{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The AMUNDI MSCI NORDIC UCITS ETF is a UCITS-compliant ETF that tracks the MSCI Nordic Countries 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/outflows or better exposure to index constituents, not as an inherent part of the investment strategy. Securities lending is used as a secondary feature to generate additional income but is well-managed within UCITS rules with collateral requirements. There is no significant leverage beyond UCITS limits. The ETF's structure and risks (market volatility, tracking error) are straightforward and transparent, easily understood by retail investors with basic knowledge. The underlying index is a transparent equity index. The risk profile reflects market risk, not structural complexity. According to MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, UCITS ETFs with physical replication and limited derivative use for EPM are presumed non-complex. The ETF does not embed derivatives or structured products such as CLOs, which would trigger complexity. ESMA guidance and CESR analysis confirm that such ETFs are non-complex unless synthetic replication or embedded derivatives are present. Therefore, this ETF is classified as non-complex under MiFID II."
}