{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Active management, use of financial derivative instruments, exposure to emerging market local currency debt, including contingent convertible bonds",
    "classification": "complex",
    "supporting_data": "This UCITS ETF is actively managed and explicitly uses financial derivative instruments (FDIs) to gain exposure to underlying assets, including for efficient portfolio management and investment purposes. While UCITS ETFs are generally presumed non-complex, the active use of derivativesu2014central to the investment strategyu2014introduces complexity, particularly counterparty risk and potential for losses beyond standard market risk. The fund may invest in contingent convertible debt securities, which are explicitly complex under MiFID II due to their embedded derivative features and potential for conversion or write-down under stress. The fundu2019s objective to outperform a benchmark through active selection and currency management further adds to the complexity, as the risks and payoff are not as straightforward as a passive, physically replicated ETF tracking a transparent index. The combination of active management, derivative use, and exposure to complex debt instruments in emerging markets means this ETF does not meet all criteria for non-complex classification under Article 57 of the MiFID II Delegated Regulation, particularly points (a) and (d), due to the presence of instruments embedding derivatives and the potential for the risk profile to be altered by active decisions. Therefore, despite being UCITS-compliant, this ETF is complex under MiFID II."
}