{
    "ucits": true,
    "type": "ETF",
    "leverage": true,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Active management, use of derivatives (futures, swaps, call options) for investment purposes, quantitative models, potential for market leverage, counterparty risk, ESG screening, securities lending",
    "classification": "complex",
    "supporting_data": "The ETF is actively managed and uses derivatives (futures, swaps, call options) not just for efficient portfolio management but as a core part of its investment strategy to generate income and manage risk. This introduces counterparty risk and potential market leverage, which are not typical of standard, non-complex UCITS ETFs. The use of quantitative models and the possibility of deviating materially from the benchmark index add further complexity. While the ETF is UCITS-compliant and uses physical replication for its equity holdings, the central role of derivatives in the strategy, the active management approach, and the associated risks (including counterparty risk and the potential for leverage) mean the product's structure and risks are not easily understood by a retail investor with only basic knowledge. These features override the general UCITS presumption of non-complexity and align with ESMA and MiFID II guidance that UCITS employing complex strategies or significant derivative use should be considered complex and require an appropriateness assessment[2]. The ETF does not appear to use inverse strategies or synthetic replication, but the active use of swaps and other derivatives is sufficient to trigger a complex classification under MiFID II Article 57 and Delegated Regulation EU 2017/565."
}