FIL Investments (Japan) Limited (“FIJ”), a Japanese corporation formed in 1986, has been in the
business of providing investment advisory and sub-advisory services for over 30 years. FIJ has
been registered with the SEC as an investment adviser under the U.S. Investment Advisers Act of
1940 ("Advisers Act") since 1994 and also is authorized by the Japan Financial Services Agency.
FIJ is a wholly owned subsidiary of FIL Japan Holdings KK, a Japanese company, which in turn is a
wholly owned subsidiary of FIL Asia Holding Pte Limited, 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 ("FIA"), a
Bermuda company, FIJ has provided discretionary investment advisory services with regard to
both Japanese and non-Japanese securities 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”). FIJ currently provides discretionary investment advisory services
to Japanese (non-US) institutional accounts and pension funds.
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 FIJ’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 FIJ are not related persons. FIJ may obtain research or
other advisory support from its affiliates. FIJ may also provide non-discretionary investment
advisory and research services to its affiliates
with regard to Japanese and Korean securities. FIJ
does not sponsor any wrap fee programs.
FIJ 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, FIJ’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 April 30, 2016, FIJ no longer sub advises any assets for any regulated U.S. entities and
therefore, although its processes are disclosed in this brochure, they are not applicable.
Other Activities of Certain FIJ Portfolio Managers, Analysts and Employees
From time to time, non-clients (for example, public media commentators, conference attendees,
consultants) may ask FIJ portfolio managers, analysts or other employees of FIJ 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 FIJ 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 FIJ
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 FIJ 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 FIJ account.