{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF investing in a fixed income index composed of Euro-denominated investment grade corporate bonds maturing in December 2028, with ESG screening. The ETF uses physical replication with optimization techniques to track the index and may use derivatives only for direct investment purposes, not as a core strategy. Derivative use is limited and primarily for efficient portfolio management, not synthetic replication or embedded derivatives. Securities lending is employed but managed within UCITS rules and does not dominate the risk profile. There is no significant leverage beyond UCITS limits. The index tracked is transparent and straightforward, and the ETF's structure and risks (market volatility, credit risk, liquidity risk) are understandable by retail investors with basic knowledge. According to MiFID II Article 25(4)(a)(iv), UCITS ETFs are automatically non-complex unless they embed derivatives or structured products that introduce complexity. The ETF does not embed such features. ESMA and CESR guidance confirm that physical replication UCITS ETFs without embedded derivatives or complex structures are non-complex. Therefore, this ETF is classified as non-complex under MiFID II."
}