{
    "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 automatically presumed non-complex due to the strict regulatory framework governing UCITS funds, including diversification, liquidity, and transparency requirements. The ETF tracks the Bloomberg MSCI Global Corporate High Yield SRI Sustainable Index through physical replication, mainly by direct investments in transferable securities representing the index constituents. The ETF uses derivatives only for efficient portfolio management (EPM) purposes such as managing inflows/outflows or better exposure to index constituents, which is consistent with non-complex classification. There is no indication of synthetic replication or embedded derivatives. Securities lending is used but managed within UCITS rules and does not dominate the risk profile. There is no significant leverage beyond UCITS limits. The underlying index is transparent and based on a well-known Bloomberg MSCI high yield corporate bond index with ESG criteria, supporting ease of understanding. The risk profile reflects market risk typical of high yield bonds, not structural complexity. Therefore, the ETF meets all criteria for non-complex classification under MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, and no features such as embedded derivatives, leverage, or complex structures that would trigger complexity are present. This aligns with ESMA and CESR guidance that UCITS ETFs physically replicating transparent indices and using derivatives only for EPM are non-complex. Hence, no appropriateness assessment is required for execution-only sales to retail clients."
}