{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Emerging Market Bonds, High Yield Risk, Use of Currency Derivatives for Hedging",
    "classification": "complex",
    "supporting_data": "The Fund is a UCITS ETF investing primarily in emerging market bonds, including high yield and below investment grade debt, which inherently carry higher credit, liquidity, and volatility risks. The ETF uses derivatives limited to currency hedging purposes, which introduces counterparty risk, a complexity factor under MiFID II. Although the replication method is physical, the presence of derivatives for currency hedging and the complex risk profile of emerging market debt (including credit risk, liquidity risk, and currency risk) make the product complex. The Fund is actively managed with no benchmark, investing in a diversified portfolio of bonds with varying maturities and credit qualities, including speculative grade securities. The risk and reward indicator is 4/7, reflecting significant market and credit risk but not alone determining complexity. The use of derivatives, even if limited to efficient portfolio management (currency hedging), combined with the complex underlying assets (emerging market bonds with high yield risk), leads to a classification of complex under MiFID II. The ETF does not use leverage beyond UCITS limits, nor does it embed structured products or synthetic replication. However, the complexity arises from the nature of the underlying assets and the derivative use for hedging, which introduces counterparty risk and complexity in understanding the product for a retail investor with basic knowledge."
}