{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for portfolio optimization; exposure to bonds including investment grade and structured notes; no synthetic replication or embedded derivatives",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which under MiFID II is generally presumed non-complex due to strict regulatory requirements and investor protections[1]. The ETF uses a stratified sampling strategy with portfolio optimization to replicate the SBIu00ae ESG Foreign AAA-BBB 5-10 Index, investing predominantly in bonds and transferable securities, money market instruments, and structured notes. The use of derivatives is limited to efficient portfolio management purposes, not integral to the investment objective, and no synthetic replication or embedded derivatives are indicated[extracted KID]. The fund explicitly states it will not engage in securities lending, and there is no mention of leverage beyond UCITS limits. The replication method is physical (direct investment or combination with derivatives for optimization), which supports non-complex classification[extracted KID]. The risk profile is moderate (risk category 4/7), reflecting market volatility but not structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, UCITS ETFs that do not embed derivatives as a core strategy and do not have complex features such as synthetic replication or structured products with embedded derivatives are non-complex[1][2]. ESMA guidance confirms that synthetic ETFs or structured UCITS with complex portfolio management techniques should be considered complex, but this fund does not fall into those categories[2]. Therefore, despite some derivative use for portfolio optimization, the ETF meets the criteria for non-complex instruments under MiFID II and does not require an appropriateness assessment for non-advised retail investors."
}