FIL Investment Advisors (UK) Limited, a UK company formed in 1984, has been in the business of
providing investment advisory and sub-advisory services for over 30 years. FIA UK has been
registered with the SEC as an investment adviser under the U.S. Investment Advisers Act of 1940
("Advisers Act") since 1985 and is authorized by the UK Financial Conduct Authority to provide
investment advisory and asset management services. FIA UK is a wholly owned subsidiary of FIL
Holdings (UK) Limited ("FHL"); a holding company for UK regulated companies, which in turn is a
subsidiary of FIL Financial Services Holdings Limited (“FFSH”); a holding company for FIL affiliates,
which in turn is a wholly owned subsidiary of FIL Limited ("FIL"), a Bermuda company that serves
as the holding company for the FIL group of companies ("FIL Group").
On a sub-advisory basis through a delegation from its affiliate, FIL Investment Advisors, a
Bermuda company ("FIA"), FIA UK currently provides discretionary investment advisory services
to institutional accounts, including U.S. investment companies (also referred to as “mutual
funds”) registered under the U.S. Investment Company Act of 1940 (the “1940 Act”). Fidelity
Management & Research Company LLC (“FMR”), FIAM LLC (“FIAM”), Fidelity Institutional Asset
Management Trust Company, (“FIAMTC”) and Strategic Advisers LLC (“SAI”) are the principal
investment advisers of FIA UK’s mutual fund clients.
FMR, FIAM, FIAMTC and SAI have access to investment research on a substantially delayed basis
from various subsidiaries and affiliates of FIL (including Fidelity Investments Canada ULC (“FIC”)),
which are investment advisers registered with the SEC operating principally in the United
Kingdom, Japan, and Hong Kong or Participating Affiliates (as defined below) of such registered
advisers. FMR, FIAM, FIAMTC and SAI and FIA UK are not related persons.
FIA UK or its affiliates generally have authority
to determine which securities to purchase or sell,
and the total amount of such purchases and sales and the brokers or dealers through which
transactions are effected. However, with respect to each discretionary account, FIA UK’s and its
affiliates’ authority is subject to certain limits, including the applicable investment objectives,
policies and restrictions. These limitations may be based on a variety of factors, such as
regulatory constraints, as well as policies imposed by a client or its governing body (e.g., Board
of Trustees) and may cause differences in allocations on investment opportunities, executing
brokers or dealers and/or commission rates paid. (See Brokerage Practices below).
As of 31st December 2023, FIA UK's assets under management were USD$7,348,822,000. All
assets are sub-advised on a discretionary basis.
Other Activities of Certain FIA UK Portfolio Managers, Analysts and Employees
From time to time, non-clients (for example, public media commentators, conference attendees,
consultants) may ask FIA UK portfolio managers, analysts or other employees of FIA UK or its
affiliates to express their personal views regarding a particular company, security, industry or
market sector. The views expressed by any such person are the views of only that individual and
do not necessarily represent the views of FIA UK or its affiliates or any other person in the FIL
Group. Any such views are subject to change at any time based upon market or other conditions
and FIA UK disclaims any responsibility to update such views. These views are not being offered
as investment advice and may not be relied on as such. Furthermore, because any investment
decision for an account sub-advised by FIA UK or any of its affiliates may be based on potentially
numerous factors, such views should not be construed or relied upon as an indication of trading
intent on behalf of a FIA UK account.