{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is compliant with UCITS regulations, which are automatically classified as non-complex under MiFID II Article 25(4)(a)(iv)[1]. The fund primarily invests in below-investment grade corporate debt securities, with no evidence of synthetic replication, significant derivative use, leverage, or embedded swaps. Derivatives, if used, are limited to efficient portfolio management (EPM) and do not form a core part of the investment strategy. The fund does not invest in contingent convertible bonds, structured products, or other instruments that would introduce complexity. The index tracked (ICE BofA US High Yield Constrained Index) is transparent and well-documented. The structure, risks, and investment objective are straightforward and can be understood by retail investors with basic knowledge. There is no indication of complex features such as significant leverage, synthetic replication, or embedded derivatives that would override the UCITS presumption of non-complexity[1][2]. Therefore, the ETF meets all criteria for non-complex classification under MiFID II."
}