{
    "type": "ETP",
    "ucits": false,
    "leverage": true,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": "Leverage, Derivative exposure via Copper Futures, Synthetic replication, Complex underlying commodity futures with roll costs and contango effects",
    "classification": "complex",
    "supporting_data": "The product is an Exchange Traded Commodity (ETC) issued by Leverage Shares plc, designed to track Copper Futures via a synthetic replication strategy involving derivatives (Copper Futures contracts). It uses collateralized assets and margin accounts to replicate the performance of copper prices. The product is leveraged, non-principal protected, and exposes investors to market risk and counterparty risk inherent in derivatives and collateral management. The KID explicitly states that the product is 'not simple and may be difficult to understand' and includes a comprehension alert, indicating complexity. The use of futures contracts with rolling (roll costs, contango/backwardation effects) adds complexity to the payoff and risk profile. The product is not a UCITS fund but an ETC, which is not automatically non-complex under MiFID II. According to MiFID II and ESMA guidelines, ETCs that are contracts for difference or synthetic replication products are complex due to derivative use and leverage. The product's structure, leverage, derivative use, and commodity exposure make it complex under MiFID II appropriateness rules."
}