{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for direct investment, Emerging market local currency government bonds, Securities lending",
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant, physically replicated fund tracking a transparent, capped index of emerging market local currency government bonds. While it may use financial derivative instruments (FDIs) for direct investment purposes and engages in securities lending, these features are disclosed and managed within UCITS regulatory limits. The fund's structure, risks, and objectives are clearly explained in the KIID, and there is no evidence of synthetic replication, significant leverage, embedded derivatives, or other features that would make the product difficult for a retail investor with basic knowledge to understand. The use of derivatives is not central to the investment objective but is permitted for efficient portfolio management and direct investment, which does not automatically trigger a complex classification under MiFID II for UCITS ETFs, provided risks are well-disclosed and managed[1]. The ETF does not hold contingent convertible bonds, complex indices, or other inherently complex instruments. Therefore, despite some derivative use and securities lendingu2014common in UCITS ETFsu2014the product remains non-complex under MiFID II rules[1]."
}