{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for efficient portfolio management, potential counterparty risk, but not central to strategy",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is passively managed and primarily invests in bonds issued by Multilateral Development Banks, tracking a transparent, well-documented index. The fund may use derivatives, but only for efficient portfolio management (EPM)u2014such as when direct investment is not possible or practical, or to generate efficiencies in gaining exposure to the index. The use of OTC derivatives introduces counterparty risk, but this is mitigated by the fund's collateral policy. The fund does not engage in securities lending, does not use significant leverage, and does not employ synthetic replication or swaps as a core strategy. The structure, risks, and investment objective are straightforward and disclosed in the Key Investor Information Document (KIID). The fund's risk profile reflects market volatility of the underlying bonds, not structural complexity. Under MiFID II, UCITS are generally presumed non-complex, and this presumption is not overturned here because derivative use is limited to EPM, the replication method is physical, and the risks are transparent and typical for a bond ETF. There is no evidence of embedded derivatives, complex indices, or other features that would make the product difficult for a retail investor with basic knowledge to understand. Therefore, the ETF meets the criteria for a non-complex classification under MiFID II Article 25(4) and Delegated Regulation Article 57[1][2]."
}