{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives for currency hedging, but not central to strategy; no embedded swaps, leverage, or complex indices; no securities lending; no contingent convertible bonds; no complex underlying assets",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is passively managed, tracking a transparent, ESG-screened bond index. It uses physical replication (stratified sampling) and invests at least 90% in index constituents. Derivatives are used only for currency hedging (selling CHF forwards to hedge USD exposure), not as a central part of the investment strategy. There is no securities lending, no leverage beyond UCITS limits, and no embedded swaps or complex structured products. The index is straightforward, and the fund does not hold contingent convertible bonds or other complex debt instruments. The risk profile (category 5) reflects market and credit risk of investment-grade bonds, not structural complexity. All features are consistent with UCITS regulation and MiFID II criteria for non-complex instruments, as the use of derivatives is limited to efficient portfolio management (EPM) and does not introduce material counterparty or collateral risk that would be difficult for a retail investor to understand[1]. The structure, risks, and objectives are transparent and easily comprehensible to an average retail investor with basic knowledge."
}