{
    "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 China ESG Leaders Extra UCITS ETF is a UCITS-compliant ETF that tracks the MSCI China Select ESG Rating and Trend Leaders Net Total Return Index via direct physical replication or sampling replication strategy. It primarily invests in international equities and financial derivative instruments (FDI) only for portfolio management optimization, not as a core strategy. The ETF does not use synthetic replication or total return swaps, nor does it embed derivatives integral to its investment objective. There is no indication of leverage beyond UCITS limits, no embedded complex derivatives such as structured products or contingent convertible bonds, and no capital protection features that would add complexity. The underlying index is transparent, based on ESG ratings of large and mid-cap Chinese stocks, and the ETF's structure and risks (market volatility, tracking error) are straightforward and understandable by retail investors with basic knowledge. Securities lending is not mentioned as a significant feature. According to MiFID II Article 25(4)(a)(iv), UCITS ETFs are automatically presumed non-complex unless they have features that make them complex. The ETF meets the criteria of Article 57 of the Commission Delegated Regulation (C(2016) 2398 final) for non-complex instruments: it does not embed derivatives integral to the strategy, has frequent liquidity, no excess liability beyond investment cost, no clauses altering risk fundamentally, no illiquidity from exit charges, and comprehensive, understandable information is publicly available. ESMA guidance and CESR technical advice confirm that physical replication UCITS ETFs without embedded derivatives or leverage are non-complex. Therefore, this ETF is classified as non-complex under MiFID II. This classification aligns with Janus Henderson's statement that all UCITS funds are automatically non-complex. No PRIIPs comprehension alert is required."
}