{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for currency hedging; physical replication with sampling; no embedded derivatives or leverage",
    "classification": "non-complex",
    "supporting_data": "The AMUNDI MSCI JAPAN UCITS ETF EUR Hedged Dist is a UCITS-compliant ETF that tracks the MSCI Japan Net Total Return Index using primarily physical replication with a sampling strategy. It uses derivatives only for currency hedging purposes, which is a form of efficient portfolio management (EPM) and does not constitute an inherent element of the investment strategy. The ETF does not employ leverage beyond UCITS limits, nor does it embed complex derivatives such as swaps integral to replication. The structure and risks (market volatility, tracking error, currency hedging risk) are transparent and understandable to retail investors with basic knowledge. According to MiFID II Article 25(4)(a)(iv), UCITS ETFs are generally presumed non-complex. The use of derivatives solely for hedging currency risk is consistent with non-complex classification under MiFID II Article 57 criteria, as it does not introduce significant counterparty or structural complexity. The replication method is physical (with sampling), which supports non-complexity. There is no indication of embedded derivatives, leverage, or complex structured products such as CLOs. The ETF provides comprehensive and publicly available information, including on the underlying index and holdings, supporting the criterion of adequate transparency. Therefore, under MiFID II and ESMA guidelines, this UCITS ETF is classified as non-complex and does not require an appropriateness assessment for non-advised retail sales."
}