{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers II USD Emerging Markets Bond UCITS ETF is a UCITS-compliant ETF that physically replicates the FTSE Emerging Markets USD Government and Government-Related Bond Select Index by directly purchasing a portfolio of underlying bonds. The factsheet explicitly states 'Direct Replication (physically)' and there is no mention of synthetic replication, swap agreements, or total return swaps in any of the KIID, PRIIPs KID, or factsheet documents. The fund may use derivatives only for risk management purposes, which does not trigger complexity under MiFID II. There is no leverage, inverse exposure, or capital protection mechanism. The risk profile is moderate (risk level 3 out of 7 in PRIIPs KID, and 5 out of 7 in KIID, reflecting the underlying emerging market bond risk rather than structural complexity). The fund invests in emerging market government and government-related USD-denominated bonds, including investment grade and high yield bonds, but no contingent convertible bonds or complex structured products are held. The cost structure is straightforward with a TER of approximately 0.25%, no performance fees, and minimal securities lending revenue. No complex fee structures or derivative costs are indicated. The PRIIPs KID does not carry any comprehension warnings or complexity flags. Overall, the fund exhibits a clear, linear relationship to the underlying index performance with minimal derivative use for risk management, no leverage, and physical replication, leading to a non-complex classification under MiFID II."
}