{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for portfolio optimisation; no embedded derivatives or synthetic replication; no leverage; no securities lending",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF investing predominantly in bonds and transferable securities, tracking the Bloomberg MSCI US Liquid Corporates 1-5 Year Sustainable Index using a stratified sampling strategy with portfolio optimisation. It may use derivatives but only for efficient portfolio management (EPM) purposes, not as an inherent part of the investment strategy. The ETF uses physical replication by holding a representative sample of the index components. There is no securities lending, no significant leverage, and no embedded derivatives or synthetic replication. The risk profile is moderate (risk category 3), reflecting market volatility and credit risk typical of investment grade bonds, not structural complexity. The ETF promotes ESG characteristics but does not have a sustainable investment objective that would add complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, UCITS ETFs are presumed non-complex unless they embed derivatives integral to the strategy or have complex features such as synthetic replication or leverage. The use of derivatives here is limited to EPM with minimal impact on risk-return, which does not trigger complexity. The replication method is physical, which supports non-complex classification. The ETF's structure and risks are transparent and understandable to retail investors with basic knowledge. Therefore, under MiFID II and ESMA guidelines, this UCITS ETF is classified as non-complex."
}