{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives used for currency hedging, not for core strategy; no leverage, no swaps, no inverse features; physical replication; no complex underlying bonds (e.g., CLOs, CoCos, or structured notes); transparent index; no embedded options or contingent features.",
    "supporting_data": "This UCITS ETF is passively managed and aims to track a transparent, investment-grade green bond index using physical replication. Derivatives are used only for currency hedging at the share class level, not as a core part of the investment strategy. There is no significant leverage, no use of swaps for index replication, no inverse or leveraged features, and no exposure to complex underlying bonds such as CLOs, CoCos, or structured notes. The index is well-documented and the ETFu2019s structure, risks, and objectives are clearly disclosed. The use of derivatives is limited to efficient portfolio management (EPM) for hedging currency risk, which is a common and accepted practice under UCITS rules and does not, in itself, make the ETF complex under MiFID II, provided the risks are transparent and the derivative use is ancillary. The ETF does not embed options or other contingent features that would alter the risk-return profile in a way that is difficult for a retail investor to understand. All these factors support a non-complex classification under MiFID II, as the productu2019s structure and risks remain straightforward and comprehensible for retail investors with basic knowledge.",
    "classification": "non-complex"
}