{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers USD Corporate Bond SRI PAB UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent, liquid, investment-grade corporate bond index. It uses derivatives only for efficient portfolio management (EPM), specifically to hedge currency risk between the fund's assets (USD) and share class currency (EUR), not as a core part of its investment strategy. There is no significant leverage, no embedded derivatives, no swaps, and no inverse or complex features. The structure, risks, and payoff are straightforward and easily understood by retail investors with basic knowledge. The ETF does not hold complex bonds (e.g., contingent convertibles, asset-backed securities, or structured notes) and does not track a complex or opaque index. All these elements support a non-complex classification under MiFID II Article 25(4) and Delegated Regulation Article 57, as confirmed by industry practice and regulatory presumption for standard UCITS ETFs[1]. The use of derivatives for hedging is incidental and does not introduce material counterparty or collateral risk that would make the product complex for retail investors. The ETFu2019s risk profile is driven by market and credit risk of investment-grade corporate bonds, not by structural complexity."
}