{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The SPDR Bloomberg Emerging Markets Local Bond UCITS ETF is a UCITS-compliant ETF that primarily invests in liquid local currency bonds issued by emerging market governments. It uses a stratified sampling strategy to replicate the Bloomberg Emerging Markets Local Currency Liquid Government Bond Index. The fund may use financial derivative instruments only for efficient portfolio management (EPM) purposes, such as managing portfolio inflows/outflows or hedging currency risk, with limited exposure and minimal impact on the risk-return profile. There is no indication that derivatives are integral to the investment objective or that synthetic replication is used. The ETF employs physical replication (holding a representative portfolio of underlying securities), which is transparent and straightforward. The fund does not use significant leverage beyond UCITS limits, nor does it embed complex derivatives or structured products. Securities lending is limited to a maximum of 70% of NAV and managed within UCITS rules. The underlying index is transparent and well-documented. The risk profile reflects market volatility typical of emerging market bonds but does not imply structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs that do not embed derivatives as a core strategy and use physical replication are presumed non-complex. ESMA and CESR guidance confirm that such ETFs do not require an appropriateness assessment for non-advised sales. Therefore, this ETF is classified as non-complex under MiFID II. This classification aligns with Janus Henderson Investors' statement that all UCITS funds are automatically non-complex, and with ESMA's view that synthetic or structured UCITS are complex, but physical replication UCITS ETFs are not. No evidence suggests the presence of complex features such as embedded derivatives, leverage, or opaque structures that would override the UCITS presumption. Hence, the ETF is non-complex."
}