Fidelity Supplier Policies

You shall fully comply with applicable laws and regulations while conducting business with, for, or on behalf of Fidelity.

You shall comply with Applicable Laws regarding gifts, business entertainment, or other benefits involving all business partners, including but not limited to government officials. This means that You shall not engage in any corrupt activities, including public and private sector bribery. More specifically, You shall not directly or indirectly give, offer, authorize, promise, accept, or receive any bribe, facilitation payment, kickback, or payoff, with the intent to improperly obtain or retain business or any improper advantage. 

You shall avoid participation in all forms of illegal or inappropriate activity, including, but not limited to, corruption, misrepresentation, extortion, and embezzlement. Documents prepared for Fidelity to meet any regulatory or legal requirement shall be accurate, truthful and complete, and shall comply with all applicable laws regarding their completion and accuracy.

Environmental
You shall comply with all applicable environmental laws and regulations and shall obtain, maintain, and keep current all required environmental permits, approvals, and registrations. You shall, upon request and if maintained in the normal course of business, report on Your carbon emissions and reduction targets as well as provide insight into how Your organization is addressing environmental-related risks and opportunities.

UK Employers Only
You shall take reasonable steps to prevent sexual harassment in its workplace in compliance with the UK Equality Act 2010. Fidelity does not condone the harassment of any of its workforce (including sexual harassment) and will take prompt and effective steps to address any issues involving the third-party harassment of its staff.

In addition to the above, the invoice must identify the following:

• If Supplier is domiciled outside the United States, Supplier shall perform all Services at locations outside of the United States, unless Supplier:
  • Identifies a specific portion of Services to be performed, or that have been performed, in the United States by the supplier, and
  • Itemizes the cost for the Services performed, or to be performed, in the U.S., on the invoice and Ordering Document, as applicable.  
• All invoices must include the country and relevant percentage where the supplier’s employees performed services (including vendor hosted software) or provided software support.
• Supplier must indicate the country/region in which services were performed on the face of the invoice. Examples are:
  • All Services Performed in the United Kingdom;
  • All Services Performed in Europe;
  • All Services Performed in the U.S.;
  • 75% of Services Performed in the U.S.
• The supplier’s name on the invoice must agree with the name on Line 1 of the W-8 except for the case in which a billing entity’s name is a trade name, a “doing business as” (“DBA”) name, or a disregarded entity’s (“DRE”) name. In this case, the entity’s owner name and information must be provided on Line 1 of the W-8 with the trade, DBA or DRE name on line 3 of the W-8.
• For vendor-hosted software, the invoice must identify the country in which the software was developed and maintained. For example, if the software was developed and is partially maintained in the U.S., the invoice must identify the percentage of the work that was/is performed in the U.S. If all development and maintenance occurred outside the U.S., please ensure that the invoice indicates “All Software developed and maintained outside the U.S.”
• In addition to the above, for software support (help desk, training, etc.) fees the invoice should identify the percentage of support provided by supplier employees located in the U.S. amount separately and should identify on the invoice the country or country in which those services are performed, as noted below.
• For software which has been downloaded in the Fidelity environment, and is being used in the U.S., that portion of the license and maintenance fees, may be subject to U.S. withholding tax dependent on the supplier’s domicile.

• if available, an Accessibility Conformance Report (“ACR”), and/or a Voluntary Product Accessibility Template (“VPAT”), for EIT, including EIT completed or provided by a third-party, that You are delivering to Fidelity. A self assessed VPAT and ACR completed by You will not be accepted by Fidelity as a reliable accessibility assessment of Your EIT.
• access to the EIT for accessibility review and testing.
• In an effort to assist You with making Your EIT accessible and at the request of You, Fidelity may refer You to a preferred vendor offering accessibility services. These vendors may provide assistance to You at preferred rates for remediation of EIT, completion of VPATs and ACRs and support of other accessibility items as requested.

Documentation and Compliance
Following Fidelity’s accessibility review of Your EIT, if Fidelity finds that Your EIT is inaccessible and requires remediation, Fidelity may provide an ARS describing Your required correction of inaccessible items. If Fidelity prepares and provides such ARS to You, then You shall comply with the ARS within a reasonable timeframe as agreed upon in writing by both Parties. If You fail to comply with the ARS, Fidelity may terminate the applicable agreement or ordering document for cause and without penalty and, in such case, will receive a pro-rated refund of fees paid for products and services not received.

An ARS for Your EIT shall be based on: (i) an accessibility review by Fidelity; (ii) accessibility testing by Fidelity; and/or (iii) a VPAT or ACR completed by a Fidelity-approved Third-Party Accessibility Auditor, as made available by You. Fidelity’s review and testing should not be relied upon by You as an exhaustive list of all accessibility failures but as a list of those items that Fidelity interprets as critical and serious level issues pursuant to Fidelity’s Accessibility Failure Severity Rating or other designated items which may render the EIT inaccessible to individuals with disabilities.

In addition to compliance with Applicable Laws, Your EIT shall comply with: (i) the World Wide Web Consortium’s Web Content Accessibility Guidelines version Level AA, Section 2.2 (“WCAG”) at WCAG 2.2; and (ii) the Concept of Usability for people with disabilities. Should the current published version of WCAG change and Fidelity announce adoption of such change, You shall comply with or have a roadmap to comply with the updated version of WCAG within 12 months of the published date.

Extension of Remediation Dates
The remediation dates in the ARS may be extended upon mutual agreement by the Parties prior to the initial remediation deadline, subject to the terms of this section. Such extension shall be documented by each Party via email communication. Documentation of such extension by the Parties shall be provided to Fidelity at ProcurementRSO@fmr.com.

Accessibility Representations and Warranties
You represent and warrant that: a) the EIT shall be accessible to, and usable by, individuals with disabilities; b) any authoring functionality offered by the EIT, including user interfaces that support EIT and its creation, publishing and functionality that automatically generates electronic content (such as PDF reports), substantially conforms with WCAG; c) You have an ACR, VPAT or ARS that substantially conforms with WCAG success criteria or you are progressing towards the required remediations set forth within the applicable respective documents outlined above; d) the EIT complies with Applicable Laws relating to accessibility by individuals with disabilities; and e) You shall maintain documentation of the measures taken to ensure EIT meets WCAG, including an ACR or VPAT.

You agree to: (i) upon request, provide Fidelity with any accessibility testing results and written documentation verifying accessibility; and (ii) promptly respond to and resolve accessibility issues that become known to either Party for so long as You provide products and services to Fidelity.

Definitions

• “Accessibility Conformance Report” (“ACR”) is a third-party accessibility document that reports on the conformance of EIT as measured against identified accessibility standards. “Accessibility Failure Severity Rating” refers to the severity of issues in EIT usability and focuses on the: (i) frequency with which the issue occurs; (ii) impact of the issue; and (iii) persistence of the issue. Unless otherwise communicated, Fidelity’s required remediation focuses on Critical and Serious categories of accessibility failures
  • Critical – Users with disabilities cannot use any part of a system or website due to an accessibility failure.
  • Serious – Users with disabilities will find it challenging to use the EIT due to an accessibility failure. Some incorrect results are encountered which could significantly impact proper operation.
  • Moderate - Results in some difficulty for people with disabilities, but generally will not prevent them from accessing fundamental features or content. .
  • Minor - Considered to be a nuisance or an annoyance bug for disabled end users.
• Accessibility Remediation Schedule (‘ARS’)” refers to a documented remediation plan of EIT that fails to conform to the Authoring Tool Accessibility Guidelines (ATAG), Level AA, 2.2 of WCAG. The ARS is made part of the Agreement by and between Fidelity and You.
• "Authoring Tool Accessibility Guidelines (‘ATAG’)” are software and services that authors (web developers, designers, writers, etc.) use to produce web content. ATAG is a part of a series of accessibility guidelines, including WCAG.
• “Concept of Usability” is the extent to which a product can be used by specified users to achieve specified goals effectively, efficiently and with satisfaction in a specified context of use.
• “Electronic Information Technology” or “EIT” means any computer hardware, software, operating systems, internet websites, applications, telecommunication products services, kiosks, video equipment, social media and multimedia products that are used to access, create, convert, disseminate or duplicate data or information owned, operated, or distributed by or on behalf of You now or in the future, including any successor or equivalent URLs, subdomains and all future versions and upgrades, that are accessible by any electronic or broadcast delivery channel, including personal computers, mobile access devices, or other devices now known or subsequently developed.
• “substantially conform with” applies to Your ability to comply with WCAG. If Your EIT fails to comply with WCAG and it is obligated to remediate accessibility issues identified by Fidelity, You are not considered to be substantially conforming with the current published version of WCAG A and AA as interpreted by Fidelity. This interpretation is based on a range of criteria, including but not limited to: issue severity, issue priority, usability, and user flows.
• A “VPAT®” is a Voluntary Product Accessibility Template®, a standardized form developed by the Information Technology Industry Council. The template can be used to produce an Accessibility Conformance Report that shows how EIT meets various accessibility standards. Template areas for WCAG2.2 A and AA and for Section 508 Chapters 3 and 4 are needed to show compliance with the IT Accessibility Standards.

1. Voluntary labor
   The use of forced labor whether in the form of indentured labor, bonded labor, or prison labor by You is prohibited. You shall 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 You shall be written in a language understood by the workers and in a manner that clearly conveys the conditions of employment. You shall comply with all local and national minimum working age laws or regulations and not use child labor. You 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 shall 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. You shall be responsible for the quality, performance, behavior, supervision and protection of Your personnel.
3. Nondiscrimination
   You shall not engage in discrimination on any basis prohibited by applicable/local law.

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.

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 opinion, has engaged in wrongdoing.

If you wish to report questionable behavior or a possible violation of any Policy, 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: