{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The JPM Global Government Bond Active UCITS ETF is a UCITS-compliant ETF, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency. The ETF pursues an actively managed strategy investing primarily in global government and government-related debt securities, mainly investment grade, with some exposure to emerging markets and ESG integration. It may use derivatives only for efficient portfolio management purposes, not as an inherent part of its investment objective or replication method. There is no indication of synthetic replication, embedded derivatives, leverage beyond UCITS limits, or complex structured products such as CLOs. The replication method is physical, holding underlying securities rather than relying on swaps or synthetic instruments. The ETFu2019s structure and risks (market volatility, credit risk of sovereign bonds) are straightforward and understandable by retail investors with basic knowledge. Securities lending is not mentioned as a significant feature, and leverage is not used beyond UCITS limits. The underlying benchmark is a transparent fixed-rate government bond index. Therefore, the ETF meets the criteria of Article 57 of the Commission Delegated Regulation and MiFID II for non-complex instruments, exempting it from appropriateness assessments for non-advised sales. This classification aligns with ESMA guidance and industry practice that UCITS ETFs with physical replication and limited derivative use for EPM are non-complex. No complex factors such as embedded derivatives, leverage, synthetic replication, or complex indices are present."
}