{
    "ucits": true,
    "type": "ETF",
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "leverage": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF investing primarily in fixed income securities that replicate the Bloomberg MSCI December 2031 Maturity USD Corporate ESG Screened Index through physical holdings of investment grade corporate bonds maturing in 2031. The ETF uses derivatives only for efficient portfolio management (EPM) purposes, such as optimising portfolio composition and short-term secured lending to offset costs, which is consistent with non-complex derivative use. There is no indication of synthetic replication or embedded derivatives such as swaps integral to the investment objective. The ETF does not employ significant leverage beyond UCITS limits, nor does it have capital protection features or complex payoff structures. The underlying index is transparent, market-cap weighted with ESG screens, and the ETF's structure and risks (market volatility, credit risk, liquidity risk) are straightforward and understandable by retail investors with basic knowledge. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, UCITS ETFs are presumed non-complex unless they embed derivatives or structured products that alter risk profiles or introduce complexity. This ETF does not embed such features and thus is classified as non-complex under MiFID II. This aligns with ESMA guidance and industry practice where physical replication and limited derivative use for EPM do not trigger complexity. Therefore, no appropriateness assessment beyond execution-only is required for retail investors investing in this ETF."
}