{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": true,
    "inverse": false,
    "complex_factors": "Use of credit default swaps and total return swaps",
    "classification": "complex",
    "supporting_data": "The Fund is a UCITS ETF investing primarily in investment grade corporate bonds denominated in USD. It is actively managed and aims for total return. The KIID and PRIIPs KID both confirm that the Fund may use financial derivative instruments including credit default swaps, currency swaps, futures, forwards, and total return swaps. These derivatives are used as part of the investment strategy, not solely for risk management, indicating inherent derivative exposure. The Fund does not use leverage or inverse strategies, and the replication method is not synthetic in the sense of full swap replication of the index, but it does use swaps and other derivatives related to the underlying securities. The monthly factsheet confirms the Fund holds a diversified portfolio of 388 fixed income securities with no mention of synthetic replication or leverage. The risk profile is moderate (risk level 3-4), but the presence of credit default swaps and total return swaps, which are complex instruments with counterparty risk, triggers MiFID II complexity classification. There is no capital protection or structured product features. Costs are straightforward with no performance fees, but securities lending is used. The complexity arises mainly from the use of credit derivatives and total return swaps embedded in the investment strategy, which may be difficult for retail investors to fully understand. Therefore, despite physical holdings, the derivative usage and swap exposure classify the Fund as complex under MiFID II."
}