{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Fidelity ESG USD EM Bond UCITS ETF is classified as non-complex under MiFID II based on the following analysis:1. **Replication Method**: The fund uses physical replication, investing directly in debt securities denominated in USD issued by governments and government agencies of emerging market countries. There is no mention of synthetic replication or swap agreements in the KIID or PRIIPs documents.2. **Derivative Usage**: While the KIID mentions that the fund 'may use derivatives for efficient portfolio management and currency hedging purposes,' this is a standard disclosure and does not indicate extensive or complex derivative usage. The PRIIPs KID and factsheet do not provide evidence of swap usage or derivative instruments beyond basic hedging.3. **Leverage and Inverse Exposure**: The fund does not employ leverage or inverse strategies. The investment objective is straightforward: to achieve income and capital growth through a portfolio of emerging market bonds.4. **Underlying Asset Complexity**: The underlying assets are sovereign and quasi-sovereign debt instruments, which are relatively standard and transparent. The fund does not invest in complex structured products, contingent convertible bonds (CoCos), or other illiquid securities.5. **Risk Profile**: The fund is categorized in risk class 5, indicating a medium level of risk, which is typical for bond funds. The risk disclosures are clear and do not suggest complexity beyond what is expected for an emerging market bond fund.6. **UCITS Compliance**: The fund is UCITS-compliant, which inherently limits the use of complex strategies and derivatives to those that are transparent and suitable for retail investors.7. **Additional Factors**: The PRIIPs KID does not contain a comprehension warning, and the factsheet does not indicate any complex structures or strategies. The fund's holdings are representative of the benchmark, and the tracking error is minimal.**Conclusion**: The fund's use of derivatives is limited to efficient portfolio management and hedging, which is standard practice for bond funds. The overall structure is transparent, and the risks are easily understandable by retail investors. Therefore, the fund is classified as non-complex under MiFID II.",
    "confidence": 90
}