{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for currency hedging, but not central to strategy; no embedded derivatives, no leverage, no complex indices, no contingent convertible bonds, no swaps, no securities lending, no capital protection features, no opaque index, no significant leverage, no roll costs or contango/backwardation effects",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is passively managed and tracks the Bloomberg US Liquid Corporatesu2122 Index (Total Return) using a stratified sampling strategy, primarily holding the underlying bonds directly (physical replication). Derivatives may be used for efficient portfolio management, specifically for currency hedging to GBP, but this is ancillary and not central to the investment objective. The ETF does not engage in securities lending, does not use leverage beyond UCITS limits, and does not hold embedded derivatives, structured products, or complex indices. The risks disclosed are standard for fixed income ETFs (credit risk, interest rate risk, currency risk, market volatility), and the structure is transparent and straightforward. The ETF complies with UCITS regulations, which are designed for retail investor protection and transparency. Under MiFID II, UCITS ETFs are generally presumed non-complex unless they employ complex strategies or hold complex underlying assets, which is not the case here. The use of derivatives is limited to risk management (currency hedging) and does not introduce material counterparty or collateral risk that would make the product difficult for a retail investor to understand. Therefore, the ETF meets all criteria for non-complex classification under MiFID II Article 25(4) and Article 57 of the Delegated Regulation[1]."
}