{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None identified",
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant fund, which is automatically classified as non-complex under MiFID II Article 25(4)(a)(iv), unless it is a structured UCITS or uses derivatives in a way that introduces complexity beyond efficient portfolio management[1]. The fund's documentation states that derivatives may be used only for efficient portfolio management (EPM) purposes, such as managing inflows/outflows, hedging currency risk, or reducing transaction costs, and not as a core part of the investment strategy. There is no evidence of synthetic replication, embedded derivatives, or other complex features such as leverage, swaps, or inverse strategies. The fund tracks a transparent, rules-based index of emerging market sovereign debt, and its structure, risks, and objectives are clearly disclosed and understandable for retail investors. The absence of complex instruments (e.g., CLOs, structured products, or significant derivative exposure beyond EPM) and the use of physical replication support the non-complex classification. The fund does not appear to be a structured UCITS as defined in Regulation (EU) No 583/2010, nor does it fail any of the Article 57 criteria for non-complex instruments[1][2]. Therefore, it qualifies as non-complex under MiFID II."
}