{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "derivatives": false,
    "swaps": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Fidelity ESG USD EM Bond UCITS ETF primarily invests in USD-denominated emerging market sovereign and quasi-sovereign bonds, using physical holdings of debt securities. 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, indicating minimal derivative exposure. There is no mention of synthetic replication, swap agreements, or counterparty risk related to derivatives. The fund is UCITS compliant, with no leverage or inverse exposure. The risk profile is moderate (risk class 3-5 in KIID, 3 in PRIIPs KID), consistent with bond market volatility but not indicative of complexity. The monthly factsheet confirms physical bond holdings, no use of swaps or complex structured products, and a straightforward benchmark (J.P. Morgan ESG EMBI Global Diversified Index). Costs are standard with no performance fees or swap fees. There are no capital protection or structured features. No complexity flags such as contingent convertible bonds or leverage are present. The fund\u2019s ESG overlay and active management do not add complexity under MiFID II. Therefore, the ETF is classified as non-complex."
}