{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Invests in below investment grade emerging market bonds, including high yield and non-rated debt; no embedded derivatives or structured products; no synthetic replication; no significant leverage; risks mainly market, credit, liquidity, currency hedging",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF investing primarily in a broad range of emerging market bonds, including below investment grade and non-rated debt securities. It is actively managed with no benchmark and invests in physical debt securities such as fixed income bonds, floating rate bonds, and commercial paper. The ETF does not embed derivatives as an inherent part of its strategy but may use derivatives for currency hedging, which is considered efficient portfolio management (EPM) with minimal impact on risk-return profile. There is no indication of synthetic replication or use of total return swaps. The fund does not employ significant leverage beyond UCITS limits. The risks disclosed relate to market risk, credit risk, liquidity risk, currency risk, and emerging market risk, all of which are typical for bond funds and understandable by retail investors with basic knowledge. The fund is not capital protected and does not have complex payoff structures. The underlying index or portfolio is transparent, consisting of bonds from emerging markets with varying maturities and credit qualities. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, UCITS ETFs that invest physically in bonds without embedded derivatives or complex structures are presumed non-complex. The use of derivatives solely for currency hedging does not trigger complexity. Therefore, this UCITS ETF is classified as non-complex under MiFID II rules."
}