{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF investing in a portfolio of high yield corporate bonds, aiming to replicate the Markit iBoxx EUR Liquid High Yield Index through physical holdings of bonds. The fund may use derivatives only for risk management and efficient portfolio management purposes, not as an inherent part of the investment strategy. Securities lending is employed as a secondary feature to generate additional income but is well-managed under UCITS rules with collateral requirements. There is no significant leverage beyond UCITS limits, no embedded derivatives, and the replication method is physical, holding underlying securities. The index tracked is transparent and well-documented. The risks disclosed relate to market volatility, credit risk, interest rate risk, and sector concentration, which are standard for bond ETFs and do not imply structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs that physically replicate transparent indices and use derivatives only for efficient portfolio management with minimal impact on risk-return profile are classified as non-complex. The absence of embedded derivatives, leverage, or complex structured products such as CLOs supports this classification. Therefore, this UCITS ETF is non-complex under MiFID II and does not require an appropriateness assessment for non-advised sales."
}