{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "Investment in complex underlying assets (AAA-rated CLOs)",
    "classification": "complex",
    "supporting_data": "The Janus Henderson Tabula EUR AAA CLO UCITS ETF invests primarily in AAA-rated Collateralised Loan Obligations (CLOs), which are complex structured credit products. The fund is actively managed and aims to outperform the J.P. Morgan European CLO AAA index subset. The KIID and PRIIPs documents explicitly state that the product 'is not simple and may be difficult to understand' and is 'not intended for basic investors' under MiFID II. The fund invests at least 80% in CLO securities, which are structured products with inherent credit, liquidity, and prepayment risks, and depend on CLO managers' performance. The fund does not use synthetic replication or swaps; derivatives are only used for hedging interest rate and currency risk, not as an inherent part of the investment strategy, so 'derivatives' is false. There is no leverage or inverse exposure. The replication is physical, investing directly in CLO securities. The risk profile is moderate (risk category 2-3), but the complexity arises from the nature of the underlying assets (CLOs), which are complex and may be difficult for retail investors to understand. The fund has no capital protection and carries liquidity and credit risks typical of CLOs. The ongoing charges are straightforward (0.35% TER) with no performance fees or swap fees. The complexity classification is driven primarily by the underlying asset complexity (CLOs), not by leverage, synthetic replication, or derivative usage. The PRIIPs KID also includes a comprehension warning and states the product is 'not simple and may be difficult to understand,' reinforcing the complex classification under MiFID II."
}