{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Emerging market bonds, high yield risk, liquidity risk, currency hedging risk, credit risk, interest rate risk, no benchmark, active management",
    "classification": "non-complex",
    "supporting_data": "The Eurizon SLJ EM Bond Strategic Income UCITS ETF is a UCITS-compliant, physically replicated ETF that invests primarily in a diversified portfolio of emerging market bonds, including both investment grade and below investment grade debt. The fund is actively managed with no benchmark, but there is no evidence of significant use of derivatives for investment purposes (only for efficient portfolio management, such as currency hedging). The main risks disclosed are typical of emerging market bond funds: high yield (credit) risk, liquidity risk, currency risk (with hedging), credit risk, and interest rate risk. These risks, while material, are standard for the asset class and do not introduce structural complexity (e.g., no embedded derivatives, no leverage beyond UCITS limits, no synthetic replication, no complex indices). The fundu2019s structure, objectives, and risks are transparently disclosed in the KIID, supporting the view that a retail investor with basic knowledge could understand the product. The absence of a benchmark and active management do not, in themselves, make the ETF complex under MiFID II, as the risks are clearly stated and the fund operates within UCITS rules. Therefore, despite the elevated risk profile (reflected in a risk indicator of 4/7), the ETF is classified as non-complex because it does not embed derivatives, does not use swaps or leverage as a core strategy, and does not have features that make its risks or payoff difficult for a retail investor to understand."
}