{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Active management with bonds including corporate, securitizations, convertible bonds; no synthetic replication; derivatives used not central to strategy",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which under MiFID II is generally presumed non-complex. It employs an active management approach investing primarily in sovereign and supra-sovereign bonds, with some exposure to corporate bonds, securitizations, and convertible bonds. The fund does not replicate or track its benchmark and does not use synthetic replication or total return swaps, which are typical complexity drivers. Derivatives risk is mentioned but appears limited and related to portfolio management rather than being integral to the investment objective. There is no indication of leverage beyond UCITS limits or embedded derivatives that would trigger complexity. The fund's structure and risks (credit risk, interest rate risk, liquidity risk) are typical for bond funds and understandable by retail investors with basic knowledge. The fund's ongoing charges are low (0.30%), and it is regulated by the Central Bank of Ireland. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, UCITS ETFs that do not embed derivatives as a core strategy and do not have complex features are non-complex. Although the fund invests in some complex bonds (e.g., convertible bonds), this does not automatically make the ETF complex if the overall structure remains transparent and understandable. Therefore, the fund is classified as non-complex under MiFID II criteria."
}