{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Tabula GCC Sovereign USD Bonds UCITS ETF aims to track the ICE Gulf Cooperation Council Government Bond ex-144a Index by investing primarily in a portfolio of USD-denominated sovereign fixed rate bonds and Sukuks issued by GCC countries. The ETF uses a sampling strategy but invests directly in physical bonds, with no mention of synthetic replication, swap agreements, or derivative instruments as part of its core strategy. The risk profile is moderate (risk level 3-4), with no leverage or inverse exposure. The fund does not include capital protection or structured features. Counterparty risk is disclosed but relates to standard operational risks such as safekeeping and custody, not derivative counterparty risk. Costs are straightforward with a single ongoing charge of 0.45%, no performance fees, and no swap or derivative fees. The PRIIPs KID confirms the product is not simple but does not indicate derivative usage beyond risk management. The monthly factsheet confirms physical bond holdings, no use of swaps or leverage, and a straightforward index methodology with country caps and liquidity filters. There are no complex underlying assets such as contingent convertible bonds or CLOs. Overall, the ETF exhibits a clear, linear relationship to the underlying sovereign bond index, with minimal complexity factors. Therefore, under MiFID II, this ETF is classified as non-complex."
}