{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for currency hedging, actively managed, no benchmark, invests in high yield and emerging market bonds, liquidity risk, credit risk, interest rate risk, emerging market risk, currency risk",
    "classification": "non-complex",
    "supporting_data": "The Eurizon SLJ EM Bond Strategic Income UCITS ETF is a UCITS-compliant, physically replicated, actively managed ETF with no benchmark, investing primarily in a diversified portfolio of emerging market bonds, including high yield and investment grade debt. It uses derivatives solely for currency hedging to manage exchange rate risk between the fund's base currency and the share class currency, which is a standard efficient portfolio management (EPM) practice under UCITS rules and does not, by itself, make the ETF complex. The ETF does not use leverage beyond temporary UCITS borrowing limits, does not employ swaps or synthetic replication, and is not inverse. The main risks disclosed are high yield risk, liquidity risk (due to less liquid emerging market bonds), credit risk, interest rate risk, emerging market risk, and currency risku2014all of which are typical for this asset class and do not introduce structural complexity beyond what a retail investor with basic knowledge could understand. The ETF's structure, objectives, and risks are transparently disclosed in the KIID. There is no evidence of embedded derivatives, contingent convertible bonds, complex indices, or other features that would make the payoff or risk profile difficult to understand. Under MiFID II, UCITS ETFs are presumed non-complex unless they employ complex portfolio management techniques or structured features that are not present here[1][2]. The use of derivatives for currency hedging is limited to EPM and does not introduce material counterparty or collateral risk that would override the UCITS presumption of non-complexity. Therefore, despite the higher risk profile (reflected in the KIID risk indicator), the ETF remains non-complex under MiFID II."
}