{
    "ucits": true,
    "type": "ETF",
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "leverage": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for hedging and portfolio optimization; exposure to bonds including investment grade corporate bonds; no synthetic replication or embedded derivatives",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF investing predominantly in bonds that are constituents of the Bloomberg MSCI US Liquid Corporates Sustainable Index, using a stratified sampling strategy with portfolio optimisation. It invests at least 90% in index constituents, mainly investment grade bonds, and may use derivatives only for hedging currency risk and efficient portfolio management (e.g., currency forwards for GBP hedging). The ETF does not engage in securities lending, does not use leverage beyond UCITS limits, and does not employ synthetic replication or embedded derivatives. The replication is physical via direct investment in bonds. The risk profile is moderate (risk category 5) due to market volatility and credit risk inherent in bonds, but this does not imply structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, UCITS ETFs are presumed non-complex unless they embed derivatives integral to the strategy or have complex features such as synthetic replication or structured products. The derivatives used here are limited to hedging and do not alter the risk-return profile significantly. The index tracked is transparent and well-documented. Therefore, the ETF meets the criteria for non-complex classification under MiFID II and does not require an appropriateness assessment for non-advised retail clients."
}