{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Contingent Convertible Bonds, Active Management, ESG Screening",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicated, primarily investing in investment grade USD-denominated corporate debt securities, and does not use derivatives as an inherent element of its strategyu2014only for efficient portfolio management (EPM) with minimal impact on risk-return. The ETF may invest up to 5% in contingent convertible bonds (CoCos), which are complex instruments, but this exposure is capped and not central to the strategy. The ETF is actively managed and applies ESG screening, but these features do not introduce structural complexity or opacity that would make the product difficult for a retail investor with basic knowledge to understand. The underlying index (Bloomberg US Corporate Bond Index) is transparent and well-documented. There is no significant leverage, no use of swaps or synthetic replication, and no embedded derivatives beyond the limited CoCo exposure. The ETFu2019s structure, risks, and objectives are clearly disclosed in the KIID. Under MiFID II, UCITS are generally presumed non-complex unless they employ complex portfolio management techniques or hold a material proportion of complex instrumentsu2014neither condition is met here given the limited CoCo exposure and absence of synthetic replication or significant derivative use[1][2]. Therefore, despite the presence of some complex features (CoCos), the ETF as a whole remains non-complex for MiFID II purposes."
}