{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Fidelity ESG USD EM Bond UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Fidelity ESG USD EM Bond UCITS ETF is a UCITS-compliant bond ETF investing primarily in USD-denominated emerging market sovereign and quasi-sovereign debt securities. The fund uses physical replication by directly holding a diversified portfolio of bonds representative of the JP Morgan ESG EMBI Global Diversified Index. The KIID and PRIIPs KID explicitly state that derivatives may be used only for efficient portfolio management and currency hedging, not as an inherent part of the investment strategy, which means derivative use is ancillary and not complexity-driving. There is no mention of synthetic replication, swap agreements, or counterparty risk exposure. The fund does not employ leverage, inverse or amplified exposure, nor does it have capital protection or structured product features. The risk profile is moderate (risk class 3-5 in KIID, 3 in PRIIPs KID), consistent with a straightforward bond ETF. The monthly factsheet confirms no use of swaps or synthetic replication, and the portfolio consists of liquid emerging market sovereign bonds with no complex structured products or contingent convertible bonds. Costs are standard with no performance fees or swap fees. There is no complexity warning or comprehension warning in the PRIIPs KID. Overall, the fund exhibits a clear, linear relationship to underlying bond performance with minimal derivative use for risk management only, physical replication, and no leverage or complex underlying assets, leading to a non-complex classification under MiFID II."
}