{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which is automatically non-complex under MiFID II unless it has features that make its structure, risks, or payoff difficult for retail investors to understand[1]. The ETF tracks a transparent, well-documented government bond index using physical replication (optimized sampling), which is straightforward and transparent for retail investors. Derivatives may be used, but only for efficient portfolio management (EPM) purposes such as hedging and risk management, not as a core part of the investment strategy. There is no significant leverage, no embedded derivatives, no swaps, and no inverse or synthetic replication. Securities lending is permitted but is a secondary feature, well-managed within UCITS rules, and does not dominate the risk profile. The index is transparent, and the fundu2019s structure and risks (market volatility, tracking error, interest rate risk) are easily understood by retail investors with basic knowledge. No complex features such as contingent convertible bonds, complex indices, or significant counterparty risk are present. Therefore, the fund meets all criteria for non-complex classification under MiFID II Article 25(4) and Article 57 of the Delegated Regulation[1]."
}