Fidelity Management Trust CompanySM Our Investment Management Business and Policies As of March 31, 2021 This document provides important information for clients investing in commingled pools and separate accounts managed by Fidelity Management Trust Company. The information contained in this document has not been approved or verified by any securities, banking, or regulatory authority. MATERIAL CHANGES Material changes since this document was issued on March 20, 2020 are described below: • Updates have been made to the "Other Financial Industry Activities and Affiliations" section to reflect Digital Brokerage Services LLC as an affiliated broker-dealer. • Updates have been made to describe the types of asset management services and products that Fidelity manages. • Updates have been made to the Transactions with Certain Brokers disclosure in the "Brokerage Practices" section to address exchanges that FMTC or its affiliates have an interest. Table of Contents About Fidelity Management Trust Company……………………………………………………….….. 4 Fees and Compensation……………………………………..………………………………………….. 5 Performance-Based Fees and Side-by-Side Management………………………………………….. 6 Methods of Analysis, Investment Strategies, and Risk of Loss……………………………………… 7 Disciplinary Information……………………………………………………………………………….…. 12 Other Financial Industry Activities and Affiliations……………………………………………...…….. 12 Code of Ethics and Related Policies, Participation or Interest in Client Transactions, and Personal Trading……………………………………………………………………. 17 Brokerage Practices……………………………………………………………………………………… 19 Significant Cash Flow Policy…………………………………………………………………………….. 27 Limitations on Withdrawals for Stable Value Commingled Pools……………………………………. 28 Review of Accounts………………………………………………………………………………………. 28 Client Referrals and Other Compensation……………………………………………………………... 29 Voting Client Securities…………………………………………………………………………………... 29 Financial Information……………………………………………………………………………………... 32 Contact Information………………………………………………………………………………………. 32 About Fidelity Management Trust (as defined below) of such registered advisers. Company Certain of FIL’s subsidiaries and affiliates (including FIC), which are not companies Fidelity Management Trust Company (“FMTC”) is registered with the SEC (each, a “Participating a limited purpose trust company organized and Affiliate”), may have access to information (such operating under the laws of the Commonwealth of as through employees who work for both a FIL Massachusetts. Established in 1981, it is wholly registered adviser and the unregistered FIL owned by FMR LLC, the parent company of the subsidiary or affiliate) concerning securities businesses more commonly known as Fidelity recommendations for the registered adviser’s U.S. Investments (“Fidelity Investments”). FMTC clients. FMTC disclaims that it is a related person provides investment management services to to FIL. commingled pools (referred to as funds or pools) and separate accounts, as well as providing Although FMTC or its affiliates provides advice to various other directed trustee and custodial certain FMTC accounts regarding certain services. This document is intended to provide commodity interests, FMTC is not registered as a information about FMTC’s investment commodity pool operator or commodity trading management business. adviser. FMTC’s institutional clients generally include FMTC and/or its affiliates may provide all defined benefit and defined contribution plans of necessary office facilities and personnel for corporations, not-for-profit entities, tax exempt servicing some of the accounts’ investments, and plans of state or municipal governments, pay the salaries and fees of officers of certain collective investment trusts, and separately accounts and of personnel of certain accounts managed accounts. Many such plans and performing services relating to research, investors are subject to the Employee Retirement statistical, and investment activities. In addition, Income Security Act of 1974, as amended FMTC provides the management and ("ERISA"). FMTC may retain affiliated or non- administrative services necessary for the affiliated entities, including advisers and sub- operation of its accounts. These services may advisers, to provide investment management include facilitating relations with custodians, services or use the services of affiliated personnel transfer and pricing agents, accountants, pursuant to various agreements, including underwriters, and other persons dealing with intercompany agreements. clients; preparing general communications and conducting client relations; maintaining records; FMTC may, to the extent permitted by its developing management and shareholder agreements, delegate investment discretion to a services for each fund, if applicable; and sub-adviser who manages all or a portion of the furnishing reports, evaluations, and analyses. account. If FMTC has engaged a sub-adviser to FMTC or its affiliates may in certain manage a FMTC account, the sub-adviser’s circumstances reimburse costs, commissions, trading and associated policies will apply to that fees, or levies of FMTC’s clients. account, subject to applicable law. FMTC may also use affiliates for other services, including, but From time to time, a manager, analyst, or other not limited to, trading, proxy voting, securities employee of FMTC or its affiliates may express lending, and investment and corporate views regarding a particular company, security, compliance, or utilize the services of certain industry, or market sector. The views expressed personnel of its affiliates as supervised persons of by any such person are the views only of that FMTC under personnel sharing arrangements or individual as of the time expressed and do not other intercompany arrangements. FMTC may necessarily represent the views of FMTC or any also have access to investment research from its other person in their organizations. Any such affiliates and/or the services of personnel of an views are subject to change at any time based on affiliate. FMTC or its affiliates may have access to market or other conditions, and FMTC and its investment research on a substantially delayed affiliates disclaim any responsibility to update basis from various subsidiaries and affiliates of such views. These views may not be relied on as FIL Limited (including Fidelity Investments investment advice and, because investment Canada ULC (“FIC”), which are investment decisions for an account managed by FMTC or its advisers registered with the SEC operating affiliates are based on numerous factors, may not principally in the United Kingdom, Japan, be relied on as an indication of trading intent on Hong Kong, or Participating Affiliates behalf of an account. 4 FMTC or its affiliates generally have authority to Upon request, FMTC may provide pricing determine which securities to purchase or sell, the information to a client about any securities held in total amount of such purchases and sales, and that client’s account that have been subject to a the brokers or dealers through which transactions fair market valuation. However, FMTC does not are effected. However, with respect to each provide pricing services. discretionary account, this authority is subject to certain limits, including applicable investment Collective investment funds managed by FMTC objectives, policies, and restrictions. These may invest any uninvested cash of the fund in a limitations may be based on a variety of factors, registered investment company known as the such as regulatory constraints, as well as policies Fidelity Cash Central Fund (“Cash Central Fund”), imposed by a client or its governing body (e.g., and cash collateral from securities lending board of trustees) and may cause differences in activities may be invested in the Fidelity Securities commission rates. Lending Cash Central Fund, for which affiliates of FMTC act as adviser(s) and service provider(s). With regard to accounts or collective investment The Cash Central Fund and the Fidelity Securities products governed by ERISA, the client is Lending Cash Central Fund (collectively, the responsible for a plan’s compliance with ERISA “Funds”) are investment vehicles created requirements concerning investments in exclusively for cash management purposes of the “employer securities”, “employer real property”, or Fidelity mutual funds and other advisory accounts “qualifying employer real property” as such terms of Fidelity Investments, FMTC, and their affiliates. are defined in Section 407 of ERISA (collectively, The Funds incur certain costs related to their “restricted securities”) and for identifying certain investment activities (such as custodial expenses) financial intermediaries or parties in interest that but do not pay an investment management fee could result in prohibited transactions under from their respective assets. Instead, FMR or an ERISA, including, but not limited to, broker- affiliate pays the investment management fee on dealers affiliated with such plan. The client is behalf of the investing funds. Additional responsible for informing FMTC in writing of any information about the Fidelity Cash Central Fund restrictions on account investments (including or the Fidelity Securities Lending Cash Central identifying such restricted securities or parties in Fund, including the prospectus and annual and interest to the plan) required in order for that plan semi-annual reports, is available upon request. to comply with ERISA. In the absence of such information, FMTC takes no responsibility