{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for currency hedging, high-yield bond exposure, securities lending",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicated, tracking a transparent, liquid high-yield bond index. It uses derivatives (FX forwards) solely for currency hedging, not as a core investment strategy. Securities lending is conducted within UCITS limits and is not a dominant risk factor. The ETF does not use leverage, swaps, or inverse strategies. While high-yield bonds and currency hedging introduce credit, market, and counterparty risks, these are standard for the asset class and do not make the structure opaque or difficult for a retail investor with basic knowledge to understand. The ETF complies with UCITS regulations, which are designed for retail investor protection, and there is no evidence of complex embedded derivatives, contingent convertible bonds, or other features that would trigger a complex classification under MiFID II Article 57[1][2]. Therefore, despite some derivative use and a higher risk profile, the ETF remains non-complex under MiFID II rules for UCITS."
}