{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Investment in AAA-rated European CLOs, exposure to complex structured credit products, liquidity and credit risks inherent in CLOs",
    "classification": "complex",
    "supporting_data": "The Janus Henderson Tabula EUR AAA CLO UCITS ETF invests primarily in AAA-rated European Collateralised Loan Obligations (CLOs), which are complex structured credit products. The fund does not use synthetic replication or swaps; it physically holds CLO securities. Derivatives are only used for hedging interest rate and currency risk, not as part of the investment strategy, so derivative exposure is minimal and for risk management only. There is no leverage or inverse exposure. However, CLOs themselves are complex instruments with embedded credit, liquidity, and structural risks, including dependence on CLO managers, prepayment and extension risks, and potential mark-to-market losses even on AAA tranches. The KIID explicitly states the product is 'not simple and may be difficult to understand,' and highlights liquidity risk, CLO credit risk, and structural risks. The risk rating is moderate (3 out of 7), reflecting these factors. No capital protection or structured payoff features are present. Fees are straightforward with no performance fees or swap fees. Given the underlying asset complexity (CLOs) and the product's nature, MiFID II classifies this ETF as complex despite physical replication and no leverage or synthetic exposure."
}