{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": "Derivatives (FDIs, including swaps and futures) are used for investment purposes, not just efficient portfolio management. The ETF may use total return swaps and exchange-traded equity futures to achieve its objective, introducing counterparty and collateral risk. The structure and risks (including concentration, operational, currency, liquidity, and emerging markets risks) are disclosed, but the use of derivatives central to the strategy may make the product difficult for a retail investor with basic knowledge to understand.",
    "supporting_data": "The ETF is UCITS-compliant and primarily uses physical replication to track its index, holding equity securities and depositary receipts. However, it explicitly states that it may use financial derivative instruments (FDIs)u2014specifically, total return 'unfunded' OTC swaps and exchange-traded equity futuresu2014for investment purposes, not solely for efficient portfolio management. This introduces risks such as counterparty risk and collateral risk, which are not typical of plain-vanilla, physically replicated UCITS ETFs. The ETF is highly concentrated in a niche sector, which increases risk but does not, by itself, make the product complex under MiFID II. The key complexity driver is the active use of derivatives as part of the investment strategy, which goes beyond the limited, risk-mitigating use typically allowed for non-complex UCITS. The risks are transparently disclosed in the KIID, but the structure may still be difficult for a retail investor with basic knowledge to understand, especially given the central role of derivatives.",
    "classification": "complex"
}