{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF tracks a transparent, rules-based index of USD-denominated emerging market sovereign bonds using physical replication (optimized sampling). The fund may use derivatives for efficient portfolio management (EPM) and currency hedging, but not as a core part of its investment strategy. There is no evidence of embedded derivatives, swaps, leverage, or inverse strategies. The structure, risks, and payoff are straightforward and consistent with typical UCITS bond ETFs. The fund is UCITS-compliant, and UCITS ETFs are generally presumed non-complex under MiFID II unless they employ complex strategies or structured features, which is not the case here[1]. The use of derivatives for EPM and hedging, if limited and well-disclosed, does not automatically trigger a complex classification for UCITS ETFs under current regulatory practice, provided the risks remain transparent and the fundu2019s profile is not materially altered[1]. The index is transparent, and the fundu2019s documentation is comprehensive and accessible. No features were identified that would make the product difficult for a retail investor with basic knowledge to understand."
}