratios and dynamic sector selection) make this a complex product under MiFID II. The PRIIPs KID confirms a medium risk classification (4/7), and the KIID explicitly mentions derivative and counterparty risks. The fact that the fund may switch between synthetic and physical replication adds another layer of complexity. While the underlying assets are global equities, the dynamic selection process and derivative-based replication make this unsuitable for retail investors without specialist knowledge.",
    "confidence": 90
}