{
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": "Derivative use for efficient portfolio management, potential for counterparty risk, possible use of structured notes",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is passively managed, tracks a transparent bond index, and primarily uses physical replication (stratified sampling) to achieve its objective. While the fund may use derivatives for efficient portfolio management (EPM) and may hold structured notes, these features are not central to the investment strategy and are within UCITS limits. There is no securities lending, no significant leverage, and no embedded derivatives that would fundamentally alter the risk profile. The fund's structure, risks (mainly credit and market risk), and investment policy are straightforward and disclosed in the KID. Under MiFID II, UCITS ETFs are generally presumed non-complex unless they employ complex strategies or hold complex instruments as a core part of their strategy, which is not the case here. The use of derivatives is limited and for risk management, not for synthetic replication or complex payoff structures. Therefore, despite the possibility of derivative use and holding structured notes, the ETF remains non-complex for MiFID II purposes."
}