Fidelity Supplier Code of Conduct

All Fidelity Suppliers are expected to fully comply with all applicable laws and regulations while conducting business with or on behalf of Fidelity. Such laws include but are not limited to:

1. Trade controls and export, re-export, and import laws
2. Anti-trust, anti-corruption, anti-money laundering and fair competition laws
3. U.S. Immigration laws - Suppliers shall comply with applicable immigration laws and regulations in any jurisdiction where they operate and only employ workers with a legal right to work in the relevant location
4. Laws governing participation in international boycotts which are not sanctioned by United States (U.S.) government

Further, Fidelity requires its Suppliers to comply with all laws and regulations regarding gifts, business entertainment, or other benefits involving all business partners, including but not limited to government officials. This means that Fidelity Suppliers must prohibit all corrupt activities, including public and private sector bribery. More specifically, Fidelity prohibits directly or indirectly giving, offering, authorizing, promising, accepting, or receiving any bribe, facilitation payment, kickback, or payoff, with the intent to improperly obtain or retain business or any improper advantage.

All forms of illegal or inappropriate activity, including, but not limited to, corruption, misrepresentation, extortion, embezzlement is strictly prohibited. Records prepared for Fidelity must be accurate, truthful and complete, and must comply with all applicable laws regarding their completion and accuracy.

If a Supplier, with Fidelity’s prior written approval, engages in any advertising, marketing, or promotional activities that reference or implicate Fidelity or its logo, products, or services in any manner, such materials must be truthful and accurate, with clear and conspicuous disclosure of material terms and limitations of advertised offers.

Suppliers are expected to compete based on the merit of their products and services, not through gifts, entertainment, or other business courtesies. Suppliers must never provide gifts to Fidelity employees because even a well-intentioned gift might constitute a bribe under certain circumstances or create conflicts of interest. It is never permissible to give currency as a gift. Any meals, or entertainment must comply with applicable laws, must not violate the giver's and/or recipient's policies on the matter, and must be consistent with local custom and practice.

Suppliers must avoid the appearance of actual improprieties or conflicts of interest. Suppliers must not deal directly with any Fidelity employee whose spouse, domestic partner, or other family member or relative holds a significant financial interest with the Supplier.

Fidelity expects its Suppliers to share its commitment to human rights and equal opportunity in the workplace. All workers must be treated with the utmost dignity and respect, and Fidelity's Suppliers must conduct their employment practices to the highest standards of human rights.

1. Voluntary labor
   The use of forced labor whether in the form of indentured labor, bonded labor, or prison labor by Fidelity Suppliers is prohibited. Suppliers must not support any form of human trafficking of involuntary labor through threat, force, fraudulent claims, or other coercion. Any workers' contracts, if any, which are provided by a Supplier must be written in a language understood by the workers and clearly convey the conditions of employment. Suppliers must comply with all local and national minimum working age laws or regulations and not use child labor. Suppliers cannot employ anyone under the age of 15, under the age for completing compulsory education, or under the legal minimum working age for employment—whichever is higher.
   
   
2. Working Hours and Wages
   Compensation paid to employees must comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Employees should have the ability to earn fair wages, as determined by applicable local law. Suppliers are fully responsible for the quality, performance, behavior, supervision and protection of their personnel.
   
   
3. Nondiscrimination
   Suppliers must not engage in discrimination on any basis prohibited by applicable/local law. Fidelity embraces diversity and equal opportunity as fundamental principles and key components of its corporate strategy.

Suppliers must be committed to the safety and health of their employees and must ensure that required training and applicable certifications of Supplier personnel have been completed prior to that individual initiating any work activity when engaging with Fidelity. Suppliers must have or subscribe to a written safety and health program. Suppliers are responsible for assuring that all workers are provided with a safe place to work and are qualified to perform their work functions safely.

Supplier must maintain a comprehensive business continuity plan (“BCP) that provides for the restoration of technology and business operations in the event of an unplanned event. Such BCP should include risk analysis, business impact analysis, and disaster recovery strategies for different scenarios, including geographic/regional events, pandemics, natural disasters (e.g., tornado, hurricane, flooding, fire) and other unplanned events (data center outage, hardware failures, communication outage, power outage), applicable to, without limitation, Supplier’s operations associated with the services provided to Fidelity.

1. Supplier Diversity
   Fidelity is committed to conducting business in a fair and equitable manner, including partnering with diverse suppliers to help develop and strengthen their businesses and ultimately utilize the power of our firm to drive positive impact in the communities we serve. Our partners are a critical component of our ability to provide industry leading solutions to our customers. We believe that diversity drives innovation and creativity, therefore having a diverse supplier network of partners is imperative to our continued success as a company.
   
   Fidelity’s suppliers are expected to support Fidelity's Supplier Diversity initiatives by providing diverse businesses with a fair opportunity to bid and acquire supply chain contracts. Fidelity defines “Diverse Businesses” as businesses certified with any of the following or equivalent classifications, including but not limited to: woman-owned (WBE), minority-owned (MBE), veteran-owned (VOBE, including disabled and service-disabled), disability-owned (DOBE), Disadvantaged Business Enterprise (DBE), LGBTQ-owned, HubZone, and Small (SBA/SBE).
   
   
2. Environmental
   Fidelity is committed to protecting the environment and embraces principles of environmental responsibility in our business practices every day. As part of Fidelity's commitment, we look to partner with suppliers who promote a culture of sustainability, those who commit to minimizing the adverse effects their operations have on the environment and encourage environmentally responsible business practices in collaboration with both internal and external stakeholders. We require that our supply chain achieve the following:
   • Follow existing regulations and laws. Suppliers must work in compliance with all applicable environmental laws and regulations. Suppliers must obtain, maintain, and keep current all required environmental permits, approvals, and registrations.
   • Consider the environmental impact of business operations. Suppliers should consider the full environmental impacts of their business operations, products and services, prioritize resource efficient products, and minimize hazardous impacts by eliminating, reducing, or replacing them with organic, environmentally sensitive alternatives. Suppliers are encouraged to implement and disclose strategies that reduce their impact on the environment—such as greenhouse gas emissions and consumption reduction and ecosystem-related impacts (energy, water, raw materials, waste streams, etc.)—and address climate-related impacts to their overall business resilience and continuity.
     
     
3. Accessibility
   Fidelity is committed to ensuring that all associates and clients with a disability will be able to obtain digital information as fully, equally and independently as a person without a disability. As part of Fidelity’s commitment to accessibility its Suppliers agree to use best efforts to conform to the Web Content Accessibility Guidelines 2.1 AA (“WCAG”) for accessibility compliance on all digital technology that is customer or associate facing.

On occasion, individuals may desire a degree of confidentiality or even anonymity regarding an issue they wish to raise. In such cases, Fidelity will balance this desire for confidentiality or anonymity with Fidelity's responsibilities to its customers, employees, and shareholders as well as its legal and regulatory obligations. The manner in which confidentiality is addressed for an individual case will be based on this balance. Information may be disclosed to those who Fidelity determines have a need to know the information, such as those who may investigate or resolve the concern.

As a result, neither complete confidentiality nor anonymity is guaranteed with respect to an individual’s use of any of the communication channels available at Fidelity.

However, individuals reporting unethical conduct will not be subject to retaliation for reporting or helping to resolve a concern. Fidelity may take action against any individual who, in Fidelity's view, has engaged in wrongdoing.

If you wish to report questionable behavior or a possible violation of the Supplier Code of Conduct, you are encouraged to work with your primary Fidelity contact to resolve your concern. If that is not possible or appropriate, please contact Fidelity through any of the following methods: