{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for portfolio management, Emerging market bond exposure, Illiquidity risk, High volatility, Credit risk, Currency risk",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which is automatically non-complex under MiFID II unless it is a structured UCITS or uses derivatives in a way that introduces significant complexity or risk not easily understood by retail investors[1]. The fund may use derivatives for efficient portfolio management (EPM), such as hedging currency risk or managing inflows/outflows, but does not use them as a core strategy to replicate the index (i.e., no synthetic replication or total return swaps). The fund's main risksu2014emerging market bond exposure, credit risk, illiquidity, and currency risku2014are typical for the asset class and do not, by themselves, make the ETF complex under MiFID II. The fund does not engage in securities lending, does not use significant leverage beyond UCITS limits, and does not embed complex derivatives or structured products like CLOs. The replication method is physical (stratified sampling), supporting transparency. While the fund's risk category is high (5/7), this reflects market risk, not structural complexity. The fund's documentation is comprehensive and publicly available, in line with UCITS requirements. Therefore, despite the use of derivatives for EPM and the high-risk profile, the fund remains non-complex under MiFID II[1][2]."
}