Fidelity Management & Research (Hong Kong) Limited (“FMR (Hong Kong)”) is authorized by the
Hong Kong Securities and Futures Commission to deal in securities, advise on securities, dealing in
futures contracts and provide asset management services. FMR (Hong Kong) may provide investment
advisory or portfolio management services as a sub-adviser with respect to certain clients of Fidelity
Management & Research Company LLC (“FMR”), including investment companies in the Fidelity
family of mutual funds (the “Fidelity Funds” or “Fidelity group of funds”), and for clients of other
affiliated and unaffiliated advisers. FMR (Hong Kong), a wholly-owned subsidiary of FMR, which in turn
is wholly-owned by FMR LLC, has been registered with the Securities and Exchange Commission
(“SEC”) since 2008. FMR (Hong Kong) may also provide other services to affiliated or unaffiliated
parties that may require licensing in the local jurisdiction.
FMR (Hong Kong) provides investment supervisory services, including sub-advisory services, to
institutional accounts, principally investment companies (also referred to as “mutual funds”) registered
under the Investment Company Act of 1940 (the “1940 Act”). FMR (Hong Kong) may provide to certain
investment company and other institutional clients of FMR or its affiliates research, investment
advisory, and/or discretionary asset management services principally relating to securities of issuers
located outside of North America, including Hong Kong and elsewhere in Asia. For its research
services, FMR (Hong Kong) may provide this research, which may include written research notes and
ratings, to other affiliates and unaffiliated investment managers and financial institutions, in some
instances on a delayed basis. FMR (Hong Kong) or its affiliates provide all necessary office facilities
and personnel for servicing the funds' investments, and pays the salaries and fees of all officers of the
funds, members of the Boards of Trustees who are “interested persons” of the funds, FMR (Hong
Kong) or its affiliates, and all personnel of the funds, FMR (Hong Kong), or its affiliates who perform
services relating to research, statistical and investment activities. Though FMR (Hong Kong) advises
the mutual funds and other institutional accounts it manages regarding certain commodity interests,
FMR (Hong Kong) is not registered as a commodity pool operator or commodity trading adviser.
For the Fidelity group of funds, FMR (Hong Kong) or its affiliates, subject to the supervision of the
Board of Trustees of each fund in the Fidelity group of funds, provide the management and
administrative services necessary for the operation of the Fidelity group of funds. These services
include: providing facilities for maintaining each fund’s organization; supervising relations with
custodians, transfer and pricing agents, accountants, underwriters and other persons dealing with the
funds; at the direction of the funds, preparing all general shareholder communications and conducting
shareholder relations; at the direction of the funds, maintaining each fund’s records and the registration
and notice filing status of each fund’s shares under federal and state law; developing management and
shareholder services for each fund; and furnishing reports, evaluations and analyses on a variety of
subjects to the Board of Trustees of each fund in the Fidelity group of funds.
In certain instances, FMR (Hong Kong), to the extent permitted by its advisory contracts, delegates
investment discretion over all or a portion of the portfolio to one or more sub-advisers, including FMR
(Hong Kong)’s affiliates and various subsidiaries and affiliates of FIL Limited (“FIL”). If FMR (Hong
Kong) or
its affiliates engage FIL or another unaffiliated entity to sub-advise an FMR (Hong Kong) fund
or account, or a portion of an FMR (Hong Kong) fund or account, the sub-adviser’s policies and
procedures, including trade allocation and conflicts of interest, will apply to that fund or account, except
for certain fund Board-approved affiliated transaction policies subject to applicable law. FMR (Hong
Kong) has access to investment research on a substantially delayed basis from various subsidiaries
and affiliates of FIL, 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. Certain of FIL’s subsidiaries and affiliates (including Fidelity Investments Canada ULC
(“FIC”)), which are companies not registered with the SEC (each, a “Participating Affiliate”), have
access to information (such as through employees who work for both a FIL registered adviser and the
unregistered FIL subsidiary or affiliate) concerning securities recommendations for the registered
adviser’s U.S. clients.
Additionally, each of FMR LLC, the ultimate parent company of FMR (Hong Kong), and FIL Limited
have contracted on an arms-length basis for the provision of compliance monitoring and reporting
services in their respective jurisdictions. As such, certain individuals supporting compliance and
operations functions will have access to information concerning securities recommendations for each
others' clients. Subsidiaries of FIL Limited also distribute investment strategies advised by FMR (Hong
Kong) and its affiliates outside of the U.S. FMR (Hong Kong) disclaims that it is a related person of FIL.
In the course of FMR (Hong Kong)’s providing its investment advisory services, a portfolio manager,
analyst or other employee of FMR (Hong Kong) or its affiliates will, from time to time, express views
regarding a particular company, security, industry or market sector. The views expressed by any such
person are the views of only that individual as of the time expressed and do not necessarily represent
the views of FMR (Hong Kong) or its affiliates or any other person in the Fidelity organization. Any
such views are subject to change at any time based upon market or other conditions and FMR (Hong
Kong) disclaims any responsibility to update such views. These views may not be relied on as
investment advice and, because investment decisions for an account managed by FMR (Hong Kong)
or its affiliates are based on numerous factors, may not be relied on as an indication of trading intent
on behalf of any such account.
FMR (Hong Kong) or its affiliates generally have authority to determine which securities to purchase or
sell and the total amount of such purchases and sales. However, with respect to each discretionary
account, FMR (Hong Kong)’s and its affiliates’ authority is subject to certain limitations, including the
applicable investment objectives, policies and restrictions. These limitations are based on a variety of
factors, including regulatory constraints and policies formally imposed by a client or its governing body
(e.g., Board of Trustees) through, for example, a management agreement, and can cause differences
in an account’s holdings, risk profile, commission rates, timing of trades and overall execution. With
respect to FMR (Hong Kong)’s registered investment company clients, many of the applicable
investment policies and limitations are set forth in each client’s registration statement filed with the
SEC.
As of December 31, 2023, FMR (Hong Kong) managed $24,407,640,788 of client assets on a
discretionary basis. As of December 31, 2023, FMR (Hong Kong) did not manage any client assets on
a non-discretionary basis.