{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers II US Treasuries 1-3 UCITS ETF is a UCITS-compliant ETF that physically replicates the iBoxx $ Treasuries 1-3 Index by directly purchasing US Treasury bonds with maturities between 1 and 3 years. The factsheet explicitly states the portfolio methodology is 'Direct Replication (physically)', and there is no mention of synthetic replication, swap agreements, or derivative instruments used as part of the investment strategy. The KIID and PRIIPs KID documents confirm that derivatives may be used only for risk management purposes, not as an inherent part of the investment strategy, which under MiFID II means derivatives exposure is considered minimal and not complexity-driving. There is no leverage, inverse exposure, or capital protection features. The risk profile is low (category 2 out of 7), consistent with a straightforward bond index tracking fund. The fund invests in liquid, transparent US Treasury bonds, with no complex underlying assets such as contingent convertible bonds or CLOs. Costs are simple, with a low ongoing charge of 0.06% and no performance fees or swap fees. No significant counterparty risk or collateral management risks are disclosed. The index tracked is a standard government bond index without complex structured features. There are no references to roll costs, contango, or backwardation effects. Therefore, the fund does not meet any of the MiFID II complexity criteria related to synthetic replication, leverage, complex underlying assets, or structured features. The fund is classified as non-complex."
}