{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Complex underlying assets (CLOs)",
        "Structured products",
        "Credit risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF invests in AAA-rated Collateralised Loan Obligations (CLOs), which are structured products backed by diversified portfolios of senior secured bank loans. While the ETF itself does not use derivatives for leverage or inverse exposure, the underlying CLOs are complex structured products that require specialist knowledge to understand. The ETF's risk profile is tied to the creditworthiness of the underlying loans and the structural protections of the CLOs, which may not be easily understood by retail investors. The ETF's investment in CLOs, which are asset-backed securities with complex cash flow structures, contributes to its classification as a complex financial instrument under MiFID II. Additionally, the ETF's focus on CLOs, which are not as liquid as corporate bonds, and the potential for credit default risks further support this classification.",
    "confidence": 90
}