{
    "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 15+Y UCITS ETF is a UCITS-compliant ETF that tracks the Bloomberg Barclays Euro Treasury 50bn 15+ Year Bond Index via physical replication, primarily investing in fixed-rate, investment grade sovereign bonds denominated in euros with maturities over 15 years. The ETF may use securities lending as a secondary technique, which under MiFID II does not automatically render it complex if well-managed and collateralized. There is no indication of embedded derivatives integral to the investment strategy, no synthetic replication, no significant leverage beyond UCITS limits, and no structured or contingent convertible bonds involved. The ETF's structure and risks (market risk, credit risk, operational risk) are transparent and understandable to retail investors with basic knowledge. The ETF does not embed derivatives as part of its core strategy but may use them only for efficient portfolio management if at all, which does not trigger complexity. The underlying index is transparent and straightforward, supporting non-complex classification. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, UCITS ETFs using physical replication and investing in straightforward government bonds without embedded derivatives or complex features are automatically non-complex. Therefore, this ETF is classified as non-complex under MiFID II. This aligns with ESMA and CESR guidance that physical replication UCITS ETFs tracking transparent indices and without embedded derivatives or leverage are non-complex. No comprehension alert is required in the PRIIPs KID for this ETF."
}