{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Amundi Global Aggregate Green Bond UCITS ETF is a UCITS-compliant ETF that tracks a transparent, investment-grade green bond index via physical replication or sampling replication. It primarily invests in bonds comprising the benchmark index, which are investment grade and labeled green bonds, with no indication of embedded derivatives or synthetic replication. The ETF may engage in securities lending, but this is a secondary feature managed under UCITS rules with collateral requirements, not significantly increasing complexity. There is no significant leverage beyond UCITS limits, no embedded derivatives, and the structure and risks (market risk, credit risk, liquidity risk) are straightforward and understandable by retail investors with basic knowledge. The ETF does not use synthetic replication or total return swaps, and derivatives, if any, are used only for efficient portfolio management with minimal impact on risk-return profile. The underlying index is transparent and well-documented. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs that physically replicate transparent indices and do not embed derivatives or complex features are automatically non-complex. ESMA guidance and regulatory practice confirm that such UCITS ETFs do not require an appropriateness assessment and are suitable for execution-only distribution to retail investors. Therefore, this ETF is classified as non-complex under MiFID II."
}