{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivative usage for direct investment purposes",
        "Emerging market exposure with potential liquidity risks"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication to track its benchmark index, with derivatives used only for direct investment purposes rather than for leverage or synthetic replication. The fund's risk profile is driven by its exposure to emerging market government bonds, which inherently carry higher credit and liquidity risks, but these are typical of the asset class and do not introduce structural complexity. The KIID explicitly states that derivatives may be used for direct investment, but there is no indication of leverage, inverse strategies, or synthetic replication. The fund's risk rating of 5 is consistent with the volatility of emerging market bonds rather than structural complexity. The absence of swaps, leverage, or capital protection mechanisms further supports the non-complex classification.",
    "confidence": 90,
    "counter_argument": "Some might argue that the use of derivatives for direct investment purposes could introduce complexity, especially given the emerging market focus. However, the derivatives are not used for leverage or synthetic replication, and the fund's overall structure remains transparent and aligned with its benchmark. The risks are primarily market-driven rather than structural, which aligns with non-complex classification under MiFID II.",
    "risk_level": "The fund's risk level is rated 5 out of 7, reflecting the higher volatility and credit risks associated with emerging market bonds, but this does not indicate structural complexity."
}