{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Amundi Euro Government Bond 5-7Y UCITS ETF is a UCITS-compliant ETF that tracks the Bloomberg Barclays Euro Treasury 50bn 5-7 Year Bond Index via physical replication, primarily investing in the underlying sovereign bonds denominated in euros with maturities between 5 and 7 years. The ETF may use securities lending as a secondary technique, which under MiFID II does not automatically render the product complex if well-managed and collateralized. There is no indication of embedded derivatives or synthetic replication, nor significant leverage beyond UCITS limits. The ETF's structure and risks (market risk, credit risk, operational risk) are straightforward and transparent to a retail investor with basic knowledge. The ETF does not embed derivatives integral to its investment objective, and derivative use is limited to efficient portfolio management, if any. The underlying index is transparent and well-documented. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, UCITS ETFs using physical replication and not embedding derivatives or complex features are presumed non-complex. ESMA guidance confirms that synthetic ETFs or structured UCITS with complex derivative strategies are complex, but this ETF does not fall into those categories. Therefore, the ETF is classified as non-complex under MiFID II, and no appropriateness assessment or comprehension alert is required for retail investors investing on a non-advised basis[1][2][3][4]."
}