{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "High yield fallen angels, ESG screening, limited derivative use, liquidity risk, credit risk, counterparty risk",
    "classification": "non-complex",
    "supporting_data": "The Tabula Global High Yield Fallen Angels Paris-aligned Climate UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent, rules-based index of high yield corporate bonds downgraded from investment grade. It uses an optimisation strategy and may not hold every index constituent, but does not rely on synthetic replication or swaps. The use of financial derivative instruments (FDIs) is expected to be limited and for direct investment purposes, not as a core replication mechanism. The ETF is subject to UCITS diversification, liquidity, and risk-spreading rules, and its structure and risks (market, credit, liquidity, counterparty) are disclosed in a manner consistent with UCITS requirements. The ETF does not use significant leverage, embedded derivatives, or complex payout structures. While the underlying bonds are high yield (and thus carry higher credit and liquidity risk), the ETF itself does not embed complex features that would make it difficult for a retail investor with basic knowledge to understand its structure or risks. The presence of a comprehension alert in the KID suggests the manufacturer has considered complexity, but under MiFID II and ESMA guidance, UCITS ETFs are generally presumed non-complex unless they are 'structured UCITS' (which use algorithm-based payoffs or similar complex features) or fail the Article 57 criteria. This ETF does not appear to meet those exceptions. Therefore, despite higher underlying risk and limited derivative use, it is classified as non-complex under MiFID II[1][2]."
}