{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF, which under MiFID II is automatically presumed non-complex due to the strict regulatory framework governing UCITS funds[1]. The ETF aims to replicate the J.P. Morgan GBI - EM Global Diversified 10% Cap 1% Floor index by investing primarily in fixed income securities that compose the index, using physical replication techniques with optimization. The use of derivatives is limited and only for efficient portfolio management purposes, not integral to the investment objective, and no embedded derivatives or structured products are indicated[search data]. Securities lending is employed but managed within UCITS rules and does not dominate the risk profile[search data]. There is no indication of significant leverage beyond UCITS limits. The ETF invests in emerging market local government bonds, which may carry credit and liquidity risks, but these are market risks, not structural complexity. The index tracked is transparent and well-documented. The ETF's structure and risks are straightforward and understandable by retail investors with basic knowledge. Therefore, the ETF meets the criteria for non-complex classification under MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, as it does not embed derivatives integral to the strategy, uses physical replication, and has transparent, comprehensible risks[1][2]."
}