{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Vanguard USD Treasury Bond UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Vanguard USD Treasury Bond UCITS ETF employs a passive, physical replication strategy by acquiring a representative sample of US Treasury bonds to track the Bloomberg Global Aggregate US Treasury Float Adjusted Index. There is no indication of synthetic replication or use of swap agreements. The fund may use derivatives only for risk or cost reduction or to generate extra income, but this is ancillary and not inherent to the investment strategy, so derivatives are marked false. There is no leverage, inverse or amplified exposure. The underlying assets are investment grade US Treasury bonds, which are liquid and transparent. The risk profile is moderate-low (risk level 3-4), consistent with a straightforward bond ETF. Costs are simple with a low ongoing charge (0.07%) and no performance fees or complex fee structures. The PRIIPs KID explicitly states the fund is 'not simple and may be difficult to understand' but this is a standard caution for bond ETFs with currency and interest rate risks, not due to structural complexity. The monthly factsheet confirms physical holdings, no funded or unfunded swaps, and no complex structured products. No capital protection or contingent features are present. Overall, the fund meets criteria for non-complex classification under MiFID II."
}