{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The AMUNDI MSCI USA SRI CLIMATE NET ZERO AMBITION PAB UCITS ETF is a UCITS-compliant ETF that tracks the MSCI USA SRI FILTERED PAB NR Close Index through direct physical replication by holding the underlying securities in proportions close to the index. The ETF uses derivatives only for efficient portfolio management (EPM) purposes such as managing inflows and outflows, and currency hedging, with minimal impact on the risk-return profile. Securities lending is used as a secondary feature to generate additional income but is well-managed within UCITS rules. There is no significant leverage beyond UCITS limits, no embedded derivatives, and no synthetic replication. The index tracked is transparent and based on large and mid-cap US equities with ESG and climate transition criteria, which are straightforward for retail investors to understand. The risk profile reflects market and currency risks typical of equity ETFs, without structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs using physical replication and limited derivative use for EPM are presumed non-complex. The ETF does not embed complex features such as contingent convertible bonds, structured products, or synthetic replication that would trigger a complex classification. Therefore, it meets all criteria for non-complex classification under MiFID II. This aligns with regulatory guidance that all UCITS funds are automatically non-complex unless they employ complex portfolio management techniques or invest in complex instruments, which is not the case here. Hence, no appropriateness assessment is required for non-advised sales, and no comprehension alert is mandated."
}