{
    "type": "ETF",
    "ucits": true,
    "fund_name": "iShares Spain Govt Bond UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The ETF aims to track the Bloomberg Spain Treasury Bond Index by investing primarily in Spanish government bonds with a credit rating equivalent to Spain's sovereign rating. The fund uses physical replication with a sampled methodology, directly holding fixed income securities rather than synthetic replication or swap-based structures. The KIID and PRIIPs KID documents mention the possible use of financial derivative instruments (FDIs) only for direct investment purposes or risk management, not as an inherent part of the investment strategy, and no swap agreements or counterparty risk related to derivatives are highlighted as material. The monthly factsheet confirms a physical product structure with no indication of synthetic replication or leverage. The risk profile is moderate low (risk level 3-4), consistent with direct bond exposure, and no leverage or inverse exposure is present. Costs are straightforward with a TER of 0.20%, no performance fees, and no complex fee structures. There are no capital protection or structured product features. The fund engages in securities lending, but this does not increase complexity under MiFID II. No complex underlying assets such as contingent convertible bonds or CLOs are held; the portfolio consists almost entirely of Spanish government bonds. There is no mention of contango, backwardation, or roll costs that would imply complexity. Overall, the fund exhibits characteristics of a non-complex ETF under MiFID II criteria."
}