{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for currency hedging, Emerging market bond risk, Securities lending",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicated, tracking a transparent, well-documented index of USD-denominated emerging market government and government-related bonds. It uses derivatives solely for currency hedging at the share class level and for efficient portfolio management, not as a core part of its investment strategy. Securities lending is conducted within UCITS limits and is a secondary, well-disclosed feature. The ETF does not use leverage beyond UCITS limits, does not embed complex derivatives (e.g., swaps, options, or structured notes), and does not have features that would make its risk profile difficult for a retail investor with basic knowledge to understand. The risksu2014emerging market volatility, credit risk, interest rate risk, and currency risku2014are standard for the asset class and are clearly disclosed. The structure, objectives, and risks are transparent and in line with UCITS regulatory requirements, supporting a non-complex classification under MiFID II Article 25(4) and Delegated Regulation Article 57[1]. While ESMA has noted that some complex UCITS (e.g., synthetic ETFs, structured UCITS) should be considered complex, this ETF does not exhibit those featuresu2014its derivative use is limited and ancillary, not integral to achieving its objective[2]. Therefore, despite the use of derivatives for hedging and the inherent risks of emerging market bonds, the ETF remains non-complex under MiFID II rules for UCITS ETFs with these characteristics."
}