{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for efficient portfolio management; investment in below investment grade corporate bonds; active management strategy",
    "classification": "complex",
    "supporting_data": "The asset is a UCITS ETF, which generally presumes non-complexity under MiFID II. However, this ETF invests primarily in EUR-denominated below investment grade corporate debt securities, which are higher risk and potentially less liquid. The ETF pursues an actively managed strategy rather than passive index tracking, and may use derivatives for efficient portfolio management purposes. Although derivatives are used only for EPM and not as an inherent part of the investment objective, the presence of derivatives combined with the complexity of the underlying assets (high yield bonds, including emerging markets exposure) increases the complexity. The ETF does not use synthetic replication but physical replication of bonds. The investment in below investment grade bonds and the active management strategy introduce risks and features that are difficult for a retail investor with basic knowledge to fully understand, such as credit risk, liquidity risk, and the impact of active selection. According to MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, such features typically lead to a classification as complex. Therefore, despite being a UCITS ETF, the combination of active management, use of derivatives, and exposure to complex fixed income instruments results in a complex classification under MiFID II."
}