{
    "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, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency[1]. The ETF uses a stratified sampling strategy (a form of physical replication) to track the Bloomberg Emerging Markets USD Sovereign & Agency 3% Country Capped Index, which is a transparent and well-documented index. The ETF employs currency forwards solely for hedging currency risk, which is considered efficient portfolio management (EPM) and does not inherently introduce complexity under MiFID II rules[1]. There is no indication of embedded derivatives integral to the investment objective, no synthetic replication, no leverage beyond UCITS limits, and no securities lending. The fund explicitly states it will not enter into securities lending, and the use of derivatives is limited to currency hedging, which is generally not considered complex if counterparty risk is minimal and well-managed[1][2]. The risk profile is driven by market volatility typical of emerging market bonds, not structural complexity. The ETF does not invest in complex structured products such as CLOs or other asset-backed securities embedding derivatives, which would trigger a complex classification[2]. Therefore, based on the MiFID II Article 254, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, this UCITS ETF is classified as non-complex."
}