FIL Investment Advisors, a Bermuda company formed in 1983, has been in the business of
providing investment advisory and sub‐advisory services for over 30 years. FIA has been
registered with the SEC as an investment adviser under the U.S. Investment Advisers Act of
1940 ("Advisers Act") since 1984 and also is authorized by the Hong Kong Securities and
Futures Commission to advise on securities and futures and provide asset management
services. FIA 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, FIA 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’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 are not related persons.
FIA has delegated or may delegate all or a portion of its advisory responsibilities to its affiliates
FIL Investment Advisors (UK) Ltd. (“FIA UK”), FIL Investments (Japan) Limited (“FIJ”). FIA UK and
FIJ are registered as investment advisers under the Investment Advisers Act of 1940. FIA also
utilizes the services
of other Participating Affiliates (see Other Financial Industry Activities and
Affiliations below).
FIA 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’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's assets under management were USD $9,036,407,246. All assets
are sub‐advised on a discretionary basis.
Other Activities of Certain FIA Portfolio Managers, Analysts and Employees
From time to time, non‐clients (for example, public media commentators, conference
attendees, consultants) may ask FIA portfolio managers, analysts or other employees of FIA 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 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 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 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 account.