{
    "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, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency. The fund aims to replicate the ICE BofAML Euro High Yield Constrained Index by investing primarily in fixed income securities (bonds) that make up the index, using physical replication techniques and optimization methods. Although the fund may use financial derivative instruments (FDIs), these are employed for direct investment purposes and currency hedging, not as an inherent element of the investment strategy, and their use is limited and for efficient portfolio management. The derivatives used (e.g., FX forwards for hedging) do not introduce significant counterparty or structural risks that would make the product complex. Securities lending is employed but managed within UCITS rules with collateral requirements, and does not dominate the risk profile. There is no significant leverage beyond UCITS limits. The underlying index is transparent and straightforward, composed of Euro denominated, fixed rate sub-investment grade corporate bonds with clear eligibility criteria and monthly rebalancing. The risk profile reflects market and credit risk typical of high yield bonds but does not imply structural complexity. The fundu2019s structure, replication method, and risk factors are understandable by retail investors with basic knowledge. According to MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, this ETF meets the criteria for non-complex classification: it is a UCITS fund, uses physical replication, derivatives are limited to EPM and currency hedging with minimal impact on risk-return, no embedded derivatives or leverage beyond UCITS limits, and the productu2019s structure and risks are transparent and comprehensible. Therefore, the classification is non-complex."
}