{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of currency forwards for hedging; exposure to emerging market bonds with credit risk; no embedded derivatives or structured products",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which under MiFID II is generally presumed non-complex. It uses physical replication via stratified sampling and portfolio optimisation techniques to track the J.P. Morgan USD EM IG ESG Diversified Bond Index. The ETF employs currency forwards solely for currency hedging purposes, which is considered derivative use for efficient portfolio management (EPM) and does not inherently trigger complexity. The fund explicitly states it will not engage in securities lending, and there is no indication of leverage beyond UCITS limits or embedded derivatives such as swaps or structured products. The underlying index is transparent and well-documented, focusing on investment grade emerging market bonds with ESG criteria. Although the bonds carry credit risk and some liquidity risk typical of emerging markets, these risks relate to market volatility and not structural complexity. The fund's structure and risks are straightforward and understandable by retail investors with basic knowledge. Therefore, according to MiFID II Article 254, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, this UCITS ETF is classified as non-complex."
}