Strategic Advisers LLC

Fidelity Go® Form ADV, Part 2A Brochure Strategic Advisers LLC 155 Seaport Boulevard Boston, MA 02210-2698 800.343.3548 Fidelity.com March 30, 2026 This brochure provides information about the qualifications and business practices of Strategic Advisers LLC (“Strategic Advisers”), a Fidelity Investments® company, as well as information about the Fidelity Go® program. Throughout this brochure and related materials, Strategic Advisers refers to itself as a “registered investment adviser” or as being “registered.” These statements do not imply a certain level of skill or training. Please call us at 800.343.3548 with any questions about the contents of this brochure. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Strategic Advisers is available on the SEC’s website at adviserinfo.sec.gov.  S U M M A R Y O F M A T E R I A L C H A N G E S The SEC requires registered investment advisers to provide and deliver an annual summary of material changes to their advisory services program brochure (also referred to as the Form ADV, Part 2A Brochure). The section below highlights only material revisions that have been made to the Fidelity Go® Form ADV, Part 2A Brochure (the “Program Brochure”) from December 5, 2025, through March 30, 2026. Clients and prospective clients can obtain a copy of the Program Brochure, without charge, by calling 800.343.3548, by visiting Fidelity.com/information, or by visiting the SEC’s website at adviserinfo.sec.gov. Capitalized terms are defined in the Program Brochure. Material Changes There have been no material changes since the December 5, 2025, Program Brochure. Other Changes • The chart in “Other Considerations” in “Fees and Compensation” has been updated to provide further and updated information about the programs, accounts, and services available through Strategic Advisers and its affiliates. • “Information about Fidelity and Fidelity Representative Compensation” has been updated to provide further information about how Fidelity and its representatives are compensated. • “Opening and Funding a Program Account” in “Types of Clients” has been updated to clarify that certain product features dependent on reaching an asset threshold will generally be available in a client’s account within five business days of reaching the required asset threshold. • “Additional Information about Strategic Advisers’ Investment Practices” in “Methods of Analysis, Investment Strategies, and Risk of Loss” has been updated to describe Strategic Advisers’ practices with respect to investing Program Accounts in mutual funds. • “Material Risks” in “Methods of Analysis, Investment Strategies, and Risk of Loss” has been updated to provide further information with respect to the efficacy of tax-smart investing techniques for Program clients in lower federal income tax brackets. • Certain minor revisions have been made to the text that describes Strategic Advisers’ affiliates in “Other Financial Industry Activities and Affiliations.” 2  T A B L E O F C O N T E N T S SUMMARY OF MATERIAL CHANGES 2 ADVISORY BUSINESS 4 FEES AND COMPENSATION 8 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT 13 T YPES OF C LIENTS 13 ME THODS OF ANALYSIS, INVESTMEN T STR ATEGIES AND RISK OF LOSS 16 DISC IP L INARY INFOR MATION 25 OTHER FINANCIAL INDUSTRY ACTIV I TIES AND AFFILIATIONS 25 CODE OF E THICS, PARTICIPATION OR I NTER EST IN CLIENT TRANSACTIONS AND PERSON AL TRADI NG 28 BROKERAGE PRACTIC ES 29 REVIEW OF ACCOUNTS 32 CLIENT REFERRAL S AND OTHER COMPEN SATION 33 CUSTODY 35 INVESTMENT DISCRE TION 35 VOTING CLIENT SECURITIES 35 FINANCIAL INFORMATION 36 3  A D V I S O R Y B U S I N E S S Strategic Advisers is a registered investment adviser and an indirect, wholly owned subsidiary of FMR LLC (collectively with Strategic Advisers and its affiliates, “Fidelity Investments,” “Fidelity,” “us,” “our,” or “we”). Strategic Advisers was formed in 1977 and offers a number of investment advisory programs, including the Fidelity Go® program (the “Program”) described in this Program Brochure. Strategic Advisers provides a variety of investment management services, including discretionary portfolio management services and nondiscretionary advisory services to retail and institutional clients, including but not limited to Fidelity affiliates. As of December 31, 2025, Strategic Advisers total assets under management were approximately $1,321,075,214,792 on a discretionary basis and $49,050,110,419 on a nondiscretionary basis. The Program is designed for a client (“client” or “you”) who seeks a digitally provided discretionary investment management experience. To participate in the Program, you must complete an online enrollment process and agree to accept electronic delivery of contracts, disclosure documents, prospectuses, trade confirmations, account statements, and other Program materials and regulatory documents (herein, “Program documents”). You should not participate in the Program if you do not wish to interact digitally. Regular and continuous internet access is required to enroll in the Program and to access all related Program documents. If you are accessing the Program through Fidelity’s mobile application, then you should ensure that you have downloaded the most up-to-date version of the Fidelity mobile application to access the available Program services. You also have an obligation to maintain a current and accurate email address to ensure that you can receive your Program-related communications and/or Program documents, and your participation in a Program can be terminated by us if you request to unenroll from electronic delivery for your Program-related communications and/or Program documents. The Program includes discretionary investment management services made available to clients through the Fidelity Go website and Fidelity’s mobile applications (the “Program Website”). Strategic Advisers applies tax- smart investing techniques to taxable Program Accounts, as discussed in more detail below. Tax-loss harvesting in equity Flex Funds, a component of tax-smart investing techniques, is available to taxable accounts with a balance of at least $25,000. Trading and custody services are included in the Program’s discretionary management services. There is no minimum to open a Fidelity Go Program Account; however, a Program Account will not be invested according to the selected asset allocation strategy until the Program Account has a balance of at least $10. The Program offers nondiscretionary financial planning through the Program Website or via telephone by a team of Fidelity representatives. To be eligible for the nondiscretionary financial planning available through the Program, you must invest and maintain at least $25,000 in at least one Fidelity Go Program Account. Clients who maintain health savings accounts through the Program and clients who are nearing or in retirement will have access to the nondiscretionary financial planning offered in the Program, but they should understand that such financial planning will not address health care spending strategies or retirement income planning. Identification and Selection of an Asset Allocation Strategy As part of the Program’s enrollment process, you will be required to provide us with certain initial information about yourself, including but not limited to your age, goal, initial investment, time horizon, household income, risk tolerance, and, for taxable accounts, marginal federal income tax rate (collectively, “Initial Information”), that we will use to identify a long-term asset allocation strategy for your Program Account. Please note that, if you are converting a Fidelity Brokerage Services LLC (“FBS”) individual retirement account into a Program Account, we will assume a “retirement” goal for your Program Account. You are able to change the goal for your Program Account when filling out the Initial Information. Each asset allocation strategy is composed of Fidelity Flex® mutual funds (“Flex Funds”), as described below, which provide exposure to a combination of stocks, bonds, and short-term investments and is one in a series of asset allocations that range from conservative (lower risk and return potential) to aggressive (higher risk and return potential). You can, and we encourage you to, also provide us with additional information about yourself (including but not limited to your investment experience and knowledge, emergency fund, 4  other assets, and financial situation, collectively, “Additional Information”), which will allow us to know you better. The Initial Information and Additional Information (together, “Profile Information”) help us create your personal profile and will impact the asset allocation strategy that is proposed to you. You can update your Profile Information online anytime, and we encourage you to keep this information current. For taxable Program Accounts, the marginal federal income tax rate you provide will determine which investments we select as part of the fixed income portion of your asset allocation strategy, and help inform how we deploy any additional tax-smart investing techniques available to your Program Accounts. Please note that joint Program Account owners who file their federal income taxes separately may not be subject to the same marginal federal income tax rate, and we will consider only the marginal federal income tax rate that such owners provide. In such a case, the Program Account may not be managed according to both owners’ marginal federal income tax rate. In the event that you do not provide Additional Information, we will propose an asset allocation strategy for your Program Account using your Initial Information along with assumed responses based on information derived from investors in the Program and other Fidelity programs and services (our “profiling assumptions”). A portion of the profiling assumptions for Program Accounts with a retirement goal are based on similarly aged investors in Fidelity programs and services, and a portion of the profiling assumptions for Program Accounts with other goals are based on investors in the Program with a similar investment time horizon. This means that the profiling assumptions will differ depending on the goal of your Program Account. We use a proprietary framework based on aggregate investor data to inform our profiling assumptions. You should understand that if you do not answer certain questions aimed at collecting your Profile Information, including those concerning your emergency fund, financial situation, and investment knowledge/experience, we will assume values for those responses. For example, if you have a Program Account with a retirement goal, our profiling assumptions will generally assume that your emergency fund, investment experience, and investment knowledge increase as you age. It is also important for you to understand that the profiling assumptions are periodically reviewed and updated based on the investor information we have in our database, and such updates can result in changes to the profiling assumptions that are used as part of your Profile Information. We encourage you to provide the Additional Information to ensure that the Program services you receive are based on your particular information rather than our profiling assumptions, and to keep such Additional Information updated as appropriate. As part of the Program enrollment process, you can select the proposed asset allocation strategy or another asset allocation strategy that you believe is appropriate for you, subject to certain constraints and limitations. If you select an asset allocation strategy that differs from the one that we suggest, we will provide discretionary management for your Program Account consistent with your selected asset allocation strategy. You should understand that the performance of a Program Account with a client-selected asset allocation strategy likely will differ, at times significantly, from the performance of a Program Account managed according to the asset allocation strategy we proposed. Unless you are enrolled in Smart Shift, as described below, your Program Account’s asset allocation strategy will not change unless (i) you initiate a change, or (ii) the asset allocation strategy for the account is no longer appropriate based on your Profile Information. The Program offers Smart Shift, an account feature through which we manage your Program Account to an investment time horizon that reflects when you anticipate starting to withdraw from your Program Account. Smart Shift is only available to clients who are invested in the asset allocation strategy that we recommend. Program Accounts managed with Smart Shift are designed to align with our suggested asset allocation based on your Profile Information, and, if Additional Information is not provided, our profiling assumptions. The asset allocation strategy for your Program Account will change over time if Smart Shift is enabled. Clients with a retirement goal who are within three years of when they, or if planning with a partner through the Program, they or their partner, anticipate withdrawing from their Program Account (their “Retirement Year”) must provide an anticipated withdrawal amount as part of their Profile Information for us to manage their account in Smart Shift. You will not be eligible for Smart Shift if you, or if planning with a partner through 5  the Program, you or your partner, are within three years of your Retirement Year and fail to provide your anticipated withdrawal amount. We reserve the right to discontinue your participation in Smart Shift unless and until you provide us with your anticipated withdrawal amount. Smart Shift is not available for clients with a retirement goal once they, or if planning with a partner through the Program, they or their partner, reach their Retirement Year. In addition, information regarding the potential value of a Program Account over time can also be provided to you. Using client-provided inputs and a number of assumptions, we will display information about hypothetical asset projection scenarios and roughly estimate how those scenarios can perform over time. It is important for you to understand that the modeling provided is hypothetical in nature, is provided for illustrative purposes only, does not reflect actual investment results, and does not guarantee future investment outcomes. The information shown or made available to you can vary with each use and over time. Discretionary Investment Management Services Your Program Account, and each asset allocation strategy used in the Program, will be invested in certain Flex Funds that are available only to certain fee-based accounts offered by Fidelity. The Flex Funds are managed by Fidelity Management & Research Company LLC (“FMRCo”) and its affiliates. Unlike many other mutual funds, the Flex Funds do not charge management fees or, with limited exceptions, fund expenses. Instead, compensation for access to the Flex Funds is paid out of the fees charged by certain fee-based accounts offered by Fidelity that include Flex Funds as underlying investments, including the Program. A Program Account will be periodically rebalanced or reallocated to the portfolio identified for your selected asset allocation strategy as further described in the section below entitled “Methods of Analysis, Investment Strategies, and Risk of Loss.” The specific Flex Funds or number of Flex Funds in which a Program Account is invested could change, and the underlying Flex Funds held in a Program Account can differ based on whether a Program Account is a taxable, health savings, or individual retirement account. For additional information about the Flex Funds selected for a Program Account, please see the respective fund’s prospectus. A client can impose reasonable restrictions on the management of any Program Account. You can request a restriction from the list available on the Program Website. All requested investment restrictions are subject to our review and approval. If a restriction is accepted, Program Account assets will be invested in a manner that is appropriate given the restriction. Reasonable restrictions will not apply to the underlying securities or holdings in the Flex Funds purchased in a Program Account. It is important to understand that imposing an investment restriction can delay the start of discretionary management on and can impact the performance of a Program Account, at times significantly, as compared with the performance of a Program Account managed without restrictions, possibly producing lower overall results. Not all requested restrictions will be considered reasonable for each asset allocation strategy, and a previously accepted restriction will be removed if we change your asset allocation strategy to one for which that restriction is not considered reasonable. For Program Accounts that are not enrolled in Smart Shift, any client-imposed restrictions will be removed if the client changes the asset allocation strategy for the Program Account, and the client can subsequently request new investment restrictions for the Program Account on the Program Website. You can reevaluate restrictions at any time. Strategic Advisers uses certain tax-smart investing techniques in taxable Program Accounts. Tax-loss harvesting is available only in taxable Program Accounts that invest and maintain at least $25,000. However, please note that the stated goal that you assign to your Program Account and the asset allocation strategy you select for that Program Account are of primary importance. Accordingly, the application of tax-smart investing techniques to that Program Account is a secondary consideration. You should understand that significant tax consequences can result from investing in a Program Account, even if such a Program Account employs the available tax-smart investing techniques, as such techniques are not Strategic Advisers’ primary focus in managing your Program Account. For additional considerations related to tax-smart investing techniques, including but not limited to tax-loss harvesting, please see the disclosure below under “Methods of Analysis, Investment Strategies, and Risk of Loss.” 6  Responsibility of Clients We rely on client information to provide the services for the Program. As a client, you have a responsibility to regularly review and, should it become inaccurate, update your Profile Information for your Program Account and to maintain a current and accurate email address to receive Program-related communications and Program documents. Your Program Account will continue to be managed on a discretionary basis using your Profile Information, and it is your responsibility to advise us through the Program’s Website if there are any changes to your Profile Information. It is important for you to understand that your Profile Information, which is used to determine an appropriate asset allocation strategy for your Program Account and includes your marginal federal income tax rate for taxable Program Accounts, will not automatically update as a result of any changes you model on your own in any financial planning tool that is made available online, information you input to other Fidelity accounts or investment programs, or pursuant to any changes that you make to recurring contribution amounts unless also reflected in your Profile Information. If you maintain multiple relationships with Fidelity, then you should ensure that your personal, financial, and other important information is independently updated for each respective service or account. Financial Planning Services and Access to a Fidelity Representative In addition to the discretionary investment management services described above, clients who invest and maintain $25,000 or more in at least one Program Account will have access to nondiscretionary financial planning services designed to assist you in evaluating one or more identified goals. As part of the Program enrollment, you will assign a goal for each Program Account you open. Once enrolled, you can use the Program Website to view your Program Accounts and engage with self-guided planning tools and resources. These tools are designed to help you evaluate your ability to meet your identified goals; identify action steps; and select, prepare for, and complete financial planning sessions designed to present strategies to help you evaluate your financial needs (the “Financial Planning Services”). You have access to the Financial Planning Services through the Program Website and via telephone assistance from a team of Fidelity representatives, but the Financial Planning Services do not include in-person or in-branch financial planning services with a Fidelity representative. The team of phone-based Fidelity representatives can help you evaluate your financial goals and objectives, and provide general assistance with products and services provided by Fidelity outside of the Program. We use various financial planning analytics and applications to look at your identified goals, the assets held in your Program Accounts, and any other assets you identify that are held in other Fidelity programs or accounts, or at a third party that you have designated toward a goal (“Other Assets”). We will help you in evaluating your ability to meet your identified goals; however, we are not obligated to provide ongoing financial planning advice, update any analysis provided, or monitor your progress toward a planning or investment goal. Any self-directed modeling, including any what-if or other changes you model on your own in any financial planning tool that is made available to you online, either through the Financial Planning Services or otherwise through Fidelity, will not automatically update your Profile Information or your asset allocation strategy for your Program Accounts. It is important to understand that there can be significant differences between any asset allocation modeling shown in a financial plan and the performance you will experience in a Program Account. The Financial Planning Services do not include initial or ongoing advice regarding specific securities or other investments, any financial analysis provided outside this Program (including prior to enrolling in the Program), or any financial planning that you engage in on your own in a financial planning tool that is made available online. Other than with respect to your Program Accounts, which are managed on a discretionary basis through the Program, whether and how to implement any asset allocation or other recommendations provided as a component of our Financial Planning Services is your responsibility and is separate and distinct from the Financial Planning Services. Specifically, Other Assets are not managed as part of the Program and are subject to separate and distinct terms, conditions, and, as applicable, fees. In addition, if you choose to implement 7  some or all of the asset allocation or other recommendations provided as part of the Financial Planning Services through Fidelity, a Fidelity entity will act as a broker-dealer or investment adviser depending on the products or services selected, and you will be subject to separate, applicable charges, fees, or expenses. Please see the “Guide to Brokerage and Investment Advisory Services at Fidelity Investments” available at Fidelity.com/information or speak with a Fidelity representative for more information. It is important to understand that Fidelity representatives can act in the capacity of a registered representative of FBS, Strategic Advisers’ affiliated broker-dealer. Any financial planning a client receives from a Fidelity representative prior to us accepting your Program Client Agreement is provided by FBS and is not part of the Program services. F E E S A N D C O M P E N S A T I O N Advisory Fees The Program charges an advisory fee based on a Program Account’s average daily asset balance, payable after the end of each quarter. Program Accounts will be charged an advisory fee in accordance with the table below by calculating average daily assets at the end of each month to determine the advisory fee rate to assess for that month, and the advisory fees for each month during a quarter are added together to determine the quarterly advisory fee. If the end of the month falls on a nonbusiness day, the Program Account value on the end of the last business day of the month will be applied to any subsequent nonbusiness days in that month. The Program Advisory Fee paid includes the ongoing discretionary management of a Program Account; the brokerage, clearing, and custody services provided by Strategic Advisers’ affiliates; and, as applicable, the financial planning and Fidelity representative access noted above. Please see the table below for the advisory fee rates for the Program. ADVISORY FEE SCHEDULE FOR PROGRAM ACCOUNTS Average Daily Assets* Advisory Fee Account balances of less than $25,000 No advisory fee Account balances of $25,000 and above 0.35% annually * Average daily assets of the Program Accounts are determined on the last business day of the month and used to calculate the advisory fee rate to assess for that month. The quarterly advisory fee deducted after the end of each quarter from Program Accounts will be the sum of each month’s advisory fee for that quarter, and the advisory fee rate can vary from month to month during a quarter based on the average daily assets determined on the last business day of each month during the quarter. Billing The advisory fee will be deducted from your Program Account on a quarterly basis after the end of each quarter. Program Accounts are not aggregated for billing purposes. Certain assets in your Program Account could be liquidated to pay the advisory fee; this liquidation could generate a taxable gain or loss in a taxable Program Account. Accounts that cross from one advisory fee tier to another advisory fee tier during a billing period or that are funded mid-month will be assessed a pro rata fee for the number of days within the billing period for which the Program Account was funded. For example, if your average Program Account balance does not exceed $25,000 during the months of July and August but does exceed $25,000 for the month of September, you will be assessed the 0.00% advisory fee for the days in July and August and the 0.35% advisory fee for days in September. If you open a Program Account during the month of September and your average daily assets for the days in September that your account was funded exceeded $25,000, then you are assessed a 0.35% advisory fee only for those days in September when your account was funded. It is important that you understand that the 0.35% advisory fee applies to the entirety of your Program Account balance. For example, in the scenario described above, you would not pay an advisory fee for the months of July and August, but the 0.35% advisory fee would be applied to the entirety of your Program Account, not just the amounts of $25,000 and above, for the month of September. 8  Additional Fee Information Your Program Advisory Fee could be reduced by a Credit Amount, as defined below. The Credit Amount is intended to address the conflicts of interest that arise from Program Account investments that generate revenue for Fidelity by reducing the advisory fees paid to Strategic Advisers by the amount of compensation, if any, Strategic Advisers or its affiliates retain that is derived as a direct result of investments imported into Program Accounts. As stated above, your Program Account assets will be invested in Flex Funds and the fee structures of the Flex Funds afford transparency into the total fees you pay. The Flex Funds are not subject to the Credit Amount because Fidelity receives no fees from the Flex Funds for managing or handling the business affairs of the funds and pays the expenses of each fund, with limited exceptions. See “Client Referrals and Other Compensation” below for additional information about the Credit Amount and the sale of transferred securities imported into Program Accounts. All fees are subject to change. Strategic Advisers has the ability to negotiate the advisory fee for certain accounts. Strategic Advisers could also agree to waive fees, in whole or in part, in its sole discretion, including but not limited to (i) in connection with promotional efforts and other programs, including but not limited to situations designed to facilitate transitions between advisory programs, or (ii) for certain current and former employees of Fidelity. This will result in certain clients paying less than the standard fee. In addition, and to the extent applicable, Program Accounts with negotiated or no advisory fees do not receive the Credit Amount; instead, any Credit Amount generated from such Program Accounts will be allocated, pro rata based on assets, among the other open Program Accounts at the time the Credit Amount is applied. Generally, you will not pay any commissions for transactions executed through affiliates of Strategic Advisers, transaction fees, or sales loads on the securities purchased in a Program Account. You are responsible for any fees incurred in connection with wash sales that can occur in a non-Program Account, as well as fees resulting from the sale of any securities used to fund your initial investment in a Program Account (whether such sale is inside or outside a Program Account) and any subsequent withdrawals that you initiate. If a mutual fund purchased for a Program Account incurs a redemption or other administrative fee as a result of not being held for a minimum time period, Fidelity can, in its sole discretion, choose to pay any such redemption fees on behalf of Program clients, but is under no obligation to do so. While you will not generally pay commissions for transactions executed through Strategic Advisers’ affiliates, Strategic Advisers and its affiliates incur costs to make the Flex Funds available to you and incur costs to execute transactions in your Program Account. This is a conflict of interest, as Strategic Advisers and its affiliates are disincentivized to execute transactions in your Program Account. Strategic Advisers mitigates this conflict by conducting investment oversight of its discretionary management, including evaluating its investment performance in Program Accounts. Your Program Advisory Fee does not cover the charges resulting from transactions executed with or through broker-dealers that are not affiliates of Strategic Advisers, including but not limited to commissions, markups and markdowns, transfer taxes, exchange fees, regulatory fees, odd-lot differentials, handling charges, electronic fund and wire transfer fees, or any other charges imposed by law or otherwise agreed to with regard to Program Accounts. These transaction charges will be reflected on trade confirmations and/or Program Account statements to the extent applicable. Strategic Advisers or an affiliate can voluntarily assume the cost of certain commissions for equity transactions executed through broker-dealers unaffiliated with Strategic Advisers; Program clients will not be charged commissions for such transactions. Your Program’s Advisory Fee also does not cover a regulatory charge of a few cents per $1,000 of securities sold. Please note that the amount of this regulatory fee varies over time, and because variations will not be immediately known to Fidelity, the amount will be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, Fidelity will retain the excess. These charges will be reflected on Program Account statements and/or trade confirmations. The advisory fee does not cover costs associated with implementing any suggestions provided as part of our Financial Planning Services, other than the discretionary investment management services provided through the Program. 9  Strategic Advisers’ affiliates sponsor promotional offers that provide clients with the ability to receive cash compensation or a reduced advisory fee for opening and funding certain accounts. Accounts opened through the Program are, from time to time, included in the list of account types and investment solutions eligible for such promotional offers. The Program’s eligibility for such promotional offers creates a conflict of interest, as Strategic Advisers and its affiliates are incentivizing clients to use the Program rather than Strategic Advisers‘ other managed account programs or self-directed investment options available through FBS. Strategic Advisers will also, from time to time, provide cash compensation to Program clients for taking qualifying actions with respect to their Program Account, such as certain interactions with Program features. Any compensation will be deposited into the client’s Program Account, will be subject to the advisory fee applicable to the Program, and may have tax consequences. A promotional offer is not a recommendation to implement any asset allocation strategy or select a particular account type or investment solution. Also, during the time you are enrolled in the Program, you could be eligible to receive certain cash or noncash compensation or services offered by Strategic Advisers’ affiliates based, in whole or in part, on the amount you invest with the Program. It is important to understand that such services are not part of the Program’s services for which the Program Advisory Fee is paid. In addition, while enrolled in the Program, you could receive information about how to access financial wellness and/or professional support resources and services that are offered by entities unaffiliated with Fidelity, some of which pay compensation to Fidelity as a result of your use of such resources or services. Such resources and services are not included as part of the Program’s services, and any applicable costs associated with enrolling in or subscribing to these resources or services would be in addition to the Program Advisory Fee. Other Considerations In evaluating the Program, please consider that Fidelity offers a variety of investment advisory services and brokerage offerings. These offerings are summarized below to assist you in understanding and comparing the services and offerings. For more detailed information regarding an investment advisory service, please review the respective Form ADV, Part 2A Brochure available at Fidelity.com/information or through a Fidelity representative. Refer to the “Guide to Brokerage and Investment Advisory Services at Fidelity Investments” available at Fidelity.com/information for more information regarding our roles and responsibilities when providing brokerage and advisory services. Please note that, other than the self-directed brokerage account offered by FBS, the advisory programs included in the chart below are each offered by Strategic Advisers. PRODUCT DESCRIPTION INVESTMENT GENERAL ELIGIBILITY FEE STRUCTURE Fidelity Go® No account minimum; $10 to invest Less than $25,000 invested: no advisory fee Portfolio based on a client’s investment profile and composed of a mix of zero expense ratio Fidelity mutual funds Asset-based advisory fee: 0.35% annually for $25,000 and above Invests in zero expense ratio Fidelity mutual funds that do not charge management fees (or with limited exceptions, fund expenses) Digitally provided discretionary investment management and planning; access to a team of phone-based representatives for one-on-one financial coaching for clients who maintain $25,000 or more in a Fidelity Go account and tax-loss harvesting for taxable accounts with $25,000 or more Fidelity Managed FidFolios® $5,000 minimum investment Asset-based advisory fee: 0.40% or 0.70% annually Digitally provided discretionary invest- ment man agement of a single asset class (including tax-smart investing techniques) A mix of individual securities, either stocks or American Depositary Receipts, depending on the client’s selected strategy 10  PRODUCT DESCRIPTION INVESTMENT GENERAL ELIGIBILITY FEE STRUCTURE Fidelity® Strategic Disciplines Asset-based advisory fee: 0.20%–0.70% annually for equity strategies and 0.35%– 0.40% annually for fixed income strategies, depending on the amount invested Discretionary investment management of a single asset class (including tax-smart investing techniques); planning and advice is provided through a dedicated representative A mix of individual securities, including but not limited to stocks, bonds, American Depositary Receipts, and/or exchange-traded products and mutual funds, depending on the client’s selected strategy Depending on strategy selected, account investment minimums of $100,000 (equity strategies) and $350,000 (bond strategies), each subject to qualification for support from a dedicated Fidelity representative, which is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) (effective in the second quarter of 2026, the account investment minimum will be $200,000 for taxable bond strategies and $250,000 for municipal bond strategies) Fidelity® Wealth Services $50,000 minimum investment Asset-based advisory fee: 1.10% annually, less a fee credit that reflects compensation retained by Fidelity as a direct result of a client’s investments Fidelity Advisory Services provides customized planning, advice, and discretionary investment management (including tax-smart investing techniques); planning and advice is provided by a centralized team of phone-based representatives A mix of Fidelity and non-Fidelity mutual funds and exchange-traded products invested using a dynamic asset allocation that can respond to changes in the economic business cycle; offered with multiple investment approaches and universes Wealth Management and Private Wealth Management provide customized planning, advice, and discretionary investment management (including tax-smart investing techniques); planning and advice is provided through a dedicated representative supported by a service team A mix of Fidelity and non-Fidelity mutual funds and exchange- traded products and, depending on a client’s preferences and investment profile, individual securities, invested using a dynamic asset allocation that can respond to changes in the economic business cycle; offered with multiple investment approaches and universes Asset-based advisory fee: 0.50%–1.50% annually, depending on the amount invested, less a fee credit that reflects compensation retained by Fidelity as a direct result of a client’s investments (additional fees of up to 0.40% for management of certain individual security strategies can also apply where advisory services are not provided solely by a Strategic Advisers affiliate) $50,000 minimum account investment for Wealth Management and $2 million minimum investment and $10 million investable assets for Private Wealth Management, each subject to qualification for support from a dedicated Fidelity representative, which is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) Fidelity Wealth Advisor Solutions® Investment vehicles will vary by unaffiliated investment advisor and strategy Investment minimums will vary by unaffiliated investment advisor and services provided Advisory fees will vary by unaffiliated investment advisor and services provided A referral network of unaffiliated investment advisors that provide customized wealth management and investment strategies 11  PRODUCT DESCRIPTION INVESTMENT GENERAL ELIGIBILITY FEE STRUCTURE Self-Directed Brokerage Account Transaction fees and investment expenses vary based on investment vehicle selected; no ongoing asset-based advisory fee charged by Strategic Advisers Self-directed trading through FBS, with access to Fidelity’s online tools, planning, and resources, and support provided by brokerage representatives. A dedicated representative is available based on relationship No minimum to open a brokerage account. Qualification for support from a dedicated Fidelity representative is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) Brokerage customers can choose from a wide variety of investments, including mutual funds, exchange-traded funds, stocks, bonds, and insurance and annuity products. Note that certain securities available through Strategic Advisers’ advisory services are not available in self- directed brokerage accounts As described in the chart above, FBS offers self-directed brokerage accounts and financial planning and can provide dedicated support from a Fidelity representative depending on a client’s overall relationship with Fidelity. A client could therefore purchase planning services separately from another firm, plan independently using the tools and analytics that are used to support the Financial Planning Services provided through the Program that are also made available by FBS at Fidelity.com without a fee, or, if the client qualifies for dedicated support from a Fidelity representative, work with the Fidelity representative to receive planning services offered by FBS without a fee. While you can obtain similar products and services from Fidelity or other firms without enrolling in the Program, you would not receive the same discretionary services offered through the Program; the Flex Funds used by the Program would not be generally available for purchase outside of the Program; investments could be subject to sales loads or transaction and redemption charges that are generally waived as part of the Program; and, if you invest and maintain at least $25,000 in at least one Program Account, you would not generally be able to obtain the same combination of investment and financial planning services. The overall cost of purchasing the products and services separately will most likely differ from the Program Advisory Fee. Clients should consider the value of these advisory services when making such comparisons. Information about Fidelity and Fidelity Representative Compensation Fidelity representatives who support the Program are associated with Strategic Advisers and FBS. Fidelity representatives act on behalf of FBS when recommending an advisory program offered by Strategic Advisers. Once a client enrolls in the Program, the Fidelity representative will be providing Strategic Advisers services. Separate and apart from the Program, Fidelity representatives, including those who support the Program, can provide clients with a variety of FBS services, including investment education and advice, financial analyses, planning services, and help with implementing any nondiscretionary recommendations as part of the Financial Planning Services. When providing services for FBS, these Fidelity representatives are acting solely as registered representatives of FBS, and the Program’s fees are not related to those FBS services. Fidelity representatives receive base pay based on their experience and role. In addition to base pay, Fidelity representatives are also eligible to receive either variable compensation or an annual bonus, and certain representatives are also eligible to receive longer-term compensation. Fidelity representatives who receive an annual bonus do not receive compensation based directly on the sale of any product or service, but they do have an indirect financial incentive to recommend products or services that pay more compensation to Fidelity because annual bonus funding is based in part on Fidelity’s financial performance. For Fidelity representatives who receive variable compensation, variable compensation depends on the representative’s role and can be impacted by client loyalty, the amount of assets a client transfers to Fidelity, the amount of assets invested initially and on an ongoing basis, referring potential clients to other Fidelity representatives who enroll the client in a Fidelity investment product or service, and client family members opening Fidelity accounts. Whether and how much each Fidelity representative receives in each component is generally determined based on the representative’s role, responsibilities, performance measures, and their manager’s assessment of the representative’s performance. 12  Fidelity and the Fidelity representatives who support the Program and who are eligible to receive variable compensation receive different amounts of compensation depending on the type of product or service a client selects. Fidelity and those representatives will earn more compensation if a client (i) enrolls in any service level of Fidelity Wealth Services than if a client enrolls in Fidelity Go or Fidelity Managed FidFolios, or (ii) enrolls in the Wealth Management or Private Wealth Management service level of Fidelity Wealth Services than if a client enrolls in the Fidelity Advisory Services service level of Fidelity Wealth Services. Please note that Fidelity representatives do not earn variable compensation with respect to Standalone Planning. The compensation received by Fidelity and those representatives in connection with FBS offerings (e.g., stocks, bonds, ETFs, mutual funds) is typically less than the compensation received in connection with a client choosing to participate in a Fidelity advisory program. Products and services that generally require more time to engage with a client and/or that are more complex provide greater compensation to a representative and Fidelity. This compensation structure creates a financial incentive for Fidelity and its representatives to recommend investments in more complex or time-consuming products and services over others, and to recommend that a client maintain an investment in such products and services over time. Fidelity addresses these conflicts of interest by having processes in place that require our representatives to make recommendations that are in the best interest of clients, paying compensation based on the time and complexity of the relevant product or service, training and supervising our representatives, and disclosing these conflicts of interest to clients so that they can consider the conflicts when making financial decisions. To see specific compensation levels for the managed account programs mentioned above and other products, including an example of compensation that can be earned by Financial Consultants, please see the “Fidelity Investments Compensation Disclosure” document (available at Fidelity.com/information), or contact a Fidelity representative. Clients should read the information contained in the “Fidelity Investments Compensation Disclosure” document carefully, and can ask a representative at any time whether and how they are compensated with respect to a particular product or service and about the financial incentives and conflicts of interest that Fidelity has when making recommendations of products or services. P E R F O R M A N C E - B A S E D F E E S A N D S I D E - B Y - S I D E M A N A G E M E N T Strategic Advisers does not charge performance-based fees in connection with the Program. In addition, Strategic Advisers does not engage in side-by-side management with respect to the strategies employed for the Program. T Y P E S O F C L I E N T S The Program is generally available to individual investors who are U.S. persons (including a U.S. resident alien), typically reside in the United States, and have a valid taxpayer identification number. The Program is not available to foreign investors. You can enroll taxable, health savings, or individual retirement accounts in the Program. You must also have regular internet access and be comfortable with a digital investment experience and online services. All Program-related communications, materials, and Program documents will be delivered electronically. You will be sent an electronic notification regarding the availability of Program documents, and a link or website address where the Program documents can be accessed. It is important to note that if you want to revoke your consent to electronic delivery of Program-related communications and/or Program documents, you will need to terminate your participation in the Program. Opening and Funding a Program Account To enroll in the Program, you must agree to the Program Client Agreement, which details the terms and conditions under which the client appoints Strategic Advisers to provide the Program services. Our advisory relationship with a client begins when we accept the client’s Program Client Agreement. 13  Except with respect to a Program investment proposal, preliminary discussions or recommendations made before we accept your Program Client Agreement are not intended as investment advice provided by Strategic Advisers, including but not limited to any financial planning provided by Fidelity representatives, as described above. The Program Client Agreement requires that you delegate discretionary authority to Strategic Advisers, which includes the authority to determine which funds to purchase or sell and the total amount of such purchases and sales, subject to certain Program and regulatory limitations and Strategic Advisers’ internal policies and procedures. You also acknowledge through the Program Client Agreement that Strategic Advisers may, but is not obligated to, retain one or more sub-advisors with respect to the management of your Program Account. Your Program Client Agreement establishes a brokerage account with FBS. During your participation in the Program, your Program Account will not be available for self-directed brokerage activities. There is no minimum to open a Program Account; however, once you have enrolled in the Program, you will have 90 days to fund your Program Account. You must deposit at least $10 for us to begin managing your account, and you must invest and maintain $25,000 or more in at least one Program Account to be eligible for the Financial Planning Services. Taxable Program Accounts that invest and maintain $25,000 are eligible for tax-loss harvesting. If you have not funded your Program Account within 90 days, we can terminate your participation in the Program. We reserve the right, in our sole discretion, to remove your access to the Financial Planning Services if you do not maintain $25,000 in at least one Program Account and to cease tax-loss harvesting if your taxable Program Account falls below $25,000. In general, your Program Advisory Fees will begin to accrue after a Program Account has been deemed in good order for management purposes. We can, in our sole discretion, change the Program Account opening minimum, the minimum amount at which we will begin managing your account, or the minimum amount at which clients become eligible for the Financial Planning Services at any time. You can fund your Program Account or add further assets to an existing account by depositing cash or securities acceptable to us. A Program Account will be reviewed for investment once we receive all the required information and the funding process, including, if applicable, the settlement of funds used to fund the Program Account, is complete. A Program Account will typically begin trading, and certain features based on assets, such as the Financial Planning Services or tax-loss harvesting, will become available within five business days of initial or subsequent deposits. The Program’s general policy is to invest cash deposits in the core Fidelity money market fund identified as the cash sweep vehicle for your Program Account (“Core Money Market Fund”) as soon as reasonably practicable, then further invest portions of these assets in accordance with your selected asset allocation strategy. Fidelity will determine, in its sole discretion, which securities will be eligible to fund a Program Account. A Fidelity representative can provide information as to whether a specific mutual fund, exchange-traded product (“ETP”), or other security is available to fund a Program Account. As a general matter, securities transferred into a Program Account that are lightly traded; have restrictions on their sale, transfer, or liquidation; or are otherwise difficult to price, sell, transfer, or redeem will be ineligible to fund a Program Account. Transferred securities imported into Program Accounts must be held free and clear of any liens, pledges, or other legal or contractual restrictions. At times, Fidelity will not accept individual securities that are otherwise generally available to fund a Program Account due to internal guidelines or state or federal regulations. We will liquidate transferred securities imported into Program Accounts as soon as reasonably practicable, and the transfer of such securities into a Program Account is deemed to be your directive to Fidelity to sell any such securities upon transfer. We do not consider the potential tax consequences of these sales when following your deemed direction to sell such securities. Any tax-smart investing techniques available to taxable Program Accounts will not be used when liquidating securities transferred into a Program Account. We also reserve the right to transfer an ineligible security back to the account from which you are transferring the assets or to another like-registered account held at Fidelity. Sales of transferred securities will be subject to redemption and other applicable fees, including commissions on sales of securities; however, under certain circumstances, we can voluntarily assume the costs of certain commissions. You could realize a taxable gain or loss when these shares are sold. In addition, when Fidelity Funds are purchased in taxable Program Accounts, you could receive taxable distributions out of earnings that have accrued before purchase (a situation referred to as “buying a dividend”). 14  It is important that you understand that the long-term asset allocation strategy we recommend for your Program Account will not consider funds deposited into your account by Fidelity pursuant to any promotional offers, which are described in more detail in the “Fees and Compensation” section of this Program Brochure. You should add the value of any such funds to the amount you list as your initial investment in the Initial Information if you want us to consider such funds in recommending an asset allocation strategy to you. Additional Deposits Additional deposits can be made to your Program Account at any time, including funding your Program Accounts with transferred securities as described above and acceptable to us. Discretionary management of additional deposits will generally occur as soon as reasonably practicable but could be delayed for various reasons, including time needed to liquidate securities, special handling instructions, or funding your Program Account in accordance with the investment minimum. Depending on the size of the deposit made and the size of the positions held in your Program Account, deposits can remain invested in your Core Money Market Fund until such time as your Program Account is rebalanced. In general, we will begin charging the Program Advisory Fee on additional deposits once assets have been received into the Program Account and have been deemed in good order for management purposes. It is important to understand that additional deposits into a taxable Program Account with assets of $25,000 or more can limit the tax efficiency of the Program Account, as the additional deposits will be used to purchase Flex Funds and such purchases could result in wash sales. For more information on wash sales and the applicability of the wash-sale rule, please see “Investment Universe” and “Material Risks” under “Methods of Analysis, Investment Strategies, and Risk of Loss.” Withdrawals, Account Closure, and Program Termination At any time, you can contact us to request a withdrawal from a Program Account, elect to close one or more of your Program Accounts, or elect to close all Program Accounts and terminate Program enrollment. If you instruct us to terminate your participation in the Program, we will cease managing your Program Account, additional deposits will no longer be accepted into your Program Account, and any Program Account features will be terminated. In addition, Strategic Advisers reserves the right to terminate your participation in the Program (or to limit your rights to access any or all Program Account features, products, or services) for any reason, including but not limited to (i) if you fail to maintain a current, accurate, and valid email address, (ii) if you revoke your consent to electronic delivery of Program-related communications and/or Program documents, (iii) if any authorized person on a Program Account resides outside the United States, (iv) if the balance of your Program Accounts falls below the minimum investment level required for your Program, (v) if opening multiple Program Accounts to avoid paying Program Advisory Fees in accordance with the fee schedule included in this brochure, or (vi) if the Program is deemed no longer appropriate for you. Should either party terminate the investment advisory relationship, the Program Advisory Fee will be prorated from the beginning of the last quarter to the termination date, which is defined as the date when the Program Account is no longer managed by Fidelity on a discretionary basis. You will be required to provide instructions to be used in the event of withdrawals or Program Account closure. You have the option of electing either that assets be liquidated and the proceeds sent to you by check or transferred to a bank account (or other account), or, as permitted, having the assets transferred in-kind to another account. While the timing of trading and settlement can vary, liquidating trades for partial and full withdrawal requests will typically be placed within the next five business days of the request. While such instructions are pending, we could place trading restrictions on the Program Account. It is important to understand that the Flex Funds purchased in a Program Account can only be held in certain Fidelity fee-based accounts. When a Program Account holds Flex Funds, termination from the Program will result in the sale of those securities held in the Program Account unless you transfer the Flex Funds to another Fidelity fee-based account that includes or accepts the Flex Funds held in your Program Account. Strategic 15  Advisers will not transfer the Flex Funds held in your Program Account to another financial institution or to a Fidelity self-directed brokerage account, and any request a client makes to transfer the Flex Funds to such an account will result in our redeeming such funds and transferring the proceeds in cash. Taxable Program Accounts could incur a taxable gain or loss in connection with such sale. If any proceeds remain in a Program Account after you terminate from a Program, the proceeds will be held in the Core Money Market Fund, and we will restrict the account pending your liquidation or transfer instructions. Note that liquidation of assets in taxable accounts could have tax consequences. There can be instances where we need to place a do-not-trade restriction on one or more Program Accounts, including when processing a trade correction, when we need to comply with a court order, or when we need additional Profile Information from a client. For the period when a do-not-trade restriction is in effect, discretionary management of the Program Accounts will be suspended and we will not monitor the Program Accounts for potential purchases and sales of securities, and any deposits made during the do-not-trade period will not be invested until the do-not-trade restriction has been removed. M E T H O D S O F A N A L Y S I S , I N V E S T M E N T S T R A T E G I E S A N D R I S K O F L O S S Investment Approach As discussed above, we use a proprietary algorithm to identify one in a series of long-term asset allocation strategies for your Program Account based on your Profile Information. We have created portfolios of Flex Funds for each asset allocation strategy and invest Program Accounts in alignment with the respective portfolio, subject to reasonable restrictions that you can impose. Each portfolio of Flex Funds provides an exposure to stocks, bonds, and short-term investments, or a combination thereof, depending on the particular Flex Fund, and is one in a series of asset allocations that range from conservative (i.e., a strategy that has a lower allocation to equities and a lower risk and return potential) to aggressive (i.e., a strategy that has a higher allocation to equities and a higher risk and return potential). As described above, you can also provide us with Additional Information about yourself, and providing the Additional Information will allow us to know you better and can impact the proposed asset allocation strategy. Strategic Advisers uses a proprietary framework based on aggregate investor data to inform our profiling assumptions. It is important to understand that the various profiling assumptions we consider will vary over time and based on your goal. We will periodically review and update the profiling assumptions based on the investor information we have in our database, and such updates will result in changes to the profiling assumptions that are used in connection with your Profile Information. Investment Universe The Program is designed to provide investors with a portfolio of Flex Funds. For the equity and certain fixed income portions of a portfolio, Program Account assets will be invested in passively managed Flex Funds that seek to replicate the performance of relevant market indexes. Short-duration nonmunicipal fixed income and all municipal asset portions of a Program Account can be invested in both passively and actively managed Flex Funds. The Flex Funds are managed by affiliates of Strategic Advisers, including FMRCo. For additional information about the Flex Funds selected for your Program Account and the associated risks, please see the respective fund’s prospectus. Program Accounts that have a more conservative asset allocation strategy will typically hold a higher percentage of bond funds than other Program Accounts. The specific mix of Flex Funds chosen will depend on the asset allocation strategy selected for your Program Account, could change over time in light of changes to your personal situation, and could deviate at times from the asset allocation strategy you originally viewed as part of the Program’s online enrollment process. 16  About Tax-Smart Investing Techniques As stated above, Strategic Advisers will use tax-smart investing techniques in taxable Program Accounts. Over the long run, tax-smart investing techniques are intended to contribute to helping clients reach their investing goals. It is important to understand that the Program Account’s goal is of primary importance, and that the application of tax-smart investing techniques is a secondary consideration. Strategic Advisers can implement trades in taxable Program Accounts that trigger significant tax consequences in seeking to manage taxable Program Accounts consistently with long-term strategy investment objectives. The potential federal income tax consequences of holding, buying, and selling securities are considered as part of the investment services for taxable Program Accounts, but we do not consider state or local taxes; foreign taxes, including those applied to dividends and any potential reclaim; federal tax rules applicable to entities; or estate, gift, or generation- skipping transfer taxes. The tax-smart investing techniques Strategic Advisers uses when it makes trading decisions to buy, hold, or sell securities for a client’s taxable Program Account, will vary depending on the asset level in the taxable Program Account and the asset allocation strategy selected. The tax-smart investing techniques referenced throughout this brochure refer to one or more of the following: Ability to harvest tax losses (available only in taxable Program Accounts that invest and maintain $25,000 or more). The Flex Funds can experience price declines, possibly below a client’s adjusted tax basis in the security as determined by the tax basis information on record for the client’s Program Account. In such instances, losses could be realized in the equity Flex Funds in the client’s Program Account for tax purposes. In cases where an equity Flex Fund position is sold to realize a capital loss for tax purposes, the position usually will be replaced with another Flex Fund we believe will maintain comparable market exposure. In harvesting tax losses, Strategic Advisers does not attempt to harvest every potential tax loss that occurs in the client’s taxable Program Account and will consider factors, such as investment risk, available comparable Flex Fund alternatives, and potential wash sales in the Program Account when deciding whether to harvest tax losses. Importantly, Strategic Advisers will only seek to harvest tax losses in the Flex Funds that hold equity securities. Therefore, tax-loss harvesting opportunities become increasingly limited in asset allocation strategies that are more heavily weighted in fixed income Flex Funds. Strategic Advisers considers the potential application of the wash-sale rule when evaluating transactions in a Program Account. Clients should understand, however, that Strategic Advisers does not prevent or avoid wash sales in all cases. The wash-sale rule requires taxpayers to defer losses that would otherwise be realized if the taxpayer acquires a substantially identical investment 30 days before or after the sale. While Strategic Advisers considers whether its trading in a taxable Program Account may trigger the wash-sale rule, we will nevertheless engage in transactions that are potentially subject to the wash-sale rule if we determine that such transactions are consistent with the asset allocation strategy. Strategic Advisers will monitor for wash sales within a taxable Program Account. However, the wash-sale rule not only applies to investment transactions occurring in a taxable Program Account, but also to transactions in other accounts held by the client, the client’s spouse, and certain entities controlled by the client and/or spouse. With respect to the Flex Funds, Strategic Advisers will only monitor for wash sales in the Program Account in which it is harvesting a potential tax loss; it will not monitor your other Program Accounts or other accounts within or outside of Fidelity to ensure that purchases in those Program Accounts do not trigger a wash sale. If the client and/or their spouse maintain more than one taxable Program Account, Strategic Advisers will employ the tax-smart investing techniques in each Program Account but will not monitor for wash sales across those taxable Program Accounts. The wash-sale rule is complex, and while Strategic Advisers seeks to monitor wash sales in a taxable Program Account, you are ultimately responsible for determining whether the wash-sale rule applies to any particular transaction in your Program Account and in any other investment accounts. You should consult a tax advisor with respect to the wash-sale rule based on your individual circumstances. Opportunities to avoid and/or postpone capital gain realizations. If there are specific lots of Flex Funds in a Program Account—a block of Flex Fund shares bought at a particular time at a particular price—lots are reviewed and the potential federal income tax burden associated with selling that lot is weighted against the potential investment merits of the sale, such as performance potential, added diversification, and support 17  of risk-management strategies. Once Strategic Advisers decides to sell an eligible Flex Fund position, it will attempt to sell the lot(s) that will generate the lowest overall federal income tax burden (or generate a loss for tax purposes) using the tax basis and holding period information on record, with a preference for long-term capital gains over short-term capital gains. Additional Information about Strategic Advisers’ Investment Practices Strategic Advisers generally uses both fundamental and quantitative investment strategies to manage Program Accounts. This involves both evaluating characteristics such as sector weightings, duration, valuation, and market capitalization, as well as focusing on key economic indicators and trends. When determining how to allocate assets among underlying mutual funds, Strategic Advisers considers a variety of objective and subjective factors, including but not limited to proprietary fundamental and quantitative fund research, a manager’s experience and investment style, fund availability, current public information about a fund, performance history, asset size, and portfolio turnover—and overall fit within Program Accounts. Strategic Advisers’ investment professionals will obtain and use information from various sources to assist in making allocation decisions among asset classes as well as decisions regarding the purchase and sale of specific mutual funds. Sources of information used include publicly available information and performance data on mutual funds, individual securities, equity markets, fixed income markets, international markets, and broad-based economic indicators. Strategic Advisers will use both primary sources (e.g., talking directly with managers) and secondary sources (reports prepared by fund companies and other sources that provide data on specific fund investment strategies, portfolio management teams, fund positioning, portfolio risk characteristics, performance attribution, and historical fund returns) as inputs into its investment process. However, as described earlier in this brochure, Program Account assets will be invested in certain Flex Funds. Strategic Advisers does not seek access to material nonpublic information on any investment used by the Program. With respect to Fidelity Funds used by the Program, the investment team at Strategic Advisers that manages Program Accounts does not have access to material nonpublic information of the Fidelity Funds. If, based on the information you provide, Strategic Advisers determines that your Program Account requires modification to its asset allocation strategy, Strategic Advisers will generally make such changes as soon as reasonably possible, even if such changes trigger additional trading or, in the case of taxable accounts, significant tax consequences. Strategic Advisers has internal limits and thresholds on how much it will invest Program Accounts in a mutual fund or ETP, and such limits and thresholds typically apply in the aggregate across all client accounts. Strategic Advisers can also consult fund managers to understand the manager’s guidelines or policies, if any, concerning fund share ownership limits. From time to time, Strategic Advisers and/or its affiliates can determine that, as a result of regulatory requirements that apply to Strategic Advisers and/or its affiliates due to investments in a particular country or in an issuer operating in a particular regulated industry, investments in the securities of issuers domiciled or listed on trading markets in that country or operating in that regulated industry above certain thresholds are impractical or undesirable. The foregoing limits and thresholds could apply at the Program Account level or in the aggregate across all accounts (or certain subsets of accounts) managed, sponsored, or owned by, or otherwise attributable to, Strategic Advisers and its affiliates. For investment risk management and other purposes, Strategic Advisers and its affiliates also generally apply internal aggregate limits on the amount of a particular issuer’s securities owned by all such accounts, including funds managed by Strategic Advisers and its affiliates. In such instances, investment flexibility will be restricted, and Strategic Advisers could limit or exclude a client’s investment in a particular issuer, which can also include investment in related derivative instruments. Material Risks Risks Associated with Financial Planning. The projections and other analyses presented to a client in the course of providing the Financial Planning Services are not guarantees. In particular, projections are hypothetical in nature; are for illustrative purposes only; do not reflect actual investment, tax, or other 18  planning results; and are not guarantees of future outcomes. Any modeling results shown will vary with each use and over time. In addition, our assumptions and methodologies used in financial planning are adjusted from time to time, which can have an impact on the results obtained. The financial planning analyses provided through the Program are based on the information provided by clients and certain static assumptions—for example, fixed return rates, fixed life expectancies, and fixed rates of income or cash flow. In reality, these variables will not be static—market fluctuation will affect overall asset performance, and uncertain life expectancy could cause clients to outlive their resources or fail to accumulate necessary resources. In addition, financial planning analyses include probabilistic modeling, whereby the probability of success varies based on differing assumptions and on changing circumstances and market information. The Financial Planning Services can include asset allocation modeling to help a client evaluate their ability to meet identified goals; however, there can be significant differences between any asset allocation modeling shown to a client and the performance a client will actually experience for their Program Accounts. Asset allocation modeling is performed at the asset class level, assumes broad diversification within each asset class, and is not designed to predict the future performance of any particular security or investment product, and results will vary with each use and over time. In addition, the financial planning analyses do not model the individual return characteristics of every security or investment a client owns, and, as a result, the modeling process is subject to significant variability based on the differences in performance between the securities actually owned by a client and the capital market assumptions used in the modeling process. To the extent that the characteristics of a client’s assets vary significantly from those of the broadly diversified asset class assumptions used, actual performance can deviate significantly from the projections provided as a component of our financial planning services. If an asset allocation recommendation with respect to a particular goal is provided as part of our Financial Planning Services, it can differ from the asset allocation strategy identified for a Program Account associated with that goal. Unless otherwise indicated, the financial planning analysis assumes that the asset allocation of all the accounts associated with a goal, when aggregated, will generally reflect the asset allocation recommended with respect to the goal. Clients remain responsible for the asset allocation of any Other Assets associated with a goal. If the aggregated asset allocation for all of a client’s accounts associated with a goal does not match the goal asset allocation recommended for that goal, the differential can have a significant impact on the outcome of our financial planning analyses. As part of the Financial Planning Services, we can identify certain account types or account structures that are generally designed to help investors reach their goals, including the use of tax-deferred or tax-free retirement, insurance, and educational savings accounts. There is no guarantee that a client’s use of these account structures will be beneficial in helping the client reach their goals. In addition, the legal and tax treatment of these types of accounts could change in the future, leading to unexpected consequences for any such accounts, and we are under no obligation to update you about potential changes in the tax law or the tax treatment of any account. Any financial planning analysis services made available to clients will provide more specific details about the risks and limitations associated with that analysis. Fidelity does not provide tax, accounting, or legal advice. Accordingly, any resource or information presented to clients in conjunction with the Program about tax considerations affecting financial transactions or estate arrangements is provided for informational purposes. Clients should consult their tax and legal advisors regarding their particular circumstances. Risks Associated with Investment Strategies. In general, all the portfolios managed by Strategic Advisers in the Program are subject to the list of investment risks discussed below. However, investment strategies that have higher concentrations of equity will have greater exposure to the risks associated with equity investments, such as stock market volatility and foreign exposure. On the other hand, investment strategies that have a higher exposure to fixed income will have greater exposure to the risks associated with those products, such as credit risk and bond investment risk. 19  The discretionary investment management strategies implemented for clients in the Program, including conservative investments, involve risk of loss. Investments in a Program Account are not bank deposits and are not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed, and the value of your assets will fluctuate due to market conditions and other factors. You could lose money by investing in mutual funds. You could lose money by investing in a Program Account. Many factors affect each investment’s or Program Account’s performance and potential for loss. Strategies that pursue investments in equities will be subject to stock market volatility, and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Strategies that pursue fixed income investments (such as bond or money market funds) will see values fluctuate in response to changes in interest rates, inflation, and prepayment risks, as well as default risks for both issuers and counterparties; changing interest rates, including rates that fall below zero, can have unpredictable effects on markets and can result in heightened market volatility. Developments that disrupt global economies and financial markets, such as wars, acts of terrorism, the spread of infectious illness or other public health issues, recessions, or other events, can magnify factors that affect performance. These strategies are also affected by impacts to the individual issuers, such as changes in an issuer’s credit quality, or changes in tax, regulatory, market, or economic developments. In addition, investments in certain bond structures are less liquid than other investments and therefore are more difficult to trade effectively. Municipal bond funds carry additional risks, which are discussed below. Nearly all investments or accounts are subject to volatility in non-U.S. markets, through either direct exposure or indirect effects in U.S. markets from events abroad. Those investments and accounts that are exposed to emerging markets are potentially subject to heightened volatility from greater social, economic, regulatory, and political uncertainties, as the extent of economic development, political stability, market depth, infrastructure, capitalization, and regulatory oversight can be less than in more developed markets. It is important to understand that a Program Account’s actual asset allocation can deviate from the identified asset allocation strategy for reasons that include market movement and investment decisions to overweight or underweight certain asset classes to seek to increase potential returns or reduce risks. If you have selected an asset allocation strategy for your Program Account that differs from the allocation proposed, the performance of your Program Account could differ, at times significantly, from the performance of an account managed according to the asset allocation strategy originally proposed to you. For more details about the risks associated with discretionary investment management strategies implemented for clients in the Program, please see the Strategic Advisers Form ADV, Part 2A Brochure included in your Program materials. In addition to the risks identified above, a summary of additional risks follows: Investing in Mutual Funds. Your Program Account bears all the risks of the investment strategies employed by the mutual funds held in your Program Account, including the risk that a mutual fund will not meet its investment objectives. For the specific risks associated with a mutual fund, please see its prospectus. Money Market Funds. Cash balances in Program Accounts will be invested in the Core Money Market Fund. You could lose money by investing in a money market fund. Although a money market fund seeks to preserve the value of a client’s investment at $1.00 per share, it cannot guarantee it will do so. An investment in a money market fund is not a bank account and is not insured or guaranteed by the FDIC or any other government agency. Fidelity, the sponsor of Fidelity’s money market funds, is not required to reimburse money market funds for losses, and a client should not expect that Fidelity will provide financial support to a Fidelity money market fund at any time, including during periods of market stress. Fidelity’s government and U.S. Treasury money market funds will not impose a fee upon the sale of a client’s shares. Quantitative Investing. Funds or securities selected using quantitative analysis can perform differently from the market as a whole as a result of the factors used in the analysis, the weight placed on each factor, changes 20  to the factors’ behavior over time, market volatility, or the quantitative model’s assumption about market behavior. In addition, Strategic Advisers’ quantitative investment strategies rely on algorithmic processes and therefore are subject to the risks described below under the heading “Operational Risks.” Foreign Exposure. Investing in foreign securities and securities of U.S. entities with substantial foreign operations are subject to interest rate, currency exchange rate, economic, tax, operational, regulatory, and political risks, all of which are likely to be greater in emerging markets. These risks are particularly significant for funds that focus on a single country or region or emerging markets. Foreign markets can be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile. Foreign markets can also offer less protection to investors than U.S. markets. For example, foreign issuers are generally not bound by uniform accounting, auditing, and financial reporting requirements and standards of practice comparable to those applicable to U.S. issuers. Adequate public information on foreign issuers might not be available, and it could be difficult to secure dividends and information regarding corporate actions on a timely basis. Regulatory enforcement can be influenced by economic or political concerns, and investors could have difficulty enforcing their legal rights in foreign countries. Furthermore, investments in securities of foreign entities can result in clients owning an interest in a passive foreign investment company (“PFIC”). Clients holding an interest in a PFIC could be subject to additional tax liabilities and filing requirements as a result of such investments. The rules regarding investments in PFICs are complex, and clients are urged to consult their tax advisors. Derivatives. Certain funds used by Strategic Advisers, including the Flex Funds, contain derivatives. Generally speaking, a derivative is a financial contract whose value is based on the value of a financial asset (such as a stock, bond, or currency), a physical asset (such as gold, oil, or wheat), or a market index (such as the S&P 500® Index). Investments in derivatives subject these funds to risks different from, and possibly greater than, those of the underlying securities, assets, or market indexes. Some forms of derivatives, such as exchange- traded futures and options on securities, commodities, or indexes, have been trading on regulated exchanges for decades. These types of derivatives are standardized contracts that can easily be bought and/or sold, and whose market values are determined and published daily. Nonstandardized derivatives (such as swap agreements), on the other hand, tend to be more specialized or complex and can be more difficult to value. Derivatives could involve leverage because they can provide investment exposure in an amount exceeding the initial investment. As a result, the use of derivatives can cause these funds to be more volatile, because leverage tends to exaggerate the effect of any increase or decrease in the value of a fund’s portfolio securities. Growth Investing. Growth stocks can react differently to issuer, political, market, and economic developments from the market as a whole and other types of stocks. Growth stocks tend to be more expensive relative to their earnings or assets compared with other types of stocks. As a result, growth stocks tend to be sensitive to changes in their earnings and more volatile than other types of stocks. Value Investing. Value stocks can react differently to issuer, political, market, and economic developments from the market as a whole and other types of stocks. Value stocks tend to be inexpensive relative to their earnings or assets compared with other types of stocks. However, value stocks can continue to be inexpensive for long periods of time and as a result never realize their full expected value. Stock Investments. Stock markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Different parts of the market can react differently to these developments. Value and growth stocks can perform differently from other types of stocks. Growth stocks can be more volatile. Value stocks can continue to be undervalued by the market for long periods of time. In addition, stock investments are subject to risk related to market capitalization as well as company- specific risk. Bond Investments. In general, the bond market is volatile, and fixed income securities carry interest rate risk. As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities. During periods of very low or negative interest rates, we could be unable to maintain positive returns on bond investments. Very low or negative interest rates can magnify interest rate risk for 21  the markets as a whole and for individual bond investments. Changing interest rates, including rates that fall below zero, can also have unpredictable effects on markets and can result in heightened market volatility. The ability of an issuer of a bond to repay principal prior to a security’s maturity can cause greater price volatility, and if a bond is prepaid, a bond fund might have to invest the proceeds in securities with lower yields. Fixed income securities also carry inflation risk, as well as credit and default risks for both issuers and counterparties. The interest payments of inflation-protected bonds are variable and usually rise with inflation and fall with deflation. Unlike individual bonds, most bond funds do not have a maturity date, so holding them until maturity to avoid losses caused by price volatility is not possible. In addition, investments in certain bond structures are less liquid than other investments and therefore more difficult to trade effectively. Credit Risk. Changes in the financial condition of an issuer or counterparty, and changes in specific economic or political conditions that affect a particular type of security or issuer, can increase the risk of default by an issuer or counterparty, which can affect a security’s or instrument’s credit quality or value. Lower-quality debt securities and certain types of other securities involve greater risk of default or price changes due to changes in the credit quality of the issuer. Municipal Bonds and Municipal Bond Funds. The municipal market can be significantly affected by adverse tax, legislative, or political changes, and by the financial condition of the issuers of municipal securities. Municipal bond funds normally seek to earn income and pay dividends that are expected to be exempt from federal income tax. If a fund investor is a resident in the state of issuance of the bonds held by the fund, interest dividends could also be exempt from state and local income taxes. Income exempt from regular federal income tax (including distributions from municipal and money market funds) could be subject to state, local, or federal alternative minimum tax. Certain funds normally seek to invest only in municipal securities generating income exempt from both federal income taxes and the federal alternative minimum tax; however, outcomes cannot be guaranteed, and the funds sometimes generate income subject to these taxes. For federal tax purposes, a fund’s distribution of gains attributable to a fund’s sale of municipal or other bonds is generally taxable as either ordinary income or long-term capital gains. Tax code changes could impact the municipal bond market. Tax laws are subject to change, and the preferential tax treatment of municipal bond interest income could be removed or phased out for investors at certain income levels. Because many municipal bonds are issued to finance similar projects, especially those relating to education, health care, transportation, and utilities, conditions in those sectors can affect the overall municipal market. Budgetary constraints of local, state, and federal governments on which the issuers are relying for funding can also impact municipal bonds. In addition, changes in the financial condition of an individual municipal insurer can affect the overall municipal market, and market conditions can directly impact the liquidity and valuation of municipal bonds. Risks and Limitations Associated with Tax-Smart Investing Techniques. For taxable Program Accounts utilizing tax-smart investing techniques, you should understand that there are risks and limitations associated with the use of such techniques, and these limitations can result in tax-inefficient trades. Strategic Advisers believes appropriate asset allocation and diversification are of primary importance, and we will make changes to a Program Account’s asset allocation even if such changes trigger significant tax consequences, including but not limited to wash sales or the realization of short- and/or long-term capital gains. You should consult a tax and/or legal advisor prior to enrolling in a Program Account that will use tax-smart investing techniques as well as on an ongoing basis to determine whether the wash-sale rule or other special tax rules could apply to your tax situation, and to determine the efficacy of the tax-smart investing techniques to your current and future tax situation. Strategic Advisers relies on information a client provides in applying tax-smart investing techniques and does not offer tax advice. Strategic Advisers manages for federal income taxes in deploying tax-smart investing techniques but does not manage in consideration of state or local taxes; foreign taxes, including those applied to dividends and any potential reclaim; federal tax rules applicable to entities; or estate, gift, or generation-skipping transfer taxes. In harvesting tax losses, Strategic Advisers does not attempt to harvest every potential tax loss that occurs in a taxable Program Account. Importantly, Strategic Advisers does not harvest tax losses in Flex Funds that invest in fixed income securities. Therefore, tax-loss harvesting opportunities become more limited in asset allocation strategies that invest more heavily in Flex Funds that 22  invest in fixed income securities (e.g., a 50/50 equity to fixed income asset allocation strategies will have less opportunities to harvest tax losses than a 85/15 equity to fixed income asset allocation strategy). You should also be aware that, in cases where a Flex Fund is sold to realize a capital loss for tax purposes, Strategic Advisers can replace that position with one or a combination of Flex Funds designed to provide comparable market exposure, and it is important to understand that in a given year, due to investment decisions or market conditions, you could receive varying levels of taxable distributions within a Program Account. In general, Strategic Advisers will not sell a Flex Fund merely to avoid a taxable fund distribution but, in fact, looks at the overall portfolio to determine the most appropriate action. A Program Account that seeks to harvest tax losses will generally trade more frequently than other Program Accounts. There are implicit trading opportunity costs associated with the additional turnover, which can affect the returns of a client’s Program Account. It is important to note that the performance of any replacement investments will not be the same as that of the investment sold, and any replacement investments can perform worse than the investment that was sold. In addition, any tax-related benefits resulting from tax-smart investing techniques can be offset or even outweighed by investment losses and/or missed gains (realized and unrealized). Furthermore, there are not clear guidelines on what constitutes a “substantially identical” security for purposes of the wash-sale rule. As such, there can be no guarantee that the Flex Funds Strategic Advisers selects as a replacement for a Flex Fund sold in a client’s Program Account will not be deemed substantially identical for purposes of the wash- sale rule. Although the tax-smart investing techniques seek to enhance after-tax returns, they may not consider all the tax rules, regulations, and limitations applicable to your particular facts and circumstances, which, in certain circumstances, will reduce the effectiveness of tax-smart investing techniques. You should understand that the benefits derived from any tax-smart investing techniques will likely be greater for clients in higher tax brackets. Since the value of offsetting capital gains or ordinary income is directly tied to your applicable federal capital gains and ordinary income tax rates, clients in lower federal capital gains and ordinary income tax rates experience reduced benefits relative to those in higher federal capital gains and ordinary income tax rates. Legislative and Regulatory Risk. Investments in your Program Account could be adversely affected by new (or revised) laws or regulations. Changes to laws or regulations could impact the securities markets as a whole, specific industries, or individual issuers of securities. Generally, the impact of these changes will not be fully known for some time. Investment Research Risks and Limitations. The investment research process employed by Strategic Advisers includes gathering, cleaning, culling, and analyzing large amounts of data from external public sources and/ or third-party data providers, including, in some instances, through the use of generative artificial intelligence (“AI”) and large language models (“LLM”). It is not possible or practicable, however, to factor all relevant, available data into economic forecasts or trading decisions. In addition, due to the automated nature of this data gathering and the fact that much of this data comes from third-party sources, it is inevitable that not all desired or relevant data will be available to, or processed by, Strategic Advisers at all times. Clients should be aware that there is no guarantee that the data used in generating forecasts or making trading decisions will be the most accurate data available or even free of errors. Furthermore, the use of AI and LLMs may require training of the models to be used in the research process and proper engagement by analysts in order to yield the desired outcome. There can be no guarantee that LLMs can be trained to address all scenarios or that they will provide complete and accurate responses in all situations. AI and LLMs are subject to various risks, including (i) the data used to train LLMs suffers inaccuracies, biases, or flaws that may cause the AI model to respond other than as intended; (ii) weak controls in the development and use of AI allow it to be deployed for use cases for which it was not intended; and (iii) the AI may provide inaccurate or fabricated responses to queries it is unable to process. Fidelity has adopted a Generative AI policy and governance framework so that the use of AI and LLMs is targeted and limited, and that AI and LLMs are trained using known and appropriate data sources and are subject to controls and oversight, which helps ensure that the use of AI and LLMs is but one input into the research process. Clients should assume that the foregoing limitation and risks associated with gathering, cleaning, culling, and analysis of large amounts of data from third-party, other external sources, and the use of AI and LLMs, are an inherent part of investing. 23  There may also be incidents where data fails to load or internal systems fail to retrieve or capture the data, for example, because of changes in the vendor’s or our system configurations due to upgrades, enhancements, maintenance or errors, or that LLMs provide incorrect information in response to certain prompts. Clients should assume that these data errors, like other system implementation errors, and their ensuing risks and impact are an inherent part of investing. Accordingly, unless otherwise required to do so, Strategic Advisers does not expect to disclose discovered data errors to clients. Cybersecurity Risks. With the increased use of technologies to conduct business, Strategic Advisers and its affiliates are susceptible to operational, information security, and related risks. These risks could include events that are wholly or partially beyond our control and may have a negative effect on our ability to conduct business activities. We believe that we have taken reasonable steps to mitigate these risks, but do not believe that we can eliminate them altogether. In general, cyber incidents can result from deliberate attacks or unintentional events that can arise from external or internal sources. Cyberattacks include but are not limited to gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software coding) for purposes of misappropriating assets or sensitive information; corrupting data, equipment, or systems; and causing operational disruption. Cyberattacks can also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). Cyber incidents affecting Strategic Advisers, its affiliates, or any other service providers (including but not limited to accountants, custodians, transfer agents, and financial intermediaries used by Fidelity or by an issuer of securities) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, interference with the ability to calculate asset prices, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities in which an account invests, counterparties with which an account engages in transactions, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. Operational Risks. Operational risks can include risk of loss arising from failures in internal processes, people, or systems, such as routine processing incidents or major systems failures, or from external events, such as exchange outages. In addition, algorithms are used in providing the Program services and contribute to operational risks. For example, algorithms are used as part of the process whereby Strategic Advisers recommends an appropriate asset allocation that corresponds to a level of risk consistent with a client’s Profile Information. In providing Financial Planning Services, algorithms are also used in analyzing the potential for success of a client’s financial plan. Strategic Advisers uses algorithms in support of its discretionary portfolio management process. There is a risk that the data input into the algorithms could have errors, omissions, or imperfections, or that the algorithms do not operate as intended (generally referred to as “processing incidents”). Any decisions made in reliance on incorrect data or algorithms that do not operate as intended can expose Program Accounts to potential risks. Issues in the algorithm are often extremely difficult to detect and could go undetected for long periods of time or never be detected. These risks are mitigated by testing and human oversight of the algorithms and their output. We believe that the oversight and testing performed on our algorithms and their output will enable us to identify and address issues appropriately. However, there is no assurance that the algorithms will always work as intended. In general, we will not assess each Program Account individually, nor will we override the outcome of the algorithm with respect to any particular Program Account. Not all processing incidents arising from operational failures, including those resulting from the mistakes of third parties, will be compensable by Strategic Advisers to clients. Strategic Advisers maintains policies and procedures that address the identification and resolution of processing incidents, consistent with applicable standards of care, to ensure that clients are treated fairly when a processing incident has been detected. The determination of whether, and how, to address a processing incident is made by Strategic Advisers or its affiliates, in their sole discretion. 24  Processing incidents will be reviewed to determine whether there was a financial impact on a client’s Program Account based on, among other things, the relevant investment strategy, and to evaluate the materiality of the impact. If we determine that a material financial impact has occurred, we will make an appropriate correction or otherwise reimburse the Program Account in an amount Strategic Advisers or its affiliates determine is appropriate based on all relevant circumstances. Typically, processing incidents that result in a financial impact of less than $10 per Program Account are not considered material. Other examples of impact that could affect the performance of a Program Account but would likely not be material include impacts arising from computer, communications, data processing, network, cloud computing, backup, business continuity or other operating, information, or technology systems, including those we outsource to other providers, failing to operate as planned or becoming disabled, overloaded, or damaged as a result of a number of factors. These factors could include events that are wholly or partially beyond our control and could have a negative impact on our ability to conduct business activities. Though losses arising from operating, information, or technology systems failures could adversely affect the performance of a Program Account, such losses would likely not be reimbursable under Strategic Advisers’ policies and procedures. Past performance is not a guarantee of future returns. Investing in securities and other investments involves a risk of loss that a client should understand and be willing to bear. D I S C I P L I N A R Y I N F O R M A T I O N There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Strategic Advisers’ advisory business or the integrity of its management personnel. O T H E R F I N A N C I A L I N D U S T R Y A C T I V I T I E S A N D A F F I L I A T I O N S Strategic Advisers is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is a wholly owned subsidiary of FMR LLC. FMR LLC is a Delaware limited liability company that, together with its affiliates and subsidiaries, is generally known to the public as Fidelity Investments or Fidelity. Various direct or indirect subsidiaries of FMR LLC are engaged in investment advisory, brokerage, banking, or insurance businesses. From time to time, Strategic Advisers and its clients will have material business relationships with any of the subsidiaries and affiliates of FMR LLC. In addition, the principal officers of Strategic Advisers serve as officers and/or employees of affiliated companies that are engaged in various aspects of the financial services industry. Strategic Advisers is not registered as a broker-dealer, futures commission merchant, or commodity trading advisor, nor does it have an application pending to register as such. Strategic Advisers is registered with the U.S. Commodity Futures Trading Commission (“CFTC”) under the Commodity Exchange Act of 1936, as amended (“CEA”), as a commodity pool operator (“CPO”) and is a member of the National Futures Association (“NFA”). Certain personnel of Strategic Advisers, FBS, and National Financial Services (“NFS”) share premises and have common supervision. In addition, certain management persons of Strategic Advisers are registered representatives of FBS, a Strategic Advisers affiliate and a registered broker-dealer. Strategic Advisers has, and its clients could have, a material relationship with the following affiliated companies: Investment Companies and Investment Advisers • Fidelity Management & Research Company LLC (“FMRCo”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Investment Advisers Act of 1940 (“Advisers Act”). FMRCo provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FMRCo acts as sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients and provides model portfolio recommendations and environmental filtering services to Strategic Advisers in connection with Strategic 25  Advisers’ provision of discretionary portfolio management to certain clients. Strategic Advisers pays FMRCo an administrative fee for handling the business affairs of the registered investment companies advised by Strategic Advisers, and Strategic Advisers compensates FMRCo for making certain mutual funds available to managed account programs offered by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FMRCo. • Fidelity Institutional Wealth Adviser LLC (“FIWA”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FIWA provides nondiscretionary investment management services and sponsors the Fidelity Managed Account Xchange® and Fidelity Managed Account Xchange programs (turnkey asset management programs made available to financial intermediaries). Strategic Advisers provides model portfolio services to FIWA in connection with FIWA’s services to its institutional and intermediary clients, and FIWA compensates Strategic Advisers for such services. In addition, Strategic Advisers shares employees from time to time with FIWA. • FIAM LLC (“FIAM”), a wholly owned subsidiary of FIAM Holdings LLC, which in turn is wholly owned by FMR LLC, is a registered investment adviser under the Advisers Act and is registered with the Central Bank of Ireland. FIAM provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. Strategic Advisers has sub-advisory agreements with FIAM for certain registered investment companies advised by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FIAM. • FMR Investment Management (UK) Limited (“FMR UK”), an indirect, wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act, has been authorized by the U.K. Financial Conduct Authority to provide investment advisory and portfolio management services, and is registered with the Central Bank of Ireland. FMR UK provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR UK for certain registered investment companies advised by Strategic Advisers. • Fidelity Management & Research (Japan) Limited (“FMR Japan”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Japan Financial Services Agency (Kanto Local Finance Bureau) to provide investment advisory and discretionary investment management services. FMR Japan provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Japan for certain registered investment companies advised by Strategic Advisers. • Fidelity Management & Research (Hong Kong) Limited (“FMR Hong Kong”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Hong Kong Securities & Futures Commission to advise on securities, deal in futures contracts, provide asset management services, and conduct trading services. FMR Hong Kong provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Hong Kong for certain registered investment companies advised by Strategic Advisers. • Fidelity Diversifying Solutions LLC (“FDS”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FDS is registered with the CFTC under the CEA as a CPO and as a commodity trading advisor. FDS is a member of the NFA. FDS provides discretionary advisory and sub-advisory services. FDS acts as a sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients. Broker-Dealers • Fidelity Distributors Company LLC (“FDC”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Securities Exchange Act of 1934 (the “Exchange Act”). FDC acts as principal underwriter of business development companies and 26  the registered investment companies in the Fidelity group of funds, and also markets those funds and other products to third-party financial intermediaries and certain institutional investors. • National Financial Services LLC (“NFS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. NFS is a fully disclosed clearing broker-dealer that provides clearing, settlement, and execution services for other broker-dealers, including its affiliate FBS. Fidelity Capital Markets (“FCM”), a division of NFS, provides trade executions for Fidelity affiliates and other clients. Additionally, FCM operates CrossStream®, an alternative trading system (“ATS”) that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. CrossStream is used to execute transactions for investment company and other clients. NFS provides transfer agent or subtransfer agent services and other custodial services to certain Fidelity clients. • LeveL Markets, LLC, a registered broker-dealer and operator of two ATSs, the Luminex ATS and the LeveL ATS, which allow orders submitted by subscribers to be crossed against orders submitted by other subscribers. LeveL Holdings, LLC, owns LeveL Markets, LLC. Fidelity Global Brokerage Group, Inc., and FMR Sakura Holdings, Inc., each a wholly owned subsidiary of FMR LLC, have membership interests in LeveL Holdings, LLC, along with other members. LeveL Markets, LLC, charges a commission to both sides of each trade executed in the Luminex ATS and LeveL ATS. Luminex ATS and LeveL ATS are used to execute transactions for Fidelity affiliates’ investment company and other advisory clients. NFS serves as a clearing agent for transactions executed in the Luminex ATS and LeveL ATS. • Fidelity Brokerage Services LLC (“FBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act and provides brokerage products and services, including the sale of shares of registered investment companies in the Fidelity group of funds to individuals and institutions, including retirement plans, and acts as placement agent for certain privately offered investment funds advised by Strategic Advisers’ affiliates. In addition, along with Fidelity Insurance Agency, Inc. (“FIA”), FBS distributes variable insurance products that are issued by Fidelity Investments Life Insurance Company (“FILI”) and Empire Fidelity Investments Life Insurance Company® (“EFILI”), both Fidelity affiliates, as well as by third parties. FBS provides shareholder services to certain of Fidelity’s clients. FBS is the introducing broker for managed accounts offered by Strategic Advisers and places orders for execution with its affiliated clearing broker, NFS. • Digital Brokerage Services LLC (“DBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. DBS provides securities brokerage to retail customers through a digital mobile application–based brokerage platform. DBS receives remuneration from FMRCo for expenses incurred in servicing and marketing FMRCo products. Insurance Companies or Agencies • FILI, a wholly owned subsidiary of FMR LLC, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates. • EFILI, a wholly owned subsidiary of FILI, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates to residents of New York. • FIA, a wholly owned subsidiary of FMR LLC, is engaged in the business of selling life insurance and annuity products of affiliated and unaffiliated insurance companies. Banking Institutions • Fidelity Management Trust Company (“FMTC”), a wholly owned subsidiary of FMTC Holdings LLC, which in turn is wholly owned by FMR LLC, is a limited-purpose trust company organized and operating under the laws of the Commonwealth of Massachusetts that provides nondiscretionary trustee and custodial 27  services to employee benefit plans and IRAs through which individuals can invest in affiliated or unaffiliated registered investment companies. FMTC also provides discretionary investment management services to institutional clients. • Fidelity Personal Trust Company, FSB, a wholly owned subsidiary of Fidelity Thrift Holding Company, Inc., which in turn is wholly owned by FMR LLC, is a federal savings bank that offers fiduciary services that include trustee or co-trustee services, custody, principal and income accounting, investment management services, and recordkeeping and administration. Limited Partnerships and Limited Liability Company Investments Strategic Advisers provides discretionary investment management to partnerships and limited liability companies designed to facilitate acquisitions by mutual funds offered by Strategic Advisers. These funds are privately offered consistent with stated investment objectives. Strategic Advisers does not currently engage in borrowing, lending, purchasing securities on margin, short selling, or trading in commodities. Participating Affiliate Certain employees of Fidelity Strategic Advisers Ireland, Limited (“Strategic Ireland”), can from time to time provide certain services, including but not limited to research, operations, and investment management support services for Strategic Advisers, which Strategic Advisers could use for its clients. Strategic Ireland is not registered as an investment adviser under the Advisers Act and is deemed to be a “Participating Affiliate” of Strategic Advisers (as this term has been used by the SEC’s Division of Investment Management in various no-action letters granting relief from the Advisers Act’s registration requirement for certain affiliates of registered investment advisers). Strategic Advisers deems Strategic Ireland and each of the Strategic Ireland Associated Employees as “associated persons” of Strategic Advisers within the meaning of Section 202(a)(17) of the Advisers Act. Strategic Ireland Associated Employees and Strategic Ireland through such employees can contribute to Strategic Advisers’ research process and could have access to information concerning securities that are being selected for clients prior to the effective implementation of such selections. As a Participating Affiliate of Strategic Advisers, Strategic Ireland has agreed to submit itself to the jurisdiction of United States courts for actions arising under United States securities laws in connection with investment advisory activities conducted for Strategic Advisers’ clients. Strategic Advisers maintains a list of Strategic Ireland Associated Employees whom Strategic Ireland has deemed associated persons, and Strategic Advisers will make the list available to its current U.S. clients upon request. C O D E O F E T H I C S , P A R T I C I P A T I O N O R I N T E R E S T I N C L I E N T T R A N S A C T I O N S A N D   P E R S O N A L T R A D I N G Strategic Advisers has adopted a Code of Ethics for Personal Trading (the “Code of Ethics”). The Code of Ethics applies to all officers, directors, employees, and other supervised persons of Strategic Advisers and requires that they place the interests of Strategic Advisers’ clients above their own. The Code of Ethics establishes securities transaction requirements for all covered employees and their covered persons, including their spouses. More specifically, the Code of Ethics contains provisions requiring the following: • Standards of general business conduct reflecting the investment advisers’ fiduciary obligations; • Compliance with applicable federal securities laws; • Employees and their covered persons to move their covered accounts to FBS unless an exception exists or prior approval has been granted; • Reporting and review of personal securities transactions and holdings for persons with access to certain nonpublic information; • Prohibition of purchasing securities in initial public offerings unless an exception has been approved; • Reporting of Code of Ethics violations; and 28  • Distribution of the Code of Ethics to all supervised persons, documented through acknowledgments of receipt. Core features of the Code of Ethics generally apply to all Fidelity employees. The Code of Ethics also imposes additional restrictions and reporting obligations on certain advisory personnel, research analysts, and portfolio managers. Such restrictions and reporting obligations include the following: • The preclearing of transactions in covered securities with limited exceptions; • A prohibition on investments in limited offerings without prior approval; • A prohibition on personal trading by a portfolio manager within seven days before or after a trade in any covered security of the same issuer by a fund or account managed by such portfolio manager except in limited circumstances; • The reporting of transactions in covered securities on a quarterly basis with limited exceptions; • The reporting of securities accounts and holdings of covered securities at the time of hire and annually thereafter; and • The disgorgement of profits from short-term transactions with limited exceptions. Violation of the Code of Ethics requirements can also result in the imposition of remedial action. The Code of Ethics will generally be supplemented by other relevant Fidelity policies, including the Policy on Inside Information, Rules for Broker-Dealer Employees, and other written policies and procedures adopted by Fidelity and Strategic Advisers. A copy of the Code of Ethics will be provided to any client or prospective client on request. From time to time, Strategic Advisers and its related persons can buy or sell securities for themselves and recommend those securities to clients. The conflicts of interest involved in such activities are contemplated in the Code of Ethics and other relevant Fidelity policies. In particular, the Code of Ethics and other Fidelity policies are designed to make it clear to Fidelity personnel that they should never place their personal interests ahead of Fidelity’s clients in an attempt to benefit themselves or another party. The Code of Ethics and other Fidelity policies impose sanctions if these requirements are violated. From time to time, in connection with our business, certain supervised persons obtain material nonpublic information that is usually not available to other investors or the general public. In compliance with applicable laws, Strategic Advisers has adopted a comprehensive set of policies and procedures that prohibits the use of material nonpublic information by investment professionals or any other employees and that limits the transactions that Strategic Advisers can implement for Program Accounts. In addition, Fidelity has implemented a Corporate Gifts & Entertainment Policy intended to set standards for business entertainment and the giving or receiving of gifts, to help employees make sound decisions with respect to these activities, and to ensure that the interests of Strategic Advisers’ clients come first. Similarly, to support compliance with applicable “pay to play” laws, Fidelity has adopted a Personal Political Contributions & Activities Policy that requires employees to preclear any political contributions and activities. Fidelity also has a Global Anti-Corruption Policy regarding commercial bribery and bribery of government officials that prohibits directly or indirectly giving, offering, authorizing, promising, accepting, or receiving any bribe, facilitation payment, kickback, or payoff (whether in cash or any other form) with the intent to improperly obtain or retain business or any improper advantage. B R O K E R A G E P R A C T I C E S Account Transaction Information Transactions in your Program Account are facilitated by FBS, which is a registered broker-dealer, a member NYSE and SIPC, and an affiliate of Strategic Advisers. NFS, another affiliate of Strategic Advisers, is a registered broker-dealer and member NYSE and SIPC, and has custody of your assets and will perform certain Program 29  services, including the implementation of discretionary management instructions as well as custodial and related services. Clients will be sent prompt confirmations from NFS for any transactions in a Program Account; however, with respect to automatic investments, automatic withdrawals, dividend reinvestments, and transactions that involve the Core Money Market Fund, the account statement will serve in lieu of a confirmation. Clients will also receive a prospectus for any new fund not previously held in a Program Account. In addition, clients will be sent Program Account statements electronically from NFS. Program Account statements and transaction confirmations are also available online at Fidelity.com. Clients should carefully review all statements and other communications received from FBS and NFS. Program Account statements will provide holdings and transaction information, including trades, contributions, withdrawals, advisory fees, and estimated gain/loss and tax basis information. The routing details of a particular order, if applicable, will be provided upon request, and an explanation of order routing practices will be provided on an annual basis. In addition, from time to time, Fidelity will provide aggregated trade execution data to clients and prospective clients. Broker Selection and Transactions in Program Accounts In situations where you have imported securities into your Program Account, Strategic Advisers has a duty to seek best execution for transactions in client accounts. Strategic Advisers will place trades for Program Accounts with affiliated or unaffiliated registered broker-dealers (“brokers”) and may choose to execute an order using electronic channels (including broker-sponsored algorithms) or by manually working an order with a broker. In selecting brokers, Strategic Advisers may consider a range of factors deemed relevant in the context of a particular trade, including but not limited to price; costs; the size, nature, and type of the order; speed of execution; financial condition and reputation of the broker; broker-specific considerations (e.g., not all brokers are able to execute all types of trades); broker willingness to commit capital; our trader’s assessment of whether and how closely the broker will follow our instructions; and confidentiality and potential for leakage. As described above in Fees and Compensation, the Program Advisory Fee includes the cost of commissions associated with transactions executed through affiliated brokers. As a result, most trades for Program Accounts that involve equity securities and other securities where commissions are charged will be executed with Strategic Advisers’ affiliated broker, NFS. However, Strategic Advisers has the authority to execute transactions with an unaffiliated broker (also referred to as “trading away”) consistent with its duty to seek best execution. While the Program Advisory Fee does not include the cost of commissions for transactions executed through unaffiliated brokers, Strategic Advisers or its affiliate is voluntarily assuming the cost of commissions for transactions executed by unaffiliated brokers. As a result, Program clients are not charged commissions for such transactions. Strategic Advisers and its affiliates reserve the right to stop assuming the cost of commissions associated with trading away, subject to prior notice to Program clients. The Program fee does not cover transaction charges for securities where the counterparty imposes a markup, markdown, and/or dealer spread. The net price of the security will include these transaction charges and Program Accounts will bear these costs. In seeking best execution for a transaction, Strategic Advisers will have no obligation to solicit competitive bids for each transaction and Strategic Advisers will not necessarily select the broker that charges the lowest available price or commission rate; however, Strategic Advisers believes that its policies, taking into consideration the factors stated above, are designed to result in transaction processing that is favorable to Program clients. Strategic Advisers conducts periodic reviews of trade execution. Although it is Strategic Advisers’ policy to treat each client’s account in a fair and equitable manner over time, there can be no assurance that all Program Accounts will receive the same execution and certain Program Accounts will experience a more or less favorable execution depending on market conditions. Please see the Fees and Compensation section above for further information about Program fees, brokerage commissions, and additional fees for transactions in a Program Account. 30  Trade Aggregation and Allocation Strategic Advisers’ policy is to treat each of its clients’ accounts in a fair and equitable manner over time when aggregating and allocating orders for the purchase and sale of securities. While Strategic Advisers is under no obligation to aggregate orders for Program Accounts, in general, Strategic Advisers will choose to aggregate trades for Program Accounts and/or aggregate Program Account trades with trades for other client accounts (including certain proprietary accounts of Strategic Advisers or its affiliates and Fidelity employee accounts managed by Strategic Advisers) when, in Strategic Advisers’ judgment, aggregation is in the best interest of all clients involved and it is operationally feasible to do so. Orders are aggregated into a “block trade” to facilitate seeking best execution, to negotiate more favorable commission rates, or to allocate equitably among clients the effects of any market fluctuations that might have otherwise occurred had these orders been placed independently. Aggregated orders are generally allocated on a pro rata basis among similarly situated client accounts participating in a block trade until the order is filled. Client accounts included in a block trade receive the same average price for the trade and shares are allocated according to the purchase and sale orders actually placed for each client account included in the block trade. Strategic Advisers can create multiple block trades for both buy and sell orders in the same security, and it is therefore possible that block trades will receive different prices depending on when the orders for each block trade are filled throughout the day. When a client account is not part of a block trade, that client account will receive a price different from the prices obtained for Program Accounts that participate in the aggregated orders. If Strategic Advisers does not complete an order in a single day (e.g., when an aggregate order for client accounts exceeds the available supply or to minimize market impact), the partially filled order will be allocated on a pro rata basis among client accounts in the block. Strategic Advisers has adopted trade allocation policies for managing client accounts, including Program Accounts designed to achieve fairness and not to purposefully disadvantage comparable client accounts over time when allocating purchases and sales. Cross Trades To the extent permitted by law and applicable policies and procedures, Strategic Advisers can (but is not obligated to) execute agency cross trades for Program Accounts. Agency cross trades are trades in which Strategic Advisers, or any person controlling, controlled by, or under common control with Strategic Advisers, acts as both investment adviser and broker for a client, and as broker for the party or parties on the other side of the trade. Agency cross trades will be executed in accordance with Section 206(3) of the Advisers Act, requiring written consent, confirmations of transactions, annual reporting, and compliance procedures. To the extent permitted by law and applicable policies and procedures, Strategic Advisers can (but is under no obligation to) execute advisor cross trades for Program Accounts when Strategic Advisers believes that such trades are in the best interest of all clients involved. Advisor cross trades are trades in which Strategic Advisers, or an affiliate, acts as investment adviser to both clients involved in the trade. An advisor cross trade will be facilitated between client accounts either directly or through a broker-dealer, including FBS or NFS, and the relevant crossing value will be determined based on one or more third-party pricing services, actual market bids, and/or closing prices as reflected on a national securities exchange. Neither Strategic Advisers nor its affiliates will receive transaction-based compensation for advisor cross trades. Soft Dollars Strategic Advisers does not have a soft dollar program and therefore does not consider the provision of research or brokerage as a criterion for broker selection. 31  Client-Directed Brokerage Program Accounts are not available for brokerage activities outside of the activities directed by Strategic Advisers, including but not limited to margin trading or trading of securities by you or any of your designated agents. R E V I E W O F A C C O U N T S We will contact you at least annually to request that you evaluate whether there have been any changes to your personal financial situation that could affect your Profile Information or the Program services, including whether you wish to impose any reasonable restrictions on the management of your Program Account or reasonably modify any existing restrictions. If you advise us of a change, we will evaluate whether that change requires us to propose a different asset allocation strategy for your Program Account. If we fail to hear from you during this process, we will update your investment time horizon and Program Account balance and, when applicable, the profiling assumptions that can be used for your Profile Information, but we will otherwise assume that your Profile Information has not changed. We will typically notify you of a proposed change to your asset allocation in advance; however, if we determine that your current asset allocation strategy is no longer appropriate based on your Profile Information, we will reassign your Program Account to an appropriate asset allocation strategy and we will notify you after the change has been made. Your continued acceptance of a Program’s services subsequent to notification of a change to your asset allocation strategy will be deemed as your consent to any modification to the discretionary investment management services for your Program Account. For clients who are eligible for the Financial Planning Services, we can also suggest that you review and update your Profile Information during your financial planning sessions with a Fidelity representative. You also have access to periodic reports that detail the performance of your Program Account and summarize the market activity during the period. Industry standards are applied when calculating performance information. Strategic Advisers also makes available account performance on a password-protected website. At least quarterly, we will also send you a reminder to notify us of any change in your financial situation or investment needs. You can access and update the Profile Information you have provided to us on the Program Website, and we encourage you to periodically review your Profile Information and provide updated Profile Information any time there is a change so that we can identify a more personalized asset allocation strategy for your Program Account. Ongoing Review and Adjustments of Program Accounts Strategic Advisers monitors Program Accounts and their investments periodically. Market conditions and/or an upturn or downturn in a particular security will at times cause a “drift” in your investment portfolio away from the long-term risk level associated with the Program Account. Strategic Advisers can choose to rebalance a Program Account to bring it back in line with your selected asset allocation strategy. The number of times your Program Account is rebalanced will vary based on economic and market conditions, as well as changes in the attractiveness or appropriateness of specific funds or managers. Strategic Advisers can also modify the funds held in a Program Account to accommodate new fund allocations and fund closures. As described earlier in this brochure, we will invest all Program Account assets in certain Flex Funds. In managing Program Accounts, Strategic Advisers could decide to rebalance or adjust allocations for a number of reasons, including but not limited to the following: • The weighting of a particular asset class, sector, or individual security that Strategic Advisers believes has too much or too little representation in connection with Program allocations; • Changes in the fundamental attractiveness or appropriateness of a particular mutual fund; • Changes in a client’s Profile Information and any consequent changes to an associated investment strategy; • Deposits/withdrawals of cash or securities into/from a Program Account; and • Accommodating mutual fund closures or limitations. 32  Strategic Advisers’ investment management team will make decisions regarding reallocations within the portfolio in which the Program Account is invested. These decisions are based on the investment management team’s assessment of market and economic conditions and potential investment opportunities. Strategic Advisers will generally trade a Program Account when the portfolio to which it is aligned is changed. In determining whether a Program Account requires trading on a given day, Strategic Advisers relies on the prior trading day’s closing values of the funds held in a Program Account. In general, Strategic Advisers does not attempt to conduct intraday account evaluations, and Strategic Advisers does not generally attempt to time intraday price fluctuations in its decisions to buy or sell securities. In certain instances, a do-not-trade restriction will be placed on a Program Account for reasons including but not limited to processing a trade correction, client request, or to comply with a court order. For the period when a do-not-trade restriction is on a Program Account, Strategic Advisers will suspend management of the Program Account and will not monitor the Program Account for potential purchases and sales of securities. Additionally, in certain instances, deposits to a Program Account will not be invested and withdrawal requests will not be processed during a do-not-trade period. Strategic Advisers is not held responsible for any market loss experienced as a result of a do-not-trade restriction. C L I E N T R E F E R R A L S A N D O T H E R C O M P E N S A T I O N Affiliates of Strategic Advisers are compensated for providing services, including for investment management, distribution, transfer agency, servicing, and custodial services, to certain Fidelity and non-Fidelity mutual funds, ETPs, and other investments a client could use to implement any financial planning recommendations made through the Program. These affiliates include FMRCo and its affiliates as the investment adviser for the Fidelity Funds; FDC as the underwriter of the Fidelity Funds; and Fidelity Investments Institutional Operations Company LLC (“FIIOC”) as transfer agent for the Fidelity Funds, servicing agent for non-Fidelity funds, and recordkeeper of certain workplace savings plans. Strategic Advisers affiliates also receive compensation and other benefits in connection with portfolio transactions executed on behalf of the Fidelity and non-Fidelity mutual funds, ETPs, and other investments. FMRCo and its affiliates also obtain brokerage or research services, consistent with Section 28(e) of the Exchange Act, from broker-dealers in connection with the execution of the Fidelity Funds’ portfolio security transactions. FBS and NFS receive compensation for executing portfolio transactions and providing, among other things, clearance, settlement, custodial, and other services to Fidelity and non-Fidelity mutual funds, ETPs, and other investments, and NFS provides securities lending agent services to certain Fidelity Funds for which it receives compensation. FBS, NFS, and FIIOC also offer Fidelity’s mutual fund platform, FundsNetwork®, and provide shareholder and other services (including, for a limited number of participants on the platform, the sharing of certain aggregated data regarding ETF holdings in client accounts) to participating mutual funds and ETPs (or their sponsors) for which FBS, NFS, and FIIOC receive compensation. Neither FBS nor NFS receives any compensation in connection with directing equity trades for Program Accounts to market makers for execution. We can execute trades through alternative trading systems or national securities exchanges, including but not limited to ones in which a Fidelity affiliate has an ownership interest, such as Members Exchange, a registered national securities exchange. Any decision to execute a trade through an alternative trading system or exchange in which a Fidelity affiliate has an interest would be made in accordance with applicable law, including best execution obligations. For trades placed on certain national securities exchanges, not limited to ones in which a Fidelity affiliate has an ownership interest, Fidelity could receive exchange rebates from such trades for Program Accounts, and these rebates will be subject to the Credit Amount (as described below) and will be allocated, pro rata based on assets, among Program Accounts. If you transfer securities to fund a Program Account, the advisory fee applied to a Program Account can be reduced by a Credit Amount. The Credit Amount is intended to address the conflicts of interest that arise from Program Account investments that generate revenue for Fidelity by reducing the advisory fees paid to Strategic Advisers by the amount of compensation, if any, Strategic Advisers or its affiliates retain that is derived as a 33  direct result of investments imported into Program Accounts, as detailed below. A Credit Amount is applied after the end of each quarter. Fund expenses, which vary by fund and class, are expenses that mutual fund and ETP shareholders typically pay. Details of mutual fund or ETP expenses can be found in each mutual fund’s or ETP’s respective prospectus. These expenses are not separately itemized or billed; rather, the published returns of mutual funds and ETPs are shown net of their expenses. To the extent applicable, a Credit Amount will be calculated for any mutual funds or ETPs transferred to a Program Account, as follows: • For Fidelity Funds and ETPs, the Credit Amount will equal the underlying investment management and any other fees or compensation Strategic Advisers or its affiliates retain from these funds and ETPs, as a direct result of such investments transferred into Program Accounts. • For non-Fidelity funds and ETPs, the Credit Amount will equal the distribution fees, shareholder servicing fees, and any other fees or compensation Strategic Advisers or its affiliates retain from these funds and ETPs (or their affiliates), as a direct result of such investments transferred into Program Accounts. A total Credit Amount is allocated to a Program Account to arrive at the net advisory fee you pay. Individual securities transferred into a Program Account do not affect the calculation of the Credit Amount and the Flex Funds are not subject to the Credit Amount calculation because the Flex Funds do not charge management fees or, with limited exceptions, fund expenses. It is important to understand that Strategic Advisers’ affiliates receive compensation for providing a variety of services to mutual funds and ETPs. Such compensation is included in the Credit Amount only to the extent that it is retained as a direct result of investment by Program Accounts. Compensation that is not directly derived from Program Account assets is not included in the Credit Amount. Credit Amounts for non-Fidelity funds and ETPs are calculated one month after the end of each month, and as a result, a Credit Amount for non-Fidelity funds and ETPs will not be applied against the advisory fee for any partial period during the month in which a Program Account is closed. In such circumstances, Credit Amounts not applied to a closed Program Account are allocated, pro rata based on assets, among the open Program Accounts in a Program at the time the Credit Amount is applied. In addition, certain de minimis revenue received by Strategic Advisers’ affiliates could be donated to charity (rather than included in the Credit Amount) or could be allocated, pro rata based on assets, among the open Program Accounts. This operational process results in credits that would otherwise be attributable to one Program Account being received by another Program Account. The compensation described above that is retained by Strategic Advisers’ affiliates as a direct result of investments by Program Accounts in Fidelity and non-Fidelity funds and ETPs will be included in the Credit Amount, which reduces your advisory fee. However, to the extent that Strategic Advisers’ affiliates, including FBS, NFS, or FIIOC, receive compensation that is neither a direct result of, nor directly derived from, investments by the Program Accounts, such compensation is not included in the Credit Amount, does not reduce the advisory fee, and will be retained by such affiliates. Receipt of compensation in addition to the advisory fee creates a financial incentive for Strategic Advisers and its affiliates to select investments that will increase such compensation. Strategic Advisers seeks to address this financial conflict of interest through the application of the Credit Amount, which will reduce the advisory fee, as applicable, and through personnel compensation arrangements (including those of our investment professionals and the Fidelity representatives) that are not differentiated based on the investments or share classes selected for Program Accounts. Strategic Advisers and its affiliates have also implemented controls reasonably designed to prevent the receipt of compensation from affecting the nature of the advice provided to Program Accounts. As described herein, Program Account assets will be invested in certain Flex Funds. The Flex Funds are available only to certain fee-based accounts offered by Fidelity, and compensation for access to Flex Funds is paid out of the fees charged by Fidelity fee-based accounts that include Flex Funds as underlying investments, including the Program Account. FMRCo is compensated for its services out of such advisory fees. FMRCo receives no fee from the Flex Funds for handling the business affairs of the funds, and Fidelity 34  pays the expenses of each fund with the limited exceptions of expenses for typesetting, printing, and mailing proxy materials to shareholders, all other expenses incidental to holding meetings of the fund’s shareholders (including proxy solicitation), fees and expenses of certain trustees, interest, Rule 12b-1 fees (if any), taxes, and such nonrecurring expenses as can arise, including costs of any litigation to which the fund can be a party, and any obligation it can have to indemnify its officers and trustees with respect to litigation. The fund shall also pay its nonoperating expenses, including brokerage commissions and fees and expenses associated with the fund’s securities lending program, if applicable. Strategic Advisers engages certain non-affiliates to promote the Program’s services. These non-affiliates earn a fixed fee from Strategic Advisers, paid through its affiliates, for each account opened through such non- affiliates’ promotion of the Program. You will receive a disclosure that describes the particular arrangement if you open a Program Account through a non-affiliate’s promotion of the Program. These arrangements create a conflict of interest, as the non-affiliate is incentivized to encourage you to open a Program Account, regardless of whether the non-affiliate would otherwise do so, due to the compensation it earns from Strategic Advisers. Client referrals are provided by affiliated entities, including FBS or other affiliates, pursuant to referral agreements where applicable. As noted in “Information about Fidelity and Fidelity Representative Compensation,” some Fidelity representatives receive variable compensation or an annual bonus in addition to their normal base pay for distributing and supporting Program Accounts. Additionally, Strategic Advisers refers clients to other independent investment advisers in connection with a referral program in which such independent investment advisers participate for a fee payable to Strategic Advisers. C U S T O D Y NFS has custody of your assets and will perform certain services for the benefit of your Program Account, including the implementation of discretionary management instructions, as well as custodial and related services. Certain personnel of Strategic Advisers, FBS, and NFS share premises and have common supervision. In addition, clients will be sent statements electronically from NFS that will detail all holdings and transaction information, including trades, additions, withdrawals, shifts in investment allocations, Program Advisory Fees, and estimated gain/loss and tax basis information. Statements and confirmations are also available online at Fidelity.com. Clients should carefully review all statements and other communications received from NFS (see the “Brokerage Practices” section above). Strategic Advisers is deemed to have custody under the Advisers Act because its affiliate NFS serves as qualified custodian for Program Accounts. I N V E S T M E N T D I S C R E T I O N Strategic Advisers’ portfolio management services for Program Accounts include the discretionary authority to determine which securities to purchase or sell, the total amount of such purchases and sales, and the brokers or dealers through which transactions are executed in Program Accounts. Such discretionary authority is subject to certain limits, including the Program’s investment objectives and policies, regulatory constraints, and those investment restrictions we agree to impose based on a client’s request, in accordance with applicable laws. V O T I N G C L I E N T S E C U R I T I E S Strategic Advisers does not generally acquire authority for, or exercise, proxy voting on a client’s behalf in connection with managing Program Accounts. Unless you direct us otherwise, you will receive proxy materials directly from the funds or NFS. Strategic Advisers will not advise you on the voting of proxies. You must exercise any proxy voting directly. 35  F I N A N C I A L I N F O R M A T I O N Strategic Advisers does not solicit prepayment of client fees. Strategic Advisers is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. 36  FOR MORE INFORMATION, PLEASE CALL US TOLL-FREE AT 8 0 0 . 3 4 3 . 3 5 4 8 Monday through Friday, 8 a.m. to 7 p.m . Ea stern time Keep in mind that investing involves risk. The value of your investment will fluctuate over time, and you may gain or lose money. Diversification and asset allocation do not ensure a profit or guarantee against loss. Fidelity does not provide legal or tax advice, and the information provided is general in nature and should not be considered legal or tax advice. Consult an attorney, tax professional, or other advisor regarding your specific legal or tax situation. The Russell 3000® Index is a market capitalization–weighted index designed to measure the performance of the 3,000 largest companies in the U.S. equity market. The S&P 500® Index is a market capitalization–weighted index of 500 common stocks chosen for market size, liquidity, and industry group representation to represent U.S. equity performance. Fidelity, Fidelity Investments, the Fidelity Investments logo, Fidelity Flex, FundsNetwork, Fidelity Go, Fidelity Managed FidFolios, Fidelity Wealth Advisor Solutions, Empire Fidelity Investments Life Insurance Company, Fidelity Managed Account Xchange, and CrossStream are registered service marks of FMR LLC. Fidelity Brokerage Services LLC, Member NYSE, SIPC, 900 Salem Street, Smithfield, RI 02917 © 2026 FMR LLC. All rights reserved. 1012996.8.0 03/26 1.9905100.108 

Fidelity Managed FidFolios® Form ADV, Part 2A Brochure Strategic Advisers LLC 155 Seaport Boulevard Boston, MA 02210-2698 617.563.7000 Fidelity.com March 30, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Strategic Advisers LLC (“Strategic Advisers”), a Fidelity Investments® company, as well as information about Fidelity Managed FidFolios®. Throughout this brochure and related materials, Strategic Advisers refers to itself as a “registered investment adviser” or as being “registered.” These statements do not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please call us at 800.544.3455. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Strategic Advisers is available on the SEC’s website at adviserinfo.sec.gov.  S U M M A R Y O F M A T E R I A L C H A N G E S The SEC requires registered investment advisers to provide and deliver an annual summary of material changes to their advisory services program brochure (also referred to as the Form ADV, Part 2A brochure). The section below highlights only material revisions that have been made to the Fidelity Managed FidFolios Form ADV, Part 2A brochure (the “Program Brochure” or “Brochure”) from March 31, 2025, through March 30, 2026. Clients and prospective clients can obtain a copy of the Program Brochure without charge by calling 800.544.3455, by visiting Fidelity.com/information, or by visiting the SEC’s website at adviserinfo.sec.gov. Capitalized terms are defined in the Program Brochure. Material Changes • There have been no material changes since the March 31, 2025, Program Brochure. Other Changes • The chart in “Other Considerations” has been updated to provide further and updated information about the programs, accounts, and services available from Strategic Advisers and its affiliates. • “Information about Fidelity and Fidelity Representative Compensation” has been updated to provide further information about how Fidelity and its representatives are compensated. • “Material Risks” has been updated to provide further information with respect to the efficacy of tax-smart investing techniques for Program clients in lower federal income tax brackets. • Certain minor revisions have been made to the text that describes Strategic Advisers’ affiliates in “Other Financial Industry Activities and Affiliations.” 2  T A B L E O F C O N T E N T S SUMMARY OF MATERIAL CHANGES 2 S ER VIC ES , F EES A ND COMPEN SATION 4 ACCOUNT REQUIREMENTS AN D T YPES OF CLIEN TS 14 PORTFOLIO MANAGER SELECTION AN D EVALUATION 17 CLIENT INFORMATION PROVIDED TO POR TFOLIO MANAGERS 26 CLIENT CONTAC T WITH POR TFOLIO MAN AGERS 26 ADDITIONAL INFORMATION 26 BROKERAGE PRACTIC ES 30 3  S E R V I C E S , F E E S A N D C O M P E N S A T I O N Strategic Advisers is a registered investment adviser under the Investment Advisers Act of 1940 (“Advisers Act”) and an indirect, wholly owned subsidiary of FMR LLC (collectively with Strategic Advisers and its affiliates, “Fidelity Investments,” “Fidelity,” “us,” “our,” or “we”). Strategic Advisers was formed in 1977 and offers a number of investment advisory programs, including Fidelity Managed FidFolios (the “Program”) and provides a variety of investment management services, including discretionary portfolio management services to retail and institutional clients and nondiscretionary advisory services to certain institutional clients, including but not limited to Fidelity affiliates. As described below, Fidelity Managed FidFolios is a digitally delivered separately managed account program in which clients hire Strategic Advisers and authorize us to retain one or more investment advisers (“sub-advisors”) on their behalf to implement a selected investment strategy on a discretionary basis (“Program Services”). The Program offers eight investment strategies (each a “Strategy” and, collectively the “Strategies”): • U.S. Large Cap Strategy • Dividend Income Strategy • International Strategy • U.S. Large Cap Index Strategy • International Index Strategy • U.S. Total Market Index Strategy • U.S. Low Volatility Index Strategy • Environmental Focus Strategy Each Strategy is designed to achieve a specific investment objective through investing in stocks. These Strategies seek to achieve their individual objectives while incorporating enhanced customization and tax- smart investing techniques for taxable accounts. Fidelity Managed FidFolios uses fractional share trading, which allows us to allocate a client’s assets efficiently among hundreds of positions based on dollar amount rather than share size. Discretionary investment management is provided through one or more accounts (each, a “Program Account”) made available to clients through the Fidelity Managed FidFolios website and Fidelity’s mobile applications (the “Program website”). The Program is designed for clients (also referred to as “you” throughout this Brochure) who seek a personalized and professionally managed stock portfolio facilitated by a digital experience. To participate in the Program, clients must complete an online enrollment process and agree to accept electronic delivery of contracts, disclosure documents, prospectuses, trade confirmations, account statements, and other Program materials and regulatory documents (“Program documents”). Clients should not participate in the Program if they do not wish to interact digitally. Regular and continuous digital access is required to enroll in the Program and to access all related Program documents. Clients accessing the Program through Fidelity’s mobile application should ensure that they have downloaded the most up-to-date version of the Fidelity mobile application to access the available Program services. Clients also have an obligation to maintain a current and accurate email address to ensure that they can receive their Program-related communications and/or Program documents. We reserve the right to terminate a client’s participation in the Program if they request to unenroll from electronic delivery for Program-related communications and/or Program documents. 4  Discretionary Investment Management Services The Program’s Strategies generally provide an account consisting of individual stocks and/or American Depositary Receipts (“ADRs”) (i.e., a single asset class). Like all portfolios that are composed exclusively of equity securities, these Strategies are expected to have increased risk and volatility as compared with an account that holds a diversified mix of bonds, equities, and other investment types. Accordingly, clients should be comfortable with the risk of holding only equity securities in their Program Account. As part of our investment management services in the Program, we will obtain information regarding a client’s financial situation, risk tolerance, tax situation, and investment horizon (“Profile Information”). Investment Strategies Clients can choose from the following investment strategies: The U.S. Large Cap Strategy invests in stocks and seeks capital appreciation and to outperform the S&P 500® Index over a full market cycle. The Strategy invests primarily in U.S. large-cap stocks but can also invest in securities not included in its index, including non-U.S. large-cap stocks, ADRs, real estate investment trusts (“REITs”), and exchange-traded products (“ETPs”). For taxable accounts, the Strategy seeks to enhance after- tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. Strategic Advisers has retained Fidelity Management & Research Company LLC (“FMRCo”), an affiliate of Strategic Advisers, to provide investment models (each a “Model Portfolio”) that it will use in managing accounts enrolled in the Strategy. Strategic Advisers will blend Model Portfolios for multiple investment exposures (e.g., growth, value, and core equity) at its discretion based on market cycle implications and overall portfolio positioning. The Dividend Income Strategy invests in stocks and seeks capital appreciation and dividend income greater than that of the S&P 500® Index over a full market cycle. For taxable accounts, the Strategy seeks to enhance after-tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. Strategic Advisers has retained FMRCo to provide a Model Portfolio that Strategic Advisers will use in managing accounts enrolled in the Strategy. The International Strategy invests in securities and seeks capital appreciation and to outperform the MSCI EAFE Index (Net MA Tax) over a full market cycle. The Strategy invests primarily in ADRs and a proprietary mutual fund designed for use in Program Accounts that invests in foreign securities where ADRs are either unavailable or inappropriate. For taxable accounts, the Strategy seeks to enhance after-tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. Strategic Advisers has retained FMRCo to provide Model Portfolios that it will use in managing accounts enrolled in the Strategy. Strategic Advisers will blend Model Portfolios for multiple investment exposures (e.g., growth, value, and core equity) at its discretion based on market cycle implications and overall portfolio positioning. The U.S. Large Cap Index Strategy invests in stocks and seeks to approximate the pretax risk and return characteristics of the Fidelity U.S. Large Cap Index℠ (the “Large Cap Index”) while enhancing after-tax returns using tax-smart investing techniques. The Large Cap Index is designed to reflect the performance of the stocks of the largest 500 U.S. companies based on float-adjusted market capitalization. The Strategy seeks to enhance after-tax returns of taxable Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. In addition, while this Strategy looks to approximate the pretax risk and return characteristics of the Large Cap Index, it will invest in only a subset of the stocks that make up the index. The International Index Strategy invests in securities and seeks to approximate the pretax risk and return characteristics of the Fidelity Developed International ex North America Focus Index (Net) while enhancing after-tax returns through the use of tax-smart investing techniques. This Strategy invests primarily in ADRs. The Fidelity Developed International ex North America Focus Index (Net) is designed 5  to reflect the performance of the developed international equity market, including large-cap stocks, based on float-adjusted market capitalization. This Strategy seeks to enhance after-tax returns of taxable Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. In addition, while this Strategy looks to approximate the pretax risk and return characteristics of the Fidelity Developed International ex North America Focus Index (Net), it will invest in only a subset of the stocks that make up the index. The U.S. Total Market Index Strategy invests in stocks and seeks to approximate the pretax return and overall risk profile of the Fidelity U.S. Total Investable Market Index while actively trading holdings in an attempt to enhance after-tax returns through the use of tax-smart investing techniques. The Fidelity U.S. Total Investable Market Index is a float-adjusted market capitalization–weighted index designed to reflect the performance of the stocks of the largest 3,000 U.S. companies based on float-adjusted market capitalization. The Strategy seeks to enhance after-tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. While this Strategy looks to approximate the pretax risk and return characteristics of the Fidelity U.S. Total Investable Market Index, it will purchase only a subset of the stocks that make up the index. The U.S. Low Volatility Index Strategy invests in stocks and seeks to approximate the pretax return and overall risk profile of the Fidelity U.S. Low Volatility Focus Index while actively trading holdings in an attempt to enhance after-tax returns through the use of tax-smart investing techniques. The Fidelity U.S. Low Volatility Focus Index is designed to reflect the performance of large- and mid-cap stocks with lower volatility than the broader market. The Strategy seeks to enhance after-tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. While this Strategy looks to approximate the pretax risk and return characteristics of the index, it will purchase a subset of the stocks that make up the index as well as a subset of stocks from the largest 1,000 U.S. companies based on float-adjusted market capitalization. The Environmental Focus Strategy invests in stocks and seeks to reduce ownership of securities in companies that have lower environmental ratings compared with the Large Cap Index while approximating the pretax risk and return characteristics of the Large Cap Index. This Strategy seeks to enhance after-tax returns of taxable Program Accounts through the application of tax-smart investing techniques that include but are not limited to proactive tax-loss harvesting and deferring the realization of capital gains. Please note that the Strategy’s goal of delivering a portfolio with a better aggregate environmental rating compared with the index could constrain the degree to which tax-smart investing techniques can be implemented. In addition, while this Strategy seeks to approximate the pretax risk and return characteristics of the Large Cap Index, it will purchase only a subset of the stocks that make up the index. It is important to understand that the application of environmental sustainability data and filtering will cause an account invested according to the Environmental Focus Strategy to forgo certain investment opportunities, which will cause such an account to perform differently, perhaps significantly, compared with an account that does not exclude issuers based on such criteria. To develop a portfolio that seeks to reduce the ownership of companies that have lower environmental ratings compared with the Large Cap Index, Strategic Advisers has retained the services of its affiliate FMRCo. FMRCo will use a screening process to filter the Large Cap Index. First, FMRCo will reduce the investment universe by applying six broad exclusionary criteria that seek to exclude issuers that are directly engaged in, and/or derive significant revenue from, certain industries or product lines. Such issuers may include but are not limited to: • companies that are both in the top 30% of their sector and top 10% of the index with respect to carbon emissions; • companies that are both in the top 30% of their sector and top 10% of the index with respect to water usage; 6  • companies subject to certain FMRCo sustainable portfolio exclusions (including civilian semiautomatic firearms manufacturers, tobacco producers, for-profit prison companies, cluster munitions and land mine manufacturers, and thermal coal production and/or mining companies); • companies with coal reserves; • companies with oil and gas reserves; • companies that generate electric power from thermal coal; and • companies with environmental ratings in or near the bottom 50%. FMRCo relies on its proprietary research as well as data from third parties in applying these exclusionary criteria. FMRCo will rank issuers based on environmental ratings and provide Strategic Advisers with an investment universe that seeks to include the highest-scoring stocks in each sector (generally, the top 50%) as measured across a variety of environmental factors (the “Environmental Factors”) as determined by FMRCo analysts in their discretion to be most relevant for each sub-industry. FMRCo analysts select these Environmental Factors and assign weights to them for each stock in the Large Cap Index. These Environmental Factors include but are not limited to carbon emissions, water stress, and toxic emissions and waste. FMRCo uses data from a number of third-party data vendors (e.g., CDP and MSCI) as well as proprietary data to analyze the Environmental Factors. FMRCo will generally review and update stock weighting scores monthly. At any time, FMRCo can change Environmental Factors and stock-scoring processes as well as its process and data sources for evaluating issuers on any Environmental Factor. After the application of these exclusionary criteria and the scoring of all stocks in the index, the investment universe will generally include the top-scoring 200–300 issuers in the Large Cap Index, which represents approximately 40%–60% of the Large Cap Index. Strategic Advisers will generally invest in only a subset of the securities of those issuers included in the environmentally screened investment universe, resulting in portfolios consisting of 100–200 stocks that, in the aggregate, have a better environmental rating compared with the Large Cap Index as a whole. FMRCo’s exclusionary criteria do not capture all possible Environmental Factors, and there is no common industry standard relating to the development and application of environmental sustainability criteria. Certain exclusions are based in whole or in part on data provided by one or more third-party vendors and are, therefore, subject to each vendor’s industry and product line definitions (which may differ from those of FMRCo and Strategic Advisers) and data limitations. Data used in applying the exclusion criteria may include inputs self-disclosed by companies as well as estimates where public disclosures are unavailable. The subjective value that an investor assigns to certain types of environmental sustainability criteria can differ substantially from that of FMRCo and Strategic Advisers, and reasonable investors can differ in their views of what constitutes positive or negative environmental sustainability characteristics. As a result, clients should not assume that the Environmental Focus Strategy will necessarily invest in stocks of issuers that reflect their own environmental beliefs and values. In addition, the Environmental Factors that FMRCo considers in evaluating an issuer’s environmental rating will change over time. Strategic Advisers reserves the right to use a different service provider to perform the environmental sustainability data assessment at any time. Any change in the service provider would likely result in the consideration of different factors in evaluating an issuer’s environmental rating, which could substantially change the portfolio for Environmental Focus Strategy accounts. 7  If Strategic Advisers has been directed by a client to act as agent to vote proxies with respect to the individual securities held in a Program Account, Strategic Advisers will vote proxies pursuant to the directions provided by Institutional Shareholder Services Inc. (“ISS”). Please note that the Environmental Focus Strategy does not evaluate or consider proxy voting in attempting to reach its objective. Accordingly, it is possible that ISS’ proxy voting directions can be inconsistent with, or contrary to, the environmental goal of an Environmental Focus Strategy account. Additional Information about Investment Techniques Tax-Smart Investing Techniques While each Strategy uses tax-smart investing techniques in taxable accounts, please note that the stated investment objective is of primary importance. Accordingly, the application of tax-smart investing techniques is a secondary consideration. Clients should understand that significant tax consequences can result from investing in a Strategy with a primary focus other than tax-smart investing techniques. For example, each Strategy has a corresponding investable universe of investments that has been constructed by Strategic Advisers. With respect to the Environmental Focus Strategy, stocks used to fund a Program Account that are not included in the environmentally screened investable universe for the Strategy will be sold without regard to potential tax consequences of such sales. Realizing gains could create a tax liability, particularly when offsetting losses are not available. For additional considerations related to tax-smart investing techniques, please see the disclosure below under “Opening and Funding a Program Account” and “Methods of Analysis, Investment Strategies, and Risk of Loss.” Fractional Share Investing Each Strategy can invest in fractional shares of individual securities. Please see “Methods of Analysis, Investment Strategies and Risk of Loss” below for more information about fractional share investing in Client Accounts. Investment Restrictions A client can impose reasonable restrictions on the management of a Program Account. Any proposed restriction is subject to our and the sub-advisor’s review and approval. Reasonable restrictions for Program Accounts typically are limited to the restriction of up to five individual securities or up to two industries. Reasonable restrictions will not apply to underlying securities or holdings that are held in a mutual fund, ETP, or any other types of pooled vehicles purchased in the Program Account. If a restriction is accepted, assets will be invested in a manner that is appropriate given the restriction, which can include investment in ETPs. It is important to understand that imposing an investment restriction can delay the start of discretionary management and can impact the performance of a Program Account, at times significantly, as compared with a Program Account managed without restrictions, possibly producing lower overall results. Program Account restrictions must be requested online. Responsibility of Clients We rely on client information to provide the Program Services. It is the client’s responsibility to advise us of changes to their financial situation, risk tolerance, tax situation, and time horizon. Such changes can result in modification to the tax-smart investing techniques used for a Program Account. Clients with multiple relationships with Fidelity should understand that updating information about a Program Account does not update information about an account enrolled in another advisory service or one that is self- directed. Accordingly, clients should ensure that their personal, financial, and other important information is independently updated for each respective service or account. 8  FEES AND COMPENSATION Advisory Fees—General Information. Clients will be charged an annual Gross Advisory Fee of 0.40% for the U.S. Large Cap Index Strategy, the International Index Strategy, the U.S. Total Market Index Strategy, the U.S. Low Volatility Index Strategy, and the Environmental Focus Strategy, and 0.70% for the U.S. Large Cap Strategy, the Dividend Income Strategy, and the International Strategy, in each case, based on average daily assets held in a Program Account (average daily assets are determined on the last business day of the quarter). The Gross Advisory Fee includes the Program Services described herein and is payable after the end of each quarter. The Gross Advisory Fee includes the ongoing discretionary management of a Program Account as well as the brokerage, clearing, and custody services provided by Strategic Advisers’ affiliates. The following fees are in addition to the Gross Advisory Fee: (i) certain charges resulting from transactions executed with or through broker-dealers that are not affiliates of Strategic Advisers; and (ii) markups and markdowns, transfer taxes, exchange fees, regulatory fees, odd-lot differentials, handling charges, electronic fund and wire transfer fees, ADR custody fees, or any other charges imposed by law or otherwise agreed to with regard to a Program Account. Strategic Advisers or its affiliate can voluntarily assume the cost of certain commissions for equity transactions executed with or through broker-dealers that are not affiliates of Strategic Advisers; clients will not be charged commissions for such transactions. The Gross Advisory Fee also does not include underlying expenses charged by the core Fidelity money market fund, which is the cash sweep vehicle for a Program Account. These fund expenses, which vary by fund and class, are expenses that all mutual fund shareholders pay. Details of the core money market fund expenses can be found in the fund’s prospectus, which is provided to clients with their enrollment materials and is available on Fidelity.com. These expenses are not separately itemized or billed; rather, the published returns of a mutual fund are shown net of its expenses. Billing. The Net Advisory Fee will be deducted automatically from a client’s Program Account after the end of each quarter and will not be billed separately. Certain assets in a Program Account could be liquidated to pay the fees; this liquidation could generate a taxable gain or loss in a taxable Program Account. Additional Fee Information. A client’s Gross Advisory Fee will be reduced by a credit amount (the “Credit Amount”) with respect to the core Fidelity money market fund and any securities a client elects to transfer into a Program Account. The Credit Amount is intended to address the conflicts of interest that arise from Program Account investments that generate revenue for Fidelity by reducing the advisory fees paid to Strategic Advisers by the amount of compensation, if any, Strategic Advisers or its affiliates retain that is derived as a direct result of investments held in or transferred into a Program Account. The underlying mutual fund expenses that are paid to Strategic Advisers or its affiliates as a direct result of investments by a Program Account will be included in the Credit Amount that reduces the Gross Advisory Fee; the Credit Amount is applied after the end of each quarter. For Fidelity Funds, the Credit Amount will equal the underlying investment management and any other fees or compensation Strategic Advisers or its affiliates retain from such a fund as a direct result of investments by Program Accounts. For non-Fidelity mutual funds, the Credit Amount will equal the distribution fees, shareholder servicing fees, and any other fees or compensation Strategic Advisers or its affiliates retain from these funds (or their affiliates) as a direct result of investments by Program Accounts. It is important to understand that Strategic Advisers’ affiliates receive compensation for providing a variety of services to mutual funds, as described below in “Client Referrals and Other Compensation.” Such compensation is included in the Credit Amount only to the extent that it is retained as a direct result of investment by Program Accounts. Compensation that is not directly derived from Program Account assets is not included in the Credit Amount. In addition, certain de minimis revenue received by Strategic Advisers’ affiliates could be donated to charity (rather than included in the Credit Amount) or could be allocated, pro rata based on client assets, among open Program Accounts in the Program. All fees are subject to change and Strategic Advisers has the ability to negotiate advisory fees for certain accounts. Strategic Advisers also could agree to waive fees, in whole or in part, in its sole discretion, including but not limited to (i) in connection with promotional efforts and other programs, including but not limited to situations designed to facilitate transitions between advisory programs; or (ii) for certain current and former 9  employees of Fidelity. This will result in certain clients paying less than the standard fee. In addition, accounts with negotiated advisory fees do not receive the Credit Amount; instead, required Credit Amounts will be allocated, pro rata based on assets, among the other open Program Accounts in the Program at the time the Credit Amount is applied. This operational process results in credits that would otherwise be attributable to one Program Account being received by another Program Account. In certain circumstances, Fidelity will manage certain other accounts in a manner substantially similar to a Program Account under arrangements that can include negotiated terms and conditions that depart from the standard service offering. Generally, except as described above, clients will not pay any commissions, transaction fees, or sales loads on the securities purchased in a Program Account. Clients are responsible for any fees resulting from the sale of securities used to fund a client’s investment in a Program Account (whether such sale is inside or outside a Program Account) and any subsequent withdrawals that the client initiates. The Program Fee includes fees paid to the sub-advisor for the discretionary portfolio management services provided to Program Accounts; Strategic Advisers pays the sub-advisor a portion of the Program Fee, which varies based on the amount of assets under management. The Program Fee does not include amounts charged with respect to a regulatory fee that applies to all sales of securities and which varies over time. This charge is estimated and assessed in advance; this process could lead to overestimating or underestimating the actual regulatory fee. To the extent that such estimated amount is greater than the actual regulatory fee, Fidelity will retain the excess. Account size is a factor affecting the impact of an overestimated regulatory fee. These charges will be reflected on statements and/or trade confirmations. Strategic Advisers’ affiliates sponsor promotional offers that provide clients with the ability to receive cash compensation or a reduced Advisory Fee for opening and funding certain accounts. Accounts opened through the Program are, from time to time, included in the list of account types and investment solutions eligible for such promotional offers. The Program’s eligibility for such promotional offers creates a conflict of interest, as Strategic Advisers and its affiliates are incentivizing clients to use the Program rather than Strategic Advisers’ other managed account programs or self-directed investment options available through Fidelity Brokerage Services LLC (“FBS”). Strategic Advisers can also, from time to time, provide cash compensation to Program clients for taking qualifying actions with respect to their Program Account, such as certain interactions with Program features. Any compensation will be deposited into the client’s Program Account, will be subject to the Advisory Fee applicable to the Program, and may have tax consequences. A promotional offer is not a recommendation to implement any asset allocation strategy or select a particular account type or investment solution. Also, during the time a client is enrolled in the Program, the client could be eligible to receive certain services offered by Strategic Advisers’ affiliates based, in whole or in part, on the amount invested with the Program. It is important to understand that such services are not part of the Program Services for which the Program Fee is paid. In addition, while enrolled in the Program, a client could receive information about how to access financial wellness and/or professional support resources and services that are offered by entities unaffiliated with Fidelity, some of which pay compensation to Fidelity as a result of a client’s use of such resources or services. Such resources and services are not included as part of Program Services and any applicable costs associated with enrolling in or subscribing to these resources or services would be separate from and in addition to the Program Fee. Other Considerations. In evaluating the Program, please consider that Fidelity offers a variety of investment advisory services and brokerage offerings. These offerings are summarized below to assist clients in understanding and comparing the services and offerings. For more detailed information regarding each offering and investment advisory service, please review the respective Form ADV, Part 2A brochure available at Fidelity.com/information or through a Fidelity representative. Refer to the “Guide to Brokerage and Investment Advisory Services at Fidelity Investments” (available at Fidelity.com/information) for more information regarding our roles and responsibilities when providing brokerage and advisory services. 10  Please note that, other than the self-directed brokerage account offered by FBS, the advisory programs included in the chart below are each offered by Strategic Advisers. PRODUCT DESCRIPTION INVESTMENT GENERAL ELIGIBILITY FEE STRUCTURE Fidelity Go® No account minimum; $10 to invest Less than $25,000 invested: no advisory fee Portfolio based on a client’s investment profile and composed of a mix of zero expense ratio Fidelity mutual funds Asset-based advisory fee: 0.35% annually for $25,000 and above Invests in zero expense ratio Fidelity mutual funds that do not charge management fees (or with limited exceptions, fund expenses) Digitally provided discretionary investment management and planning; access to a team of phone-based representatives for one-on-one financial coaching for clients who maintain $25,000 or more in a Fidelity Go account and tax-loss harvesting for taxable accounts with $25,000 or more Fidelity Managed FidFolios® $5,000 minimum investment Asset-based advisory fee: 0.40% or 0.70% annually Digitally provided discretionary invest- ment man agement of a single asset class (including tax-smart investing techniques) A mix of individual securities, either stocks or American Depositary Receipts, depending on the client’s selected strategy Fidelity® Strategic Disciplines Asset-based advisory fee: 0.20%–0.70% annually for equity strategies and 0.35%– 0.40% annually for fixed income strategies, depending on the amount invested Discretionary investment management of a single asset class (including tax-smart investing techniques); planning and advice is provided through a dedicated representative A mix of individual securities, including but not limited to stocks, bonds, American Depositary Receipts, and/or exchange-traded products and mutual funds, depending on the client’s selected strategy Depending on strategy selected, account investment minimums of $100,000 (equity strategies) and $350,000 (bond strategies), each subject to qualification for support from a dedicated Fidelity representative, which is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) (effective in the second quarter of 2026, the account investment minimum will be $200,000 for taxable bond strategies and $250,000 for municipal bond strategies) 11  PRODUCT DESCRIPTION INVESTMENT GENERAL ELIGIBILITY FEE STRUCTURE Fidelity® Wealth Services $50,000 minimum investment Asset-based advisory fee: 1.10% annually, less a fee credit that reflects compensation retained by Fidelity as a direct result of a client’s investments Fidelity Advisory Services provides customized planning, advice, and discretionary investment management (including tax-smart investing techniques); planning and advice is provided by a centralized team of phone-based representatives A mix of Fidelity and non-Fidelity mutual funds and exchange-traded products invested using a dynamic asset allocation that can respond to changes in the economic business cycle; offered with multiple investment approaches and universes Wealth Management and Private Wealth Management provide customized planning, advice, and discretionary investment management (including tax-smart investing techniques); planning and advice is provided through a dedicated representative supported by a service team A mix of Fidelity and non-Fidelity mutual funds and exchange- traded products and, depending on a client’s preferences and investment profile, individual securities, invested using a dynamic asset allocation that can respond to changes in the economic business cycle; offered with multiple investment approaches and universes Asset-based advisory fee: 0.50%–1.50% annually, depending on the amount invested, less a fee credit that reflects compensation retained by Fidelity as a direct result of a client’s investments (additional fees of up to 0.40% for management of certain individual security strategies can also apply where advisory services are not provided solely by a Strategic Advisers affiliate) $50,000 minimum account investment for Wealth Management and $2 million minimum investment and $10 million investable assets for Private Wealth Management, each subject to qualification for support from a dedicated Fidelity representative, which is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) Fidelity Wealth Advisor Solutions® Investment vehicles will vary by unaffiliated investment advisor and strategy Investment minimums will vary by unaffiliated investment advisor and services provided Advisory fees will vary by unaffiliated investment advisor and services provided A referral network of unaffiliated investment advisors that provide customized wealth management and investment strategies Self-Directed Brokerage Account Transaction fees and investment expenses vary based on investment vehicle selected; no ongoing asset-based advisory fee charged by Strategic Advisers Self-directed trading through FBS, with access to Fidelity’s online tools, planning, and resources, and support provided by brokerage representatives. A dedicated representative is available based on relationship No minimum to open a brokerage account. Qualification for support from a dedicated Fidelity representative is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) Brokerage customers can choose from a wide variety of investments, including mutual funds, exchange-traded funds, stocks, bonds, and insurance and annuity products. Note that certain securities available through Strategic Advisers’ advisory services are not available in self- directed brokerage accounts A client could invest directly in the individual securities available through the Program through a Fidelity brokerage account or a brokerage account at another firm without an advisory fee. Also note that Fidelity Strategic Disciplines, described in the chart above, offers certain investment strategies that are substantially similar to those in the Program, with the added benefit of support from a dedicated Fidelity representative, at the same or a lower advisory fee rate, depending on account balance. Fidelity Strategic Disciplines has a per-account minimum investment of $100,000, subject to qualification for support from a dedicated Fidelity advisor. Investments in the U.S. Large Cap Strategy, the Dividend Income Strategy, and the International Strategy would have the same advisory fee rate if a client invests in Fidelity Strategic 12  Disciplines for account balances up to $300,000 and will have a lower advisory fee rate for balances above that amount. Investments in the U.S. Large Cap Index Strategy, the International Index Strategy, the U.S. Total Market Index Strategy, the U.S. Low Volatility Index Strategy, and the Environmental Focus Strategy would have the same advisory fee rate if a client invests in Fidelity Strategic Disciplines for account balances up to $1 million and will have a lower advisory fee rate for balances above that amount. In addition, the Strategies available through the Program, while designed for the Program, could be similar to a mutual fund or other product available for direct investment by the client, and the operating expenses of such a mutual fund or other product could differ from the Program Fee. However, while clients can obtain products and services from Fidelity or other firms that are similar to one or more of the Program’s services, investments could be subject to sales loads or transaction and redemption charges that are generally waived as part of the Program; and the overall cost of purchasing the products and services separately will most likely differ from the Program Fee. Factors that bear upon the cost of the Program in relation to the cost of the same or similar products and services purchased separately include, among other things, the amount of brokerage trades executed through Fidelity- affiliated broker-dealers (the charges for which are included in the Gross Advisory Fee) as compared with the brokerage trades executed through other broker-dealers (the charges for which are not included in the Gross Advisory Fee). Information about Fidelity and Fidelity Representative Compensation. Fidelity representatives who support the Program are associated with Strategic Advisers and FBS. Fidelity representatives act on behalf of FBS when recommending an advisory program offered by Strategic Advisers. Please note that Fidelity representatives are not able to provide investment advice or financial planning in connection with the Program. Once a client enrolls in the Program, the Fidelity representative will be providing Program Services. Separate and apart from the Program, Fidelity representatives, including those who support the Program, can provide clients with a variety of FBS services, including investment education and advice, financial analyses, and financial planning services. When providing services for FBS, these Fidelity representatives are acting solely as registered representatives of FBS, and Program Fees are not related to those FBS services. Fidelity representatives receive base pay based on their experience and role. In addition to base pay, Fidelity representatives are also eligible to receive either variable compensation or an annual bonus, and certain representatives are also eligible to receive longer-term compensation. Fidelity representatives who receive an annual bonus do not receive compensation based directly on the sale of any product or service, but they do have an indirect financial incentive to recommend products or services that pay more compensation to Fidelity because annual bonus funding is based in part on Fidelity’s financial performance. For Fidelity representatives who receive variable compensation, variable compensation depends on the representative’s role and can be impacted by client loyalty, the amount of assets a client transfers to Fidelity, the amount of assets invested initially and on an ongoing basis, referring potential clients to other Fidelity representatives who enroll the client in a Fidelity investment product or service, and client family members opening Fidelity accounts. Whether and how much each Fidelity representative receives in each component is generally determined by the representative’s role, responsibilities, and performance measures, and their manager’s assessment of the representative’s performance. Fidelity and the Fidelity representatives who support the Program and who are eligible to receive variable compensation receive different amounts of compensation depending on the type of product or service a client selects. The compensation received by Fidelity and those representatives in connection with FBS offerings (e.g., stocks, bonds, ETFs, mutual funds) is typically less than the compensation received in connection with a client choosing to participate in a Fidelity advisory program. Products and services that generally require more time to engage with a client and/or that are more complex provide greater compensation to a representative and Fidelity. This compensation structure creates a financial incentive for Fidelity and its representatives to recommend investments in more complex or time-consuming products and services over others, and to recommend that a client maintain an investment in such products and services over time. 13  Fidelity addresses these conflicts of interest by having processes in place that require our representatives to make recommendations that are in the best interest of clients, paying compensation based on the time and complexity of the relevant product or service, training and supervising our representatives, and disclosing these conflicts of interest to clients so that they can consider the conflicts when making financial decisions. To see specific compensation levels for the managed account programs mentioned above and other products, including an example of compensation that can be earned by Financial Consultants, please see the “Fidelity Investments Compensation Disclosure” document (available at Fidelity.com/information), or contact a Fidelity representative. Clients should read the information contained in the “Fidelity Investments Compensation Disclosure” document carefully, and can ask a representative at any time whether and how they are compensated with respect to a particular product or service and about the financial incentives and conflicts of interest that Fidelity has when making recommendations of products or services. A C C O U N T R E Q U I R E M E N T S A N D T Y P E S O F C L I E N T S The Program is generally available to individual investors who are U.S. persons (including a U.S. resident alien), typically reside in the United States, and have a valid U.S. taxpayer identification number. The Program is not available to foreign investors. Strategic Advisers can, in its sole discretion, decline to permit participation in the Program for any reason. Program Accounts can be either tax- advantaged accounts (e.g., traditional, Roth, and rollover individual retirement accounts, collectively “retirement accounts”) or taxable accounts. The U.S. Large Cap Index Strategy, the U.S. Total Market Index Strategy, the U.S. Low Volatility Index Strategy, and the International Index Strategy are each available only for taxable accounts, while the U.S. Large Cap Strategy, the International Strategy, the Dividend Income Strategy, and the Environmental Focus Strategy are each available to both taxable and retirement accounts. Clients must also have regular internet access and be comfortable with a digital investment experience and online services. All Program-related communications, materials, and Program documents will be delivered electronically. Clients will be sent an electronic notification regarding the availability of Program documents, and a link or website address where the Program documents can be accessed. It is important to note that if a client wants to revoke their consent to electronic delivery of Program-related communications and/or Program documents, we will terminate their participation in the Program. Each Strategy has a per-account investment minimum (“Strategy Minimum”) of $5,000. Please note that clients can open a Program Account without reaching the Strategy Minimum; however, assets used to fund the account will not be invested according to the selected Strategy until the Strategy Minimum has been reached. Until the Strategy Minimum is reached, assets will be invested in the core Fidelity money market fund. Strategic Advisers can, in its sole discretion, elect to change or waive a Strategy Minimum at any time. Please note that if a Program Account balance falls below the Strategy Minimum stated above, it can affect the sub-advisor’s ability to manage the Program Account according to the selected Strategy. Program Accounts that fall below the Strategy Minimum can be removed from the Program. To enroll in the Program, a client must agree to the Program Client Agreement, which details the terms and conditions under which the client appoints Strategic Advisers to provide the Program Services. Our advisory relationship with a client begins when we accept the Program Client Agreement. Preliminary discussions or recommendations made before we accept a Program Client Agreement are not intended as investment advice provided by Strategic Advisers. The Program Client Agreement requires that clients delegate discretionary authority to Strategic Advisers and authorize Strategic Advisers to hire a sub-advisor to implement the selected Strategy for the client’s Program Account. The Program Client Agreement will also permit sub-advisors to provide day-to-day 14  investment management for the clients’ Program Account, which includes the authority to determine which securities to purchase or sell, the total amount of such purchases and sales, and the brokers or dealers through which transactions are executed in Program Accounts, subject to certain Program and regulatory limitations and a sub-advisor’s internal policies and procedures. The Program Client Agreement also establishes a brokerage account with FBS, a registered broker-dealer, affiliate of Strategic Advisers and member of NYSE and SIPC. During a client’s participation in the Program, the client’s Program Account will not be available for the client’s self-directed brokerage activities. Another affiliate of Strategic Advisers, National Financial Services LLC (“NFS”), a registered broker- dealer and a member of NYSE and SIPC, has custody of client assets and will perform certain account services, including the implementation of discretionary management instructions, as well as custodial and related services. Certain personnel of Strategic Advisers, FBS, and NFS share premises and have common supervision. Strategic Advisers does not acquire authority for, or exercise proxy voting on behalf of, a client in connection with offering Program Accounts. However, clients can direct Strategic Advisers to act as agent to vote proxies with respect to the investments held in a Program Account whereby clients must instruct Strategic Advisers to vote proxies for individual securities pursuant to the directions provided by ISS (a summary of which is available at Fidelity.com/information). The environmental goal of the Environmental Focus Strategy is applied to the selection of securities in Program Accounts only, and is not incorporated into proxy voting decisions for Program Accounts. Accordingly, ISS’ proxy voting directions will not necessarily take sustainability characteristics into consideration and it is possible that ISS’ proxy voting directions will be inconsistent with, or contrary to, the environmental goal of the Environmental Focus Strategy. Opening and Funding a Program Account Clients can fund a Program Account by depositing cash and/or eligible securities, which will generally include the following: • Cash; • Core Fidelity money market funds; • Common stocks and REITs listed in the S&P 500, Russell 3000®, and Dow Jones U.S. Total Stock Market indexes; • ADRs that meet certain liquidity requirements; and • Certain ETPs. Once we receive all the required information, and the funding processes and settlement of funds used to fund the Program Account have been completed, a Program Account will be reviewed for investment and will typically begin trading within five business days. The Program’s general policy is for cash deposits to be invested in the core Fidelity money market fund identified as the cash sweep vehicle for Program Accounts as soon as reasonably practicable, then further invest portions of these assets in accordance with the selected Strategy. Fidelity will determine, in its sole discretion, which securities will be eligible to fund a Program Account. Transferred securities imported into Program Accounts must be held free and clear of any liens, pledges, or other legal or contractual restrictions. At times, Fidelity will not accept individual securities due to internal guidelines or state or federal regulations. Alternatively, Fidelity reserves the right to transfer an ineligible security back to the account from which the client transferred the asset or to another like-registered account held at Fidelity. Each Strategy has a corresponding investable universe of investments that has been constructed by the sub-advisor. For Program Accounts managed with tax-smart investing techniques, funding with securities that are included in the investable universe can result in the sub-advisor continuing to hold and manage such securities, depending on the concentration and tax impact of selling. 15  Securities used to fund the account that are not included in the applicable investable universe will be sold without regard to the potential tax consequences of such sales. Sales of eligible and ineligible transferred securities will be subject to redemption and other applicable fees, including commissions on sales of securities; however, under certain circumstances, the Program can voluntarily assume the costs of certain commissions. A client could realize a taxable gain or loss when these shares are sold. In addition, when securities are purchased in Program Accounts, the client could receive taxable distributions out of the earnings that have accrued before such purchases (a situation referred to as “buying a dividend”). For initial funding or subsequent deposits to a Program Account managed with tax-smart investing techniques, Fidelity must be provided with tax basis information for all securities that will be managed. Discretionary portfolio management will not occur for such a Program Account until the completed tax basis information has been received. Although Fidelity is required to report certain tax basis information to the Internal Revenue Service, Fidelity will not otherwise verify (and is not otherwise responsible for) the accuracy of the tax basis information provided. Additional deposits of cash or securities can be made to a Program Account at any time. Discretionary management of additional deposits will generally occur as soon as reasonably practicable but can be delayed for certain reasons, including time needed to liquidate securities, special handling instructions, or because the additional deposit may not necessitate trading at that time. In general, we will begin charging advisory fees on additional deposits once assets have been received into the Program Accounts and have been deemed in good order for management purposes. Withdrawals, Account Closure, and Program Termination A client can request a withdrawal from a Program Account, elect to close one or more Program Accounts, or elect to close all Program Accounts and terminate Program enrollment. If a client instructs us to terminate their participation in the Program, we will cease managing the Program Account, additional deposits will no longer be accepted into the Program Account, and any Program Account features will be terminated. In addition, Strategic Advisers reserves the right to terminate a client’s Program Services (or limit the client’s rights to access any or all account features, products, or services) for any reason, including (i) if a client fails to maintain a valid email address, (ii) if a client revokes their consent to electronic delivery of Program-related communications and/or Program documents, (iii) if any authorized person on a Program Account resides outside the U.S., (iv) if the balance of a Program Account falls below the Strategy Minimum, or (v) if the Program is deemed no longer appropriate for a client. Should either party terminate the investment advisory relationship, the Program Fee will be prorated from the beginning of any unbilled quarter to the termination date, which is defined as the date when we no longer manage the Program Account on a discretionary basis. Clients will be required to provide instructions to be used in the event of withdrawals or Program Account closure. Clients have the option of electing that assets either be liquidated and the proceeds sent to the client by check or transferred to a bank account (or other account) or be transferred in-kind to another account. While the timing of trading and settlement can vary, liquidating trades for partial and full withdrawal requests will typically be placed within the next five business days of the request. In-kind asset transfer instructions will typically be placed within five business days of such a request. For partial withdrawal requests, if transfer instructions are not provided, Fidelity will generally reinvest the cash proceeds of any sales into the client’s discretionarily managed Program Account after 30 days. Note that liquidation of assets in taxable accounts could have adverse tax consequences. It is important to understand that Program Accounts in certain strategies can hold a mutual fund that clients would not be able to buy or sell directly in a retail brokerage account and are able to hold only as part of the Program and that specific Strategy. In general, if an investor ceases to be a Program client or requests a transfer of such fund, shares of such fund will be redeemed, subject to the terms and conditions specified in the fund’s prospectus. 16  There can be instances where we need to place a do-not-trade restriction on a Program Account, including when a client requests a security be transferred from a Program Account, when processing a trade correction, when we need to comply with a court order, when a client asks us to process a withdrawal and keep the proceeds from the sale of securities used to fund the withdrawal in the account until the client provides further instructions for the transfer of the proceeds, or when we need additional information from a client. For the period when a do-not-trade restriction is in effect, we generally will not trade or otherwise manage the Program Account until the do-not-trade restriction has been removed. Please note that in certain situations, withdrawal or account closure requests by way of liquidation can take longer to fully process, as the sub-advisor could take additional time to sell securities at a desirable price. Please note that certain types of securities, such as certain foreign securities, can have extended or less frequent settlement periods, and their trading markets can be fragmented or thinly traded, which could affect the amount of time it takes to process withdrawal or closure requests. There can be no assurance as to how long it might take to obtain a desirable price for such securities or whether a desirable price can be obtained. P O R T F O L I O M A N A G E R S E L E C T I O N A N D E V A L U A T I O N Strategic Advisers offers the Program and provides discretionary investment management services to Program Accounts directly and, therefore, does not evaluate or select other portfolio managers to provide services directly to Program Accounts. Strategic Advisers does, however, evaluate and select Model Providers to provide investment models for certain strategies, as described further below. While performance information is reviewed for accuracy and compliance with applicable standards, performance information is not reviewed by a third party to determine or verify its accuracy or compliance with presentation standards. Performance-Based Fees and Side-By-Side Management Strategic Advisers does not currently charge performance-based management fees for any of its advisory services and, therefore, does not engage in side-by-side management. Methods of Analysis, Investment Strategies and Risk of Loss About the Use of Model Portfolios. Strategic Advisers has retained its affiliate FMRCo to provide investment models to be used by Strategic Advisers in rendering discretionary investment advisory services to the Dividend Income Strategy, International Strategy, and U.S. Large Cap Strategy Program Accounts. FMRCo provides Strategic Advisers with Model Portfolios and provides periodic updates to each Model Portfolio. FMRCo is not acting as investment adviser or portfolio manager with respect to Program Accounts. Rather, Strategic Advisers is the portfolio manager and has the discretion to implement the models as provided by FMRCo or to make modifications as it deems appropriate. FMRCo could provide a similar Model Portfolio or manage accounts using a similar investment strategy for its other clients and could provide the model to such accounts or clients prior to providing it to Strategic Advisers. At any time, Strategic Advisers can determine to no longer receive a Model Portfolio from FMRCo, in which case Strategic Advisers can engage another investment firm to provide a Model Portfolio or manage Program Accounts without recommendations from a Model Portfolio provider. For the International Strategy and the U.S. Large Cap Strategy, Strategic Advisers will blend the Model Portfolios it receives from FMRCo in its discretion, based on market cycle implications and overall portfolio positioning. FMRCo will generally use fundamental and quantitative analysis to select stocks for the Model Portfolio. Strategic Advisers has designed investment guidelines for the Model Portfolios delivered by FMRCo. These guidelines can change from time to time. 17  About Strategic Advisers’ Model Provider Selection Process. Prior to selecting FMRCo to provide Model Portfolios, Strategic Advisers performed a comprehensive review of FMRCo and its investment style and approach. Strategic Advisers’ review included, among other things, assessing information about FMRCo and its investment strategy. In selecting FMRCo, Strategic Advisers considered a variety of factors, including but not limited to investment approach, portfolio characteristics, and FMRCo’s experience with similar investment strategies. Strategic Advisers evaluated information from both quantitative and qualitative analyses, including but not limited to FMRCo’s investment strategy, security coverage, experience, growth of assets under management, stability of management, governance program, and trading and operational capabilities. Strategic Advisers will evaluate FMRCo’s adherence to the investment guidelines not less than semiannually based on the factors described above. Strategic Advisers, in its sole discretion, can replace FMRCo without prior notice to clients if, for example, Strategic Advisers determines that FMRCo is not adhering to the investment guidelines for the Dividend Income Strategy. Additionally, a Model Portfolio provided by FMRCo could reflect trading decisions previously made by FMRCo for its discretionary client accounts and funds. As a result, Dividend Income Strategy, International Strategy, and U.S. Large Cap Strategy Program Accounts could receive prices that are more favorable or less favorable than the prices obtained by FMRCo’s discretionary client accounts and funds, particularly with respect to thinly traded securities. Aggregate holding limits and other investment limits applicable to such prior trading decisions, and collectively to the discretionary accounts of FMRCo, Strategic Advisers, and their affiliates generally, could result in investment opportunities not being included in a Model Portfolio. Strategic Advisers does not have a predetermined allocation with respect to the use of Fidelity or non-Fidelity model providers. To the extent that Strategic Advisers retains a Fidelity model provider, Fidelity will retain more compensation than if a non-Fidelity model provider were retained, and Fidelity will achieve greater efficiencies and economies of scale with respect to the research and management services that it provides to clients. Therefore, the use of a Fidelity model provider presents a conflict of interest. Strategic Advisers’ investment professionals are not compensated based on the use of Fidelity or non-Fidelity model providers. About Tax-Smart Investing Techniques. While each Strategy uses tax-smart investing techniques in taxable accounts, please note that the stated investment objective is of primary importance. Accordingly, the application of tax-smart investing techniques is a secondary consideration. Clients in these Strategies should understand that significant tax consequences can result from investing in a Strategy with a primary focus other than tax-smart investing techniques. For example, each Strategy has a corresponding investable universe of investments that has been constructed by Strategic Advisers. With respect to the Environmental Focus Strategy, stocks used to fund a Program Account that are not included in the environmentally screened investable universe for the Strategy will be sold without regard to potential tax consequences of such sales. Realizing gains could create a tax liability, particularly when offsetting losses are not available. Strategic Advisers cannot guarantee the effectiveness of its tax-smart investing techniques in serving to reduce or minimize a client’s overall tax liability or the tax results of a given transaction, and Strategic Advisers does not take direction from a client on when to take gains or losses from the client’s taxable Program Account. Over the long run, tax-smart investing techniques are intended to contribute to helping clients reach their investment goals. However, Strategic Advisers can implement trades in accounts that trigger significant tax consequences in seeking to manage the Program Accounts consistently with long-term strategy investment objectives. The potential federal income tax consequences of holding, buying, and selling securities are considered as part of the investment services, but we do not consider state or local taxes; foreign taxes, including those applied to dividends and any potential reclaim; federal tax rules applicable to entities; or estate, gift, or generation-skipping taxes. The tax-smart investing techniques Strategic Advisers uses when it makes trading decisions to buy, hold, or sell securities for a client’s taxable Program Account, will vary depending on the size of the Program Account and the investment strategy selected. The tax-smart investing techniques referenced throughout this brochure refer to one or more of the following: 18  Ability to harvest tax losses. Individual stock positions can experience price declines, possibly below a client’s adjusted tax basis in the security (as determined by the tax basis information on record for the client’s Program Account). In such instances, losses could be realized in the client’s Program Account for tax purposes. In cases where a position is sold to realize a capital loss for tax purposes, the position usually will be replaced with one or a combination of investments we believe will maintain comparable market exposure. In harvesting tax losses, Strategic Advisers does not attempt to harvest every potential tax loss that occurs in the client’s taxable Program Account and will consider factors such as investment risk, available comparable investment alternatives, and potential wash sales when deciding whether to harvest tax losses. Strategic Advisers considers the potential application of the wash-sale rules when evaluating transactions in taxable Program Accounts. However, clients should understand that Strategic Advisers does not prevent or avoid wash sales in all cases. The wash-sale rule requires taxpayers to defer losses that would otherwise be realized if the taxpayer acquires a substantially identical investment 30 days before or after the sale. While Strategic Advisers considers whether its trading in taxable Program Accounts may trigger the wash-sale rules, we will nevertheless engage in transactions that are potentially subject to the wash-sale rules if we determine that such transactions are consistent with the investment objective of the Strategy. Strategic Advisers will monitor for wash sales within taxable Program Accounts. However, the wash-sale rule not only applies to investment transactions occurring in a taxable Program Account, but also to transactions occurring in other investment accounts, whether maintained at Fidelity or at another financial institution, which are held by the client, the client’s spouse, and certain entities controlled by the client and/or a spouse. As a result, clients can have wash sales arising from transactions within taxable Program Accounts as well as other accounts (whether maintained at Fidelity or another institution). The wash-sale rule is complex, and while Strategic Advisers seeks to monitor wash sales in taxable Program Accounts, clients are ultimately responsible for determining whether the wash-sale rules apply to any particular transaction in their Program Accounts or in their other investment accounts. Clients should consult their tax advisors with respect to the application of the wash-sale rules based on their individual circumstances. Opportunities to avoid and/or postpone capital gain realizations. If there are specific lots of securities in a client’s Program Account—a block of shares bought at a particular time at a particular price—lots are reviewed and the potential federal income tax burden associated with selling that lot is weighed against the potential investment merits of the sale, such as performance potential, added diversification, and support of risk- management strategies. Once Strategic Advisers decides to sell an eligible security, it will attempt to sell the lot(s) that will generate the lowest overall federal income tax burden (or generate a loss for tax purposes) using the tax basis and holding period information on record, with a preference for long-term capital gains over short-term capital gains. For additional considerations related to tax-smart investing techniques, please see the disclosure below under “Opening and Funding a Program Account.” Fractional Share Investing Each Strategy can invest in fractional shares of individual securities. Clients should be aware that the use of fractional shares can result in the receipt of fewer dividends. Please note that any dividends received that are valued at less than $0.01 but that round up to $0.01 will be credited to a Program Account, but amounts that do not round up to $0.01 will not be distributed to the Program Account that held the fractional share. If any amount is not distributed and the aggregate value is less than or equal to $1.00 per security, it will be retained by NFS, and when it exceeds $1.00, it will be escheated to the state of Delaware. Also, with respect to proxy voting, clients are not able to vote a fractional share of an individual security; however, if clients elect to appoint Strategic Advisers as proxy voting agent on their behalf, such fractional shares can generally be voted because such fractional shares will be aggregated for purposes of proxy voting. Fractional shares cannot be transferred to an account outside of Fidelity; in such situations, the fractional share would need to be sold and a taxable gain or loss incurred. 19  Additional Information about Strategic Advisers’ Investment Practices Clients can generally fund their Program Accounts with Fidelity money market funds, certain stocks, and ADRs. Should a client elect to transfer eligible securities into a Program Account, those securities will be reviewed and evaluated by Strategic Advisers for possible incorporation into the client’s Program Account, but there can be no guarantee that any or all eligible securities transferred into a Program Account will be incorporated into the client’s Program Account. Strategic Advisers retains discretion to sell such eligible securities at any time and without prior notice to the client, and, by enrolling in the Program, the client acknowledges that Strategic Advisers can sell any such eligible securities at any time if they determine it is appropriate to do so, without prior notice to the client. For taxable Program Accounts, clients could realize a taxable gain or loss when those securities are sold, which could affect the after-tax performance/return of the Program Account as well as the clients’ tax liability. While Strategic Advisers does consider the potential tax consequences of the sale of eligible securities, the stated investment objective is of primary importance, and the application of tax-smart investing techniques is a secondary consideration. Accordingly, clients who fund a taxable Program Account with appreciated securities should understand that Strategic Advisers can sell such securities, notwithstanding that the sale could trigger significant tax consequences. Please contact a Fidelity representative for more information about opening and funding a Program Account. With respect to retirement Program Accounts enrolled in the Environmental Focus Strategy, the Dividend Income Strategy, the U.S. Large Cap Strategy and the International Strategy, Strategic Advisers generally does not consider the potential tax consequences of these sales. In addition, should a client transfer into a Program Account eligible securities that are not included in a Strategy’s investable universe, or that are part of the investable universe but do not align with Strategic Advisers’ investment allocation of such securities, Strategic Advisers will generally liquidate those securities in whole or in part as soon as reasonably practicable. From time to time, Strategic Advisers and/or its affiliates can determine that, as a result of regulatory require- ments that apply to Strategic Advisers and/or its affiliates due to investments in a particular country or in an issuer operating in a particular regulated industry, investments in the securities of issuers domiciled or listed on trading markets in that country or operating in that regulated industry above certain thresholds are impractical or undesirable. The foregoing limits and thresholds can apply at the Program Account level or in the aggregate across all accounts (or certain subsets of accounts) managed, sponsored, or owned by, or otherwise attributable to, Strategic Advisers and its affiliates. For investment risk management and other pur- poses, Strategic Advisers and its affiliates also generally apply internal aggregate limits on the amount of a particular issuer’s securities that can be owned by all such accounts. In such instances, investment flexibility can be restricted, and Strategic Advisers can limit or exclude a client’s investment in a particular issuer, which can include investment in related derivative instruments and investment flexibility will be restricted. To the extent that a Program Account already owns securities that directly or indirectly contribute to an ownership threshold being exceeded, Strategic Advisers could sell securities held in such Program Account in order to bring account-level and/or aggregate ownership below the relevant threshold. In the event that any such sales result in realized losses for a Program Account, that Program Account will bear such losses depending on the particular circumstances. MATERIAL RISKS Risks Associated with Investment Strategies. The discretionary investment management strategies implemented for Program clients involve risk of loss. Investments in a Program Account are not bank deposits and are not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. A client could lose money by investing in individual securities and mutual funds. A client could lose money by investing in a Program Account. Many factors affect each investment’s or Program Account’s performance and potential for loss. Strategies that pursue investments in equities will be subject to stock market volatility and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Strategies that pursue fixed income investments (such as bond or money market funds) will see values fluctuate in response to changes in interest rates, inflation and prepayment risks, as 20  well as default risks for both issuers and counterparties; changing interest rates, including rates that fall below zero, can have unpredictable effects on markets and can result in heightened market volatility. Developments that disrupt global economies and financial markets, such as wars, acts of terrorism, the spread of infectious illness or other public health issues, recessions, or other events, can magnify factors that affect performance. These strategies are also affected by impacts to the individual issuers, such as changes in an issuer’s credit quality, or changes in tax, regulatory, market, or economic developments. In addition, investments in certain bond structures are less liquid than other investments and therefore are more difficult to trade effectively. Municipal bond funds carry additional risks, which are discussed below. Nearly all investments or accounts are subject to volatility in non-U.S. markets, through either direct exposure or indirect effects in U.S. markets from events abroad. Those investments and accounts that are exposed to emerging markets are potentially subject to heightened volatility from greater social, economic, regulatory, and political uncertainties, as the extent of economic development, political stability, market depth, infrastructure, capitalization, and regulatory oversight can be less than in more developed markets. In addition to the risks identified above, a summary of additional risks follows: Risks of Equity Investments. Stock markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Different parts of the market can react differently to these developments. Value and growth stocks can perform differently from other types of stocks. For example, certain growth stocks can be more volatile than the market, and certain value stocks can continue to be undervalued by the market for long periods of time. In addition, stock investments could be subject to risk related to market capitalization as well as company-specific risk. Foreign securities are subject to interest rate, currency exchange rate, economic, regulatory, and political risks, all of which could be greater in emerging markets. Foreign Exposure. Investing in foreign securities and securities of U.S. entities with substantial foreign operations are subject to interest rate, currency exchange rate, economic, tax, operational, regulatory, and political risks, all of which are likely to be greater in emerging markets. These risks are particularly significant for investment strategies that focus on a single country or region or emerging markets. Foreign markets can be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile. Foreign markets can also offer less protection to investors than U.S. markets. For example, foreign issuers are generally not bound by uniform accounting, auditing, and financial reporting requirements and standards of practice comparable to those applicable to U.S. issuers. Adequate public information on foreign issuers might be unavailable, and it could be difficult to secure dividends and information regarding corporate actions on a timely basis. Regulatory enforcement can be influenced by economic or political concerns, and investors could have difficulty enforcing their legal rights in foreign countries. Foreign governments may decide to seize or confiscate securities held by foreign investors or assets held by foreign issuers, restrict an investor’s ability to sell or redeem securities, suspend or limit an issuer’s ability to make dividend or interest payments, and/or limit or entirely restrict repatriation of invested capital, profits, and dividends. Furthermore, investments in securities of foreign entities can result in clients owning an interest in a passive foreign investment company (“PFIC”). Clients holding an interest in a PFIC could be subject to additional tax liabilities and filing requirements as a result of such investments. The rules regarding investments in PFICs are complex, and clients are urged to consult their tax advisors. Risks of Investing in ADRs. ADRs are alternatives to directly purchasing foreign securities, but they are subject to many of the risks associated with investing directly in foreign securities. The depositary bank could charge fees for various services, including forwarding dividends and interest, and for corporate actions. Investing in ADRs could make it more difficult for U.S. persons to benefit from applicable tax treaty rates that could otherwise reduce withholding on any distributions from the underlying foreign issuer. Recovery of any extra foreign tax withheld can be costly and complex, and recovery could be unavailable for certain registration types, such as individual retirement accounts. 21  Risks and Limitations Associated with Tax-Smart Investing Techniques. Clients should understand that there are risks and limitations associated with the use of tax-smart investing techniques, and these limitations can result in tax-inefficient trades. The strategy investment objective is of primary importance, and Strategic Advisers will make changes to a Program Account even if such changes trigger significant tax consequences, including but not limited to wash sales and the realization of short- and long-term capital gains. Clients should consult their tax and/or legal advisor prior to enrolling in the Program as well as on an ongoing basis to determine whether the wash-sale rule or other special tax rules could apply to their tax situation, and to determine the efficacy of the tax-smart investing techniques to their current and future tax situation. Strategic Advisers relies on information a client provides in applying tax-smart investing techniques and does not offer tax advice. Strategic Advisers actively manages for federal income taxes, but does not actively manage for state or local taxes; foreign taxes, including those applied to dividends and any potential reclaim; federal tax rules applicable to entities; or estate, gift, or generation-skipping transfer taxes. In harvesting tax losses, Strategic Advisers does not attempt to harvest every potential tax loss that occurs in a taxable Program Account. Clients should also be aware that, in cases where a position is sold to realize a capital loss for tax purposes, Strategic Advisers can replace that position with one or a combination of investments designed to provide comparable market exposure, and it is important to understand that in a given year, due to investment decisions or market conditions, a client could receive varying levels of taxable distributions within a taxable Program Account. In general, Strategic Advisers will not sell merely to avoid a taxable distribution but, in fact, looks at the overall Program Account to determine the most appropriate action. There are implicit trading opportunity costs associated with the additional turnover, which can affect the returns on a client’s Program Account. A taxable Program Account will generally trade more frequently than a Program Account that is not managed using tax- smart investing techniques. There are implicit trading opportunity costs associated with the additional turnover, which can affect the returns on a client’s Program Account. It is important to note that the performance of any replacement investments will not be the same as that of the investment sold, and any replacement investments can perform worse than the investment that was sold. In addition, any tax-related benefits resulting from tax- smart investing techniques can be offset or even outweighed by investment losses and/or missed gains (realized and unrealized). Furthermore, there are not clear guidelines on what constitutes a “substantially identical” security to another ETP or mutual fund for purposes of the wash-sale rule. As such, there can be no guarantee that a replacement investment selected by Strategic Advisers will not be deemed “substantially identical” for purposes of the wash-sale rule. Although taxable Program Accounts seek to enhance after-tax returns, tax-smart investing techniques may not take into account all of the tax rules, regulations, and limitations applicable to a client’s particular facts and circumstances, which, in certain circumstances, will reduce the effectiveness of tax- smart investing techniques. Clients should understand that the benefits derived from any tax-smart investing techniques will likely be greater for clients in higher tax brackets. Since the value of offsetting capital gains or ordinary income is directly tied to the applicable federal capital gains or ordinary income tax rates, clients in lower federal capital gains and ordinary income tax rates experience reduced benefits relative to those in higher federal capital gains and ordinary income tax rates. Environmental Focus Investing Risk. Because of the subjective nature of environmentally sustainable investing, there can be no guarantee that environmental sustainability criteria used by Fidelity will reflect the beliefs or values of any particular client. The incorporation of environmental sustainability factors can affect a Program Account’s exposure to certain companies or industries and may not work as intended. Clients should understand that the application of environmental sustainability criteria does not mean that an Environmental Focus Strategy account will exclude any and all security issuers that are deemed to have negative environmental sustainability characteristics; rather, the application of environmental sustainability criteria is intended to create an investment universe that has a higher aggregate environmental rating, as measured by FMRCo, than the Large Cap Index. Investing based on environmental sustainability factors could cause an Environmental Focus Strategy Program Account to forgo certain investment opportunities available to Strategies that do not use such criteria. An account can underperform other investments that do not assess environmental sustainability factors or that use a different methodology to identify and/or incorporate environmental sustainability factors. Information regarding environmental practices is obtained through voluntary or third-party reporting, which 22  could be inaccurate or incomplete. Information used to evaluate environmental sustainability factors may not be readily available, complete, or accurate, and can vary across providers and issuers, as environmental sustainability is not uniformly defined. As a result, there is a risk that FMRCo could incorrectly assess a security or issuer. There is also a risk that Strategic Advisers or FMRCo does not apply the relevant environmental sustainability criteria correctly or that an account could have indirect exposure to issuers that do not meet the relevant environmental sustainability criteria used by such account. There could be limitations with respect to the readiness of environmental sustainability data in certain sectors as well as limited availability of investments with relevant environmental sustainability characteristics in certain sectors. FMRCo can change its environmental sustainability assessment of an issuer over time. Socially responsible norms differ by region. There is no assurance that the environmental sustainability investing strategy and techniques employed will be successful. Past performance is not a guarantee or reliable indicator of future results. Quantitative Investing. Securities selected using quantitative analysis can perform differently from the market as a whole as a result of the factors used in the analysis, the weight placed on each factor, changes to the factors’ behavior over time, market volatility, or the quantitative model’s assumption about market behavior. In addition, Strategic Advisers’ quantitative investment strategies rely on algorithmic processes and, therefore, are subject to the risks described below under the heading “Operational Risks.” To the extent that the quantitative models fail to adequately match the risk and return profile of a referenced index used in managing a particular Strategy, a Program Account could perform differently; it could underperform, or it could outperform the corresponding reference index on a pretax basis. In addition, to the extent that the components of the corresponding reference index perform in a highly correlated fashion, the Strategy could be less effective at harvesting the tax losses on which the after-tax portion of the Strategy relies. Money Market Fund Risk. A client could lose money by investing in a money market fund. Although a money market fund seeks to preserve the value of a client’s investment at $1.00 per share, it cannot guarantee it will do so. An investment in a money market fund is not a bank account and is not insured or guaranteed by the FDIC or any other government agency. Fidelity, the sponsor of Fidelity’s money market funds, is not required to reimburse money market funds for losses, and a client should not expect that Fidelity will provide financial support to a Fidelity money market fund at any time, including during periods of market stress. Fidelity’s government and U.S. Treasury money market funds will not impose a fee upon the sale of a client’s shares. ETPs. An ETP is a security that trades on an exchange and can seek to track an index, a commodity, or a basket of assets. ETPs can be actively or passively managed. The performance of a passively managed ETP might not correlate with the performance of the asset it seeks to track. ETPs trade on secondary markets or exchanges and are exposed to market volatility and the risks of the ETP’s underlying securities. ETPs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Investment Research Risks and Limitations. The investment research process employed by Strategic Advisers includes gathering, cleaning, culling, and analyzing large amounts of data from external public sources and/ or third-party data providers, including, in some instances, through the use of generative artificial intelligence (“AI”) and large language models (“LLM”). It is not possible or practicable, however, to factor all relevant, available data into economic forecasts or trading decisions. In addition, due to the automated nature of this data gathering and the fact that much of this data comes from third-party sources, it is inevitable that not all desired or relevant data will be available to, or processed by, Strategic Advisers at all times. Clients should be aware that there is no guarantee that the data used in generating forecasts or making trading decisions will be the most accurate data available or even free of errors. Furthermore, the use of AI and LLMs may require training of the models to be used in the research process and proper engagement by analysts in order to yield the desired outcome. There can be no guarantee that LLMs can be trained to address all scenarios or that they will provide complete and accurate responses in all situations. AI and LLMs are subject to various risks, including (i) the data used to train LLMs suffers inaccuracies, biases, or flaws that may cause the AI model to respond other than as intended; (ii) weak controls in the development and use of AI allow it to be deployed for use cases for which it was not intended; and (iii) the AI may provide inaccurate or fabricated responses to queries it is unable to process. Fidelity has adopted a Generative AI policy and governance framework so that the use 23  of AI and LLMs is targeted and limited, and that AI and LLMs are trained using known and appropriate data sources and are subject to controls and oversight, which helps ensure that the use of AI and LLMs is but one input into the research process. Clients should assume that the foregoing limitation and risks associated with gathering, cleaning, culling, and analysis of large amounts of data from third-party, other external sources, and the use of AI and LLMs, are an inherent part of investing. There may also be incidents where data fails to load or internal systems fail to retrieve or capture the data, for example, because of changes in the vendor’s or our system configurations due to upgrades, enhancements, maintenance or errors, or that LLMs provide incorrect information in response to certain prompts. Clients should assume that these data errors, like other system implementation errors, and their ensuing risks and impact are an inherent part of investing. Accordingly, unless otherwise required to do so, Strategic Advisers does not expect to disclose discovered data errors to clients. Cybersecurity Risk. With the increased use of technologies to conduct business, Strategic Advisers and its affiliates are susceptible to operational, information security, and related risks. These risks could include events that are wholly or partially beyond our control and may have a negative effect on our ability to conduct business activities. We believe that we have taken reasonable steps to mitigate these risks, but do not believe that we can eliminate them altogether. In general, cyber incidents can result from deliberate attacks or unintentional events that can arise from external or internal sources. Cyberattacks include but are not limited to gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software coding) for purposes of misappropriating assets or sensitive information; corrupting data, equipment, or systems; and causing operational disruption. Cyberattacks can also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). Cyber incidents affecting Strategic Advisers, its affiliates, or any other service providers (including but not limited to accountants, custodians, transfer agents, and financial intermediaries used by Fidelity or by an issuer of securities) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, interference with the ability to calculate the net asset value (“NAV”), impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities in which an account invests, counterparties with which an account engages in transactions, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. Legislative and Regulatory Risk. Investments in a Program Account could be adversely affected by new (or revised) laws or regulations. Changes to laws or regulations could impact the securities markets as a whole, specific industries, individual issuers of securities, and a sub-advisor’s determinations with respect to the expected rate of return, value, or creditworthiness of a particular security. Generally, the impact of these changes will not be fully known for some time. Operational Risks. Operational risks can include risk of loss arising from failures in internal processes, people, or systems, such as routine processing incidents or major systems failures, or from external events, such as exchange outages. Strategic Advisers uses algorithms in support of its discretionary portfolio management processes, which can contribute to operational risks. For example, algorithms are used as part of the process whereby Strategic Advisers recommends an appropriate asset allocation that corresponds to a level of risk consistent with a client’s Profile Information. In providing financial planning services, algorithms are used in analyzing the potential for success of a client’s financial plan. A sub-advisor can use algorithms in support of its discretionary portfolio management process. There is a risk that the data input into the algorithms could have errors, omissions, or imperfections, or that the algorithms do not operate as intended (generally referred to as “processing incidents”). Any decisions made in reliance on incorrect data or algorithms that do not operate as intended can expose Program Accounts to potential risks. Issues in the algorithm are often extremely difficult to detect and could go undetected for long periods of time or never be detected. These risks are mitigated by testing and human oversight of the algorithms and their output. We believe that the oversight and testing performed on our algorithms and their output will enable us to identify and address issues appropriately. 24  However, there is no assurance that the algorithms will always work as intended. In general, we will not assess each Program Account individually, nor will we override the outcome of the algorithm with respect to any particular Program Account. Not all processing incidents arising from operational failures, including those resulting from the mistakes of third parties, will be compensable by Strategic Advisers to clients, depending on the applicable facts and circumstances. Strategic Advisers maintains policies and procedures that address the identification and resolution of processing incidents, consistent with applicable standards of care, to ensure that clients are treated fairly when a processing incident has been detected. The determination of whether, and how, to address a processing incident is made by Strategic Advisers or its affiliates, in their sole discretion. Processing incidents will be reviewed to determine whether there was a financial impact on a client’s Program Account based on, among other things, the relevant investment strategy, and to evaluate the materiality of the impact. If we determine that a material financial impact has occurred, we will make an appropriate correction or otherwise reimburse the Program Account in an amount Strategic Advisers or its affiliates determines is appropriate based on all relevant circumstances. Typically, processing incidents that result in a financial impact of less than $10 per Program Account are not considered material. Other examples of impact that could affect the performance of a Program Account but would likely not be material include impacts arising from computer, communications, data processing, network, cloud computing, backup, business continuity or other operating, information, or technology systems, including those we outsource to other providers, failing to operate as planned or becoming disabled, overloaded, or damaged as a result of a number of factors. These factors could include events that are wholly or partially beyond our control and could have a negative impact on our ability to conduct business activities. Though losses arising from operating, information, or technology systems failures could adversely affect the performance of a Program Account, such losses would likely not be reimbursable under Strategic Advisers’ policies and procedures. Past performance is not a guarantee of future returns. Investing in securities and other investments involves a risk of loss that a client should understand and be willing to bear. Voting Client Securities Strategic Advisers does not generally acquire authority for, or exercise, proxy voting on a client’s behalf in connection with managing Program Accounts. Unless a client directs Strategic Advisers otherwise pursuant to the paragraph below, the client will receive proxy materials directly from the issuer of the security (or its service provider). Strategic Advisers will not advise clients on the voting of proxies. Clients must exercise any proxy voting directly. Notwithstanding the information above, a client can direct Strategic Advisers to act as agent to vote proxies on the client’s behalf for the funds and other securities held in Program Accounts. For Fidelity Funds, clients who make such a direction must instruct Strategic Advisers to vote proxies of a Fidelity Fund in the same proportion as the vote of all other holders of such Fidelity Fund. For other securities, such clients must instruct Strategic Advisers to vote proxies pursuant to the directions provided by ISS, an unaffiliated third-party proxy advisory services provider. Please note that, unlike general proxy votes, Strategic Advisers generally treats certain voluntary corporate actions as subject to the exercise of its discretion as an investment manager. Accordingly, Strategic Advisers will make decisions with respect to voluntary corporate actions directly as part of the investment management services it provides to Program Accounts. However, clients retain the right to make elections with respect to voluntary corporate actions if they so choose; if a client would like to make an election with respect to a security subject to a voluntary corporate action, the client will need to contact us to transfer the security out of the client’s Program Account. In connection with this election, a client must acknowledge that Strategic Advisers is acting solely at the client’s direction, and does not exercise discretion with respect to the voting of any proxy. Clients receive information about ISS’ proxy voting policies in the summary of ISS’ proxy voting guidelines available at Fidelity.com/information. In some instances, ISS will be unable to provide proxy voting directions, in which case Strategic Advisers will not vote such proxy because it does not have discretion to 25  determine how proxies are voted. To obtain a copy of ISS’ summary proxy voting guidelines or information on how investment proxies were voted, please contact a Fidelity representative. In addition, a client can request that Strategic Advisers act as agent for receipt of certain legally required communications, including prospectuses, annual and semiannual reports, and proxy materials for mutual funds that are not managed by FMRCo or an affiliate thereof, and other individual securities. Clients should be aware that, to the extent that a Program Account holds a fractional share of an individual security, they will not be able to vote the fractional share; however, where Strategic Advisers is acting as proxy voting agent on the client’s behalf, such fractional share can generally be voted. In addition, clients are not able to take any discretionary or voluntary corporate action with respect to any fractional share position. C L I E N T I N F O R M A T I O N P R O V I D E D T O   P O R T F O L I O   M A N A G E R S Strategic Advisers has access to the relevant Program Account information, including Profile Information and, for accounts managed with tax-smart investing techniques, information on record with Strategic Advisers regarding the client’s tax situation and the tax characteristics of the securities in the client’s Program Account. The discretionary portfolio management services will be affected by incomplete or inaccurate information. If changes to a client’s personal, financial, or tax situation occur, the client should promptly update their Profile Information online using the Program website. C L I E N T C O N T A C T W I T H P O R T F O L I O M A N A G E R S Clients can visit the Program website at any time to access detailed information about their Program Accounts or to update their Profile Information. While Strategic Advisers can provide clients with information about the management of Program Accounts from time to time, Strategic Advisers does not typically meet with or communicate directly with Program clients. A D D I T I O N A L I N F O R M A T I O N Custody Clients must establish and maintain a brokerage account with FBS to participate in the Program, and NFS serves as the qualified custodian for Program Accounts. Clients should carefully review all statements and other communications received from NFS and FBS. NFS and FBS are broker-dealers and affiliates of Strategic Advisers. Strategic Advisers is deemed to have custody under the Advisers Act because its affiliate NFS serves as qualified custodian for Program Accounts. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Strategic Advisers’ advisory business or the integrity of its management personnel. Other Financial Industry Activities and Affiliations Strategic Advisers is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is a wholly owned subsidiary of FMR LLC. FMR LLC is a Delaware limited liability company that, together with its affiliates and subsidiaries, is generally known to the public as Fidelity Investments or Fidelity. Various direct or indirect subsidiaries of FMR LLC are engaged in investment advisory, brokerage, banking, or insurance businesses. From time to time, Strategic Advisers and its clients will have material business relationships with any of the subsidiaries and affiliates of FMR LLC. In addition, the principal officers of Strategic Advisers serve as officers and/or employees of affiliated companies that are engaged in various aspects of the financial services industry. 26  Strategic Advisers is not registered as a broker-dealer, futures commission merchant, or commodity trading advisor, nor does it have an application pending to register as such. Strategic Advisers is registered with the U.S. Commodity Futures Trading Commission (“CFTC”) under the Commodity Exchange Act of 1936, as amended (“CEA”), as a commodity pool operator (“CPO”) and is a member of the National Futures Association (“NFA”). Certain personnel of Strategic Advisers, FBS, and NFS share premises and have common supervision. Certain management persons of Strategic Advisers are registered representatives of FBS, a Strategic Advisers affiliate and a registered broker-dealer. In addition, Strategic Advisers has entered into an intercompany agreement with FBS, pursuant to which FBS provides to Strategic Advisers various operational, administrative, analytical, and technical services, and the personnel necessary for the performance of such services. Strategic Advisers has, and its clients could have, a material relationship with the following affiliated companies: Investment Companies and Investment Advisers • Fidelity Management & Research Company LLC (“FMRCo”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FMRCo provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FMRCo acts as sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients and provides model portfolio recommendations and environmental filtering services to Strategic Advisers in connection with Strategic Advisers’ provision of discretionary portfolio management to certain clients. Strategic Advisers pays FMRCo an administrative fee for handling the business affairs of the registered investment companies advised by Strategic Advisers, and Strategic Advisers compensates FMRCo for making certain mutual funds available to managed account programs offered by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FMRCo. • Fidelity Institutional Wealth Adviser LLC (“FIWA”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FIWA provides nondiscretionary investment management services and sponsors the Fidelity Managed Account Xchange® and Fidelity Managed Account Xchange programs (turnkey asset management programs made available to financial intermediaries). Strategic Advisers provides model portfolio services to FIWA in connection with FIWA’s services to its institutional and intermediary clients, and FIWA compensates Strategic Advisers for such services. In addition, Strategic Advisers shares employees from time to time with FIWA. • FIAM LLC (“FIAM”), a wholly owned subsidiary of FIAM Holdings LLC, which in turn is wholly owned by FMR LLC, is a registered investment adviser under the Advisers Act and is registered with the Central Bank of Ireland. FIAM provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. Strategic Advisers has sub-advisory agreements with FIAM for certain registered investment companies advised by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FIAM. • FMR Investment Management (UK) Limited (“FMR UK”), an indirect, wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act, has been authorized by the U.K. Financial Conduct Authority to provide investment advisory and portfolio management services, and is registered with the Central Bank of Ireland. FMR UK provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR UK for certain registered investment companies advised by Strategic Advisers. • Fidelity Management & Research (Japan) Limited (“FMR Japan”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Japan Financial Services Agency (Kanto Local Finance Bureau) to provide investment advisory and discretionary investment management services. FMR Japan provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Japan for certain registered investment companies advised by Strategic Advisers. 27  • Fidelity Management & Research (Hong Kong) Limited (“FMR Hong Kong”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Hong Kong Securities & Futures Commission to advise on securities, deal in futures contracts, provide asset management services, and conduct trading services. FMR Hong Kong provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Hong Kong for certain registered investment companies advised by Strategic Advisers. • Fidelity Diversifying Solutions LLC (“FDS”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FDS is registered with the CFTC under the CEA as a CPO and as a commodity trading advisor. FDS is a member of the NFA. FDS provides discretionary advisory and sub-advisory services. FDS acts as a sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients. Broker-Dealers • Fidelity Distributors Company LLC (“FDC”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Securities Exchange Act of 1934 (the “Exchange Act”). FDC acts as principal underwriter of business development companies and the registered investment companies in the Fidelity group of funds, and also markets those funds and other products to third-party financial intermediaries and certain institutional investors. • National Financial Services LLC (“NFS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. NFS is a fully disclosed clearing broker-dealer that provides clearing, settlement, and execution services for other broker-dealers, including its affiliate FBS. Fidelity Capital Markets (“FCM”), a division of NFS, provides trade executions for Fidelity affiliates and other clients. Additionally, FCM operates CrossStream®, an alternative trading system (“ATS”) that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. CrossStream is used to execute transactions for investment company and other clients. NFS provides transfer agent or subtransfer agent services and other custodial services to certain Fidelity clients. • LeveL Markets, LLC, a registered broker-dealer and operator of two ATSs, the Luminex ATS and the LeveL ATS, which allow orders submitted by subscribers to be crossed against orders submitted by other subscribers. LeveL Holdings, LLC, owns LeveL Markets, LLC. Fidelity Global Brokerage Group, Inc., and FMR Sakura Holdings, Inc., each a wholly owned subsidiary of FMR LLC, have membership interests in LeveL Holdings, LLC, along with other members. LeveL Markets, LLC, charges a commission to both sides of each trade executed in the Luminex ATS and LeveL ATS. Luminex ATS and LeveL ATS are used to execute transactions for Fidelity affiliates’ investment company and other advisory clients. NFS serves as a clearing agent for transactions executed in the Luminex ATS and LeveL ATS. • Fidelity Brokerage Services LLC (“FBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act and provides brokerage products and services, including the sale of shares of registered investment companies in the Fidelity group of funds to individuals and institutions, including retirement plans, and acts as placement agent for certain privately offered investment funds advised by Strategic Advisers’ affiliates. In addition, along with Fidelity Insurance Agency, Inc. (“FIA”), FBS distributes variable insurance products that are issued by Fidelity Investments Life Insurance Company (“FILI”) and Empire Fidelity Investments Life Insurance Company® (“EFILI”), both Fidelity affiliates, as well as by third parties. FBS provides shareholder services to certain of Fidelity’s clients. FBS is the introducing broker for managed accounts offered by Strategic Advisers and places orders for execution with its affiliated clearing broker, NFS. • Digital Brokerage Services LLC (“DBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. DBS provides securities brokerage to retail customers through a digital mobile application–based brokerage platform. DBS receives remuneration from FMRCo for expenses incurred in servicing and marketing FMRCo products. 28  Insurance Companies or Agencies • FILI, a wholly owned subsidiary of FMR LLC, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates. • EFILI, a wholly owned subsidiary of FILI, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates to residents of New York. • FIA, a wholly owned subsidiary of FMR LLC, is engaged in the business of selling life insurance and annuity products of affiliated and unaffiliated insurance companies. Banking Institutions • Fidelity Management Trust Company (“FMTC”), a wholly owned subsidiary of FMTC Holdings LLC, which in turn is wholly owned by FMR LLC, is a limited-purpose trust company organized and operating under the laws of the Commonwealth of Massachusetts that provides nondiscretionary trustee and custodial services to employee benefit plans and IRAs through which individuals can invest in affiliated or unaffiliated registered investment companies. FMTC also provides discretionary investment management services to institutional clients. • Fidelity Personal Trust Company, FSB, a wholly owned subsidiary of Fidelity Thrift Holding Company, Inc., which in turn is wholly owned by FMR LLC, is a federal savings bank that offers fiduciary services that include trustee or co-trustee services, custody, principal and income accounting, investment management services, and recordkeeping and administration. Limited Partnerships and Limited Liability Company Investments Strategic Advisers provides discretionary investment management to partnerships and limited liability companies designed to facilitate acquisitions by mutual funds offered by Strategic Advisers. These funds are privately offered consistent with stated investment objectives. Strategic Advisers does not currently engage in borrowing, lending, purchasing securities on margin, short selling, or trading in commodities. Participating Affiliate Certain employees of Fidelity Strategic Advisers Ireland, Limited (“Strategic Ireland”), can from time to time provide certain services, including but not limited to research, operations, and investment management support services for Strategic Advisers, which Strategic Advisers could use for its clients. Strategic Ireland is not registered as an investment adviser under the Advisers Act and is deemed to be a “Participating Affiliate” of Strategic Advisers (as this term has been used by the SEC’s Division of Investment Management in various no-action letters granting relief from the Advisers Act’s registration requirement for certain affiliates of registered investment advisers). Strategic Advisers deems Strategic Ireland and each of the Strategic Ireland Associated Employees as “associated persons” of Strategic Advisers within the meaning of Section 202(a)(17) of the Advisers Act. Strategic Ireland Associated Employees and Strategic Ireland through such employees can contribute to Strategic Advisers’ research process and could have access to information concerning securities that are being selected for clients prior to the effective implementation of such selections. As a Participating Affiliate of Strategic Advisers, Strategic Ireland has agreed to submit itself to the jurisdiction of United States courts for actions arising under United States securities laws in connection with investment advisory activities conducted for Strategic Advisers’ clients. Strategic Advisers maintains a list of Strategic Ireland Associated Employees whom Strategic Ireland has deemed associated persons, and Strategic Advisers will make the list available to its current U.S. clients upon request. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Strategic Advisers has adopted a Code of Ethics for Personal Trading (the “Code of Ethics”). The Code of Ethics applies to all officers, directors, employees, and other supervised persons of Strategic Advisers and requires that they place the interests of Strategic Advisers’ clients above their own. The Code of Ethics establishes 29  securities transaction requirements for all covered employees and their covered persons, including their spouses. More specifically, the Code of Ethics contains provisions requiring the following: • Standards of general business conduct reflecting the investment advisers’ fiduciary obligations; • Compliance with applicable federal securities laws; • Employees and their covered persons to move their covered accounts to FBS unless an exception exists or prior approval has been granted; • Reporting and review of personal securities transactions and holdings for persons with access to certain nonpublic information; • Prohibition of purchasing securities in initial public offerings unless an exception has been approved; • Reporting of Code of Ethics violations; and • Distribution of the Code of Ethics to all supervised persons, documented through acknowledgments of receipt. Core features of the Code of Ethics generally apply to all Fidelity employees. The Code of Ethics also imposes additional restrictions and reporting obligations on certain advisory personnel, research analysts, and portfolio managers. Such restrictions and reporting obligations include the following: • The preclearing of transactions in covered securities with limited exceptions; • A prohibition on investments in limited offerings without prior approval; • A prohibition on personal trading by a portfolio manager within seven days before or after a trade in any covered security of the same issuer by a fund or account managed by such portfolio manager except in limited circumstances; • The reporting of transactions in covered securities on a quarterly basis with limited exceptions; • The reporting of securities accounts and holdings of covered securities at the time of hire and annually thereafter; and • The disgorgement of profits from short-term transactions with limited exceptions. Violation of the Code of Ethics requirements can also result in the imposition of remedial action. The Code of Ethics will generally be supplemented by other relevant Fidelity policies, including the Policy on Inside Information, Rules for Broker-Dealer Employees, and other written policies and procedures adopted by Fidelity and Strategic Advisers. A copy of the Code of Ethics will be provided to any client or prospective client on request. From time to time, Strategic Advisers and its related persons can buy or sell securities for themselves and recommend those securities to clients. The conflicts of interest involved in such activities are contemplated in the Code of Ethics and other relevant Fidelity policies. In particular, the Code of Ethics and other Fidelity policies are designed to make it clear to Fidelity personnel that they should never place their personal interests ahead of Fidelity’s clients in an attempt to benefit themselves or another party. The Code of Ethics and other Fidelity policies impose sanctions if these requirements are violated. From time to time, in connection with our business, certain supervised persons obtain material nonpublic information that is usually not available to other investors or the general public. In compliance with applicable laws, Strategic Advisers has adopted a comprehensive set of policies and procedures that prohibits the use of material nonpublic information by investment professionals or any other employees and that limits the transactions that Strategic Advisers can implement for Program Accounts. In addition, Fidelity has implemented a Corporate Gifts & Entertainment Policy intended to set standards for business entertainment and the giving or receiving of gifts, to help employees make sound decisions with respect to these activities, and to ensure that the interests of Strategic Advisers’ clients come first. Similarly, to support compliance with applicable “pay to play” laws, Fidelity has adopted a Personal Political Contributions 30  & Activities Policy that requires employees to preclear any political contributions and activities. Fidelity also has a Global Anti-Corruption Policy regarding commercial bribery and bribery of government officials that prohibits directly or indirectly giving, offering, authorizing, promising, accepting, or receiving any bribe, facilitation payment, kickback, or payoff (whether in cash or any other form) with the intent to improperly obtain or retain business or any improper advantage. B R O K E R A G E P R A C T I C E S Broker Selection and Transactions in Program Accounts Strategic Advisers has a duty to seek best execution for transactions in client accounts. Strategic Advisers will place trades for Program Accounts with affiliated or unaffiliated registered broker-dealers (“brokers”) and may choose to execute an order using electronic channels (including broker-sponsored algorithms) or by manually working an order with a broker. In selecting brokers, Strategic Advisers may consider a range of factors deemed relevant in the context of a particular trade, including but not limited to price; costs; the size, nature, and type of the order; speed of execution; financial condition and reputation of the broker; broker-specific considerations (e.g., not all brokers are able to execute all types of trades); broker willingness to commit capital; our trader’s assessment of whether and how closely the broker will follow our instructions; and confidentiality and the potential for information leakage. As described above in Fees and Compensation, the Program’s Advisory Fee includes the cost of commissions associated with transactions executed through affiliated brokers. As a result, most trades for Program Accounts that involve equity securities and other securities where commissions are charged will be executed with Strategic Advisers’ affiliated broker, NFS. However, Strategic Advisers has the authority to execute transactions with an unaffiliated broker (also referred to as “trading away”) consistent with its duty to seek best execution. While the Program’s Advisory Fee does not include the cost of commissions for transactions executed through unaffiliated brokers, Strategic Advisers or its affiliate is voluntarily assuming the cost of commissions for transactions executed by unaffiliated brokers. As a result, Program clients are not charged commissions for such transactions. Strategic Advisers and its affiliates reserve the right to stop assuming the cost of commissions associated with trading away, subject to prior notice to Program clients. The Program Fee does not cover transaction charges for securities where the counterparty imposes a markup, markdown, and/or dealer spread. The net price of the security will include these transaction charges and Program Accounts will bear these costs. In seeking best execution for a transaction, Strategic Advisers will have no obligation to solicit competitive bids for each transaction and Strategic Advisers will not necessarily select the broker that charges the lowest available price or commission rate; however, Strategic Advisers believes that its policies, taking into consideration the factors stated above, are designed to result in transaction processing that is favorable to Program clients. Strategic Advisers conducts periodic reviews of trade execution. Although it is Strategic Advisers’ policy to treat each client’s account in a fair and equitable manner over time, there can be no assurance that all Program Accounts will receive the same execution and certain Program Accounts will experience a more or less favorable execution depending on market conditions. Please see the Fees and Compensation section above for further information about Program Fees, brokerage commissions, and additional fees for transactions in a Program Account. Trade Aggregation and Allocation Strategic Advisers’ policy is to treat each client’s account in a fair and equitable manner over time when aggregating and allocating orders for the purchase and sale of securities. While Strategic Advisers is under no obligation to aggregate orders for Program Accounts, in general, Strategic Advisers will choose to aggregate trades for Program Accounts and/or aggregate Program Account trades with trades for other client accounts (including certain proprietary accounts of Strategic Advisers or its affiliates and Fidelity employee accounts 31  managed by Strategic Advisers) when, in Strategic Advisers’ judgment, aggregation is in the best interest of all clients involved and it is operationally feasible to do so. Orders are aggregated into a “block trade” to facilitate seeking best execution, to negotiate more favorable commission rates, or to allocate equitably among clients the effects of any market fluctuations that might have otherwise occurred had these orders been placed independently. Aggregated orders are generally allocated on a pro rata basis among similarly situated client accounts participating in a block trade until the order is filled. Client accounts included in a block trade receive the same average price for the trade and shares are allocated according to the purchase and sale orders actually placed for each client account included in the block trade. Strategic Advisers can create multiple block trades for both buy and sell orders in the same security, and it is therefore possible that block trades will receive different prices depending on when the orders for each block trade are filled throughout the day. When a client account is not part of a block trade, that client account will receive a different price from the price obtained for Program Accounts that participate in the aggregated orders. If Strategic Advisers does not complete an order in a single day (e.g., when an aggregate order for client accounts exceeds the available supply or to minimize market impact), the partially filled order will be allocated on a pro rata basis among client accounts in the block. Strategic Advisers has adopted trade allocation policies for managing client accounts, including Program Accounts, designed to achieve fairness and not to purposefully disadvantage comparable client accounts over time when allocating purchases and sales. Cross Trades To the extent permitted by law and applicable policies and procedures, Strategic Advisers can (but is not obligated to) execute “agency cross trades” for Program Accounts. Agency cross trades are trades in which Strategic Advisers, or any person controlling, controlled by, or under common control with Strategic Advisers, acts as both investment adviser and broker for a client, and as broker for the party or parties on the other side of the trade. Agency cross trades will be executed in accordance with Section 206(3) of the Advisers Act, requiring written consent, confirmations of transactions, annual reporting, and compliance procedures. To the extent permitted by law and applicable policies and procedures, Strategic Advisers can (but is under no obligation to) execute “advisor cross trades” for Program Accounts when Strategic Advisers believes such trades are in the best interest of all clients involved. Advisor cross trades are trades in which Strategic Advisers, or an affiliate, acts as investment adviser to both clients involved in the trade. An advisor cross trade will be facilitated between client accounts either directly or through a broker-dealer, including FBS or NFS, and the relevant crossing value will be determined based on one or more third-party pricing services, actual market bids, and/or closing prices as reflected on a national securities exchange. Neither Strategic Advisers nor its affiliates will receive transaction-based compensation for advisor cross trades. There can be no assurance that agency or advisor cross trades will be executed, or that such transactions will be executed in a manner that is most favorable to each Program Account that is a party to such transaction. Not all Program Accounts participate in cross trades, and a client may opt out of cross trading by contacting a Fidelity representative. Cross trades can be beneficial to clients by reducing transaction costs, and Program Accounts excluded from cross trading could miss such potential benefits. Strategic Advisers and its affiliates will have a potentially conflicting division of loyalties and responsibilities regarding both parties to a crossing transaction, including with respect to the decision to enter into such transactions and the valuation and pricing of such transactions. Strategic Advisers has developed policies and procedures relating to such transactions and conflicts. Account Transaction Information When Strategic Advisers trades in a Program Account, unless Fidelity Personal Trust Company, FSB, is acting as trustee or co-trustee with respect to the Program Account, clients will receive a confirmation of such transac- tion from NFS, except with respect to automatic investments, automatic withdrawals, dividend reinvestments, and transactions that involve the core Fidelity money market fund where a client’s account statement serves 32  in lieu of a confirmation. Clients will receive statements from NFS that will provide holdings and transaction information, including trades, contributions, withdrawals, advisory fees, and estimated gain/loss and tax basis information. Statements and confirmations are also available online at Fidelity.com and by enrolling in the electronic delivery program. Clients should carefully review all statements and other communications received from FBS and NFS. Clients will also receive a prospectus for any new mutual fund or ETP not previously held, unless the client has elected to have Strategic Advisers act as agent for the receipt of any non-Fidelity prospec- tuses. The routing details of a particular order will be provided on request, and an explanation of order routing practices will be provided on an annual basis. In addition, from time to time, Fidelity will provide aggregated trade execution data to clients and prospective clients. Soft Dollars Strategic Advisers does not have a soft dollar program and therefore does not consider the provision of research or brokerage as a criterion for broker selection. Client-Directed Brokerage Program Accounts are not available for brokerage activities outside of the activities directed by Strategic Advisers, including but not limited to margin trading or trading of securities by a client or any of the client’s designated agents. Review of Accounts Client Contact and Review of Personal Financial Situation We will contact Program clients at least annually to evaluate whether there have been any changes to their financial situation that could affect their Profile Information or the Program Services, including whether they wish to impose any reasonable restrictions on the management of the Program Account or reasonably modify any existing restrictions (the “Annual Review Process”). Clients should provide updated Profile Information any time there is a change to their goals, time horizon, tax situation, risk tolerance, or personal financial situation, even outside of the Annual Review Process. If we do not hear from a client during the Annual Review Process, we will update client information based on known information (e.g., client’s age, time horizon, and other date-relative elements of the client’s Profile Information), but we will otherwise assume that the client’s Profile Information has not changed. In some cases, the changes to this updated information will cause us to determine that a Strategy account is no longer appropriate for the client. In these instances, we will notify the client and begin the process of terminating the client’s participation in the Program. Clients will receive prompt confirmations from NFS for any transactions in their Program Accounts; however, with respect to automatic investments, automatic withdrawals, dividend reinvestments, and transactions that involve the core Fidelity money market fund, a client’s account statement serves in lieu of a confirmation. In addition, clients electronically receive statements from NFS that detail all holdings and transaction information, including trades, additions, withdrawals, shifts in investment allocations, advisory fees, and estimated gain/ loss and tax basis information. Statements and confirmations are also available online at Fidelity.com. Clients should carefully review all statements and other communications received from FBS and NFS. Strategic Advisers makes available account performance on a password-protected website. At least quarterly, we will also send each client a reminder to notify us of any change in their financial situation, investment objectives, or to impose reasonable restrictions on the management of their Program Accounts or reasonably modify any existing restrictions. Clients can access and update the Profile Information they have provided to us on the Program website. To assist in the evaluation of performance, clients will have access to information about the trading activity in their Program Account as well as information about the performance of their Program Accounts on a pretax basis. Pretax Program Account performance is calculated consistent with industry standards. In addition, clients will typically receive performance information comparing their Program Accounts with the performance of relevant industry standard indexes. Clients with taxable Program Accounts will also be provided with 33  performance information on an after-tax basis. After-tax Program Account performance is based on the pretax performance of the Program Account, and on an evaluation of the potential tax consequences of trading activity, dividends, income, and distributions in the Program Account. This after-tax performance information is based on information provided by the client about the client’s tax situation, the tax basis information related to the securities in the Program Account, and certain assumptions about the potential tax consequences of trading activity in the Program Account. Detailed information about the methodology and assumptions, and their related risks and limitations, used in calculating after-tax performance of a Program Account is provided on the Program website. While performance information is reviewed by Strategic Advisers for accuracy and compliance with applicable procedures, performance information is not reviewed or approved by a third party. Clients invested in the Environmental Focus Strategy will have access to certain sustainable investment reporting provided by FMRCo. This information is based on holdings of a Model Portfolio and a client’s Program Account. Such information will contain or be based on data compiled from third-party sources that FMRCo believes to be reliable, but neither FMRCo nor Strategic Advisers can guarantee the accuracy of any such third-party information. This information will be limited by the fact that issuers in the investment universe are not subject to reporting requirements for some of the Environmental Factors that FMRCo evaluates as part of its proprietary methodology. Sustainable investment reporting is provided for informational purposes only and should not be relied on by clients when making investment decisions or for any other purposes. Ongoing Review and Adjustments of Program Accounts On a daily basis, Strategic Advisers will evaluate a Program Account with respect to a variety of factors to determine whether the account could benefit from trading that day. Common reasons clients can experience trading in their Program Accounts include changes in the model or index, market fluctuations, tax management opportunities, and client-requested activities, such as cash deposits or withdrawals. Please note that Strategic Advisers uses the prior trading day’s closing prices in determining whether a Program Account requires trading on a given day, and in general does not attempt to conduct ongoing intraday Program Account evaluations, nor attempt to time intraday price fluctuations in its decisions to buy or sell securities. Strategic Advisers does not anticipate that each Program Account will be traded each day. Each of the securities purchased in a Program Account will appear on a client’s account statement. Securities selected for Program Accounts can be individually tailored based on a client’s existing holdings and unique financial situation and, where applicable, on the tax attributes of the assets in a Program Account. A client can expect that the securities that compose their Program Account can vary, perhaps significantly, from the securities purchased for another client’s Program Account managed using the same Strategy. There can be instances where we need to place a do-not-trade restriction on one or more Program Accounts, including when a client requests a security be transferred from a Program Account, when processing a trade correction, when we need to comply with a court order, when a client asks us to process a withdrawal and keep the proceeds from the sale of securities used to fund the withdrawal in the account until the client provides further instructions for the transfer of the proceeds, or when we need additional information from a client. For the period when a do-not-trade restriction is in effect, we will not trade or otherwise manage the Program Account until the do-not-trade restriction has been removed. Clients have periodic performance summaries or similar reports made available to them that detail the performance of a client’s Program Account(s) and summarize the market activity during the period. Industry standards are applied when calculating performance information. Strategic Advisers also makes available account performance information on a password-protected website. Client Referrals and Other Compensation Strategic Advisers and its affiliates are compensated for providing services, including for investment management, distribution, transfer agency, servicing, and custodial services, to certain Fidelity and non- Fidelity mutual funds, ETPs, and other investments in which Program Accounts are invested. These affiliates include FMRCo and its affiliates as the investment adviser for the Fidelity Funds; FDC as the underwriter of 34  the Fidelity Funds; and Fidelity Investments Institutional Operations Company LLC (“FIIOC”) as transfer agent for the Fidelity Funds, servicing agent for non-Fidelity mutual funds, and recordkeeper of certain workplace savings plans. Strategic Advisers and its affiliates also receive compensation and other benefits in connection with portfolio transactions executed on behalf of the Fidelity and non-Fidelity mutual funds, ETPs, and other investments. FMRCo and its affiliates also obtain brokerage or research services, consistent with Section 28(e) of the Exchange Act, from broker-dealers in connection with the execution of the Fidelity Funds’ portfolio security transactions. FBS and NFS receive compensation for executing portfolio transactions and providing, among other things, clearance, settlement, custodial, and other services to Fidelity and non-Fidelity mutual funds, ETPs, and other investments, and NFS provides securities lending agent services to certain Fidelity Funds for which it receives compensation. FBS, NFS, and FIIOC also offer Fidelity’s mutual fund platform, FundsNetwork®, and provide shareholder and other services (including, for a limited number of participants on the platform, the sharing of certain aggregated data regarding exchange-traded fund holdings in Program Accounts) to participating mutual funds and ETPs (or their sponsors) for which FBS, NFS, and FIIOC receive compensation, including with respect to those mutual funds in which Program Accounts are invested. Neither FBS nor NFS receives any compensation in connection with directing equity trades for Program Accounts to market makers for execution. We can execute trades through alternative trading systems or national securities exchanges, including ones in which a Fidelity affiliate has an ownership interest, such as Members Exchange, a registered national securities exchange. Any decision to execute a trade through an alternative trading system or exchange in which a Fidelity affiliate has an ownership interest would be made in accordance with applicable law, including best execution obligations. For trades placed on certain national securities exchanges, including ones in which a Fidelity affiliate has an ownership interest, Fidelity could receive exchange rebates from such trades for Program Accounts, and these rebates will be subject to the Credit Amount (as described in “Fees and Compensation”) and will be allocated, pro rata based on assets, among client Program Accounts. The compensation described above that is retained by Strategic Advisers or its affiliates as a direct result of investments by the Program Accounts in Fidelity and non-Fidelity mutual funds and ETPs will be included in the Credit Amount, which reduces the Gross Advisory Fee. However, to the extent that Strategic Advisers or its affiliates, including FBS, NFS, or FIIOC, receive compensation that is neither a direct result of, nor directly derived from, investments by the Program Accounts, such compensation is not included in the Credit Amount, does not reduce the Gross Advisory Fee, and will be retained by Strategic Advisers or affiliates. Receipt of compensation in addition to the Gross Advisory Fee creates a financial incentive for Strategic Advisers and its affiliates to select investments that will increase such compensation. Strategic Advisers seeks to address this financial conflict of interest through the application of the Credit Amount, which will reduce the Gross Advisory Fee, as applicable, and through personnel compensation arrangements (including those of Strategic Advisers’ investment professionals and Fidelity representatives) that are not differentiated based on the investments or share classes selected for Program Accounts. Strategic Advisers and its affiliates have also implemented processes reasonably designed to prevent the receipt of compensation from affecting the nature of the advice provided to Program Accounts. See “Fees and Compensation” for additional information. Client referrals are provided by affiliated entities, including FBS or other affiliates, pursuant to referral agreements where applicable. Additionally, Strategic Advisers refers clients to other independent investment advisers in connection with a referral program in which such independent investment advisers participate for a fee payable to Strategic Advisers. Financial Information Strategic Advisers does not solicit prepayment of client fees. Strategic Advisers is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. 35  FOR MORE INFORMATION, PLEASE CALL US TOLL-FREE AT 8 0 0 . 5 4 4 . 3 4 5 5 Monday through Friday, 8 a.m. to 7 p.m . Ea stern time Keep in mind that investing involves risk. The value of your investment will fluctuate over time, and you may gain or lose money. Diversification and asset allocation do not ensure a profit or guarantee against loss. Fidelity does not provide legal or tax advice, and the information provided is general in nature and should not be considered legal or tax advice. Consult an attorney, tax professional, or other advisor regarding your specific legal or tax situation. Indexes are unmanaged. It is not possible to invest directly in an index. The S&P 500 Index is a float-adjusted market capitalization–weighted index designed to reflect the performance of the stocks of the largest 500 U.S. companies based on float-adjusted market capitalization. The MSCI EAFE Index (Net MA Tax) is a float-adjusted market capitalization–weighted index designed to reflect the performance of the developed international equity market, including large-capitalization stocks. Index returns are adjusted for tax withholding rates applicable to U.S.-based mutual funds organized as Massachusetts business trusts. The Fidelity U.S. Large Cap Index is a float-adjusted market capitalization–weighted index designed to reflect the performance of the stocks of the largest 500 U.S. companies based on float-adjusted market capitalization. The Fidelity Developed International ex North America Focus Index (Net) is a float-adjusted market capitalization–weighted index designed to reflect the performance of the developed international equity market, including large-capitalization stocks. Index returns are adjusted for tax withholding rates applicable to U.S.-based mutual funds organized as Massachusetts business trusts. The Fidelity U.S. Total Investable Market Index is a float-adjusted market capitalization–weighted index designed to reflect the performance of U.S. equity market, including large-, mid-, and small-capitalization stocks. The Fidelity U.S. Low Volatility Focus Index represents the performance of a broad range of U.S. equities that in the aggregate have lower volatility relative to the broader U.S. equity market. Fidelity, Fidelity Investments, the Fidelity Investments logo, FundsNetwork, Fidelity Go, Fidelity Managed FidFolios, Fidelity Wealth Advisor Solutions, Empire Fidelity Investments Life Insurance Company, Fidelity Managed Account Xchange, and CrossStream are registered service marks of FMR LLC. Fidelity Brokerage Services LLC, Member NYSE, SIPC, 900 Salem Street, Smithfield, RI 02917 © 2026 FMR LLC. All rights reserved. 1011888.6.0 03/26 1.9904990.105 

Fidelity® Personalized Planning & Advice at Work Terms and Conditions Strategic Advisers LLC 155 Seaport Boulevard Boston, MA 02210-2698 866-811-6041 NetBenefits.com March 30, 2026 This brochure provides information about the qualifications and business practices of Strategic Advisers LLC (“Strategic Advisers”), a Fidelity Investments company, as well as information about Fidelity® Personalized Planning & Advice at Work. Throughout this brochure and related materials, Strategic Advisers refers to itself as a “registered investment adviser” or as being “registered.” These statements do not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please call us at 866-811-6041. The information in this brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Strategic Advisers is available on the SEC’s website at adviserinfo.sec.gov.  Summary of Material Changes The SEC requires registered investment advisers to provide and deliver an annual summary of material changes to their advisory services program brochure. The section below highlights only material revisions that have been made to the Fidelity® Personalized Planning & Advice at Work brochure from March 31, 2025, through March 30, 2026. Clients and prospective clients can obtain a copy of the Program Terms and Conditions without charge by visiting Fidelity.com/information, by visiting the SEC’s website at adviserinfo.sec.gov, or by calling a Fidelity representative at 866-811-6041. Capitalized terms are defined in the Program Terms and Conditions. Material Changes • There have been no material changes since the March 31, 2025, Terms and Conditions. Other Changes • Certain minor revisions have been made to the description of representative compensation and the associated conflicts in “Information about Fidelity and Fidelity Representative Compensation.” • Certain minor revisions have been made to the text that describes affiliates of Strategic Advisers in “Other Financial Industry Activities and Affiliations.” • Minor changes have been made to the text in the following sections: “Fees and Compensation;” “Methods of Analysis, Investment Strategies, and Risk of Loss;” “Review of Accounts;” “Client Referrals and Other Compensation;” “Custody;” and “Voting Client Securities.” 2  Table of Contents Page Summary of Material Changes ..................................................................................... 2 Advisory Business ........................................................................................................ 4 Fees and Compensation ............................................................................................ 13 Performance-Based Fees and Side-by-Side Management ........................................ 17 Types of Clients .......................................................................................................... 17 Methods of Analysis, Investment Strategies, and Risk of Loss .................................. 18 Disciplinary Information ............................................................................................. 30 Other Financial Industry Activities and Affiliations .................................................... 30 Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading .................................................................................................. 35 Brokerage Practices .................................................................................................... 36 Review of Accounts .................................................................................................... 36 Client Referrals and Other Compensation ................................................................ 37 Custody ...................................................................................................................... 38 Investment Discretion ................................................................................................ 39 Voting Client Securities .............................................................................................. 39 Financial Information ................................................................................................. 39 3  Terms and Conditions Important Information Advisory Business Fidelity® Personalized Planning & Advice at Work (“FPPA” or the “Program”) is a service of Strategic Advisers (sometimes referred to as “we,” “our,” or “us” throughout this document). Strategic Advisers is a registered investment adviser and an indirect, wholly owned subsidiary of FMR LLC (collectively with Strategic Advisers and its affiliates, “Fidelity Investments” or “Fidelity”). Strategic Advisers was formed in 1977 and offers retail and workplace investment programs, including FPPA. Strategic Advisers provides discretionary and nondiscretionary advisory services and acts as the investment manager to registered investment companies that invest in affiliated and unaffiliated funds. Strategic Advisers serves as the sponsor and discretionary manager to investment advisory programs. Strategic Advisers provides the discretionary and nondiscretionary advisory services (the “Program Services”) available through FPPA. As described below, the Program provides the discretionary investment management services of Strategic Advisers for your workplace savings plan account or assetized nonqualified deferred compensation account (“Plan Account,” and the managed portion referred to herein as the “Managed Account” or “Account”), as well as the participant* service, participant profiling, and nondiscretionary planning services of Strategic Advisers and its representatives (each a “Fidelity representative”). Your Managed Account assets will be invested in a portfolio constructed according to asset allocation and diversification principles. Your portfolio is expected to change from time to time based on your profile (described below), which is regularly evaluated. As described below, Strategic Advisers will identify an appropriate long- term asset allocation (also referred to as your “investment strategy”), which it will consider when investing your Managed Account in a portfolio (also referred to as your “Managed Account Allocation”) that consists of investments chosen from among the plan’s eligible investment options, which can include Fidelity Funds and/or non- Fidelity mutual funds. Strategic Advisers will have investment discretion over the investments in your Managed Account, and you will not be able to make any exchanges of assets held in your Managed Account or otherwise direct or restrict the management of such assets while enrolled. Through its discretionary authority, Strategic Advisers will invest eligible assets (both vested and non-vested) that are initially allocated to your Managed Account and your ongoing payroll contributions. Your Managed Account will regularly be evaluated for rebalancing and, to the extent that it is rebalanced, the investments in your Managed Account will change. Note that while you are enrolled in the Program, you remain eligible to sell unrestricted shares of applicable company stock (if any) and other Excluded Assets (described below) and to determine the portion of your pay to defer into your Plan Account. * Participants who enroll in the Program are sometimes referred to as “members” in materials associated with the Program. 4  In addition to the discretionary services provided as part of the Program, Strategic Advisers will provide nondiscretionary, web-based financial planning services, which you can obtain through NetBenefits.com or a Fidelity representative. Fidelity representatives are available Monday–Friday from 8:30 a.m. to 8:00 p.m. ET. Interests in the Digital Assets Account (“DAA”) are ineligible for management by FPPA. When you enroll in the Program, if you hold any plan investments, including DAA, that are not included in your proposed portfolio and are not Excluded Assets, they will be sold at the time your plan assets are rebalanced into your Managed Account Allocation. Please note that if a Fidelity representative recommends that you enroll in FPPA, it is because you would benefit from a diversified portfolio created from your workplace savings plan investment option lineup, which is actively managed through different market conditions for your specific retirement investment strategy. In addition, you prefer to have your investments managed so that the level of risk adjusts over time. Enrolling in the Program You can enroll in the Program online or through a Fidelity representative. Enrollment begins with Strategic Advisers identifying an investment strategy for your Managed Account. To develop this investment strategy, Strategic Advisers obtains initial information (“Initial Information”) from your plan sponsor (e.g., date of birth, estimated retirement age, Plan Account balance) and information about any other retirement- related accounts for which Fidelity is the recordkeeper (“Other Fidelity Retirement Account Assets”) as well as certain retirement benefit information recordkept at Fidelity and/or provided by a third party to Fidelity. You can, and we encourage you to, provide additional information about your financial situation and/or update the information provided by your plan sponsor through the Investor Profile Questionnaire, which includes questions about your risk tolerance, investment knowledge, investment experience, financial situation, contributions, estimated retirement expenses, etc. This information can be updated online at any time or through a Fidelity representative, and we encourage you to provide this information and keep it current so that we can further personalize an investment strategy for you. The information we use to provide Program Services is referred to as your “Personal Profile” herein. To the extent that you have not provided additional information through the Investor Profile Questionnaire, we will propose an investment strategy for you using your Initial Information and Other Fidelity Retirement Account Assets as well as certain retirement benefit information recordkept at Fidelity and/or provided by a third party to Fidelity along with assumed responses regarding risk tolerance, financial situation, investment knowledge, and investment experience, among other things, based on similarly aged investors in Fidelity’s programs and services (our “profiling assumptions”). We use a proprietary framework based on aggregate investor data to inform our profiling assumptions. You should understand that if you do not answer the questions about risk tolerance, emergency fund, financial situation, investment knowledge, investment experience, essential expenses, reaction to stock market decline, and income, for example, we will assume values for those responses. 5  Our profiling assumptions will generally assume that your risk tolerance decreases as you age; that your emergency fund, investment knowledge, and investment experience increase as you age; and that your income could increase or decrease depending on your age. It is important to understand that the profiling assumptions are periodically reviewed and updated based on the information we have about similarly aged investors. To the extent that the profiling assumptions affect our proposed investment strategy, an update in profiling assumptions can result in an update to your Managed Account. In some limited instances, information about you that we have on file will not be used for your Managed Account until you have confirmed its use via the Investor Profile Questionnaire. If you want to receive Program Services based on your specific information rather than our profiling assumptions, which we encourage, and to ensure that information about you that we have on file is used as part of your Personal Profile, please complete your Investor Profile Questionnaire at any time by going to NetBenefits.com or calling a Fidelity representative. In addition to accounting for Other Fidelity Retirement Account Assets as part of your Personal Profile, we can account for your other nonretirement recordkept assets and your other assets not recordkept at Fidelity (collectively, “Other Account Assets”). We encourage you to provide information regarding your Other Account Assets so that we can identify a more personalized investment strategy for you. This information can be provided to us at any time, including by authorizing a third-party service provider to provide us with this data. Adjusting Your Account to Consider Other Retirement Assets (defined below) Unless you tell us not to, if warranted, we will automatically adjust your Managed Account Allocation based on our consideration of any Other Fidelity Retirement Account Assets or other retirement assets not recordkept at Fidelity (collectively, “Other Retirement Assets”). This “Complementary Adjustment” will consider the riskiness of your Other Retirement Assets and seek to better align your Managed Account and your Other Retirement Assets (together, your “Overall Retirement Portfolio”) to your investment strategy. In addition, we will automatically adjust your Managed Account Allocation based on any non-managed assets within your Plan Account, such as self-directed brokerage assets and/or Other Excluded Investment Options (as described below). Please see the information below on how we consider self-directed brokerage assets, Excluded Investment Options, and company stock held within your Plan Account. We have two methods to provide the Complementary Adjustment. See NetBenefits.com to determine which version of the Complementary Adjustment is available for your plan. For the Standard Complementary Adjustment methodology, we consider account balances and the equity balance of your Other Retirement Assets. For the Revised Complementary Adjustment, we consider account balance, equity exposure, and certain risk characteristics, such as market capitalization or style of your Other Retirement Assets. 6  Fidelity maintains eligibility criteria for securities that can be used in your Complementary Adjustment based on factors such as asset characteristics, data availability, and alignment with our investment approach. Fidelity continuously reviews its criteria, which can result in updates to the securities included or excluded in your Complementary Adjustment. In cases where an asset does not meet our eligibility criteria or we are unable to identify the nature of an asset we may underestimate or overestimate the risk of your Other Retirement Assets when performing the Complementary Adjustment. This can lead to our proposing a different Managed Account Allocation than we would have suggested if we could have fully recognized all your Other Retirement Assets. This risk also exists following enrollment whenever we review your investment strategy and Managed Account Allocation. Please see the “Updates to Your Managed Account” section below. Based on the Initial Information or Personal Profile and any Other Retirement Assets (collectively, “your information”), we will create an investment proposal for you. After reviewing your investment proposal along with the Terms and Conditions and pricing information for the Program, you can choose to enroll in the Program. Under normal circumstances, Strategic Advisers will then begin its discretionary management by investing your Managed Account within the next five business days in alignment with your investment strategy and Managed Account Allocation. See “Discretionary Investment Management” below. The process used to determine your investment strategy and Managed Account Allocation is intended to identify an appropriate asset allocation consistent with our applicable standard of care. From time to time, the process for identifying or implementing an asset allocation may not operate as intended. If this occurs, we will repeat the asset allocation process and prospectively adjust your investment strategy and/or the Managed Account Allocation as needed. Unless you are notified otherwise, pending completion of your enrollment, your plan assets will typically remain in their then-current investments and future contributions will be invested per current investment elections on file or, if no investment elections are on file, in the Plan’s default investment option. If you make updates to your Personal Profile while your initial enrollment is pending, it is possible that discretionary management could be delayed. You should note that your plan assets immediately prior to enrollment will be used to determine an appropriate asset allocation for your Managed Account. The value of your plan assets could potentially change significantly once your enrollment is complete and assets that cannot be managed as part of the Program (other than self- directed brokerage assets, company stock, and Other Excluded Investment Options, as described below) are sold. The value of your plan assets is reevaluated at the time of your next scheduled review or when you review your Personal Profile online, whichever comes first. We encourage you to review your Managed Account Allocation on NetBenefits.com once we have started managing your Account. 7  Passive Enrollment in the Program or Enrollment as a Default Investment Option If your plan sponsor has directed that the eligible assets in your Plan Account be enrolled in the Program (referred to as “passive enrollment”), your decision to remain enrolled in the Program constitutes your approval of the investment strategy and Managed Account Allocation with which your Managed Account is aligned. In addition, certain plans use FPPA as a default investment option (i.e., your Account will be enrolled in the Program if you fail to select a portfolio of investments from your plan’s investment lineup). If either of these enrollment processes is applicable to you, you can opt out of the Program by calling a Fidelity representative. If you are being passively enrolled or you are being enrolled in FPPA as a default investment option for the first time and you do not have another Plan Account already enrolled in the Program, we will identify a Managed Account Allocation based on information provided by your plan sponsor, which may include date of birth, estimated retirement age, Plan Account balance, Other Fidelity Retirement Account Assets, and certain retirement benefit information recordkept at Fidelity and/or provided by a third party to Fidelity as well as applicable profiling assumptions. Assuming that you do not opt out of the Program, your Managed Account will then generally be invested within the next five business days to align with the Managed Account Allocation we identified. Unless you are notified otherwise, pending completion of your enrollment, your plan assets will typically remain in their then-current investments and future contributions will be invested per current investment elections on file or, if no investment elections are on file, in the Plan’s default investment option. If you are already enrolled in the Program in one or more Plan Accounts and you are being passively enrolled or enrolled in FPPA as a default investment option in a new plan, we will review the Personal Profile information we have for each Plan Account. If different information is identified for each Plan Account, we will use the following multi- account hierarchy to determine which information to use across all your Plan Accounts so that we leverage the same Personal Profile information to manage your enrolled accounts in alignment with a consistent investment strategy. Note that if you are enrolled in more than one plan, your individual Plan Accounts could have different Managed Account Allocations for a variety of reasons. • If you have enrolled in or reviewed and confirmed data in an FPPA account online, we will use the information from the most recent account you enrolled in or confirmed online; or • If you have not enrolled in or reviewed and confirmed data in an FPPA account online and have one or more previously enrolled plans in which your plan sponsor has indicated that you are an active participant, we will use the data from the most recent previously enrolled plan in which your plan sponsor has indicated that you are an active participant; or • If you have not enrolled in or reviewed and confirmed data in an FPPA account online and your plan sponsor has indicated that you are not an active participant in any previously enrolled plan, we will use data from the most recent previously enrolled plan. 8  Additionally, if you are already enrolled in the Program in one or more Plan Accounts that did not include certain Other Retirement Assets or retirement benefit information recordkept at Fidelity and/or provided by a third party to Fidelity, we will not use such information to determine your Managed Account Allocation for your subsequently opened account. If you would like this information to be used, you must go online or call a representative to authorize that these assets and/or information be included in your Personal Profile and used in determining your investment strategy and Managed Account Allocation. Discretionary Investment Management Strategic Advisers will manage your Managed Account assets using investments chosen from among the plan’s eligible investment options. Strategic Advisers will periodically rebalance the assets in your Managed Account to align with your investment strategy. In addition, as discussed in “Updates to Your Managed Account” below, we will periodically review your investment strategy and Managed Account Allocation to determine whether they remain appropriate for you. In making this determination, we consider, among other things, any updated Plan Account data and any changes to your Personal Profile. Your investment strategy and/or your Managed Account Allocation change as a result of this review. Plan sponsors can direct us to include among the plan’s eligible investment options supplemental funds chosen by the plan sponsor and available only to participants enrolled in FPPA. In such cases, references to the “plan lineup” herein and in other Program collateral shall be deemed to include the plan’s supplemental funds. Because supplemental funds are only available to participants enrolled in FPPA, once enrollment in FPPA is terminated, a participant’s interest in such supplemental funds will be redeemed, and participants must provide direction to a Fidelity representative as to how to invest assets held in supplemental funds. If no direction is provided at the time of a participant’s unenrollment, we will follow the plan sponsor’s direction as to how to invest those assets. In addition, plan sponsors can elect to exclude specific plan investment options from the Program but allow participants to continue holding these investments outside the Managed Account. The Program offers plan sponsors the option of two discretionary investment management approaches: • The FPPA core investment approach (“FPPA Core”), which seeks to construct portfolios by evaluating all the plan’s eligible investment options (including actively managed funds, index-based funds, and extended asset class investment options); or, • The FPPA index-based approach (“FPPA Index”), which seeks to construct portfolios that are diversified across asset classes and reflect a preference for the plan’s eligible index-based investment options. Fidelity does not recommend one approach over the other, and you are limited to the approach your plan sponsor has chosen to offer. Log in to NetBenefits.com or see your enrollment materials for more information regarding whether your plan sponsor has 9  selected FPPA Core or FPPA Index. Please refer to the section below entitled “Methods of Analysis, Investment Strategies, and Risk of Loss” for more information on FPPA Core and FPPA Index and about Strategic Advisers’ investment methodology. Updates to Your Managed Account • We will periodically contact you to encourage you to review and, if needed, update your Personal Profile. This review is important because it allows us to confirm that your investment strategy remains appropriate for you. • We will also automatically review your investment strategy and Managed Account Allocation periodically using updated data for any previously confirmed Other Retirement Assets as well as certain retirement benefit information recordkept at Fidelity and/or provided by a third party to Fidelity. If through this review we determine that updates are needed, your investment strategy and/or Managed Account Allocation will be changed. Your continued enrollment in the Program constitutes your approval of such changes. • As described above, from time to time, the process for identifying or implementing an asset allocation may not operate as intended. If this occurs, we will repeat the process and prospectively adjust your investment strategy and/or your Managed Account Allocation as needed. Your continued enrollment in the Program constitutes your approval of such changes. • If you are enrolled in the Program in two or more Plan Accounts and your Personal Profile information differs between or among the Plan Accounts, when we review your information, we will make updates using the multi- account hierarchy described above to determine if your investment strategy or your Managed Account Allocation should be changed. Additionally, if you are already enrolled in the Program in one or more Plan Accounts and you excluded (or failed to confirm the inclusion of) Other Account Assets and retirement benefit information recordkept at Fidelity and/or provided by a third party to Fidelity in a previous enrollment, we will not use this information to determine your investment strategy or the Managed Account Allocation to be implemented for your Managed Account. If you would like this information to be used, you must go online or call a Fidelity representative to authorize these assets or information to be included. • Strategic Advisers can also modify the methodology used to select the funds for investment in your Managed Account. In addition, Strategic Advisers regularly evaluates the available plan investment options for each Plan and may make changes to your Managed Account Allocation. (See “Methods of Analysis, Investment Strategies, and Risk of Loss—Investment Approach” for more information.) • If a reallocation occurs in connection with an automatic review and update, we will send you confirmations for any resulting trades in your Managed Account to notify you that these changes have been made. You can then go online to review your updated Managed Account Allocation. Your continued enrollment in the Program constitutes your approval of such Managed Account Allocation and/or investment strategy. 10  • Changes you make to your Personal Profile: You can update your Personal Profile information as changes occur in your situation. Changes to your Personal Profile could result in changes to the holdings in your existing Managed Account. If your Personal Profile changes result in changes to your investment strategy and/or Managed Account Allocation, we will notify you of the changes in your Account and your continued enrollment in the Program constitutes your approval of such changes. • Enrollment of an additional workplace plan in the Program: Your enrollment of an additional workplace plan in the Program could result in changes to the holdings in your existing Managed Account. See the multi-account hierarchy information above for information about how we align your asset allocation strategy if you have multiple Plan Accounts enrolled in the Program. If your enrollment of an additional workplace plan in the Program results in changes to your investment strategy or Managed Account Allocation, we will notify you of the changes in your Account and your continued enrollment in the Program constitutes your approval of such changes. • Modifications to methodology: Strategic Advisers uses assumptions and calculation processes to identify investment strategy and/or Managed Account Allocation, which use your Initial Information or Personal Profile and to identify the holdings in your Managed Account. Strategic Advisers reviews the methodologies it uses in the Program and can make adjustments or updates. If a new investment strategy or Managed Account Allocation for your Account is identified as a result of a methodology change, we will notify you of the changes in your Account and your continued enrollment in the Program constitutes your approval of such new investment strategy and/or Managed Account Allocation. Aside from the Complementary Adjustment methodology described above, note that, where a participant has multiple workplace Plan Accounts enrolled in the Service, we will generally seek to apply methodology adjustments and updates to all of a Participant’s Plan Accounts at the same time. • Evaluation of Personal Profile information and determination of whether additional or different Personal Profile information should be considered to identify the Managed Account Allocation: In such cases, the investment strategy and/or Managed Account Allocation will be modified prospectively, but no retrospective evaluation or adjustment will be made. Your continued enrollment in the Program constitutes your approval of such changes. If a reallocation occurs in connection with any update activity described above, we will send you confirmations for any resulting trades in your Managed Account to notify you that changes have been made. You can then go online to review your updated asset allocation. Your continued enrollment in the Program constitutes your approval of such new asset allocation strategy. Financial Planning and Representative Assistance In addition to the discretionary investment management services described above, Strategic Advisers provides nondiscretionary, web-based financial planning assistance as part of the Program. Financial planning is designed to help enrolled participants who wish 11  to create, implement, and track a retirement plan. Should you choose to take advantage of these planning services, Fidelity representatives are able to assist you if requested, generally Monday–Friday from 8:30 a.m. to 8:00 p.m. ET. As part of its nondiscretionary services, Strategic Advisers can provide you with an online financial planning analysis of your retirement situation. This analysis is based on certain assumptions, such as rates of return, market values, and inflation rates, and the information you provide and/or authorize to be provided. Changes in assumptions or information can affect the planning results. You should revisit the online experience regularly or contact a Fidelity representative to ensure that your analysis reflects current information and assumptions. We are not obligated to update any analysis provided, and we do not monitor your progress toward an investment goal, including any changes you model on your own in any other financial planning tool that is made available to you by Fidelity. Your financial planning analysis includes deterministic and/or probabilistic modeling and use of algorithms to model potential financial results. Deterministic modeling assumes a fixed rate of return for certain asset classes across time periods and, therefore, does not account for market uncertainty. Probabilistic simulations estimate the likelihood of a particular outcome based on simulation of market performance combining both historical market behavior and estimates of expected future behavior. In addition, our assumptions and methodologies used in financial planning are adjusted from time to time, which can have an impact on the results obtained. It is important to understand that the modeling provided in conjunction with our financial planning services is hypothetical in nature; is for illustrative purposes only; does not reflect actual investment, tax, or other planning results; and is not a guarantee of future investment outcomes. The modeling results shown will vary with each use and over time. The implementation of any recommendations provided through FPPA’s financial planning services or by a Fidelity representative is separate and distinct from the Program Services. If you choose to implement some or all of the planning recommendations through Fidelity or its representatives, a Fidelity entity will act as a broker-dealer or investment adviser, depending on the products or services you select, and you will be subject to separate, applicable charges, fees, or expenses. It is important to understand that a Fidelity representative can act in the capacity of a registered representative of Fidelity Brokerage Services, LLC (“FBS”), Strategic Advisers’ affiliated broker-dealer. Any financial planning a participant receives from a Fidelity representative prior to the participant’s enrolling in the Program is provided in that Fidelity representative’s capacity as a registered representative of FBS and is not part of the Program Services. Assets Under Management As of December 31, 2025, Strategic Advisers’ total assets under management were $1,321,075,214,792 on a discretionary basis, and $49,050,110,419 on a nondiscretionary basis. 12  Your Responsibility We rely on your Personal Profile information to provide the Program Services. It is your responsibility to periodically review as well as advise us of changes to your Personal Profile, which includes but is not limited to your time horizon, risk tolerance, and personal financial situation. Such changes can affect the Program Services and, as discussed above, can result in changes to your investment strategy and/or Managed Account Allocation to which your Managed Account is aligned. If you have multiple discretionary investment advisory relationships with Fidelity, you should ensure that your personal, financial, and other important information is updated for each respective advisory service, because changes to your Personal Profile for the Program will not result in changes to other advisory services. In addition, changes to your Personal Profile or information provided by your plan can also trigger the need for you to revisit the Program’s online experience to update or revise any analyses generated in providing the financial planning services. Fees and Compensation Advisory Fees—Gross and Net of Fee Credit The Program charges an annual net advisory fee, based on the average daily balance of the assets held in your Managed Account, payable after the end of each billing quarter, and calculated by deducting a plan credit amount (the “Plan Credit Amount”), as discussed below, from your plan’s annual gross advisory fee. The Plan Credit Amount reduces your annual gross advisory fee by the amount of certain compensation, if any, received by Fidelity affiliates as a direct result of the investments held in your Managed Account. The Plan Credit Amount is designed to reduce the conflict of interest that arises from investing your Managed Account in Fidelity Funds as compared to non-Fidelity mutual funds that are included in the plan’s eligible investment options, although it might not eliminate this differential in all cases. (Please see “Client Referrals and Other Compensation” below for additional information.) The Plan Credit Amount will be calculated daily, and, for each investment option in which FPPA invests, an amount will be calculated equal to the sum of (i) the underlying investment management fees received by Strategic Advisers or its affiliates from such investment if it is a Fidelity Fund or other Fidelity investment option (but, if applicable, not other fund expenses) and (ii) the distribution, shareholder servicing, or other fees received by Strategic Advisers or its affiliates as a result of Managed Account assets being invested in a non-Fidelity Fund or other investment product (unless, for certain plans, such amounts are paid to your plan in the form of a participant revenue credit or plan-level account/revenue credit). The Plan Credit Amount will be applied (as a percentage) equally across all Managed Accounts enrolled in the Program and deducted from the gross advisory fee to arrive at the net advisory fee for your Managed Account. It is expected that the Plan Credit Amount will vary over time, based on the investment management fees and servicing or other fees as described in (i) and (ii) above and the total amount of Managed Account assets, the funds selected for investment, as well as the plan sponsor’s investment options. Therefore, it is expected that your net advisory fee will vary over time, based on the variation of the Plan Credit Amount. 13  It is important to understand that Fidelity affiliates are compensated for providing a variety of services to mutual funds as described in “Client Referrals and Other Compensation” below. Such compensation is included in the Plan Credit Amount only to the extent that it is received as a direct result of investment by Managed Accounts. Compensation that is not directly derived from Managed Account assets is not included in the Plan Credit Amount. The standard fee schedule below reflects the maximum gross advisory fees we charge for plans that are enrolled in the Program. The annual gross advisory fees applicable to your plan might have been negotiated between your plan and Fidelity and, therefore, could differ from the fees noted below. Strategic Advisers can waive the advisory fee, in whole or in part, at its sole discretion, in connection with promotional efforts and other programs. Certain plan sponsors, including Fidelity, pay the fees for plan participants. For information about the specific annual gross advisory fees applicable to your plan, please see the Pricing Supplement applicable to your plan available on NetBenefits. com. The Program fees are solely attributable to advisory services associated with Managed Accounts. FPPA CORE: BASIC ANNUAL GROSS ADVISORY FEE SCHEDULE* Average daily account balance Less than 20% eligible participant enrollment Greater than 20% eligible participant enrollment† 0.85% 0.80% For the first $100,000 or portion thereof 0.80% 0.70% For assets between $100,000 and $250,000 or portion thereof 0.70% 0.60% All additional assets over $250,000 * Company stock assets and other ineligible assets (“Excluded Assets”) are not considered as part of the managed assets and are not included in the fee calculation. † The gross advisory fees applicable to plans that exceed 20% enrollment will take effect beginning with the first day of the quarter in which the 20% threshold was exceeded. Fund and Recordkeeping Expenses Underlying fund expenses also apply to the funds in your Managed Account and are standard expenses that all fund shareholders pay. Details of a mutual fund’s expenses can be found in its prospectus. In addition, the advisory fee does not include the recordkeeping or administrative fees charged to your Plan Account; those fees are separately charged, nonnegotiable, and subject to change, pursuant to an agreement between Fidelity and the plan’s named fiduciary. 14  Billing The net advisory fee will be deducted from your Managed Account after the end of each billing quarter, based on the average daily assets of your Managed Account over the course of the billing quarter. Unless paid by the plan sponsor, the fee will be deducted directly from your Managed Account, and your quarterly plan statement will disclose the net advisory fee assessed on your assets in the Program. There is no fee to terminate your participation in FPPA and you can terminate at any time by calling a Fidelity representative. In the event that your participation in FPPA is terminated, the gross advisory fee applicable to that quarter will be prorated based on the number of days the account was managed during the quarter, and the net advisory fees for the prorated quarter will be calculated using the partial period fee credits generated by your investments or an end-of-quarter prorated Plan Credit Amount if you remain invested in your plan. Redemption Fees Some plans offer investment options with short-term trading fees, otherwise known as redemption fees. If Strategic Advisers initiates a transaction in your Managed Account while you are enrolled in the Program, any resulting short-term trading fees will be paid by Fidelity. However, if short-term trading fees are assessed as a result of the sale of your Plan Account holdings at the time of your enrollment in the Program, you will be responsible for paying the fees. You are also responsible for paying any short-term trading fees resulting from a loan or withdrawal from your Plan Account or from any transactions you initiate after you terminate your enrollment in the Program, including the fees incurred for the exchange from supplemental funds, if applicable for your plan. Additional Fee Information All fees are subject to change. We can agree to waive fees, in whole or in part, in our sole discretion, including but not limited to for certain current and former employees of Fidelity. This will result in certain participants paying less than the standard fee. In addition, participants with waived advisory fees do not receive fee credits; instead, required Plan Credit Amounts will be allocated, pro rata based on assets, among the open Plan Accounts in the Program at the time the Plan Credit Amount is applied. The advisory fee does not cover costs associated with implementing any suggestions provided as part of our nondiscretionary financial planning service. Some plans offer prime money market mutual funds, which are subject to liquidity fees (as described in your fund’s prospectus). If Fidelity initiates a transaction in your Account while you are enrolled in FPPA, you will be responsible for paying any resulting liquidity fees. In addition, if liquidity fees are assessed as a result of the sale of your Plan Account holdings at enrollment, you will be responsible for paying the fees. You are also responsible for paying any liquidity fees resulting from a loan or a withdrawal from your Plan Account or from any transactions you initiate after the termination of your enrollment in FPPA. 15  Availability of Separate Services The tools and analytics used to support the nondiscretionary financial planning services provided through the Program are also used in connection with other services available to Fidelity clients or prospective clients, electronically or otherwise, without a fee, including tools and analytics provided in support of Fidelity brokerage services available to participants in your plan. In addition, you can invest in the investment options available in your Plan Account without enrolling in the Program and incurring the Program fee, and, in such cases, your overall costs will be lower. However, when you invest independently in the investment options available in your Plan Account, you will not receive Strategic Advisers’ discretionary management services or financial planning offered through FPPA. Information about Fidelity and Fidelity Representative Compensation Fidelity representatives who support the Program are associated with Strategic Advisers and FBS. Fidelity representatives act on behalf of FBS when recommending an advisory program offered by Strategic Advisers. Separate and apart from the Program Services, these Fidelity representatives, or other Fidelity representatives, can provide you with investment education, research, and planning services offered by FBS, and these Fidelity representatives will be acting as registered representatives of FBS when providing such services or when providing a recommendation for a Strategic Advisers investment advisory service. When providing services for FBS, Fidelity representatives are acting solely as registered representatives of FBS, and Program fees are not related to those additional services provided by FBS. When these Fidelity representatives provide discretionary and nondiscretionary investment advisory services, they will be acting as investment advisory representatives of Strategic Advisers. Fidelity representatives receive base pay based on their experience and role. In addition to base pay, Fidelity representatives are also eligible to receive either variable compensation or an annual bonus. How much, if anything, each Fidelity representative receives in each component is generally determined by the representative’s role, responsibilities, and performance measures. Fidelity representatives who receive an annual bonus do not receive compensation based directly on the sale of any product or service, but they do have an indirect financial incentive to recommend products or services that pay more compensation to Fidelity because annual bonus funding is based in part on Fidelity’s financial performance. Variable compensation of the Fidelity representatives who service plan participants in FPPA is not dependent on the number of FPPA conversations they have with participants or the number of FPPA enrollments they generate. Fidelity associates who sell FPPA to plan sponsors are compensated for entering into a successful FPPA relationship with a plan sponsor client but are not compensated based on the enrollment of any particular participant in the Program. For additional information about how Fidelity compensates its representatives in connection with the sale of FPPA and other products, please see the “Fidelity Investments Compensation Disclosure” document available on Fidelity.com/information or through a Fidelity representative. 16  Performance-Based Fees and Side-by-Side Management Strategic Advisers does not currently charge performance-based fees in connection with the Program Services provided, nor do we engage in side-by- side management with respect to the portfolios that are created for FPPA. Types of Clients Plan Eligibility Requirements FPPA is available exclusively through retirement plans that have selected us to provide investment advisory services to eligible plan participants. We require that plans offer their participants a set of investment options that can provide broad market exposure across diversifying asset classes. The investment options in the plan should include vehicles/options that provide diversified exposure to a range of asset classes, including short-term investments, bonds, domestic stocks, and international stocks. Participant Eligibility Requirements FPPA has no established asset minimums for managing participants’ Managed Accounts; however, we reserve the right to terminate a participant’s Managed Account at any time in our sole discretion. To be eligible to enroll in FPPA, you must: (i) be a U.S. person (including a U.S. resident alien) and have a valid U.S. taxpayer identification number, (ii) be currently participating in your employer’s plan, and (iii) meet any plan sponsor eligibility requirements. The Program is not available to investors residing outside of the U.S. Some plans also have restrictions for participants who hold certain nontraditional investment options (such as self-directed brokerage or company stock assets). If the plan sponsor elects to enroll your Plan Account in FPPA on your behalf, this enrollment will override any other investment elections, including any third-party trading authorization that you have selected prior to enrollment. Under certain circumstances, the Program can be offered to nonqualified deferred compensation (“NQDC”) plans. Participants and plans acknowledge that the Program (i) is only appropriate for NQDC plans that hold assets that are to be used for a retirement goal, as determined by the participant, and (ii) does not take into account any tax consequences associated with a disbursement from NQDC plans. During the time you are enrolled in FPPA, you are prohibited from initiating exchanges of assets held and from directing how new contributions are allocated in your Managed Account. Distributions, withdrawals, or loans will be executed according to plan rules and can temporarily affect our ability to maintain alignment with your Managed Account Allocation. 17  Methods of Analysis, Investment Strategies, and Risk of Loss Investment Approach This section contains information about how Strategic Advisers provides discretionary investment management services to Managed Accounts. In servicing Managed Accounts, Strategic Advisers manages each portfolio by applying a quantitative investment methodology that attempts to achieve reasonable risk- adjusted returns over time. In constructing portfolios, Strategic Advisers employs a process that is objective with respect to fund family and/or investment manager. About the FPPA Investment Approaches. We offer the following investment approaches to plan sponsors: • FPPA Core. The FPPA Core investment process seeks to construct portfolios that are diversified across asset classes and that seek to enhance risk-adjusted returns for participants, with varying risk profiles and investment time horizons. Our process aims to build portfolios using investment options drawn from all the plan’s eligible investment options, focusing on those that have demonstrated consistency in both risk characteristics and security selection discipline. Eligible investment options include actively managed funds, index-based funds, and extended asset class investment options. This approach includes active asset allocation (described below), unless otherwise directed by the plan sponsor. • FPPA Index. Like FPPA Core, the FPPA Index investment process seeks to construct portfolios that are diversified across asset classes and that seek to provide benchmark-appropriate risk-adjusted returns for participants, with varying risk profiles and investment time horizons. FPPA Index aims to build portfolios using index investments drawn from the plan’s eligible investment options, when applicable. Eligible investment options are limited to index- based funds in the primary asset classes (U.S. equity, non-U.S. equity, fixed income, and short term); if no index fund is available in the short-term asset class, the Program can select from non-index-based options in that asset class. As discussed below, this approach does not include active asset allocation, unless otherwise directed by the plan sponsor. With respect to any stable value option within a plan lineup, Strategic Advisers will use the stable value option as the short-term position in constructing its portfolios. When stable value funds are incorporated in FPPA Index portfolios, stable value funds are used as a non-index-based option to fill the short-term component of each portfolio. Active Asset Allocation. By default, the FPPA Core approach includes active asset allocation; however, a plan sponsor can elect whether to implement this feature. The active asset allocation process seeks to adjust the portfolios’ primary asset class weightings to increase return potential and/or diversification benefits. This process also uses extended asset classes—such as real estate, high-yield debt, Treasury Inflation- Protected Securities (TIPS), and commodities—to the extent that these extended asset classes are available in your plan’s investment lineup. Conversely, by default, the FPPA Index approach does not include active asset allocation, but a plan sponsor can elect to implement this feature. If a plan sponsor has selected the index approach 18  and elects to implement active asset allocation, non-index funds can be used for extended asset classes. Log in to NetBenefits.com or see your enrollment materials for more information as to whether your plan sponsor has elected to implement active asset allocation. It is important to note that the active asset allocation process used by Strategic Advisers can result in asset allocation weightings for your Managed Account that differ from those shown in your investment proposal based on your Initial Information or Personal Profile. Fund Evaluation. For plans using FPPA Core, the historical performance of the eligible primary asset class investment options (U.S. equity, non-U.S. equity, and fixed income) in the plan lineup are evaluated using a proprietary algorithm that considers relative attractiveness, the ability to maintain appropriate portfolio diversification, and ways of combining these investment options to generate additional value. Fundamental inputs are also occasionally considered for the eligible investment options. For plans using FPPA Index, a quantitative, algorithmic analysis is used to evaluate a plan’s index-based investment options to identify appropriate investments for inclusion in the portfolios in order to seek market-like returns, before expenses. Portfolio Construction. Strategic Advisers’ portfolio construction process for FPPA uses a quantitative, algorithmic approach to combine a set of investment options whose overall risk characteristics, when viewed as a portfolio, are similar to those of an appropriate asset allocation strategy for a particular risk profile of an investor. These investment strategies are defined by a series of long-term asset allocation benchmarks, which consist of weighted market index benchmarks designed to represent an appropriate asset mix for a given investor risk profile, from conservative to aggressive growth. Additionally, when identified as a part of the participant’s retirement goal, Strategic Advisers will consider Other Retirement Assets and the holdings mix of those other accounts when constructing the Managed Account Allocation. When viewed holistically, the participant’s retirement accounts will, in aggregate, approximate the risk and diversification attributes of an investment strategy that is consistent with the long-term asset allocation benchmarks for stock, bond, and/or short- term asset classes. Investment Universe. Based on the Core or Index option selected by your plan sponsor, Strategic Advisers considers mutual fund data provided by an independent third-party information service to evaluate investment options. Information concerning other investment options can be provided by Fidelity affiliates, third-party sources, or the plan sponsor. In addition, a variety of publicly available information and internally developed tools is used to evaluate the investment options. Certain plan investment options are ineligible for management by FPPA for a variety of reasons. For example, asset allocation, lifecycle, and lifestyle investment options are ineligible for FPPA due to the potential for overlapping asset allocations. Specialty investment options, such as sector, industry, country, or regional funds, as defined by Morningstar category and/or prospectus objective, are also generally ineligible for FPPA due to the inherent risk in the concentrated investment mandate. In addition, 19  as noted above, DAA is ineligible for management by FPPA. Lastly, the algorithms underlying our investment methodology do not consider extraordinary circumstances that might rule out a certain investment. However, to the extent that Strategic Advisers becomes aware of these instances and believes they might have adverse effects on the portfolio, such funds can be considered for exclusion or removal from the portfolios. When you enroll in FPPA, if a prime money market mutual fund included in your Plan Account holdings cannot be sold due to a trading restriction on that fund, we will not be able to rebalance your Plan Account holdings to align with the appropriate FPPA portfolio until the trading restriction has been lifted. In addition, if the appropriate FPPA portfolio contains a prime money market mutual fund that cannot be purchased due to a trading restriction on that fund, we will not be able to rebalance your Plan Account holdings to align with the appropriate FPPA portfolio until the trading restriction has been lifted. To the extent applicable, you will not be responsible for FPPA advisory fees until the trading restriction has been lifted and your Plan Account holdings have been aligned with the FPPA portfolio. Finally, while you are enrolled in FPPA, if your portfolio contains a prime money market mutual fund that cannot be purchased and/or sold due to a trading restriction on that fund, reallocations of your Plan Account holdings could be delayed until the trading restriction has been lifted. Please note, however, that if your plan contains both prime money market and government money market funds in the plan investment lineup, Strategic Advisers will use the government money market fund when creating the FPPA portfolios. Reviewing, Rebalancing, and Reallocating Managed Accounts On a regular basis, Strategic Advisers will evaluate the performance of portfolios, investment option changes, and time lag since the participant portfolio’s last reallocation. Generally, the portfolios will be reallocated and rebalanced three to four times a year, as well as when plan option changes necessitate the review of new portfolio allocations. These reviews are independent of the changes to your Account that can result from periodic reconsideration of your Personal Profile (including Other Retirement Assets). The investments in your Account will change either when Strategic Advisers reallocates the Account or, as discussed in “Advisory Business,” when your asset allocation changes. When plan options change, new portfolios will be created as soon as reasonably possible or as needed. In addition, your Managed Account is also reviewed periodically to determine, for example, if additional or other Personal Profile information should be considered or if the Managed Account differs from an applicable portfolio. Your Account can be adjusted. Excluded Assets Self-Directed Brokerage in Plan Accounts (if applicable). Unless limited by your plan sponsor, participants who hold a portion of their plan balance in a Self- Directed Brokerage (“SDB”) account can also enroll in the FPPA service offering. However, we will not manage or advise you on your SDB assets and they are not considered part of your Managed Account. In addition, all future contributions into your Plan Account will be directed into your Managed Account. You have the opportunity, if you choose, to reinvest assets from your SDB account into your Managed Account. 20  We will consider the value of any SDB assets when assessing your overall financial situation as part of determining an appropriate investment strategy and Managed Account Allocation. In managing your Managed Account, we will consider any SDB assets as “Other Fidelity Retirement Account Assets” as described in the section titled “Adjusting Your Account to Consider Other Retirement Assets.” Company Stock. Participants who hold company stock in their Plan Account can also enroll in the FPPA service offering. However, we will not manage or advise you on your company stock position, and company stock is not considered part of the Managed Account. If you decide to retain a portion of your Plan Account in company stock, we will consider the value of your company stock when assessing your overall financial situation as part of determining an appropriate investment strategy for your Managed Account. In addition, you can choose to have us take into account the risk of your company stock holdings or direct us to ignore the risk of your company stock holdings when suggesting a Managed Account Allocation. Each of these options is described in more detail below. Option 1. We can, at your direction, assign a Managed Account Allocation that attempts to consider the risk of company stock holdings. As a result, the Managed Account Allocation identified will be more conservative than the Managed Account Allocation made without considering the risk of any company stock holdings. However, there is no guarantee that Strategic Advisers will be able to completely offset the risk of company stock held in your Plan Account. Thereafter, we will evaluate the company stock allocation each time your Managed Account is reallocated (which happens generally three to four times per year), to help ensure that the Managed Account is assigned to an appropriate Managed Account Allocation. Option 2. Alternatively, we can assign a Managed Account Allocation that does not attempt to consider the risk of your company stock holdings. With this option, we will consider the value of your company stock when assessing your overall financial situation, but we will not attempt to consider any issuer-specific risk. Therefore, your Managed Account may be more aggressively invested than if you had requested that we attempt to offset your company stock risk. In the event that you do not inform us of how to handle the company stock holdings in your Plan Account or if you receive an employer stock grant without having elected a treatment option, we will follow the plan sponsor’s default direction for treatment of company stock, which in most cases is Option 1. You can contact us at any time to change the company-stock-handling option. While enrolled in FPPA, you cannot purchase additional shares of company stock, but you can sell unitized or other company stock holdings subject to your company’s policy, and the proceeds will be invested in your Managed Account. Other Excluded Investment Options. In rare cases, your plan sponsor will direct us not to manage specific investment options (“Excluded Investment Options”). Excluded Investment Options held by you will not be managed by Strategic Advisers as part of the portfolio. While your plan sponsor can make future contributions into an Excluded 21  Investment Option on your behalf, all other future contributions into your Plan Account will be directed into the FPPA portfolio. You have the opportunity, if you choose, to reinvest assets from Excluded Investment Options into your FPPA portfolio. We will consider the value of any Excluded Investment Options when assessing your overall financial situation as part of determining an appropriate investment strategy and Managed Account Allocation. We will consider any Excluded Investment Options as “Other Fidelity Retirement Account Assets” as described in the section titled “Adjusting Your Account to Consider Other Retirement Assets.” Additional Information about Strategic Advisers’ Investment Practices When investing in Fidelity Funds and non-Fidelity mutual funds, Strategic Advisers from time to time consults the fund’s investment manager to understand the manager’s guidelines concerning general limitations, if any, on the aggregate percentage of fund shares that can be held under management by us on behalf of all our clients. Funds are not required to accept investments and can limit how much we can purchase. Additionally, Strategic Advisers can establish internal limits on how much it invests in any one fund across the programs it manages. Regulatory restrictions sometimes limit the amount that one fund can invest in another, which means that Strategic Advisers can be limited in the amount that it can invest in any particular fund. Strategic Advisers will work closely with fund management to limit any potentially negative impact of its reallocation activities on funds held in Managed Accounts. In certain situations, liquidating positions in underlying funds will be accomplished over an extended period of time as a result of operational considerations, legal considerations, or input from underlying fund managers. From time to time, Strategic Advisers and/or its affiliates can determine that, as a result of regulatory requirements that apply to the adviser and/or its affiliates due to investments in a particular country or in an issuer operating in a particular regulated industry, investments in the securities of issuers domiciled or listed on trading markets in that country or operating in that regulated industry above certain thresholds are impractical or undesirable. The foregoing limits and thresholds will be applied at the Managed Account level or in the aggregate across all accounts (or certain subsets of accounts) managed, sponsored, or owned by, or otherwise attributable to, us and our affiliates. For investment risk management and other purposes, we and our affiliates also generally apply internal aggregate limits on the amount of a particular issuer’s securities that can be owned by all such accounts. In such instances, the adviser can limit or exclude your investment in a particular issuer, which can include investment in related derivative instruments, and investment flexibility can be restricted. To the extent that your Managed Account already owns securities that directly or indirectly contribute to an ownership threshold being exceeded, Strategic Advisers could sell securities held in such Managed Account in order to bring account-level and/or aggregate ownership below the relevant threshold. In the event that any such sales result in realized losses for a Managed Account, that Managed Account will bear such losses depending on the particular circumstances. 22  The only Fidelity Funds considered by FPPA are those that have been included in the investment menu chosen by the plan sponsor (or other responsible plan fiduciary) to be offered to plan participants and beneficiaries. To the extent that FPPA includes one or more Fidelity mutual funds in portfolios to be used in managing plan participants’ Managed Accounts, it is because the plan sponsor (or other responsible plan fiduciary) has determined that such funds are appropriate to be included in the investment menu. In constructing portfolios, we employ a process that is objective with respect to fund family and/or investment manager. The Program includes a Plan Credit Amount mechanism designed to mitigate financial conflicts of interest associated with revenue received from underlying mutual fund investments and Strategic Adviser’s assignment of plan participants to portfolios containing Fidelity Funds. Please see “Fees and Compensation” above for additional information about the Plan Credit Amount. There is no predetermined allocation of Fidelity Funds to non-Fidelity mutual funds (except that, with respect to the inclusion of money market funds in FPPA portfolios, the money market funds will be Fidelity Funds if your plan’s fund lineup includes Fidelity money market funds and some plans offer only Fidelity Funds in the investment menu). Funds are selected based on an objective, quantitative model that does not consider whether a given fund is managed by Fidelity or a third party when deciding to include a fund in an FPPA portfolio. Certain factors in the fund selection process can result in a significant portion of the portfolio invested in Fidelity Funds. Strategic Advisers does not compensate its investment managers based on the inclusion of Fidelity Funds in FPPA portfolios. Strategic Advisers’ investment manager compensation is partly based on performance of the portfolios, although other objective and subjective factors will apply. Material Risks Risks Associated with Financial Planning. The projections and other analyses presented to a participant in the course of providing our financial planning services are not guarantees. In particular, projections are hypothetical in nature, are for illustrative purposes only, do not reflect actual investment or other planning results, and are not guarantees of future outcomes. The modeling results shown will vary with each use and over time. In addition, our assumptions and methodologies used in financial planning are adjusted from time to time, which can have an impact on results obtained. The financial planning projections provided through the Program are based on the information provided by participants and, in certain cases, on static assumptions—e.g., fixed return rates, fixed life expectancies, and fixed rates of income or cash flow. In reality, these variables will not be static—market fluctuation will affect overall asset performance, and uncertain life expectancy could cause participants to outlive their resources or fail to accumulate necessary resources. In addition, financial planning analyses include probabilistic modeling, whereby the probability of success varies based on differing assumptions and on changing circumstances and market information. Results reflect only one point in time and are only one factor that participants should consider as they determine how to best plan for their future. There can be significant differences between the financial planning projections shown and the performance a participant actually experiences. 23  Changes in your Personal Profile or the information provided by your plan sponsor, as well as changes made to our online methodologies, including underlying algorithms, will affect the results obtained and can result in changes to your asset allocation. In addition, financial planning projections are performed at the asset class level, assume broad diversification within each asset class, rely on certain estimates about the performance of the securities markets, and are not designed to predict the future performance of any particular security or investment product. As such, the financial planning analyses do not model the individual return characteristics of the securities or investments a participant owns, and, as a result, the modeling process is subject to significant variability based on the differences in performance between the securities actually owned by a participant and the market assumptions used in the modeling process. To the extent that the characteristics of a participant’s assets vary significantly from those of the broadly diversified asset class assumptions used, actual performance can deviate significantly from the projections provided as a component of our financial planning services. Each financial planning analysis provides more specific details on the risks and limitations associated with that analysis. Risks Associated with Investment Strategies. All investment strategies employed by the Program involve risk of loss. Investments in a Managed Account are not bank deposits and are not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed, and the value of your assets will fluctuate due to market conditions and other factors. You could lose money by investing in a Managed Account. Many factors affect each investment’s or Managed Account’s performance and potential for loss. In addition to the risks discussed below, developments that disrupt global economies and financial markets, such as wars, acts of terrorism, economic sanctions, the spread of infectious illness or other public health issues, recessions, or other events, can magnify factors that affect performance. Nondiversified funds and accounts that invest in a smaller number of individual issuers can be more sensitive to these changes, and funds or accounts that pursue strategies that concentrate in particular industries or are otherwise subject to particular segments of the market (e.g., money market funds’ exposure to the financial services industry, municipal funds’ exposure to the municipal bond market, or the international or emerging market funds’ exposure to a particular country or region) could be significantly impacted by events affecting those industries or markets. It is important to understand that your Managed Account’s actual asset allocation can deviate from your investment strategy for reasons that include consideration of Other Retirement Assets, market movement, and investment decisions to overweight or underweight certain asset classes to seek to increase potential returns or reduce risks. In addition to the risks identified above, a summary of additional risks follows: Quantitative Investing. Funds or securities assessed using quantitative analysis can perform differently from the market as a whole as a result of the factors used in the analysis, the weight placed on each factor, changes to the factors’ behavior over time, market volatility, or the quantitative model’s assumption about market behavior. In 24  addition, Strategic Advisers’ quantitative investment strategies rely on algorithmic processes and, therefore, are subject to the risks described below under the heading “Operational Risks.” To the extent that the quantitative models fail to adequately match the risk and return profile of a reference index used in managing a particular strategy, an Account could perform differently; it could underperform or outperform the corresponding reference index. Investing in Mutual Funds. Your Managed Account bears all the risks of the investment strategies employed by the mutual funds held in your Managed Account, including the risk that these funds will not meet their investment objectives. For the specific risks associated with a fund, please see the fund’s prospectus. Money Market Fund Risk. You could lose money by investing in a money market fund. Although a money market fund seeks to preserve the value of your investment at $1.00 per share, it cannot guarantee it will do so. An investment in a money market fund is not a bank account and is not insured or guaranteed by the FDIC or any other government agency. The fund’s sponsor is not required to reimburse money market funds for losses, and you should not expect that the sponsor will provide financial support to the fund at any time, including during periods of market stress. Fidelity’s government and U.S. Treasury money market funds will not impose a fee upon the sale of your shares. Stock Investments. Stock markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Different parts of the market can react differently to these developments. Value and growth stocks can perform differently from other types of stocks. Growth stocks can be more volatile. Value stocks can continue to be undervalued by the market for long periods of time. In addition, stock investments are subject to risk related to market capitalization as well as company-specific risk. Foreign Exposure. Nearly all investments or accounts are subject to volatility in non-U.S. markets, either through direct exposure or indirect effects in U.S. markets from abroad. Foreign securities are subject to interest rate, currency exchange rate, economic, regulatory, and political risks, all of which can be greater in emerging markets. These risks are particularly significant for mutual funds and exchange-traded funds that focus on a single country or region or emerging markets. Foreign markets can be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile. Foreign governments may decide to seize or confiscate securities held by foreign investors or assets held by foreign issuers, restrict an investor’s ability to sell or redeem securities, suspend or limit an issuer’s ability to make dividend or interest payments, and/or limit or entirely restrict repatriation of invested capital, profits, and dividends. Bond Investments. In general, the bond market is volatile, and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) During periods of 25  Terms and Conditions very low or negative interest rates, we could be unable to maintain positive returns on bond investments. Very low or negative interest rates can magnify interest rate risk for the markets as a whole and for individual bond investments. Changing interest rates, including rates that fall below zero, can also have unpredictable effects on markets and can result in heightened market volatility. The ability of an issuer of a bond to repay principal before a security’s maturity can cause greater price volatility, and, if a bond is prepaid, a bond fund could have to invest the proceeds in securities with lower yields. Fixed income securities also carry inflation risk as well as credit and default risks for both issuers and counterparties. Unlike individual bonds, most bond funds do not have a maturity date, so holding them until maturity to avoid losses caused by price volatility is not possible. In addition, investments in certain bond structures are less liquid than other investments and, therefore, are more difficult to trade effectively. Credit Risk. Changes in the financial condition of an issuer or counterparty, and changes in specific economic or political conditions that affect a particular type of security or issuer, can increase the risk of default by an issuer or counterparty, which can affect a security’s or instrument’s credit quality or value. Lower-quality debt securities and certain types of other securities involve greater risk of default or price changes due to changes in the credit quality of the issuer. Legislative and Regulatory Risk. Investments in your Managed Account could be adversely affected by new (or revised) laws or regulations. Changes to laws or regulations could impact the securities markets as a whole, specific industries, or individual issuers of securities. Generally, the impact of these changes will not be fully known for some time. Derivatives. Certain funds used by Strategic Advisers can contain derivatives. Generally speaking, a derivative is a financial contract whose value is based on the value of a financial asset (such as a stock, bond, or currency), a physical asset (such as gold, oil, or wheat), or a market index (such as the S&P 500® Index). Investments in derivatives subject these funds to risks different from, and possibly greater than, those of the underlying securities, assets, or market indexes. Some forms of derivatives, such as exchange-traded futures and options on securities, commodities, or indexes, have been trading on regulated exchanges for decades. These types of derivatives are standardized contracts that can easily be bought or sold and whose market values are determined and published daily. Nonstandardized derivatives (such as swap agreements), on the other hand, tend to be more specialized or complex and can be more difficult to value and are illiquid. Derivatives can involve leverage, because they can provide investment exposure in an amount exceeding the initial investment. As a result, the use of derivatives can cause these funds to be more volatile, because leverage tends to exaggerate the effect of any increase or decrease in the value of a fund’s portfolio securities. Real Estate. Real estate is a cyclical industry that is sensitive to interest rates, economic conditions (both nationally and locally), property tax rates, and other factors. Changes in real estate values or economic downturns can have a significant negative effect on issuers in the real estate industry. Alternative Investments. Alternatives are classified as assets whose investment characteristics and/or performance differ substantially from the primary asset classes (stocks, bonds, short-term investments) and, therefore, offer opportunities for 26  additional diversification. Strategic Advisers does not invest in private equity, hedge funds, or similar investments directly in Managed Accounts; however, Strategic Advisers can invest in mutual funds that invest significantly in these instruments and, therefore, participants could have indirect exposure to these types of investments. Generally, alternatives can be illiquid. The performance of alternative investments can be volatile and may have limited liquidity. Such investments often have concentrated positions and may carry higher risks. Participants should understand that some alternative investment products often engage in leveraging and other speculative investment practices that may increase the risk of investment loss; are not required to provide periodic pricing or valuation information to investors; may involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as other registered products; and, in many cases, the underlying investments are not transparent and are known only to the investment manager of the alternative investment product. Cybersecurity Risks. With the increased use of technologies to conduct business, Strategic Advisers and its affiliates are susceptible to operational, information security, and related risks. These risks could include events that are wholly or partially beyond our control and may have a negative effect on our ability to conduct business activities. We believe that we have taken reasonable steps to mitigate these risks, but do not believe that we can eliminate them altogether. In general, cyber incidents can result from deliberate attacks or unintentional events that can arise from external or internal sources. Cyberattacks include but are not limited to gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software coding) for purposes of misappropriating assets or sensitive information; corrupting data, equipment, or systems; and causing operational disruption. Cyberattacks can also be carried out in a manner that does not require gaining unauthorized access, such as causing denial- of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). Cyber incidents affecting Strategic Advisers, its affiliates, or any other service providers (including but not limited to accountants, custodians, transfer agents, and financial intermediaries used by Fidelity or by an issuer of securities) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, interference with the ability to calculate asset prices, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities in which an account invests, counterparties with which an account engages in transactions, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. Investment Research Risks and Limitations. The investment research process employed by Strategic Advisers includes gathering, cleaning, culling, and analyzing large amounts of data from external public sources and/or third-party data providers, including, in some instances, through the use of generative artificial intelligence (“AI”) and large language models (“LLM”). It is not possible or practicable, however, to factor all relevant, available data into economic forecasts or trading decisions. In addition, 27  due to the automated nature of this data gathering and the fact that much of this data comes from third-party sources, it is inevitable that not all desired or relevant data will be available to, or processed by, Strategic Advisers at all times. Clients should be aware that there is no guarantee that the data utilized in generating forecasts or making trading decisions will be the most accurate data available or even free of errors. Furthermore, the use of AI and LLMs may require training of the models to be used in the research process and proper engagement by analysts in order to yield the desired outcome. There can be no guarantee that LLMs can be trained to address all scenarios or that they will provide complete and accurate responses in all situations. AI and LLMs are subject to various risks, including (i) the data used to train LLMs suffers inaccuracies, biases, or flaws that may cause the AI model to respond other than as intended; (ii) weak controls in the development and use of AI allow it to be deployed for use cases for which it was not intended; and (iii) the AI may provide inaccurate or fabricated responses to queries it is unable to process. Fidelity has adopted a Generative AI policy and governance framework so that the use of AI and LLMs is targeted and limited, and that AI and LLMs are trained using known and appropriate data sources and are subject to controls and oversight, which helps ensure that the use of AI and LLMs is but one input into the research process. Clients should assume that the foregoing limitation and risks associated with gathering, cleaning, culling, and analyzing of large amounts of data from third-party, other external sources, and the use of AI and LLMs, are an inherent part of investing. There may also be incidents where data fails to load or internal systems fail to retrieve or capture the data, for example, because of changes in the vendor’s or our system configurations due to upgrades, enhancements, maintenance or errors, or that LLMs provide incorrect information in response to certain prompts. Clients should assume that these data errors, like other system implementation errors, and their ensuing risks and impact are an inherent part of investing. Accordingly, unless otherwise required to do so, Strategic Advisers does not expect to disclose discovered data errors to clients. Operational Risks. Operational risks can include risk of loss arising from failures in internal processes, people, or systems, such as routine processing incidents or major systems failures, or from external events, such as exchange outages. In addition, algorithms are used in providing the Program Services. For example, algorithms are used as part of the process whereby we recommend an appropriate asset allocation strategy that corresponds to a level of risk consistent with your Personal Profile. In providing financial planning services, algorithms are also used in analyzing the potential for success of your financial plan. We also use algorithms in support of our discretionary investment management process. There is a risk that the data input into the algorithms could have errors, omissions, or imperfections, or that the algorithms do not operate as intended (generally referred to as “processing incidents”). Any decisions made in reliance on incorrect data or algorithms that do not operate as intended (e.g., assigning a participant to an inappropriate portfolio) can expose Managed Accounts to potential risks. Issues in the algorithm are often extremely difficult to detect and could go undetected for long periods of time or never be detected. These risks are mitigated by testing and human oversight of the 28  algorithms and their output. We believe that the oversight and testing performed on our algorithms and their output will enable us to identify and address issues appropriately. However, there is no assurance that the algorithms will always work as intended. In general, we will not assess each Managed Account individually, nor will we override the outcome of the algorithm with respect to any particular Managed Account. Not all processing incidents arising from operational failures, including those resulting from mistakes of third parties, will be compensable by us to you. We maintain policies and procedures that address the identification and resolution of processing incidents, consistent with applicable standards of care, to ensure that participants are treated fairly when a processing incident has been detected. The determination of whether, and how, to address a processing incident is made by us in our sole discretion. Processing incidents will be reviewed to determine whether there was a financial impact on your Managed Account, and to evaluate the materiality of the impact, among other things. If we determine that a material financial impact has occurred, we will make an appropriate correction or otherwise reimburse the Managed Account in an amount we determine is appropriate based on all relevant circumstances. Typically, processing incidents that result in a financial impact of less than $10 per Managed Account are not considered material. Other examples of impact that could affect the performance of a Managed Account but would likely not be material include impacts arising from computer, communications, data processing, network, cloud computing, backup, business continuity or other operating information, or technology systems, including those we outsource to other providers, failing to operate as planned or becoming disabled, overloaded, or damaged as a result of a number of factors. These factors could include events that are wholly or partially beyond our control and could have a negative impact on our ability to conduct business activities. In addition, as described above, to the extent that the process for identifying or implementing an asset allocation did not operate as intended and the Managed Account Allocation for your Account is determined to have been outside a predetermined range that we believe is appropriate and prudent based on our investment judgment, subject to the other conditions described above, we will put the Managed Account in the position it would have been in had the asset allocation methodology initially operated as intended. We will evaluate each situation independently, and unless prohibited by applicable regulation or a specific agreement with the plan sponsor, we will net your gains and losses from the error or a series of related errors with the same root cause and compensate you for the net loss. This corrective action could result in financial or other restitution to the Managed Account, or in inadvertent gains being reversed out of the Managed Account. Past performance is not a guarantee of future returns. Investing in securities and other investments involves a risk of loss that participants should understand and be willing to bear. Participants are encouraged to discuss these risks with a Fidelity representative. 29  Other Information about the Management of Your Account Except as otherwise required by law, Fidelity will not be liable for the following: • Any loss resulting from following your instructions or the instructions of the plan fiduciary, or using inaccurate, outdated, or incomplete information provided by you or your plan fiduciary; • Any act or failure to act by a fund or any of its agents or any other third party; or • Any loss in the market value of your Managed Account for any reason, except for losses resulting from Fidelity’s breach of fiduciary duty, bad faith, or gross negligence. Nothing herein is intended to operate as a waiver of our applicable fiduciary duties. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Strategic Advisers or the integrity of the firm’s management personnel. Other Financial Industry Activities and Affiliations Strategic Advisers is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is a wholly owned subsidiary of FMR LLC. FMR LLC is a Delaware limited liability company that, together with its affiliates and subsidiaries, is generally known to the public as Fidelity Investments or Fidelity. Various direct or indirect subsidiaries of FMR LLC are engaged in investment advisory, brokerage, banking, or insurance businesses. From time to time, Strategic Advisers and its clients will have material business relationships with any of the subsidiaries and affiliates of FMR LLC. In addition, the principal officers of Strategic Advisers serve as officers and/or employees of affiliated companies that are engaged in various aspects of the financial services industry. Strategic Advisers is not registered as a broker-dealer, futures commission merchant, or commodity trading advisor, nor does it have an application pending to register as such. Strategic Advisers is registered with the U.S. Commodity Futures Trading Commission (“CFTC”) under the Commodity Exchange Act of 1936, as amended (“CEA”), as a commodity pool operator (“CPO”) and is a member of the National Futures Association (“NFA”). Certain personnel of Strategic Advisers, FBS, and NFS share premises and have common supervision. Certain management persons of Strategic Advisers are registered representatives, employees, and/or management persons of FBS and/or Fidelity Distributors Company LLC, Strategic Advisers affiliates, and registered broker- dealers. In addition, Strategic Advisers has entered into an intercompany agreement with FBS pursuant to which FBS provides to Strategic Advisers various operational, promotional, administrative, analytical, and technical services, and the personnel necessary for the performance of such services. 30  Strategic Advisers has, and its clients could have, a material relationship with the following affiliated companies: Investment Companies and Investment Advisers • Fidelity Management & Research Company LLC (“FMRCo”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Investment Advisers Act of 1940 (the “Advisers Act”). FMRCo provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FMRCo acts as sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients and provides portfolio recommendations and environmental filtering services to Strategic Advisers in connection with Strategic Advisers’ provision of discretionary portfolio management to certain clients. Strategic Advisers pays FMRCo an administrative fee for handling the business affairs of the registered investment companies advised by Strategic Advisers, and Strategic Advisers compensates FMRCo for making certain mutual funds available to managed account programs offered by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FMRCo. • Fidelity Institutional Wealth Adviser LLC (“FIWA”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FIWA provides nondiscretionary investment management services and sponsors the Fidelity Managed Account Xchange® and Fidelity Managed Account Xchange Essentials programs (turn-key asset management programs made available to financial intermediaries). Strategic Advisers provides model portfolio services to FIWA in connection with FIWA’s services to its institutional and intermediary clients, and FIWA compensates Strategic Advisers for such services. In addition, Strategic Advisers shares employees from time to time with FIWA. • FIAM LLC (“FIAM”), a wholly owned subsidiary of FIAM Holdings LLC, which in turn is wholly owned by FMR LLC, is a registered investment adviser under the Advisers Act and is registered with the Central Bank of Ireland. FIAM provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. Strategic Advisers has sub-advisory agreements with FIAM for certain registered investment companies advised by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FIAM. • FMR Investment Management (UK) Limited (“FMR UK”), an indirect, wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act, has been authorized by the U.K. Financial Conduct Authority to provide investment advisory and portfolio management services, and is registered with the Central Bank of Ireland. FMR UK provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub- advisory agreements with FMR UK for certain registered investment companies advised by Strategic Advisers. 31  • Fidelity Management & Research (Japan) Limited (“FMR Japan”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Japan Financial Services Agency (Kanto Local Finance Bureau) to provide investment advisory and discretionary investment management services. FMR Japan provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Japan for certain registered investment companies advised by Strategic Advisers. • Fidelity Management & Research (Hong Kong) Limited (“FMR Hong Kong”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Hong Kong Securities & Futures Commission to advise on securities, deal in future contracts, provide asset management services, and conduct trading services. FMR Hong Kong provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Hong Kong for certain registered investment companies advised by Strategic Advisers. • Fidelity Diversifying Solutions LLC (“FDS”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FDS is registered with the CFTC under the CEA as a CPO and as a commodity trading advisor. FDS is a member of the NFA. FDS provides discretionary advisory and sub-advisory services. FDS acts as a sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients. Broker-Dealers • Fidelity Distributors Company LLC (“FDC”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Securities Exchange Act of 1934 (the “Exchange Act”). FDC acts as principal underwriter of business development companies and the registered investment companies in the Fidelity group of funds and also markets those funds and other products to third-party financial intermediaries and certain institutional investors. • National Financial Services LLC (“NFS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. NFS is a fully disclosed clearing broker-dealer that provides clearing, settlement, and execution services for other broker-dealers, including its affiliate FBS. Fidelity Capital Markets (“FCM”), a division of NFS, provides trade executions for Fidelity affiliates and other clients. Additionally, FCM operates CrossStream®, an alternative trading system ("ATS") that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. CrossStream is used to execute transactions for investment company and other clients. NFS provides transfer agent or subtransfer agent services and other custodial services to certain Fidelity clients. 32  • LeveL Markets, LLC, a registered broker-dealer and operator of two ATSs, operates the Luminex ATS and the Level ATS, which allow orders submitted by subscribers to be crossed against orders submitted by other subscribers. LeveL Holdings, LLC, owns LeveL Markets, LLC. Fidelity Global Brokerage Group, Inc., and FMR Sakura Holdings, Inc., each a wholly owned subsidiary of FMR LLC, have membership interests in LeveL Holdings, LLC, along with other members. LeveL Markets, LLC, charges a commission to both sides of each trade executed in the Luminex ATS and LeveL ATS. Luminex ATS and LeveL ATS are used to execute transactions for Fidelity affiliates’ investment company and other advisory clients. NFS serves as a clearing agent for transactions executed in the Luminex ATS and LeveL ATS. • Fidelity Brokerage Services LLC (“FBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act and provides brokerage products and services, including the sale of shares of registered investment companies in the Fidelity group of funds to individuals and institutions, including retirement plans, and acts as placement agent for certain privately offered investment funds advised by Strategic Advisers’ affiliates. In addition, along with Fidelity Insurance Agency, Inc. (“FIA”), FBS distributes variable insurance products, that are issued by Fidelity Investments Life Insurance Company (“FILI”) and Empire Fidelity Investments Life Insurance Company® (“EFILI”), both Fidelity affiliates, as well as by third-parties. FBS provides shareholder services to certain of Strategic Advisers’ clients. FBS is the introducing broker for managed accounts offered by Strategic Advisers and places orders for execution with its affiliated clearing broker, NFS. • Digital Brokerage Services LLC (“DBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. DBS provides securities brokerage to retail customers through a digital/mobile application-based brokerage platform. DBS receives remuneration from FMRCo for expenses incurred in servicing and marketing FMRCo products. Insurance Companies or Agencies • FILI, a wholly owned subsidiary of FMR LLC, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates. • EFILI, a wholly owned subsidiary of FILI, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates to residents of New York. • FIA, a wholly owned subsidiary of FMR LLC, is engaged in the business of selling life insurance and annuity products of affiliated and unaffiliated insurance companies. 33  Banking Institutions • Fidelity Management Trust Company (“FMTC”), a wholly owned subsidiary of FMTC Holdings LLC, which in turn is wholly owned by FMR LLC, is a limited- purpose trust company organized and operating under the laws of the Commonwealth of Massachusetts that provides nondiscretionary trustee and custodial services to employee benefit plans and individual retirement accounts through which individuals can invest in affiliated or unaffiliated registered investment companies. FMTC also provides discretionary investment management services to institutional clients. • Fidelity Personal Trust Company, FSB, a wholly owned subsidiary of Fidelity Thrift Holding Company, Inc., which in turn is wholly owned by FMR LLC, is a federal savings bank that offers fiduciary services that include trustee or co- trustee services, custody, principal and income accounting, investment management services, and recordkeeping and administration. Limited Partnerships and Limited Liability Company Investments Strategic Advisers provides discretionary investment management to partnerships and limited liability companies designed to facilitate acquisitions by mutual funds offered by Strategic Advisers. These funds are privately offered consistent with stated investment objectives. Strategic Advisers does not currently engage in borrowing, lending, purchasing securities on margin, short selling, or trading in commodities. Participating Affiliate Certain employees of Fidelity Strategic Advisers Ireland, Limited (“Strategic Ireland”), can from time to time provide certain services, including but not limited to research, operations, and investment management support services for Strategic Advisers, which Strategic Advisers could use for its clients. Strategic Ireland is not registered as an investment adviser under the Advisers Act and is deemed to be a “Participating Affiliate” of Strategic Advisers (as this term has been used by the SEC’s Division of Investment Management in various no-action letters granting relief from the Advisers Act’s registration requirement for certain affiliates of registered investment advisers). Strategic Advisers deems Strategic Ireland and each of the Strategic Ireland Associated Employees as “associated persons” of Strategic Advisers within the meaning of Section 202(a)(17) of the Advisers Act. Strategic Ireland Associated Employees and Strategic Ireland through such employees can contribute to Strategic Advisers’ research process and could have access to information concerning securities that are being selected for clients prior to the effective implementation of such selections. As a Participating Affiliate of Strategic Advisers, Strategic Ireland has agreed to submit itself to the jurisdiction of United States courts for actions arising under United States securities laws in connection with investment advisory activities conducted for Strategic Advisers’ clients. Strategic Advisers maintains a list of Strategic Ireland Associated Employees whom Strategic Ireland has deemed associated persons, and Strategic Advisers will make the list available to its current U.S. clients upon request. 34  Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading We have adopted a Code of Ethics for Personal Trading (the “Code of Ethics”). The Code of Ethics applies to all officers, directors, employees, and other supervised persons of Fidelity’s registered investment advisers and requires that they place the interests of clients above their own. The Code of Ethics establishes securities transaction requirements for all covered employees and their covered persons, including their spouses. More specifically, the Code of Ethics contains provisions requiring the following: (i) Standards of general business conduct reflecting the investment advisers’ fiduciary obligations; (ii) Compliance with applicable federal securities laws; (iii) Employees and their covered persons to move their covered accounts to FBS, unless an exception exists or prior approval has been granted; (iv) Reporting and review of personal securities transactions and holdings for persons with access to certain nonpublic information; (v) Prohibition of purchasing securities in initial public offerings, unless an exception has been approved; (vi) Reporting of Code of Ethics violations; and (vii) Distribution of the Code of Ethics to all supervised persons, documented through acknowledgments of receipt. Core features of the Code of Ethics generally apply to all Fidelity employees. The Code of Ethics also imposes additional restrictions and reporting obligations on certain advisory personnel, research analysts, and portfolio managers. Such restrictions and reporting obligations include (i) the preclearing of transactions in covered securities with limited exceptions, (ii) a prohibition on investments in limited offerings without prior approval, (iii) a prohibition on personal trading by a portfolio manager within seven days before or after a trade in any covered security of the same issuer by a fund or account managed by such portfolio manager except in limited circumstances, (iv) the reporting of transactions in covered securities on a quarterly basis with limited exceptions, (v) the reporting of securities accounts and holdings of covered securities at the time of hire and annually thereafter, and (vi) the disgorgement of profits from short-term transactions, with limited exceptions. Violation of the Code of Ethics requirements can also result in the imposition of remedial action. The Code of Ethics will generally be supplemented by other relevant Fidelity policies, including the Policy on Inside Information, Rules for Broker-Dealer Employees, and other written policies and procedures adopted by Strategic Advisers and its affiliates. A copy of the Code of Ethics will be provided to any client or prospective client on request. From time to time, our related persons can buy or sell securities for themselves and recommend those securities to clients. The conflicts of interest involved in such activities are contemplated in the Code of Ethics and other relevant Fidelity policies. In particular, 35  the Code of Ethics and other Fidelity policies are designed to make it clear to Fidelity personnel that they should never place their personal interests ahead of Fidelity’s clients in an attempt to benefit themselves or another party. The Code of Ethics and other Fidelity policies impose sanctions if these requirements are violated. From time to time, in connection with their business, certain supervised persons of Strategic Advisers obtain material nonpublic information that is usually not available to other investors or the general public. In compliance with applicable laws, Strategic Advisers has adopted a comprehensive set of policies and procedures that prohibits the use of material nonpublic information by investment professionals or any other employees and limits the transactions that Strategic Advisers can implement for Managed Accounts. In addition, Fidelity has implemented a Corporate Gifts & Entertainment Policy intended to set standards for business entertainment and the giving or receiving of gifts, to help employees make sound decisions with respect to these activities, and to ensure that the interests of clients come first. Similarly, to support compliance with applicable “pay to play” laws, Fidelity has adopted a Personal Political Contributions & Activities Policy that requires all employees to preclear any political contributions and activities. Fidelity also has a Global Anti-Corruption Policy regarding commercial bribery and bribery of government officials that prohibits directly or indirectly giving, offering, authorizing, promising, accepting, or receiving any bribe, facilitation payment, kickback, or payoff (whether in cash or any other form) with the intent to improperly obtain or retain business or any improper advantage. Brokerage Practices Strategic Advisers does not select or recommend broker-dealers to execute any trades for the Program or recommend, request, require, or permit participants to direct brokerage transactions in connection with the Program. Strategic Advisers does not aggregate, or have the opportunity to aggregate, the purchase or sale of securities for Plan Accounts. Strategic Advisers does not have a soft dollar program. Review of Accounts We will contact you periodically to request that you update your Personal Profile. This periodic review is important to help us confirm that your investment strategy remains appropriate for you. If we do not hear from you, we will automatically review your Managed Account using your Personal Profile information, including updated Plan Account data from your Fidelity workplace savings plan, as well as updated account balances for Other Account Assets of which we are aware and certain retirement benefit information recordkept at Fidelity or provided by a third party to Fidelity. If our review results in changes to your long-term asset allocation, your Managed Account Allocation will be reallocated to align with your updated Personal Profile information. In addition, if we modify the assumptions and/or methodologies used to identify your investment strategy, your Managed Account Allocation could be reallocated. We will notify you 36  about any changes that occur in your Account and/or send confirmations of any trades executed as a result of a reallocation, and your continued enrollment in the Program constitutes your approval of your investment strategy. Participants can and are encouraged to provide updated Personal Profile information any time there is a change to their Personal Profile information, even outside of the periodic review. You will receive confirmations of any transaction made in your Managed Account. You will also receive any other information that pertains to activity in your Plan Account that you would receive if you were not enrolled in the Program. On a regular basis, we will evaluate the performance of portfolios, investment option changes, and time lag since the portfolios’ last reallocation. The portfolios generally will be reallocated and rebalanced three to four times a year and when plan option changes necessitate the review of new portfolio allocations. As noted above, your Plan Account is also regularly monitored. Because of account activity you can initiate, such as loans and withdrawals, or as a result of market fluctuations, among other things, your investments can deviate from the your intended asset allocation and your Managed Account might be reallocated to ensure alignment. We and your plan will provide you with information about the performance of your Managed Account. Performance is presented in compliance with industry standards, and performance information is not reviewed or approved by any third party. We and your plan will also provide you with information about the performance of the individual mutual funds held in your Managed Account, in accordance with regulatory standards for mutual fund performance information. We will also provide you with information about the performance of non-mutual funds used in your Managed Account to the extent that we are able to obtain such information from the fund’s trustee or manager or your plan sponsor. Client Referrals and Other Compensation Affiliates of Strategic Advisers are compensated for providing services, including for investment management, distribution, transfer agency, servicing, and custodial services, to certain Fidelity Funds, non-Fidelity mutual funds, and other investments in which Managed Accounts are invested or which a participant could use to implement the Program’s financial planning recommendations. These affiliates include FMRCo and its affiliates as the investment advisers for the Fidelity Funds; FDC as the underwriter of the Fidelity Funds; and Fidelity Investments Institutional Operations Company LLC (“FIIOC”) as transfer agent for the Fidelity Funds, servicing agent for non-Fidelity mutual funds, and recordkeeper of certain workplace savings plans. Affiliates of Strategic Advisers also receive compensation and other benefits in connection with portfolio transactions executed on behalf of Fidelity Funds, non-Fidelity mutual funds, and other investments. FMRCo and its affiliates also obtain brokerage or research services, consistent with Section 28(e) of the Exchange Act, from broker-dealers in connection with the execution of the Fidelity Funds’ portfolio security transactions. 37  FBS and NFS receive compensation for executing portfolio transactions and providing, among other things, clearance, settlement, custodial, and other services to Fidelity Funds, non-Fidelity mutual funds, and other investments, and NFS provides securities lending agent services to certain Fidelity Funds for which it receives compensation. FBS, NFS, and FIIOC also offer Fidelity’s mutual fund platform, the FundsNetwork®, and provide participating mutual funds with shareholder and other services for which FBS, NFS, and FIIOC receive compensation, including with respect to those mutual funds in which Managed Accounts are invested. The compensation described above that is received by affiliates of Strategic Advisers for investment management services provided to Fidelity mutual funds held in Managed Accounts, as well as the compensation received by affiliates of Strategic Advisers as a result of investments by the Managed Accounts in non-Fidelity mutual funds will be included in the Plan Credit Amount (as described in “Fees and Compensation”), which reduces the gross advisory fee. However, to the extent that affiliates of Strategic Advisers, including FBS, NFS, or FIIOC, receive compensation from Fidelity mutual funds other than management fees, as well as the compensation from non-Fidelity mutual funds that is neither a direct result of, nor directly derived from, investments by the Managed Accounts, such compensation is not included in the Plan Credit Amount, does not reduce the gross advisory fee, and will be retained by such affiliates. Receipt of compensation in addition to the gross advisory fee creates a financial incentive for Strategic Advisers to recommend or select portfolios that contain a higher allocation to investments that will increase such compensation. Strategic Advisers seeks to address this financial conflict of interest through the application of the Plan Credit Amount, which will reduce the gross advisory fee, as applicable, through personnel compensation arrangements (including those of Strategic Advisers’ investment professionals and the Fidelity representatives) that are not differentiated based on the investments selected for Managed Accounts, or through other means under applicable law. Strategic Advisers and its affiliates have also implemented processes reasonably designed to prevent the receipt of compensation from affecting the nature of the advice provided to plan participants. See “Fees and Compensation” for additional information. Client referrals are provided by affiliated entities, including FBS or other affiliates, pursuant to referral or other agreements where applicable. Fidelity Financial Advisor Solutions and certain of its operating divisions, including FIIOC, receive compensation for services that facilitate delivery of FPPA to plan sponsor clients. Additionally, Strategic Advisers refers clients to other independent investment advisers in connection with a referral program in which such independent investment advisers participate for a fee payable to Strategic Advisers. Additional details are available upon request. Custody Account records, confirmations, and client account statements are maintained by FIIOC, a Fidelity affiliate and a registered transfer agent that provides transfer agency and recordkeeping services for the plan. You should carefully review all statements received from FIIOC with respect to your Managed Account. Strategic Advisers is deemed to have custody under the Advisers Act in certain circumstances. 38  Investment Discretion A plan sponsor must agree to the terms of the investment management agreement with Strategic Advisers, which includes the plan sponsor’s delegation of investment authority to provide discretionary investment management for Plan Accounts that have enrolled in the Program. Participants can enroll in the Program by proactively contacting us or, in some cases, through a default enrollment process selected by their plan sponsor. Voting Client Securities Strategic Advisers does not have authority for or exercise proxy voting discretion on your behalf in connection with the Program. You will receive proxies or other solicitations directly from the custodian or the transfer agent to the extent permitted by your plan, but we will not advise you on the voting of proxies for shares held in your Managed Account. In addition, we will not advise you on solicitations or legal proceedings, including bankruptcies and class actions, involving investment options. Financial Information Strategic Advisers does not solicit the prepayment of client fees. Strategic Advisers is not aware of any financial conditions that are reasonably likely to impair its ability to meet contractual commitments to clients. 39  Keep in mind that investing involves risk. The value of your investment will fluctuate over time, and you may gain or lose money. Diversification and asset allocation do not ensure a profit or guarantee against loss. Fidelity does not provide legal or tax advice, and the information provided is general in nature and should not be considered legal or tax advice. Clients and participants should consult an attorney, tax professional, or other advisor regarding their specific legal or tax situation. Fidelity® Personalized Planning & Advice at Work (“FPPA”) is a service of Strategic Advisers LLC, a registered investment adviser and a Fidelity Investments company. This service provides advisory services for a fee. Distribution support services are provided by Fidelity Brokerage Services LLC, Member NYSE, SIPC, 900 Salem Street, Smithfield, RI 02917. Recordkeeping and transfer agency services are provided by Fidelity Investments Institutional Operations Company LLC, 245 Summer Street, Boston, MA 02210. Any third-party trademarks or service marks appearing herein are the property of their respective owners. All other trademarks and service marks appearing herein are the property of FMR LLC or an affiliated company and may be registered. Fidelity Brokerage Services LLC, Member NYSE, SIPC, 900 Salem Street, Smithfield, RI 02917 © 2026 FMR LLC. All rights reserved. 834328.12.0 01/49870 1.9887603.111 40 

Fidelity® Strategic Disciplines Form ADV, Part 2A Brochure Strategic Advisers LLC 155 Seaport Boulevard Boston, MA 02210-2698 617.563.7000 Fidelity.com March 30, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Strategic Advisers LLC (“Strategic Advisers”), a Fidelity Investments® company, as well as information about Fidelity Strategic Disciplines. Throughout this brochure and related materials, Strategic Advisers refers to itself as a “registered investment adviser” or as being “registered.” These statements do not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please call us at 800.544.3455. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Strategic Advisers is available on the SEC’s website at adviserinfo.sec.gov.  S U M M A R Y O F M A T E R I A L C H A N G E S The SEC requires registered investment advisers to provide and deliver an annual summary of material changes to their advisory services program brochure (also referred to as the Form ADV, Part 2A brochure). The section below highlights only material revisions that have been made to the Fidelity Strategic Disciplines Form ADV, Part 2A brochure (the “Program Brochure” or “Brochure”) from March 31, 2025, through March 30, 2026. Clients and prospective clients can obtain a copy of the Program Brochure without charge by calling 800.544.3455, by visiting Fidelity.com/information, by visiting the SEC’s website at adviserinfo.sec.gov, or by contacting their Fidelity representative. Capitalized terms are defined in the Program Brochure. Material Changes • Effective Q4 2025, state-preference options will be available for the Fidelity Limited Duration Municipal Strategy. Please see “Investment Strategies” for more information. • Effective the second quarter of 2026, the account investment minimum will be lowered to $200,000 for taxable bond strategies and $250,000 for municipal bond strategies. Please see page 21 for further information. • The discussion of the Bond Strategies has been updated to explain that each sub-advisor generally will consider tax-loss harvesting as part of its standard portfolio management practices. Other Changes • The chart in “Other Considerations” has been updated to provide further and updated information about the programs, accounts, and services available from Strategic Advisers and its affiliates. • “Information about Fidelity and Fidelity Representative Compensation” has been updated to provide further information about how Fidelity and its representatives are compensated. • “Material Risks” has been updated to provide further information with respect to the efficacy of tax-smart investing techniques for Program clients in lower federal income tax brackets. • Certain minor revisions have been made to the text that describes Strategic Advisers’ affiliates in “Other Financial Industry Activities and Affiliations.” 2  T A B L E O F C O N T E N T S SUMMARY OF MATERIAL CHANGES 2 SERVICES, FEES AND COMPENSAT IO N 4 ACCOUNT REQUI REMENTS AND T YP ES OF C LIENTS 16 PORTFOLIO MANAGER SELECTIO N AN D EVALUATIO N 20 CLIENT INFORMATION PROVIDED TO P ORTFO LIO MAN AGERS 31 CLIENT CONTACT WITH POR TF O LIO MAN AGERS 32 ADDITIONAL INFORMATION 32 BROKERAGE PRACTICES 37 3  S E R V I C E S , F E E S A N D C O M P E N S A T I O N Strategic Advisers is a registered investment adviser under the Investment Advisers Act of 1940 (“Advisers Act”) and an indirect, wholly owned subsidiary of FMR LLC (collectively with Strategic Advisers and its affiliates, “Fidelity Investments,” “Fidelity,” “us,” “our,” or “we”). Strategic Advisers was formed in 1977 and offers a number of investment advisory programs, including Fidelity® Strategic Disciplines (the “Program”) and provides a variety of investment management services, including discretionary portfolio management services to retail and institutional clients and nondiscretionary advisory services to certain institutional clients, including but not limited to Fidelity affiliates. This brochure provides information only about Strategic Advisers’ role with respect to the Program. As described below, Fidelity Strategic Disciplines is a separately managed account program in which clients (also referred to as "you” throughout this Brochure) hire Strategic Advisers and authorize us to retain one or more investment advisers (“sub-advisors”) on their behalf to implement a selected investment strategy on a discretionary basis (“Program Services”). For Equity Strategies (listed below), Strategic Advisers has not retained sub-advisors and provides discretionary management services for accounts in the Program (“Program Accounts”). For Bond Strategies (listed below), Strategic has retained sub-advisors who provide discretionary portfolio management services for Program Accounts. The Program offers 14 investment strategies: the Breckinridge Intermediate Municipal Strategy, the Breckinridge Limited Duration Municipal Strategy, the Fidelity® Intermediate Municipal Strategy, the Fidelity® Limited Duration Municipal Strategy, the Fidelity® Core Bond Strategy, the Fidelity® Limited Duration Bond Strategy (each individually a “Bond Strategy” and collectively the “Bond Strategies”), the Fidelity® U.S. Large Cap Index Strategy, the Fidelity® U.S. Large Cap Strategy, the Fidelity® Dividend Income Strategy, the Fidelity® International Strategy, the Fidelity International Index Strategy, the Fidelity® U.S. Total Market Index Strategy, the Fidelity® U.S. Low Volatility Index Strategy, and the Fidelity® Environmental Focus Strategy (each individually an “Equity Strategy” and collectively the “Equity Strategies”). Discretionary Investment Management Services The Program’s strategies provide a portfolio consisting of bonds or equities (i.e., a single asset class). These strategies are expected to have increased risk and volatility as compared with a portfolio that holds a mix of bonds, equities, and other investment types. Accordingly, clients should be comfortable with the risk of holding a single asset class in their Program Account. As part of the Program’s investment management services, we will obtain information regarding the client’s financial situation, planned investment horizon and objectives, risk tolerance, and tax situation (“Profile Information”). A Fidelity representative can assist the client in choosing from among the following investment strategies: Investment Strategies The Breckinridge Intermediate Municipal Strategy and the Breckinridge Limited Duration Municipal Strategy each invest in investment-grade municipal bonds (as well as prerefunded and escrowed-to-maturity municipal bonds, regardless of credit rating). These strategies seek to limit risk to principal while generating federal tax-exempt interest income. A state-preference option is available for eligible clients in either strategy. With the state-preference option, state tax-exempt interest income is emphasized over national diversification. Breckinridge Capital Advisors, Inc. (“Breckinridge”), an unaffiliated registered investment adviser, is the sub-advisor for both strategies. Breckinridge conducts tax-loss harvesting as part of its standard portfolio management process for these strategies. Please refer to the Breckinridge Form ADV, Part 2A brochure for more information about its approach to tax-loss harvesting. The Fidelity Intermediate Municipal Strategy and the Fidelity Limited Duration Municipal Strategy invest in investment-grade municipal bonds (as well as prerefunded and escrowed-to-maturity municipal bonds, regardless of credit rating). These strategies seek to generate federal tax-exempt interest income while limiting risk to principal over a full market cycle. A state-preference option is available for eligible clients in the Fidelity Intermediate Municipal Strategy and Fidelity Limited Duration Municipal Strategy. With the state-preference 4  option, state tax-exempt interest income is emphasized over national diversification. Fidelity Management & Research Company LLC (“FMRCo”), an affiliate of Strategic Advisers, is the sub-advisor for both strategies. FMRCo generally will consider tax-loss harvesting as part of its standard portfolio management practices, but FMRCo has full discretion to determine whether to harvest losses in client accounts and it is under no obligation to harvest all losses. Please see the FMRCo Form ADV, Part 2A brochure for more information about its approach to tax-loss harvesting. The Fidelity Core Bond Strategy invests in investment-grade bonds, including government-related bonds, corporate bonds, mortgage bonds, asset-backed bonds, and taxable municipal bonds (as well as prerefunded and escrowed-to-maturity bonds, regardless of credit rating), and can invest in a Fidelity exchange-traded fund (“ETF”) that primarily holds securitized bonds, such as residential mortgage-backed, commercial mortgage-backed, or asset-backed securities. This strategy seeks to generate interest income while limiting risk to the client’s original investment over a full market cycle. FMRCo is the sub-advisor for the Fidelity Core Bond Strategy. FMRCo generally will consider tax-loss harvesting as part of its standard portfolio management practices, but FMRCo has full discretion to determine whether to harvest losses in client accounts and it is under no obligation to harvest all losses. Please see the FMRCo Form ADV, Part 2A brochure for more information about its approach to tax-loss harvesting. The Fidelity Limited Duration Bond Strategy invests in investment-grade bonds, including corporate bonds and government-related bonds, and can invest in a proprietary mutual fund designed for use in Program Accounts. The fund primarily holds securitized investments, such as asset-backed securities and mortgage-backed securities. This strategy seeks to generate interest income while limiting risk to the client’s original investment over a full market cycle. FMRCo is the sub-advisor for the Fidelity Limited Duration Bond Strategy. FMRCo generally will consider tax-loss harvesting as part of its standard portfolio management practices, but FMRCo has full discretion to determine whether to harvest losses in client accounts and it is under no obligation to harvest all losses. Please see the FMRCo Form ADV, Part 2A brochure for more information about its approach to tax-loss harvesting. The Fidelity U.S. Large Cap Index Strategy invests in stocks and seeks to approximate the pretax risk and return characteristics of the Fidelity U.S. Large Cap Index℠ (the “Large Cap Index”), which is designed to reflect the performance of the stocks of the largest 500 U.S. companies based on a float-adjusted market capitalization, while actively trading holdings in an attempt to enhance after-tax returns through the use of tax-smart investing techniques. The strategy seeks to enhance after-tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. In addition, while the strategy looks to approximate the risk and return characteristics of the Large Cap Index, it will purchase only a subset of the stocks that make up the index. The Fidelity U.S. Large Cap Strategy invests in stocks and seeks capital appreciation and to outperform the S&P 500® Index over a full market cycle. The strategy invests primarily in U.S. large-cap stocks but can also invest in securities not included in its index, including non-U.S. large-cap stocks, American Depositary Receipts (“ADRs”), real estate investment trusts (“REITs”), and exchange-traded products (“ETPs”). For taxable accounts, the strategy seeks to enhance after-tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. Strategic Advisers will manage the strategy’s accounts on a discretionary basis and has retained FMRCo to provide investment models (each a “Model Portfolio”) that it will use in managing accounts enrolled in the strategy. Strategic Advisers will blend Model Portfolios for multiple investment exposures (e.g., growth, value, and core equity) at its discretion based on market cycle implications and overall portfolio positioning. The Fidelity Dividend Income Strategy invests in stocks and seeks capital appreciation and dividend income greater than that of the S&P 500 Index over a full market cycle. For taxable accounts, the strategy seeks to enhance after-tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. Strategic Advisers will manage the strategy’s accounts on a discretionary basis and has retained FMRCo to provide a Model Portfolio that Strategic Advisers will use in managing accounts enrolled in the strategy. 5  The Fidelity International Strategy invests in securities and seeks capital appreciation and to outperform the MSCI EAFE Index (Net MA Tax) over a full market cycle. This investment strategy invests primarily in ADRs and a proprietary mutual fund designed for use in Program Accounts that invests in foreign securities where ADRs are either unavailable or inappropriate. For taxable accounts, the strategy seeks to enhance after-tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. Strategic Advisers will manage the strategy’s accounts on a discretionary basis and has retained FMRCo to provide Model Portfolios that it will use in managing accounts enrolled in the strategy. Strategic Advisers will blend Model Portfolios for multiple investment exposures (e.g., growth, value, and core equity) at its discretion based on market cycle implications and overall portfolio positioning. The Fidelity International Index Strategy invests in securities and seeks to approximate the pretax risk and return characteristics of the Fidelity Developed International ex North America Focus Index (Net) by investing primarily in ADRs and ETPs while actively trading holdings in an attempt to enhance after-tax returns through the use of tax-smart investing techniques. The Fidelity Developed International ex North America Focus Index (Net) is designed to reflect the performance of the developed international equity market, including large- capitalization stocks, based on float-adjusted market capitalization. The strategy seeks to enhance after-tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. In addition, while the strategy looks to approximate the pretax risk and return characteristics of the Fidelity Developed International ex North America Focus Index (Net), it will purchase only a subset of the securities that make up the index. The Fidelity U.S. Total Market Index Strategy invests in stocks and seeks to approximate the pretax return and overall risk profile of the Fidelity U.S. Total Investable Market Index while actively trading holdings in an attempt to enhance after-tax returns through the use of tax-smart investing techniques. The Fidelity U.S. Total Investable Market Index is a float-adjusted market capitalization–weighted index designed to reflect the performance of the stocks of the largest 3,000 U.S. companies based on float-adjusted market capitalization. This index spans across the market capitalization of large-, mid-, and small-cap companies. The strategy seeks to enhance after- tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. While this strategy looks to approximate the pretax risk and return characteristics of the Fidelity U.S. Total Investable Market Index, it will purchase only a subset of the stocks that make up the index. The Fidelity U.S. Low Volatility Index Strategy invests in stocks and seeks to approximate the pretax return and overall risk profile of the Fidelity U.S. Low Volatility Focus Index while actively trading holdings in an attempt to enhance after-tax returns through the use of tax-smart investing techniques The Fidelity U.S. Low Volatility Focus Index is designed to reflect the performance of large- and mid-cap stocks with lower volatility than the broader market. The strategy seeks to enhance after-tax returns of Program Accounts through methods including but not limited to proactive tax-loss harvesting and deferring the realization of capital gains. While this strategy looks to approximate the pretax risk and return characteristics of the Fidelity® U.S. Low Volatility Focus Index, it will purchase a subset of the stocks that make up the index, as well as a subset of stocks from the largest 1,000 U.S. companies based on float-adjusted market capitalization. The Fidelity Environmental Focus Strategy invests in stocks and seeks to reduce ownership of securities in companies that have lower environmental ratings compared with the Large Cap Index while approximating the pretax risk and return characteristics of the Large Cap Index. This strategy seeks to enhance after-tax returns of taxable Program Accounts through the application of tax-smart investing techniques that include but are not limited to proactive tax-loss harvesting and deferring the realization of capital gains. Please note that the strategy’s goal of delivering a portfolio with a better aggregate environmental rating compared with the index could constrain the degree to which tax-smart investing techniques can be implemented. In addition, while this strategy looks to approximate the pretax risk and return characteristics of the Large Cap Index, it will purchase only a subset of the stocks that make up the index. It is important to understand that the application of environmental sustainability data and filtering will cause an account invested according to the Environmental Focus Strategy to forgo certain investment opportunities, which will cause such an account to perform differently, perhaps significantly, compared with an account that does not exclude issuers based on such criteria. 6  To develop a portfolio that seeks to reduce the ownership of companies that have lower environmental ratings compared with the Large Cap Index, Strategic Advisers has retained the services of its affiliate FMRCo. FMRCo will use a screening process to filter the Large Cap Index. First, FMRCo will reduce the investment universe by applying six broad exclusionary criteria that seek to exclude issuers that are directly engaged in, and/or derive significant revenue from, certain industries or product lines. Such issuers may include but are not limited to: • companies that are both in the top 30% of their sector and top 10% of the index with respect to carbon emissions; • companies that are both in the top 30% of their sector and top 10% of the index with respect to water usage; • companies subject to certain FMRCo sustainable portfolio exclusions (including civilian semiautomatic firearms manufacturers, tobacco producers, for-profit prison companies, cluster munitions and land mine manufacturers, and thermal coal production and/or mining companies); • companies with coal reserves; • companies with oil and gas reserves; • companies that generate electric power from thermal coal; and • companies with environmental ratings in or near the bottom 50%. FMRCo relies on its own proprietary research as well as data from third parties in applying these exclusionary criteria. FMRCo will rank issuers based on environmental ratings and provide Strategic Advisers with an investment universe that seeks to include the highest-scoring stocks in each sector (generally, the top 50%) as measured across a variety of environmental factors (the “Environmental Factors”) as determined by FMRCo analysts in their discretion to be most relevant for each sub-industry. FMRCo analysts select these Environmental Factors and assign weights to them for each stock in the Large Cap Index. These Environmental Factors include but are not limited to carbon emissions, water stress, and toxic emissions and waste. FMRCo uses data from a number of third-party data vendors (e.g., CDP and MSCI) as well as proprietary data to analyze the Environmental Factors. FMRCo will generally review and update stock weighting scores monthly. At any time, FMRCo can change Environmental Factors and stock-scoring processes as well as its process and data sources for evaluating issuers on any Environmental Factor. After the application of these exclusionary criteria and the scoring of all stocks in the index, the investment universe will generally include the top-scoring 200–300 issuers in the Large Cap Index, which represents approximately 40%–60% of the Large Cap Index. Strategic Advisers will generally invest in only a subset of the stocks of those issuers included in the environmentally screened investment universe, resulting in portfolios consisting of 100–200 stocks that, in the aggregate, have a better environmental rating compared with the Large Cap Index as a whole. FMRCo’s exclusionary criteria do not capture all possible Environmental Factors, and there is no common industry standard relating to the development and application of environmental sustainability criteria. Certain exclusions are based in whole or in part on data provided by one or more third-party vendors and are, therefore, subject to each vendor’s industry and product line definitions (which may differ from those of FMRCo and Strategic Advisers) and data limitations. Data used in applying the exclusion criteria may include inputs self-disclosed by companies as well as estimates where public disclosures are unavailable. The subjective value that an investor assigns to certain types of environmental sustainability criteria can differ substantially from that of FMRCo and Strategic Advisers, and reasonable investors can differ in their views of what constitutes positive or negative environmental sustainability characteristics. As a result, clients should not assume that the Fidelity Environmental Focus Strategy will necessarily invest in stocks of issuers that reflect their own environmental beliefs and values. 7  In addition, the Environmental Factors that FMRCo considers in evaluating an issuer’s environmental rating will change over time. Strategic Advisers reserves the right to use a different service provider to perform the environmental sustainability data assessment at any time. Any change in the service provider would likely result in the consideration of different factors in evaluating an issuer’s environmental rating, which could substantially change the portfolio for Environmental Focus Strategy accounts. Please note: If Strategic Advisers has been directed by a client to act as agent to vote proxies with respect to the individual securities held in an Equity Strategy Program Account, Strategic Advisers will vote proxies pursuant to the directions provided by Institutional Shareholder Services Inc. (“ISS”). The Environmental Focus Strategy does not evaluate or consider proxy voting in attempting to reach its objective. Accordingly, it is possible that ISS’ proxy voting directions can be inconsistent with, or contrary to, the environmental goal of an Environmental Focus Strategy account. Additional Information about Investment Techniques Preferences A values-based preference and a sustainable investing preference are available with the Fidelity U.S. Large Cap Index Strategy and the Breckinridge Intermediate Municipal Strategy, respectively, on a pilot basis. These pilots are not currently open to new investors. Clients should understand that the performance of the Program Account with a values-based investing or a sustainable investing preference could differ, at times significantly, from the performance of a Program Account managed without such a preference. Additionally, the use of such a preference is subject to the agreement of Strategic Advisers and the applicable sub-advisor. Tax-Smart Investing Techniques While each Equity Strategy and each Bond Strategy use tax-smart investing techniques in taxable accounts, please note that the stated investment objective for each strategy is of primary importance. Accordingly, while the application of tax-smart investing techniques such as tax-loss harvesting generally will be considered as part of the portfolio management process, the implementation of tax-smart investing techniques is not the primary consideration. Clients in all strategies should understand that significant tax consequences can result from investing in a strategy with a primary focus other than tax-smart investing techniques. For example, each Equity Strategy has a corresponding investable universe of investments that has been constructed by Strategic Advisers. With respect to the Environmental Focus Strategy, stocks used to fund a Program Account that are not included in the environmentally screened investable universe for the strategy will be sold without regard to potential tax consequences of such sales. Realizing gains could create a tax liability, particularly when offsetting losses are not available. For additional considerations related to tax-smart investing techniques for Equity Strategies, please see the disclosure below under “Opening and Funding a Program Account” and “Methods of Analysis, Investment Strategies, and Risk of Loss.” For additional information about tax-smart investing techniques for Bond Strategies, please see the relevant sub-advisor’s Form ADV, Part 2A brochure. Fractional Share Investing Each Equity Strategy can invest in fractional shares of individual securities. Please see “Methods of Analysis, Investment Strategies, and Risk of Loss” below for more information about fractional share trading in Program Accounts. Investment Restrictions A client can impose reasonable restrictions on the management of a Program Account. Any proposed restriction is subject to our or the applicable sub-advisor’s review and approval. Reasonable restrictions typically are specific to the purchase of a particular individual security or industry. Reasonable restrictions will not apply to underlying securities or holdings that are held in a mutual fund, ETP, or any other type of pooled vehicles purchased in a Program Account. If a restriction is accepted, assets will be invested in a manner that is appropriate given the restriction, which can include investment in ETPs. 8  It is important to understand that imposing an investment restriction can delay the start of discretionary management on a Program Account and can impact the performance of a Program Account, at times significantly, as compared with the performance of a Program Account managed without restrictions, possibly producing lower overall results. Program Account restrictions should be requested through a Fidelity representative. Access to a Fidelity Representative Program clients have access to a dedicated Fidelity representative who can work with the client to help evaluate the Program and how it can help meet the client’s financial goals and objectives, provide assistance with enrolling in the Program, deliver Program Services, and also provide general assistance with products and services provided by Fidelity outside of the Program. It is important to understand that each Fidelity representative also acts in the capacity of a registered representative of Fidelity Brokerage Services LLC (“FBS”), Strategic Advisers’ affiliated broker-dealer. Any financial planning a client receives from a Fidelity representative prior to us accepting the client’s Program Client Agreement is provided by FBS and is not part of the Program Services. Access to Financial Planning Services At a client’s request, a Fidelity representative can provide financial planning services to help evaluate the client’s ability to meet identified goals. We use various financial planning analytics and applications to provide financial planning services; the specific analysis provided to a client will be based on the assets allocated to a goal and the complexity of the client’s financial situation. Typically, financial planning begins by understanding needs and goals related to a Program Account, as well as any “Other Assets” a client has identified (e.g., assets held in other Fidelity programs or accounts, or at a third party, that are aligned with the same goal as a Program Account). If requested, financial planning can also include goals unrelated to a Program Account. We then work with the client to obtain information regarding the client’s financial situation. Next, we will review a client’s information and prepare an analysis. Our financial planning services typically include asset allocation modeling, which helps clients evaluate their ability to meet an identified goal based on their current asset allocation and can also provide recommendations for changes to an asset allocation. In general, our asset allocation recommendations will include allocations to stock, bond, and short-term asset classes and, for qualifying clients, can include an allocation to alternative investments. Our financial planning services do not include initial or ongoing advice regarding specific securities or other investments, any financial analysis provided outside this Program (including prior to enrolling in the Program), or any financial planning that a client engages in on their own in a financial planning tool that is made available online. Depending on the complexity of the client’s financial situation, and/or assets held in a Fidelity program, we can also help a client evaluate other financial planning needs, such as retirement planning, education funding, insurance planning, employee benefits planning (e.g., equity compensation arrangements), and consideration of tax and estate planning strategies. Please note that financial planning services are available to Program Accounts owned by a natural person, but typically are not provided to an entity, such as a corporation, limited liability company, or trust. Other than with respect to Program Accounts, which are managed on a discretionary basis through the Program, whether and how to implement any asset allocation or other recommendations provided as a component of our financial planning services is the responsibility of each client and is separate and distinct from the Program Services. Specifically, Other Assets are not managed as part of the Program and are subject to separate and distinct terms, conditions, and, as applicable, fees. In addition, if a client chooses to implement some or all of the asset allocation or other recommendations provided as part of the Program’s financial planning services through Fidelity, a Fidelity entity will act as a broker-dealer or investment adviser depending on the products or services selected, and the client will be subject to separate, applicable charges, fees, or expenses. For more information, please see the “Guide to Brokerage and Investment Advisory Services at Fidelity Investments” available at Fidelity.com/information, or speak with a Fidelity representative. 9  It is important to understand that there can be significant differences between the asset allocation modeling shown in a financial plan and the performance a client will actually experience. Asset allocation modeling is performed at the asset class level, assumes broad diversification within each asset class, relies on certain estimates about the performance of the securities markets, and is not designed to predict the future performance of any particular security or investment product. In addition, our assumptions and methodologies used in financial planning are adjusted from time to time, which can have an impact on the results obtained. It is important to understand that the modeling provided in conjunction with our financial planning services is hypothetical in nature; is for illustrative purposes only; does not reflect actual investment, tax, or other planning results; and is not a guarantee of future investment outcomes. The modeling results shown will vary with each use and over time. Responsibility of Clients We rely on client information to provide the Program Services. It is the client’s responsibility to advise us of changes to their goals, time horizon, tax situation, risk tolerance, and personal financial situation. Such changes can result in modification to the tax-smart investing techniques used for a Program Account Clients with multiple relationships with Fidelity should understand that updating information about a Program Account does not update information about an account enrolled in another advisory service or one that is self- directed. Accordingly, clients should ensure that their personal, financial, and other important information is independently updated for each respective service or account. FEES AND COMPENSATION Advisory Fees—Gross and Net of the Credit Amount. The Program charges an annual Gross Advisory Fee that includes the Program Services and is payable after the end of each quarter. The Gross Advisory Fee includes any fees paid by Strategic Advisers to a sub-advisor in consideration of the applicable sub-advisor’s discretionary investment management services provided to Program Accounts. The following fees are in addition to the Gross Advisory Fee: (i) certain charges resulting from transactions executed with or through broker-dealers that are not affiliates of Strategic Advisers and (ii) markups and markdowns, transfer taxes, exchange fees, regulatory fees, odd-lot differentials, handling charges, electronic fund and wire transfer fees, ADR custody fees, or any other charges imposed by law or otherwise agreed to with regard to a Program Account. Strategic Advisers or its affiliate can voluntarily assume the cost of certain commissions for equity transactions executed with or through broker-dealers that are not affiliates of Strategic Advisers; clients will not be charged commissions for such transactions. Where a mutual fund or ETP is purchased for a client account, and with respect to the core Fidelity money market fund, the Gross Advisory Fee will not include expenses of the mutual fund or ETP. These fund expenses, which vary by fund and class, are expenses that all mutual fund and ETP shareholders pay. Details of mutual fund or ETP expenses can be found in each mutual fund’s or ETP’s respective prospectus. These expenses are not separately itemized or billed; rather, the published returns of mutual funds and ETPs are shown net of their expenses. Some of these underlying mutual fund and ETP expenses are paid to Strategic Advisers or its affiliates as a result of investments by a Program Account and will be included in a Credit Amount as described below. Advisory Fees—Credit Amount. The Gross Advisory Fee applied to a Program Account is reduced by a Credit Amount. The Credit Amount is intended to address the conflicts of interest that arise in selecting investments that generate revenue for Fidelity by reducing the advisory fees paid to Strategic Advisers by the amount of compensation, if any, Strategic Advisers or its affiliates retain that is derived as a direct result of investments by Program Accounts, as detailed below. A Credit Amount is applied after the end of each quarter. To the extent applicable, a Credit Amount will be calculated for each mutual fund or ETP held by Program Accounts as follows: • For Fidelity Funds and ETPs, the Credit Amount will equal the underlying investment management and any other fees or compensation Strategic Advisers or its affiliates retain from these funds and ETPs as a direct result of investments by Program Accounts. 10  • For non-Fidelity funds and ETPs, the Credit Amount will equal the distribution fees, shareholder servicing fees, and any other fees or compensation Strategic Advisers or its affiliates retain from these funds and ETPs as a direct result of investments by Program Accounts. An aggregate Credit Amount is then allocated to each Program Account to arrive at the Net Advisory Fee. Please note that individual securities held in a Program Account do not impact the calculation of the Credit Amount. It is important to understand that Strategic Advisers’ affiliates receive compensation for providing a variety of services to mutual funds and ETPs, as described below in “Client Referrals and Other Compensation.” Such compensation is included in the Credit Amount only to the extent that it is retained as a direct result of investment by Program Accounts. Compensation that is not directly derived from Program Account assets is not included in the Credit Amount. Credit Amounts for non-Fidelity funds and ETPs are calculated one month in arrears. As a result, when a Program Account is closed, certain Credit Amounts for non-Fidelity funds and ETPs will not be applied against the Gross Advisory Fee for any partial period during the month in which a Program Account is closed. In such circumstances, Credit Amounts not applied to a closed Program Account are allocated, pro rata based on assets, among the open Program Accounts in the Program at the time the Credit Amount is applied. In addition, certain de minimis revenue received by Strategic Advisers’ affiliates could be donated to charity (rather than included in the Credit Amount) or could be allocated, pro rata based on client assets, among open Program Accounts in the Program. This operational process results in credits that would otherwise be attributable to one Program Account being received by another Program Account. Net Advisory Fee = Gross Advisory Fee – Credit Amount Please see the charts below for the annual advisory fee charged to Program Accounts. Please note that all fees are subject to change and that Strategic Advisers has the ability to negotiate advisory fees for certain accounts. ANNUAL ADVISORY FEE SCHEDULE FOR BOND STRATEGIES Average Daily Assets* Gross Advisory Fee Up to $3,000,000 0.40% For amounts greater than $3,000,000 0.35% *Subject to applicable limitations, clients can aggregate the assets of multiple Bond Strategy accounts to take advantage of the reduced Gross Advisory Fee breakpoints shown in the chart above. Upon account opening, we automatically aggregate certain Bond Strategy account registrations that share the same tax reporting identification number (such as IRA, Roth IRA, SEP IRA, individual, joint, and certain trust account registrations). To aggregate other accounts not eligible for automatic aggregation, including those with immediate family members (the client’s legal spouse, or the client’s ancestor, descendant, or sibling (or their legal spouse)), or to request aggregation of accounts after account opening, clients must complete an Account Aggregation Form or contact a Fidelity representative. Clients are responsible for verifying that all eligible accounts have been aggregated appropriately. ANNUAL ADVISORY FEE SCHEDULE FOR EQUITY STRATEGIES Fidelity U.S. Large Cap Index Strategy, Fidelity International Index Strategy, Fidelity U.S. Total Market Index Strategy, Fidelity U.S. Low Volatility Index Strategy, Fidelity Environmental Focus Strategy Fidelity U.S. Large Cap Strategy, Fidelity Dividend Income Strategy, Fidelity International Strategy Average Daily Assets† Gross Advisory Fee Gross Advisory Fee Up to $300,000 0.40% 0.70% For the next $200,000 0.40% 0.50% For the next $500,000 0.40% 0.45% For the next $1,000,000 0.26% 0.40% For the next $1,000,000 0.23% 0.35% For amounts greater than $3,000,000 0.20% 0.30% † Subject to applicable limitations, clients can aggregate the assets of multiple Equity Strategy accounts to take advantage of the reduced Gross Advisory Fee breakpoints shown in the chart above. Upon account opening, we automatically aggregate certain Equity Strategy account registrations that share the same tax reporting identification number (such as IRA, Roth IRA, SEP IRA, individual, joint, and certain trust account registrations). To aggregate other accounts not eligible for automatic aggregation, including those with immediate family members (the client’s legal spouse, or the client’s ancestor, descendant, or sibling (or their legal spouse)), or to request aggregation of accounts after account opening, clients must complete an Account Aggregation Form or contact a Fidelity representative. Clients are responsible for verifying that all eligible accounts have been aggregated appropriately. 11  Billing. The Net Advisory Fee will be deducted from a client’s Program Account or another Fidelity account identified by the client for this purpose, after the end of each quarter. Certain assets in a Program Account could be liquidated to pay the fees; this liquidation could generate a taxable gain or loss in a taxable Program Account. Additional Fee for Complex Financial Planning. Where a client has a highly complex financial situation, in addition to the applicable Net Advisory Fee, a fee can be assessed for financial planning services. This fee will be negotiated with the client. Additional Fee Information. All fees are subject to change. In rare circumstances, Strategic Advisers negotiates the advisory fee for certain accounts. Strategic Advisers could also agree to waive fees, in whole or in part, in its sole discretion, including but not limited to in connection with promotional efforts and other programs, including but not limited to situations designed to facilitate transitions between advisory programs, or for certain current and former employees of Fidelity. This will result in certain clients paying less than the standard fee. If a waived or discounted fee results in a Credit Amount that is greater than the Gross Advisory Fee for a Program Account, the excess credits will not be allocated to the Program Account but will instead be allocated, pro rata based on assets, among the other open Program Accounts in the Program at the time the Credit Amount is applied. This operational process results in credits that would otherwise be attributable to one Program Account being received by another Program Account. In certain circumstances, Fidelity will manage certain other accounts in a manner substantially similar to a Program Account under arrangements that can include negotiated terms and conditions that depart from the standard service offering. Generally, except as described above, clients will not pay any commissions, transaction fees, or sales loads on the securities purchased in a Program Account. Clients are responsible for any fees resulting from the sale of securities used to fund a client’s investment in a Program Account (whether such sale is inside or outside a Program Account) and any subsequent withdrawals that the client initiates. If mutual funds and/or ETPs purchased for a client account incur a redemption or other administrative fee as a result of not being held for a minimum time period, Fidelity can, in its sole discretion, choose to pay any such redemption fees on behalf of a Program client but is under no obligation to do so. The Advisory Fee includes fees paid to any applicable sub-advisor for the discretionary portfolio management services provided to Program Accounts; Strategic Advisers pays sub-advisors a portion of the Program fee, which varies based on the amount of assets under management and the applicable strategy. The Advisory Fee does not cover costs associated with implementing any recommendations provided as part of our financial planning services, other than the discretionary services provided through the Program. The Gross Advisory Fee does not include amounts charged with respect to a regulatory fee that applies to all sales of securities and which varies over time. This charge is estimated and assessed in advance; this process could lead to overestimating or underestimating the actual regulatory fee. To the extent that such estimated amount is greater than the actual regulatory fee, Fidelity will retain the excess. These charges will be reflected on statements and/or trade confirmations. Strategic Advisers’ affiliates sponsor promotional offers that provide clients with the ability to receive cash compensation or a reduced advisory fee for opening and funding or maintaining certain accounts. Accounts opened through the Program are, from time to time, included in the list of account types and investment solutions eligible for such promotional offers. The Program’s eligibility for such promotional offers creates a conflict of interest, as Strategic Advisers and its affiliates are incentivizing clients to use the Program rather than Strategic Advisers’ other managed account programs or self-directed investment options available through FBS. Strategic Advisers can also, from time to time, provide cash compensation to Program clients for taking qualifying actions with respect to their Program Account, such as certain interactions with Program features. Any compensation will be deposited into the client’s Program Account, will be subject to the advisory fee applicable to the Program, and may have tax consequences. A promotional offer is not a recommendation to implement any asset allocation strategy or select a particular account type or investment solution. 12  Also, during the time a client is enrolled in the Program, the client could be eligible to receive certain services offered by Strategic Advisers’ affiliates based, in whole or in part, on the amount invested with the Program. It is important to understand that such services are not part of the Program Services for which the Program fee is paid. In addition, while enrolled in the Program, a client could receive information about how to access financial wellness and/or professional support resources and services that are offered by entities unaffiliated with Fidelity, some of which pay compensation to Fidelity as a result of the client’s use of such resources or services. Such resources and services are not included as part of the Program Services and any applicable costs associated with enrolling in or subscribing to these resources or services would be in addition to the Program fee. Other Considerations. In evaluating the Program, please consider that Fidelity offers a variety of investment advisory services and brokerage offerings. These offerings are summarized below to assist clients in understanding and comparing the services and offerings. For more detailed information regarding each offering and investment advisory service, please review the respective Program Brochure available at Fidelity.com/information or through a Fidelity representative. Refer to the “Guide to Brokerage and Investment Advisory Services at Fidelity Investments” (available at Fidelity.com/information) for more information regarding our roles and responsibilities when providing brokerage and advisory services. Please note that, other than the self-directed brokerage account offered by FBS, the advisory programs included in the chart below are each offered by Strategic Advisers. PRODUCT DESCRIPTION INVESTMENT GENERAL ELIGIBILITY FEE STRUCTURE Fidelity Go® No account minimum; $10 to invest Less than $25,000 invested: no advisory fee Portfolio based on a client’s investment profile and composed of a mix of zero expense ratio Fidelity mutual funds Asset-based advisory fee: 0.35% annually for $25,000 and above Invests in zero expense ratio Fidelity mutual funds that do not charge management fees (or with limited exceptions, fund expenses) Digitally provided discretionary investment management and planning; access to a team of phone-based representatives for one-on-one financial coaching for clients who maintain $25,000 or more in a Fidelity Go account and tax-loss harvesting for taxable accounts with $25,000 or more Fidelity Managed FidFolios® $5,000 minimum investment Asset-based advisory fee: 0.40% or 0.70% annually Digitally provided discretionary invest- ment man agement of a single asset class (including tax-smart investing techniques) A mix of individual securities, either stocks or American Depositary Receipts, depending on the client’s selected strategy 13  PRODUCT DESCRIPTION INVESTMENT GENERAL ELIGIBILITY FEE STRUCTURE Fidelity® Strategic Disciplines Asset-based advisory fee: 0.20%–0.70% annually for equity strategies and 0.35%– 0.40% annually for fixed income strategies, depending on the amount invested Discretionary investment management of a single asset class (including tax-smart investing techniques); planning and advice is provided through a dedicated representative A mix of individual securities, including but not limited to stocks, bonds, American Depositary Receipts, and/or exchange-traded products and mutual funds, depending on the client’s selected strategy Depending on strategy selected, account investment minimums of $100,000 (equity strategies) and $350,000 (bond strategies), each subject to qualification for support from a dedicated Fidelity representative, which is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) (effective in the second quarter of 2026, the account investment minimum will be $200,000 for taxable bond strategies and $250,000 for municipal bond strategies) Fidelity® Wealth Services $50,000 minimum investment Asset-based advisory fee: 1.10% annually, less a fee credit that reflects compensation retained by Fidelity as a direct result of a client’s investments Fidelity Advisory Services provides customized planning, advice, and discretionary investment management (including tax-smart investing techniques); planning and advice is provided by a centralized team of phone-based representatives A mix of Fidelity and non-Fidelity mutual funds and exchange-traded products invested using a dynamic asset allocation that can respond to changes in the economic business cycle; offered with multiple investment approaches and universes Wealth Management and Private Wealth Management provide customized planning, advice, and discretionary investment management (including tax-smart investing techniques); planning and advice is provided through a dedicated representative supported by a service team A mix of Fidelity and non-Fidelity mutual funds and exchange- traded products and, depending on a client’s preferences and investment profile, individual securities, invested using a dynamic asset allocation that can respond to changes in the economic business cycle; offered with multiple investment approaches and universes Asset-based advisory fee: 0.50%–1.50% annually, depending on the amount invested, less a fee credit that reflects compensation retained by Fidelity as a direct result of a client’s investments (additional fees of up to 0.40% for management of certain individual security strategies can also apply where advisory services are not provided solely by a Strategic Advisers affiliate) $50,000 minimum account investment for Wealth Management and $2 million minimum investment and $10 million investable assets for Private Wealth Management, each subject to qualification for support from a dedicated Fidelity representative, which is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) Fidelity Wealth Advisor Solutions® Investment vehicles will vary by unaffiliated investment advisor and strategy Investment minimums will vary by unaffiliated investment advisor and services provided Advisory fees will vary by unaffiliated investment advisor and services provided A referral network of unaffiliated investment advisors that provide customized wealth management and investment strategies 14  PRODUCT DESCRIPTION INVESTMENT GENERAL ELIGIBILITY FEE STRUCTURE Self-Directed Brokerage Account Transaction fees and investment expenses vary based on investment vehicle selected; no ongoing asset-based advisory fee charged by Strategic Advisers Self-directed trading through FBS, with access to Fidelity’s online tools, planning, and resources, and support provided by brokerage representatives. A dedicated representative is available based on relationship No minimum to open a brokerage account. Qualification for support from a dedicated Fidelity representative is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) Brokerage customers can choose from a wide variety of investments, including mutual funds, exchange-traded funds, stocks, bonds, and insurance and annuity products. Note that certain securities available through Strategic Advisers’ advisory services are not available in self- directed brokerage accounts As described in the chart above, FBS offers self-directed brokerage accounts and financial planning, and can provide dedicated support from a Fidelity representative depending on a client’s overall relationship with Fidelity. A client could therefore invest directly in the individual securities and ETPs available through the Program through a Fidelity brokerage account or a brokerage account at another firm without incurring an advisory fee. In addition, the investment strategies available through the Program, while designed for the Program, could be similar to a mutual fund or other product available for direct investment by the client, and the operating expenses of such a mutual fund or other product could differ from that of the Program. Finally, a client could purchase planning services separately from another firm, plan independently using the tools and analytics that are used to support the financial planning services provided through the Program that are also made available by FBS at Fidelity.com without a fee, or, if the client qualifies for dedicated support from a Fidelity representative, work with the Fidelity representative to receive planning services offered by FBS without a fee. However, while clients can obtain similar products and services from Fidelity or other firms without enrolling in the Program, the same combination of services would not be provided, certain investment products used by the Program are not available for purchase outside of the Program, investments could be subject to sales loads or transaction and redemption charges that are generally waived as part of the Program, and the overall cost of purchasing the products and services separately will most likely differ from the Program Fee. Factors that bear on the cost of the Program in relation to the cost of the same or similar products and services purchased separately include, among other things, the amount of brokerage trades executed through Fidelity- affiliated broker-dealers (the charges for which are included in the Gross Advisory Fee) as compared with the brokerage trades executed through other broker-dealers (the charges for which are not included in the Gross Advisory Fee). Information about Fidelity and Fidelity Representative Compensation. Fidelity representatives who support the Program are associated with Strategic Advisers and FBS. Fidelity representatives act on behalf of FBS when recommending an advisory program offered by Strategic Advisers. Once a client enrolls in the Program, the Fidelity representative will be providing Program Services. Separate and apart from the Program, Fidelity representatives, including those who support the Program, can provide clients with a variety of FBS services, including investment education and advice, financial analyses, financial planning services, and help with implementing any nondiscretionary recommendations provided as part of the Program’s financial planning services. When providing services for FBS, these Fidelity representatives are acting solely as registered representatives of FBS, and the Program Fee is not related to those FBS services. Fidelity representatives receive base pay based on their experience and role. In addition to base pay, Fidelity representatives are also eligible to receive either variable compensation or an annual bonus, and certain representatives are also eligible to receive longer-term compensation. Fidelity representatives who receive an annual bonus do not receive compensation based directly on the sale of any product or service, but they do have an indirect financial incentive to recommend products or services that pay more compensation to Fidelity because annual bonus funding is based in part on Fidelity’s financial performance. For Fidelity representatives 15  who receive variable compensation, variable compensation depends on the representative’s role and can be impacted by client loyalty, the amount of assets a client transfers to Fidelity, the amount of assets invested initially and on an ongoing basis, referring potential clients to other Fidelity representatives who enroll the client in a Fidelity investment product or service, and client family members opening Fidelity accounts. Whether and how much each Fidelity representative receives in each component is generally determined based on the representative’s role, responsibilities, performance measures, and their manager’s assessment of the representative’s performance. Fidelity and the Fidelity representatives who support the Program and who are eligible to receive variable compensation receive different amounts of compensation depending on the type of product or service a client selects. Fidelity and those Fidelity representatives will earn more compensation if a client enrolls in the Program than if a client enrolls in Fidelity Go, Fidelity Managed FidFolios, or the Fidelity Advisory Services service level of Fidelity Wealth Services. The compensation received by Fidelity and those representatives in connection with FBS offerings (e.g., stocks, bonds, ETFs, mutual funds) is typically less than the compensation received in connection with a client choosing to participate in a Fidelity advisory program. Products and services that generally require more time to engage with a client and/or that are more complex provide greater compensation to a representative and Fidelity. This compensation structure creates a financial incentive for Fidelity and its representatives to recommend investments in more complex or time- consuming products and services over others, and to recommend that a client maintain an investment in such products and services over time. Fidelity addresses these conflicts of interest by having processes in place that require our representatives to make recommendations that are in the best interest of clients, paying compensation based on the time and complexity of the relevant product or service, training and supervising our representatives, and disclosing these conflicts of interest to clients so that they can consider the conflicts when making financial decisions. To see specific compensation levels for the managed account programs mentioned above and other products, including an example of compensation that can be earned by Financial Consultants, please see the “Fidelity Investments Compensation Disclosure” document (available at Fidelity.com/information), or contact a Fidelity representative. Clients should read the information contained in the “Fidelity Investments Compensation Disclosure” document carefully, and can ask a representative at any time whether and how they are compensated with respect to a particular product or service and about the financial incentives and conflicts of interest that Fidelity has when making recommendations of products or services. A C C O U N T R E Q U I R E M E N T S A N D T Y P E S O F C L I E N T S The Program is generally available to individuals, trusts, and certain corporate entities. To participate in the Program, a client must be a U.S. person (including a U.S. resident alien), typically reside in the U.S., and have a valid U.S. taxpayer identification number. The Program is not available to non-U.S. trusts and foreign investors. Strategic Advisers can, in its sole discretion, decline to permit participation in the Program for any reason. Program Accounts can be either tax-advantaged accounts (e.g., Traditional, Roth, and SEP Individual Retirement Accounts, collectively “retirement accounts”) or taxable accounts. The Breckinridge Intermediate and Limited Duration Municipal Strategies, the Fidelity Intermediate and Limited Duration Municipal Strategies, the Fidelity U.S. Large Cap Index Strategy, the Fidelity International Index Strategy, the Fidelity U.S. Total Market Index Strategy, and the Fidelity U.S. Low Volatility Index Strategy are each available only for taxable accounts, while the Fidelity Core Bond Strategy, the Fidelity Limited Duration Bond Strategy, the Fidelity U.S. Large Cap Strategy, the Fidelity International Strategy, the Fidelity Dividend Income Strategy, and the Fidelity Environmental Focus Strategy are each available to both taxable and retirement accounts. The Program’s investment strategies have a per-account investment minimum (“Strategy Minimum”) of $350,000 for a Bond Strategy and $100,000 for an Equity Strategy. Effective in the second quarter of 2026, the account investment minimum will be $200,000 for taxable Bond Strategies and $250,000 for municipal 16  Bond Strategies. In addition, Program clients must generally qualify for support from a dedicated Fidelity representative, which is based on a variety of factors, including Program Account investment levels, assets held at Fidelity outside of the Program, and the complexity of the client’s financial situation. Private Wealth Management (“PWM”) clients are subject to a qualification and acceptance process and must typically invest at least $2 million, in the aggregate, in Program Accounts (or combined with assets invested in Fidelity Wealth Services) and have investable assets of at least $10 million. Strategic Advisers can, in its sole discretion, change or waive a Strategy Minimum or the eligibility requirements to qualify for PWM Program Services at any time. Please note that if a Program Account balance falls below the applicable Strategy Minimum stated above, it can affect the sub-advisor’s ability to manage the Program Account according to the selected investment strategy. Program Accounts that fall below the Strategy Minimum can be removed from the Program. Once the client has agreed to the terms of the Program Client Agreement, the client will have 90 days to fund the Program Account with the applicable minimum investment to satisfy the eligibility requirements for PWM Program Services. If the client has not satisfied such eligibility requirements within 90 days, Fidelity can terminate the client’s eligibility to receive PWM Program Services. Certain limitations apply to the management of a retirement Program Account holding defined benefit plan assets. Generally, only single participant defined benefit plan assets will be managed (except in the case of a retirement Program Account holding defined benefit plan assets where the plan benefits only the owner of the business sponsoring the plan and their spouse), and it will be treated as if it were a defined contribution plan. Plan-specific provisions and any plan-related documents will not be considered in the discretionary management of these assets. To enroll in the Program, a client must agree to the Program Client Agreement, which details the terms and conditions under which the client appoints Strategic Advisers to provide the Program Services. Our advisory relationship with a client begins when we accept the Program Client Agreement. Except with respect to a Program investment proposal, preliminary discussions or recommendations made before we accept a Program Client Agreement are not intended as investment advice or financial planning provided by Strategic Advisers. The Program Client Agreement requires that clients delegate discretionary authority to Strategic Advisers and direct Strategic Advisers to hire a sub-advisor to implement the selected strategy for the clients’ Program Account. The Program Client Agreement will also permit sub-advisors to provide day-to-day investment management for the clients’ Program Account, which includes the authority to determine which securities to purchase or sell, the total amount of such purchases and sales, and the brokers or dealers through which transactions are executed in Program Accounts, subject to certain Program and regulatory limitations and a sub-advisor’s internal policies and procedures. The Program Client Agreement also establishes a brokerage account with FBS, a registered broker-dealer, affiliate of Strategic Advisers, and member of NYSE and SIPC. During a client’s participation in the Program, the client’s Program Account will not be available for the client’s self-directed brokerage activities. Another affiliate of Strategic Advisers, National Financial Services LLC (“NFS”), a registered broker-dealer and a member of NYSE and SIPC, has custody of client assets and will perform certain account services, including the implementation of discretionary management instructions, as well as custodial and related services. Certain personnel of Strategic Advisers, FBS, and NFS share premises and have common supervision. Neither Strategic Advisers nor the relevant sub-advisor acquires authority for, or exercises proxy voting on behalf of, a client in connection with offering Program Accounts. However, with respect to Equity Strategies only, clients can direct Strategic Advisers to act as agent to vote proxies with respect to the investments held in a Program Account. As part of this direction, clients must instruct Strategic Advisers to vote proxies for individual securities pursuant to the directions provided by ISS (a summary of which is available at Fidelity.com/information). Opening and Funding a Program Account Bond Strategies. Clients can initially fund a Bond Strategy Program Account with cash and/or eligible securities, which include Fidelity core money market funds, individual bonds, and investment-grade municipal 17  bonds, as well as prerefunded and escrowed-to-maturity bonds, regardless of credit rating. All other security types are generally considered ineligible for funding purposes. Please note that for the Breckinridge Intermediate and Limited Duration Municipal Strategies, eligible bonds are limited to individual investment- grade municipal bonds, as well as prerefunded and escrowed-to-maturity bonds, regardless of credit rating. For taxable Program Accounts, clients could realize a taxable gain or loss when securities are sold. Equity Strategies. For Equity Strategies, clients can fund a Program Account with cash and/or eligible securities, which will generally include the following: • Cash; • Fidelity core money market funds; • Common stocks and REITs listed in the S&P 500, Russell 3000, and Dow Jones U.S. Total Stock Market indexes; • ADRs that meet certain liquidity requirements; and • Certain ETPs. For taxable Program Accounts, clients could realize a taxable gain or loss when those securities are sold, which could affect the after-tax performance/return of the Program Account as well as the clients’ tax liability. With respect to retirement Program Accounts enrolled in the Dividend Income Strategy, the International Strategy, the U.S. Large Cap Strategy, or the Environmental Focus Strategy, Strategic Advisers generally does not consider the potential tax consequences of these sales. In the event that a client funds a Program Account with eligible securities, Strategic Advisers can, in its sole discretion, sell any such securities to other Program clients or to other clients of Strategic Advisers, in accordance with its fiduciary duties and subject to its obligation to seek best execution. In addition, for the Dividend Income Strategy, the International Strategy, the U.S. Large Cap Strategy, and the Environmental Focus Strategy Program Accounts, should a client transfer into a Program Account eligible securities that are not included in the Model Portfolio or investment universe, or that are part of the Model Portfolio or investment universe but do not align with the allocations therein, Strategic Advisers will generally liquidate those securities in whole or in part as soon as reasonably practicable. Sales of eligible and ineligible transferred securities will be subject to redemption and other applicable fees, including commissions on sales of securities; however, under certain circumstances, the Program can voluntarily assume the costs of certain commissions. A client could realize a taxable gain or loss when these shares are sold. In addition, when securities are purchased in Program Accounts, the client could receive taxable distributions out of the earnings that have accrued before such purchases (a situation referred to as “buying a dividend”). Information for All Strategies. A Fidelity representative can provide information as to whether a specific security is eligible for funding or management within a Program Account. Fidelity will determine, in its sole discretion, which securities will be eligible to fund a client’s Program Account. These securities must be held free and clear of any liens, pledges, or other legal or contractual restrictions. At times, Fidelity will not accept individual securities that are otherwise generally available to fund a Program Account due to internal guidelines or state or federal regulations. If a client elects to transfer ineligible securities into a Program Account, such transfer is a directive to Fidelity by the client to sell any such securities as soon as reasonably practicable. Note that potential tax consequences of these sales are not considered. Clients should be aware that such sales can trigger significant tax consequences, including in Program Accounts that are managed with tax-smart investing techniques. Fidelity reserves the right to transfer an ineligible security back to the account from which the client transferred the assets or to another like-registered account held at Fidelity. Funding with securities can result in Strategic Advisers or the applicable sub-advisor continuing to hold and manage such securities depending on the concentration and tax impact of selling. A Fidelity representative will work with a client to collect Profile Information and will also assist the client with the account opening process, which includes but is not limited to funding the Program Account with cash and/or eligible securities, the sale of ineligible securities used to fund the Program Account, and our receipt of tax basis information for taxable accounts (described below). Once we 18  receive all required information and the funding process, including the sale of ineligible securities, is complete, an account will be reviewed for investment by Strategic Advisers or the relevant sub-advisor. Equity Strategy Program Accounts will typically begin trading within seven business days. For Bond Strategy Program Accounts, it can take a substantial period of time to invest a Program Account. (Under normal circumstances and market conditions, accounts are typically invested within 90 days of the day on which a client initially funds or makes a subsequent contribution to a Program Account, although specific circumstances can vary.) In general, Program fees will begin to accrue once a Program Account has been deemed in good order for management purposes. For initial funding or subsequent deposits to a taxable Program Account, Fidelity must be provided with tax basis information for all securities that will be managed. Discretionary portfolio management will not occur for a taxable Program Account until the completed tax basis information has been received. We will rely on the tax information provided by the client and will not verify the tax basis information provided; clients are able to update such tax basis information by contacting a Fidelity representative. If securities received by the client as a gift are deposited into a Program Account, we will use the tax basis information provided to us in connection with the gift. Additional deposits of cash or securities can be made to a Program Account at any time. Discretionary management of additional deposits will generally occur as soon as reasonably practicable but can be delayed for certain reasons, including time needed to liquidate securities, special handling instructions, or because the additional deposit may not necessitate trading at that time. In general, we will begin charging advisory fees on additional deposits once assets have been received into the Program Accounts and have been deemed in good order for management purposes. Wealth Management clients who are eligible and have elected to have one or more Program Accounts included in a goal-based plan are required to alter the terms pursuant to which they previously granted (or in the future will grant) someone else with authority over their Program Accounts. Such clients who wish to have their Program Accounts included in a goal-based plan with Program Accounts they do not jointly own are also required to grant us an authorization to accept certain instructions from either Program Account owner regarding the management of these Program Accounts. Please see the Program Client Agreement and Program documentation or contact a Fidelity representative for more information. Withdrawals, Account Closure, and Program Termination A client can request a withdrawal from a Program Account, elect to close one or more Program Accounts, or elect to close all Program Accounts and terminate Program enrollment, including with respect to the receipt of financial planning services. Generally, closure and termination instructions must be processed through a Fidelity representative. Strategic Advisers reserves the right to terminate a client’s Program Services (or limit the client’s rights to access any or all account features, products, or services) for any reason, including (i) if any authorized person on a Program Account resides outside the U.S., (ii) if the balance of a client’s Program Account falls below the required minimum investment level, or (iii) if the Program is deemed no longer appropriate for a client. Should either party terminate the investment advisory relationship, the Program fee will be prorated from the beginning of any unbilled quarter to the termination date, which is defined as the date when we no longer manage the Program Account on a discretionary basis. Clients will be required to provide instructions to be used in the event of withdrawals or Program Account closure. Clients have the option of electing that assets either be liquidated and the proceeds sent to the client by check or transferred to a bank account (or other account), or be transferred in-kind to another account. While the timing of trading and settlement can vary, for Equity Strategy accounts, liquidating trades for partial and full withdrawal requests will typically be placed within the next seven business days of the request, and in-kind asset transfer instructions will typically be placed within seven business days of such a request. For partial withdrawal requests, if transfer instructions are not provided, Fidelity will generally reinvest the cash proceeds of any sales into the client’s discretionarily managed Program Account after 30 days. Note that liquidation of assets in taxable accounts could have adverse tax consequences. 19  It is important to understand that Program Accounts can hold certain mutual funds and other securities that clients would not be able to buy or sell directly in a retail brokerage account and are able to hold only as part of the Program and that specific strategy. In general, if an investor ceases to be a Program client, a client of a specific Program Strategy, or requests a transfer of mutual funds that cannot be held outside the Program, shares of such funds will be redeemed, subject to the terms and conditions specified in the fund’s prospectus. Similarly, mortgage-backed securities, which generally cannot be purchased directly in a retail brokerage account, will be sold at the time an investor ceases to be a Program client or a client of a specific Program Strategy, with the proceeds being distributed in cash. However, if an advisory relationship is terminated due to the death, divorce, or incapacity of the account owner, the mortgage-backed securities will be liquidated in accordance with Fidelity’s operational procedures, which generally require that clients or their authorized representatives provide instructions or take other action before the securities can be sold. As a result, there likely will be a significant price difference (higher or lower) between the time the advisory relationship is terminated and the point at which the mortgage-backed securities are sold. Clients should speak with their Fidelity representative if they have any questions about this process. There can be instances where we need to place a do-not-trade restriction on one or more Program Accounts, including when a client requests a security be transferred from a Program Account, when processing a trade correction, when we need to comply with a court order, when a client asks us to process a withdrawal and keep the proceeds from the sale of securities used to fund the withdrawal in the account until the client provides further instructions for the transfer of the proceeds, or when we need additional information from a client. For the period when a do-not-trade restriction is in effect, we generally will not trade or otherwise manage the Program Account until the do-not-trade restriction has been removed. Clients continue to have access to financial planning services and their Fidelity representative(s) during the time when a do-not-trade restriction is in place. Please note that in certain situations, withdrawal or account closure requests by way of liquidation or in-kind transfer can take longer to fully process, as we or the respective sub-advisor could take additional time to sell securities at a desirable price. Please note that certain types of securities, such as municipal bonds, mortgage- backed securities, and certain foreign securities, can have extended or less frequent settlement periods, and their trading markets can be fragmented or thinly traded, which could affect the amount of time it takes to process withdrawal or closure requests. There can be no assurance as to how long it might take to obtain a desirable price for such securities or whether a desirable price can be obtained. Depending on the size of the Program Account, some bonds could be purchased for a Program Account in positions that are smaller than marketable round lots (sometimes called “broken lots” or “odd lots”). If a Program Account has an odd-lot bond position, it could be more difficult to sell than a round lot, and the sale price could be substantially lower than the price paid or the price at which the position was previously valued. With respect to taxable Program Accounts, a client can elect to have all dividends, interest, and capital gains on eligible holdings set aside for automatic distribution by completing and submitting an Earnings Automatic Withdrawal Plan form at Fidelity.com or by speaking with a Fidelity representative. Please note that upon providing these instructions to Fidelity, the amounts awaiting distribution will not be subject to Fidelity’s discretionary authority. P O R T F O L I O M A N A G E R S E L E C T I O N A N D E V A L U A T I O N Strategic Advisers is the investment adviser for the Program to which clients delegate discretion and authorize to hire a specific sub-advisor to implement the selected strategy. Currently, Strategic Advisers has engaged sub-advisors for Bond Strategies, and directly provides discretionary investment services to Equity Strategy Program Accounts. Where Strategic has hired a sub-advisor, the sub-advisor (not Strategic Advisers) will be responsible for investment selection, portfolio construction, and execution of transactions for Program Accounts. Please refer to the applicable sub-advisor’s Form ADV, Part 2A brochure for information about their investment management and trading practices. 20  Prior to identifying a sub-advisor to implement a specific investment strategy, we will review the sub-advisor’s qualifications for managing assets. In doing so, a variety of factors can be considered, including but not limited to investment approach, portfolio characteristics, total assets under management, experience, and trading and operational capabilities. Each sub-advisor will also be periodically reviewed to evaluate management of Program Accounts invested in the respective strategy. We will use the same process to select and review affiliated and unaffiliated sub-advisors. To the extent that a Fidelity sub-advisor is retained to implement a Program investment strategy, Fidelity will retain more compensation than if a non-Fidelity sub-advisor were retained; however, the use of a Fidelity sub-advisor will result in greater efficiencies and economies of scale with respect to the research and management services provided to clients. Strategic Advisers’ investment professionals are not compensated based on the use of Fidelity or non-Fidelity sub-advisors. If we decide, in our sole discretion, that circumstances make a change of sub-advisor necessary or appropriate, clients authorize Strategic Advisers to remove or replace the sub-advisor. The replacement sub-advisor could be an affiliate or independent of Strategic Advisers. We will notify clients before any change in sub-advisor. A client’s continued acceptance of Program Services after notification of the change in sub-advisor will constitute approval and agreement of any replacement sub-advisor. While performance information is reviewed for accuracy and compliance with applicable standards, performance information is not reviewed by a third party to determine or verify its accuracy or compliance with presentation standards. Performance-Based Fees and Side-By-Side Management Strategic Advisers does not currently charge performance-based management fees for any of its advisory services and, therefore, does not engage in side-by-side management. Methods of Analysis, Investment Strategies and Risk of Loss About the Use of Model Portfolios in Equity Strategies. Strategic Advisers has retained its affiliate FMRCo to provide investment models to be used by Strategic Advisers in rendering discretionary investment advisory services to the Dividend Income Strategy, International Strategy, and U.S. Large Cap Strategy Program Accounts. FMRCo provides Strategic Advisers with model portfolios (each, a “Model Portfolio” and together the “Model Portfolios”) and provides periodic updates to each Model Portfolio. FMRCo is not acting as investment adviser or portfolio manager with respect to Program Accounts. Rather, Strategic Advisers is the portfolio manager and has the discretion to implement the models as provided by FMRCo or to make modifications as it deems appropriate. FMRCo could provide a similar Model Portfolio or manage accounts using a similar investment strategy for its other clients and could provide the model to such accounts or clients prior to providing it to Strategic Advisers. At any time, Strategic Advisers can determine to no longer receive a Model Portfolio from FMRCo, in which case Strategic Advisers can engage another investment firm to provide a Model Portfolio or manage Program Accounts without recommendations from a Model Portfolio provider. For the International Strategy and the U.S. Large Cap Strategy, Strategic Advisers will blend the Model Portfolios it receives from FMRCo in its discretion, based on market cycle implications and overall portfolio positioning. FMRCo will generally use fundamental and quantitative analysis to select stocks for the Model Portfolio. Strategic Advisers has designed investment guidelines for the Model Portfolios delivered by FMRCo. These guidelines can change from time to time. About Strategic Advisers’ Model Provider Selection Process. Prior to selecting FMRCo to provide Model Portfolios, Strategic Advisers performed a comprehensive review of FMRCo and its investment style and approach. Strategic Advisers’ review included, among other things, assessing information about FMRCo and its investment strategy. In selecting FMRCo, Strategic Advisers considered a variety of factors, including but not limited to investment approach, portfolio characteristics, and FMRCo’s experience with similar investment strategies. Strategic Advisers evaluated information from both quantitative and qualitative analyses, including but not limited to FMRCo’s investment strategy, security coverage, experience, growth of assets under management, stability of management, governance program, and trading and operational capabilities. 21  Strategic Advisers will evaluate FMRCo’s adherence to the investment guidelines not less than semiannually based on the factors described above. Strategic Advisers, in its sole discretion, can replace FMRCo without prior notice to clients if, for example, Strategic Advisers determines that FMRCo is not adhering to the investment guidelines for the Dividend Income Strategy. Additionally, a Model Portfolio provided by FMRCo could reflect trading decisions previously made by FMRCo for its discretionary client accounts and funds. As a result, the Dividend Income Strategy, the International Strategy, and the U.S. Large Cap Strategy Program Accounts could receive prices that are more favorable or less favorable than the prices obtained by FMRCo’s discretionary client accounts and funds, particularly with respect to thinly traded securities. Aggregate holding limits and other investment limits applicable to such prior trading decisions, and collectively to the discretionary accounts of FMRCo, Strategic Advisers, and their affiliates generally, could result in investment opportunities not being included in a Model Portfolio. Strategic Advisers does not have a predetermined allocation with respect to the use of Fidelity or non-Fidelity model providers. To the extent that Strategic Advisers retains a Fidelity model provider, Fidelity will retain more compensation than if a non-Fidelity model provider were retained, and Fidelity will achieve greater efficiencies and economies of scale with respect to the research and management services that it provides to clients. Therefore, the use of a Fidelity model provider presents a conflict of interest. Strategic Advisers’ investment professionals are not compensated based on the use of Fidelity or non-Fidelity model providers. About Tax-Smart Investing Techniques for Equity Strategies. While each Equity Strategy uses tax-smart investing techniques in taxable accounts, please note that the stated investment objective is of primary importance. Accordingly, the application of tax-smart investing techniques is a secondary consideration. Clients in Equity Strategies should understand that significant tax consequences can result from investing in a strategy with a primary focus other than tax-smart investing techniques. For example, each strategy has a corresponding investable universe of investments that has been constructed by Strategic Advisers. With respect to the Environmental Focus Strategy, stocks used to fund a Program Account that are not included in the environmentally screened investable universe for the strategy will be sold without regard to potential tax consequences of such sales. Realizing gains could create a tax liability, particularly when offsetting losses are not available. Strategic Advisers cannot guarantee the effectiveness of its tax-smart investing techniques in serving to reduce or minimize a client’s overall tax liability or the tax results of a given transaction, and Strategic Advisers does not take direction from a client on when to take gains or losses from the client’s taxable Program Account. Over the long run, tax-smart investing techniques are intended to contribute to helping clients reach their investment goals. However, Strategic Advisers can implement trades in accounts that trigger significant tax consequences in seeking to manage the Program Accounts consistently with long-term strategy investment objectives. The potential federal income tax consequences of holding, buying, and selling securities are considered as part of the investment services, but we do not consider state or local taxes; foreign taxes, including those applied to dividends and any potential reclaim; federal tax rules applicable to entities; or estate, gift, or generation-skipping taxes. The tax-smart investing techniques Strategic Advisers uses when making trading decisions to buy, hold, or sell securities for a client’s taxable Program Account will vary depending on the size of the account and the investment strategy selected. The tax-smart investing techniques referenced throughout this brochure refer to one or more of the following: Ability to harvest tax losses. Individual stock positions can experience price declines, possibly below a client’s adjusted tax basis in the security (as determined by the tax basis information on record for the client’s Program Account). In such instances, losses could be realized in the client’s Program Account for tax purposes. In cases where a position is sold to realize a capital loss for tax purposes, the position usually will be replaced with one or a combination of investments we believe will maintain comparable market exposure. In harvesting tax losses, Strategic Advisers does not attempt to harvest every potential tax loss that occurs in the client’s taxable Program Account and will consider factors such as investment risk, available comparable investment alternatives, and potential wash sales in the account(s) that Strategic Advisers monitors for wash sales when deciding whether to harvest tax losses. 22  Strategic Advisers considers the potential application of the wash-sale rules when evaluating transactions in taxable Program Accounts. However, clients should understand that Strategic Advisers does not prevent or avoid wash sales in all cases. The wash-sale rule requires taxpayers to defer losses that would otherwise be realized if the taxpayer acquires a substantially identical investment 30 days before or after the sale. While Strategic Advisers considers whether its trading in taxable Program Accounts may trigger wash-sale rules, we will nevertheless engage in transactions that are potentially subject to the wash-sale rules if we determine that such transactions are consistent with the Program Strategy. Strategic Advisers will monitor for wash sales within taxable Program Accounts. However, the wash-sale rule not only applies to investment transactions occurring in a Program Account, but also to transactions occurring in other investment accounts, whether maintained at Fidelity or at another financial institution, which are held by the client, the client’s spouse, and certain entities controlled by the client and/or a spouse. As a result, clients can have wash sales as a result of transactions within taxable Program Accounts as well as other accounts (whether maintained at Fidelity or another institution). The wash-sale rule is complex, and while Strategic Advisers seeks to monitor wash sales in taxable Program Accounts, clients are ultimately responsible for determining whether the wash-sale rules apply to any particular transaction in their Program Accounts or in their other investment accounts. Clients should consult their tax advisors with respect to the application of the wash-sale rules based on their individual circumstances. A client can work with a Fidelity representative to identify their other accounts enrolled in the managed account programs offered by Strategic Advisers (whether the account is owned by the client or the client’s spouse) to review which accounts could be eligible related accounts for wash-sale monitoring. Clients should contact a Fidelity representative with any questions regarding how to provide relevant tax information for their Program Accounts. Eligible Private Wealth Management clients can have access to additional support and planning services. Opportunities to avoid and/or postpone capital gain realizations. If there are specific lots of securities (a block of shares bought at a particular time at a particular price) in a client’s taxable Program Account, they are reviewed and the potential federal income tax burden associated with selling a specific lot is weighed against the potential investment merits of the sale, such as performance potential, added diversification, and support of risk-management strategies. Once Strategic Advisers decides to sell an eligible security, it will attempt to sell the lot(s) that will generate the lowest overall federal income tax burden (or generate a loss for tax purposes) using the tax basis and holding period information on record, with a preference for long-term capital gains over short-term capital gains. Fractional Share Investing Each Equity Strategy can invest in whole shares or fractional shares of individual securities. Clients should be aware that the use of fractional shares could result in the receipt of fewer dividends. Please note that any dividends received that are valued at less than $0.01 but that round up to $0.01 will be credited to a Program Account, but amounts that do not round up to $0.01 will not be distributed to the Program Account that held the fractional share. If any amount is not distributed and the aggregate value is less than or equal to $1.00 per security, it will be retained by NFS, an affiliate of Strategic Advisers, and when it exceeds $1.00, it will be escheated to the state of Delaware. Also, with respect to proxy voting, clients are not able to vote a fractional share of an individual security; however, if clients elect to appoint Strategic Advisers as proxy voting agent on their behalf, such fractional shares can generally be voted because such fractional shares will be aggregated for purposes of proxy voting. Fractional shares cannot be transferred to an account outside of Fidelity; in such situations, the fractional share would need to be sold and a taxable gain or loss incurred. Additional Information about Strategic Advisers’ Investment Practices From time to time, Strategic Advisers and/or its affiliates can determine that, as a result of regulatory requirements that apply to Strategic Advisers and/or its affiliates due to investments in a particular country or in an issuer operating in a particular regulated industry, investments in the securities of issuers domiciled or listed on trading markets in that country or operating in that regulated industry above certain thresholds are impractical or undesirable. The foregoing limits and thresholds can apply at the Program Account level or in the aggregate across all accounts (or certain subsets of accounts) managed, sponsored, or owned by, 23  or otherwise attributable to, Strategic Advisers and its affiliates. For investment risk management and other purposes, Strategic Advisers and its affiliates also generally apply internal aggregate limits on the amount of a particular issuer’s securities owned by all such accounts. In such instances, investment flexibility can be restricted, and Strategic Advisers can limit or exclude a client’s investment in a particular issuer, which can include investment in related derivative instruments. To the extent that a client’s Program Account already owns securities that directly or indirectly contribute to an ownership threshold being exceeded, Strategic Advisers could sell securities held in such Program Account in order to bring account-level and/or aggregate ownership below the relevant threshold. In the event that any such sales result in realized losses for a Program Account, that Program Account will bear such losses depending on the particular circumstances. Material Risks Risks Associated with Financial Planning. The projections and other analyses presented to a client in the course of providing our financial planning services are not guarantees. In particular, projections are hypothetical in nature; are for illustrative purposes only; do not reflect actual investment, tax, or other planning results; and are not guarantees of future outcomes. The modeling results shown will vary with each use and over time. In addition, our assumptions and methodologies used in financial planning are adjusted from time to time, which can have an impact on the results obtained. The financial planning analyses provided through the Program are based on the information provided by clients and certain static assumptions—for example, fixed return rates, fixed life expectancies, and fixed rates of income or cash flow. In reality, these variables will not be static—market fluctuation will affect overall asset performance, and uncertain life expectancy could cause clients to outlive their resources or fail to accumulate necessary resources. In addition, financial planning analyses include probabilistic modeling, whereby the probability of success varies based on differing assumptions and on changing circumstances and market information. In addition, the financial planning analyses do not model the individual return characteristics of the securities or investments a client owns. Instead, our analyses model the return characteristics of asset classes, and, as a result, the modeling process is subject to significant variability based on the differences in performance between the securities actually owned by a client and the assumptions used in the modeling process with respect to asset classes. A client may own securities or investments for which we cannot determine an appropriate asset class classification; in some cases, we may assign an asset class and in others we may be unable to model the return characteristics of such a security or investment. Our financial planning analyses assume that the diversification within each asset class is consistent with broadly diversified market indexes. In addition, where our management of one or more Program Accounts is based on information a client has told us about Other Assets assigned to a particular goal, our coordinated management of the Program Accounts assumes that the diversification of the Other Assets is consistent with broadly diversified market indexes. To the extent that the characteristics of a client’s assets vary significantly from those of the broadly diversified asset class assumptions used, actual performance can deviate significantly from the projections provided as a component of our financial planning services. Unless otherwise indicated, the financial planning analyses assume that the asset allocation of the accounts associated with a goal, when aggregated, will generally reflect the Asset Allocation recommended for the goal. Accordingly, the Asset Allocation recommended with respect to a particular goal can differ from the Asset Allocation identified for discretionary management services provided to a Program Account associated with that goal, and clients are responsible for implementing the asset allocation of any Other Assets associated with a goal. If the actual aggregated asset allocation for all of a client’s accounts associated with a goal does not match the Asset Allocation recommended for that goal, the differential can have a significant impact. Although Fidelity can consider the potential effect of certain estate or tax strategies, Fidelity does not provide tax, accounting, or legal advice. Accordingly, any information presented in conjunction with the Program, including in providing the financial planning services, about tax considerations affecting financial transactions or estate arrangements is provided for informational purposes. Clients should consult their tax and legal advisors regarding their particular circumstances. 24  As part of the financial planning services, we can identify certain account types or account structures that are generally designed to help investors reach their goals, including the use of tax-deferred or tax-free retirement, insurance, and educational savings accounts. There is no guarantee that a client’s use of these account structures will be beneficial in helping the client reach their goals. In addition, the legal and tax treatment of these types of accounts could change in the future, leading to unexpected consequences for any such accounts, and we are under no obligation to update clients about potential changes in the tax law or the tax treatment of any account. Each financial planning analysis provides detailed information regarding the analysis, including risks and limitations. Risks Associated with Investment Strategies. The discretionary investment management strategies implemented for Program clients, including conservative investments, involve risk of loss. Investments in a Program Account are not bank deposits and are not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed, and the value of a client’s assets will fluctuate due to market conditions and other factors. A client could lose money by investing in mutual funds, ETPs, and/or individual securities. A client could lose money by investing in a Program Account. Many factors affect each investment’s or Program Account’s performance and potential for loss. Strategies that pursue investments in equities will be subject to stock market volatility and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Strategies that pursue fixed income investments (such as bond or money market funds) will see values fluctuate in response to changes in interest rates, inflation and prepayment risks, as well as default risks for both issuers and counterparties; changing interest rates, including rates that fall below zero, can have unpredictable effects on markets and can result in heightened market volatility. Developments that disrupt global economies and financial markets, such as wars, acts of terrorism, the spread of infectious illness or other public health issues, recessions, or other events, can magnify factors that affect performance. These strategies are also affected by impacts to the individual issuers, such as changes in an issuer’s credit quality, or changes in tax, regulatory, market, or economic developments. In addition, investments in certain bond structures are less liquid than other investments and therefore are more difficult to trade effectively. Municipal bond funds carry additional risks, which are discussed below. Nearly all investments or accounts are subject to volatility in non-U.S. markets, through either direct exposure or indirect effects in U.S. markets from events abroad. Those investments and accounts that are exposed to emerging markets are potentially subject to heightened volatility from greater social, economic, regulatory, and political uncertainties, as the extent of economic development, political stability, market depth, infrastructure, capitalization, and regulatory oversight can be less than in more developed markets. Stock Investments. Stock markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Different parts of the market can react differently to these developments. Value and growth stocks can perform differently from other types of stocks. Growth stocks can be more volatile. Value stocks can continue to be undervalued by the market for long periods of time. In addition, stock investments are subject to risk related to market capitalization as well as company- specific risk. Quantitative Investing. Funds or securities selected using quantitative analysis can perform differently from the market as a whole as a result of the factors used in the analysis, the weight placed on each factor, changes to the factors’ behavior over time, market volatility, or the quantitative model’s assumption about market behavior. In addition, Strategic Advisers’ quantitative investment strategies rely on algorithmic processes, and, therefore, are subject to the risks described below under the heading “Operational Risks.” To the extent that the quantitative models fail to adequately match the risk and return profile of a referenced index used in managing a particular strategy, a Program Account could perform differently; it could underperform or outperform the corresponding reference index on a pretax basis. In addition, to the extent that the components of the corresponding reference index perform in a highly correlated fashion—such as most stocks 25  in the index rising or falling at the same time—the strategy could be less effective at harvesting the tax losses on which the after-tax portion of the strategy relies. Fundamental Investing. Funds or securities selected using fundamental analysis (i.e., evaluating an issuer’s financial condition and/or industry position and valuation as well as forecasting market and economic conditions) can perform differently from the market when the fundamental model fails to accurately forecast risk and return. Therefore, a Program Account could underperform or outperform the index on a pretax basis. To the extent that securities become more correlated, a strategy could be less effective in achieving outperformance. Foreign Exposure. Investing in foreign securities and securities of U.S. entities with substantial foreign operations are subject to interest rate, currency exchange rate, economic, tax, operational, regulatory, and political risks, all of which are likely to be greater in emerging markets. These risks are particularly significant for investment strategies that focus on a single country or region or emerging markets. Foreign markets can be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile. Foreign markets can also offer less protection to investors than U.S. markets. For example, foreign issuers are generally not bound by uniform accounting, auditing, and financial reporting requirements and standards of practice comparable to those applicable to U.S. issuers. Adequate public information on foreign issuers might be unavailable, and it could be difficult to secure dividends and information regarding corporate actions on a timely basis. Regulatory enforcement can be influenced by economic or political concerns, and investors could have difficulty enforcing their legal rights in foreign countries. Foreign governments may decide to seize or confiscate securities held by foreign investors or assets held by foreign issuers, restrict an investor’s ability to sell or redeem securities, suspend or limit an issuer’s ability to make dividend or interest payments, and/or limit or entirely restrict repatriation of invested capital, profits, and dividends. Furthermore, investments in securities of foreign entities can result in clients owning an interest in a passive foreign investment company (“PFIC”). Clients holding an interest in a PFIC could be subject to additional tax liabilities and filing requirements as a result of such investments. The rules regarding investments in PFICs are complex, and clients are urged to consult their tax advisors. Risks of Investing in ADRs. ADRs are certificates evidencing ownership of shares of an underlying foreign issuer that are issued by depositary banks and generally trade on an established market in the U.S. or elsewhere. Certain ADRs are not traded on a national securities exchange, can be less liquid than other investments, and can therefore be more difficult to trade effectively. ADRs are alternatives to directly purchasing the underlying foreign securities in their national markets and currencies. However, ADRs are subject to many of the risks associated with investing directly in foreign securities. The depositary bank can charge fees for various services, including forwarding dividends and interest, and for corporate actions. Investing in ADRs can make it more difficult for U.S. persons to benefit from applicable treaty rates that could otherwise reduce withholding on any distributions from the underlying foreign issuer. Recovery of any extra foreign tax withheld can be costly and complex, and recovery might not be available for certain registration types, such as individual retirement accounts. Values-Based Investing. Because of the subjective nature of values-based investing, there can be no guarantee that values-based investing preferences and the related values-based themes used by Strategic Advisers will reflect the beliefs or values of any particular client. The incorporation of values-based themes can affect an account’s exposure to certain securities or ETPs. Clients should understand that a Program Account invested with a values-based investing preference will not exclude any and all security issuers that are deemed to have negative values-based characteristics. Investing based on values-based themes could cause a Program Account with a values-based investing preference to forgo certain investment opportunities available to an account without such a preference. Real Estate. Real estate is a cyclical industry that is sensitive to interest rates, economic conditions (both nationally and locally), property tax rates, and other factors. Changes in real estate values or economic downturns can have a significant negative effect on issuers in the real estate industry. 26  Money Market Fund Risk. Cash balances in a Program Account will be invested in the core Fidelity money market fund, the cash sweep vehicle for a Program Account. A client could lose money by investing in a money market fund. Although a money market fund seeks to preserve the value of a client’s investment at $1.00 per share, it cannot guarantee it will do so. An investment in a money market fund is not a bank account and is not insured or guaranteed by the FDIC or any other government agency. Fidelity, the sponsor of Fidelity’s money market funds, is not required to reimburse money market funds for losses, and a client should not expect that Fidelity will provide financial support to a Fidelity money market fund at any time, including during periods of market stress. Fidelity’s government and U.S. Treasury money market funds will not impose a fee upon the sale of a client’s shares. Risks of Bond Investments. Because of the fragmented and thinly traded nature of the bond market, and because of client-specific factors, two clients who invest in bonds in the same amount and on the same date could have entirely different individual securities in their portfolios. The bond market can be significantly affected by tax, legislative, interest rate, or political changes, and by the financial condition of the issuers. Changing interest rates, including rates that fall below zero, can have unpredictable effects on markets and can result in heightened market volatility. Tax code changes could impact the bond market. Tax laws are subject to change, and the preferential tax treatment that could apply to bond interest income could be removed or phased out for investors at certain income levels. Investing in Mutual Funds and ETPs. A Program Account bears all the risks of the investment strategies employed by the mutual funds and ETPs held in the Program Account, including the risk that a mutual fund or ETP will not meet its investment objectives. ETPs can trade at a premium or discount to their net asset value and can also be affected by the market fluctuations of their underlying investments. They can also have unique risks depending on their structure and underlying investments. For the specific risks associated with a mutual fund or ETP, please see its prospectus. Risks and Limitations Associated with Tax-Smart Investing Techniques. Clients should understand that there are risks and limitations associated with the use of tax-smart investing techniques, and these limitations can result in tax-inefficient trades. The strategy investment objective is of primary importance, and Strategic Advisers (for Equity Strategies) and the applicable sub-advisor (for Bond Strategies) will make changes to a Program Account even if such changes trigger significant tax consequences, including but not limited to wash sales and the realization of short- and long-term capital gains. Clients should consult their tax and/or legal advisor prior to enrolling in the Program as well as on an ongoing basis to determine whether the wash-sale rule or other special tax rules could apply to their tax situation, and to determine the efficacy of the tax-smart investing techniques to their current and future tax situation. Strategic Advisers (for Equity Strategies) and the applicable sub-advisor (for Bond Strategies) rely on information a client provides in applying tax-smart investing techniques and do not offer tax advice. Please see the applicable sub-advisor’s Form ADV, Part 2A brochure for information about risks associated with tax-smart investing techniques such as tax-loss harvesting in Bond Strategies. For Equity Strategies, Strategic Advisers actively manages for federal income taxes, but does not actively manage for state or local taxes; foreign taxes, including those applied to dividends and any potential reclaim; federal tax rules applicable to entities; or estate, gift, or generation-skipping transfer taxes. In harvesting tax losses, Strategic Advisers does not attempt to harvest every potential tax loss that occurs in a taxable Program Account. Clients should also be aware that, in cases where a position is sold to realize a capital loss for tax purposes, Strategic Advisers can replace that position with one or a combination of investments designed to provide comparable market exposure, and it is important to understand that in a given year, due to investment decisions or market conditions, a client could receive varying levels of taxable distributions within a taxable Program Account. In general, Strategic Advisers will not sell merely to avoid a taxable distribution but, in fact, looks at the overall Program Account to determine the most appropriate action. There are implicit trading opportunity costs associated with the additional turnover, which can affect the returns on a client’s Program Account. A 27  taxable Program Account will generally trade more frequently than a Program Account that is not managed using tax-smart investing techniques. There are implicit trading opportunity costs associated with the additional turnover, which can affect the returns on a client’s Program Account. It is important to note that the performance of any replacement investments will not be the same as that of the investment sold, and any replacement investments can perform worse than the investment that was sold. In addition, any tax-related benefits resulting from tax-smart investing techniques can be offset or even outweighed by investment losses and/or missed gains (realized and unrealized). Furthermore, there are not clear guidelines on what constitutes a “substantially identical” security to another ETP or mutual fund for purposes of the wash-sale rule. As such, there can be no guarantee that a replacement investment selected by Strategic Advisers will not be deemed “substantially identical” for purposes of the wash-sale rule. Although taxable Program Accounts seek to enhance after-tax returns, tax-smart investing techniques may not take into account all of the tax rules, regulations, and limitations applicable to a client’s particular facts and circumstances, which, in certain circumstances, will reduce the effectiveness of tax-smart investing techniques. For example, if a Tax-Smart Program Account is held by an entity treated as a corporation for U.S. federal income tax purposes, the tax-smart investing techniques used will not take into account all the tax rules applicable to that entity, such as rules limiting the use of capital losses, the potential expiration of unused capital losses from prior years, and the corporate tax rate applicable to capital gains and losses. Clients should understand that the benefits derived from any tax-smart investing techniques will likely be greater for clients in higher tax brackets. Since the value of offsetting capital gains or ordinary income is directly tied to the applicable federal capital gains or ordinary income tax rates, clients in lower federal capital gains and ordinary income tax rates experience reduced benefits relative to those in higher federal capital gains and ordinary income tax rates. Environmental Focus Investing Risk. Because of the subjective nature of environmentally sustainable investing, there can be no guarantee that environmental sustainability criteria used by Fidelity will reflect the beliefs or values of any particular client. The incorporation of environmental sustainability factors can affect a Program Account’s exposure to certain companies or industries and may not work as intended. Clients should understand that the application of environmental sustainability criteria does not mean that an Environmental Focus Strategy account will exclude any and all security issuers that are deemed to have negative environmental sustainability characteristics; rather, the application of environmental sustainability criteria is intended to create an investment universe that has a higher aggregate environmental rating, as measured by FMRCo, than the Large Cap Index. Investing based on environmental sustainability factors could cause an Environmental Focus Strategy Program Account to forgo certain investment opportunities available to strategies that do not use such criteria. An account could underperform other investments that do not assess environmental sustainability factors or that use a different methodology to identify and/or incorporate environmental sustainability factors. Information regarding environmental practices is obtained through voluntary or third-party reporting, which could be inaccurate or incomplete. Information used to evaluate environmental sustainability factors may not be readily available, complete, or accurate, and can vary across providers and issuers, as environmental sustainability is not uniformly defined. As a result, there is a risk that FMRCo could incorrectly assess a security or issuer. There is also a risk that Strategic Advisers or FMRCo does not apply the relevant environmental sustainability criteria correctly or that an account could have indirect exposure to issuers that do not meet the relevant environmental sustainability criteria used by such account. There could be limitations with respect to the readiness of environmental sustainability data in certain sectors, as well as limited availability of investments with relevant environmental sustainability characteristics in certain sectors. FMRCo can change its environmental sustainability assessment of an issuer over time. Socially responsible norms differ by region. There is no assurance that the environmental sustainability investing strategy and techniques employed will be successful. Past performance is not a guarantee or reliable indicator of future results. 28  Investment Research Risks and Limitations. The investment research process employed by Strategic Advisers includes gathering, cleaning, culling, and analyzing large amounts of data from external public sources and/ or third-party data providers, including, in some instances, through the use of generative artificial intelligence (“AI”) and large language models (“LLM”). It is not possible or practicable, however, to factor all relevant, available data into economic forecasts or trading decisions. In addition, due to the automated nature of this data gathering and the fact that much of this data comes from third-party sources, it is inevitable that not all desired or relevant data will be available to, or processed by, Strategic Advisers at all times. Clients should be aware that there is no guarantee that the data utilized in generating forecasts or making trading decisions will be the most accurate data available or even free of errors. Furthermore, the use of AI and LLMs may require training of the models to be used in the research process and proper engagement by analysts in order to yield the desired outcome. There can be no guarantee that LLMs can be trained to address all scenarios or that they will provide complete and accurate responses in all situations. AI and LLMs are subject to various risks, including (i) the data used to train LLMs suffers inaccuracies, biases, or flaws that may cause the AI model to respond other than as intended; (ii) weak controls in the development and use of AI allow it to be deployed for use cases for which it was not intended; and (iii) the AI may provide inaccurate or fabricated responses to queries it is unable to process. Fidelity has adopted a Generative AI policy and governance framework so that the use of AI and LLMs is targeted and limited, and that AI and LLMs are trained using known and appropriate data sources and are subject to controls and oversight, which helps ensure that the use of AI and LLMs is but one input into the research process. Clients should assume that the foregoing limitation and risks associated with gathering, cleaning, culling, and analysis of large amounts of data from third-party, other external sources, and the use of AI and LLMs, are an inherent part of investing. There may also be incidents where data fails to load or internal systems fail to retrieve or capture the data, for example, because of changes in the vendor’s or our system configurations due to upgrades, enhancements, maintenance or errors, or that LLMs provide incorrect information in response to certain prompts. Clients should assume that these data errors, like other system implementation errors, and their ensuing risks and impact are an inherent part of investing. Accordingly, unless otherwise required to do so, Strategic Advisers does not expect to disclose discovered data errors to clients. Cybersecurity Risk. With the increased use of technologies to conduct business, Strategic Advisers and its affiliates are susceptible to operational, information security, and related risks. These risks could include events that are wholly or partially beyond our control and may have a negative effect on our ability to conduct business activities. We believe that we have taken reasonable steps to mitigate these risks, but do not believe that we can eliminate them altogether. In general, cyber incidents can result from deliberate attacks or unintentional events that can arise from external or internal sources. Cyberattacks include but are not limited to gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software coding) for purposes of misappropriating assets or sensitive information; corrupting data, equipment, or systems; and causing operational disruption. Cyberattacks can also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). Cyber incidents affecting Strategic Advisers, its affiliates, or any other service providers (including but not limited to accountants, custodians, transfer agents, and financial intermediaries used by Fidelity or by an issuer of securities) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, interference with the ability to calculate the net asset value (“NAV”), impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities in which an account invests, counterparties with which an account engages in transactions, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. 29  Legislative and Regulatory Risk. Investments in a Program Account could be adversely affected by new (or revised) laws or regulations. Changes to laws or regulations could impact the securities markets as a whole, specific industries, individual issuers of securities, and a sub-advisor’s determinations with respect to the expected rate of return, value, or creditworthiness of a particular security. Generally, the impact of these changes will not be fully known for some time. Operational Risks. Operational risks can include risk of loss arising from failures in internal processes, people, or systems, such as routine processing incidents or major systems failures, or from external events, such as exchange outages. Strategic Advisers uses algorithms in support of its discretionary portfolio management processes, which can contribute to operational risks. For example, algorithms are used as part of the process whereby Strategic Advisers recommends an appropriate asset allocation that corresponds to a level of risk consistent with a client’s Profile Information. In providing financial planning services, algorithms are used in analyzing the potential for success of a client’s financial plan. A sub-advisor can use algorithms in support of its discretionary portfolio management process. There is a risk that the data input into the algorithms could have errors, omissions, or imperfections, or that the algorithms do not operate as intended (generally referred to as “processing incidents”). Any decisions made in reliance on incorrect data or algorithms that do not operate as intended can expose Program Accounts to potential risks. Issues in the algorithm are often extremely difficult to detect and could go undetected for long periods of time or never be detected. These risks are mitigated by testing and human oversight of the algorithms and their output. We believe that the oversight and testing performed on our algorithms and their output will enable us to identify and address issues appropriately. However, there is no assurance that the algorithms will always work as intended. In general, we will not assess each Program Account individually, nor will we override the outcome of the algorithm with respect to any particular Program Account. Not all processing incidents arising from operational failures, including those resulting from the mistakes of third parties, will be compensable by Strategic Advisers to clients. Strategic Advisers maintains policies and procedures that address the identification and resolution of processing incidents, consistent with applicable standards of care, to ensure that clients are treated fairly when a processing incident has been detected. The determination of whether, and how, to address a processing incident is made by Strategic Advisers or its affiliates, in their sole discretion. Processing incidents will be reviewed to determine whether there was a financial impact on a client’s Program Account based on, among other things, the relevant investment strategy, and to evaluate the materiality of the impact. If we determine that a material financial impact has occurred, we will make an appropriate correction or otherwise reimburse the Program Account in an amount Strategic Advisers or its affiliates determines is appropriate based on all relevant circumstances. Typically, processing incidents that result in a financial impact of less than $10 per Program Account are not considered material. Other examples of impact that could affect the performance of a Program Account but would likely not be material include impacts arising from computer, communications, data processing, network, cloud computing, backup, business continuity or other operating, information, or technology systems, including those we outsource to other providers, failing to operate as planned or becoming disabled, overloaded, or damaged as a result of a number of factors. These factors could include events that are wholly or partially beyond our control and could have a negative impact on our ability to conduct business activities. Though losses arising from operating, information, or technology systems failures could adversely affect the performance of a Program Account, such losses would likely not be reimbursable under Strategic Advisers’ policies and procedures. Past performance is not a guarantee of future returns. Investing in securities and other investments involves a risk of loss that a client should understand and be willing to bear. Clients are encouraged to discuss these risks with a Fidelity representative. 30  Voting Client Securities Strategic Advisers does not acquire authority for, or exercise, proxy voting on a client’s behalf in connection with managing Program Accounts. Unless an Equity Strategy client directs Strategic Advisers otherwise pursuant to the paragraph below, the client will receive proxy materials directly from the issuer of the security (or its service provider). Strategic Advisers will not advise clients on the voting of proxies. Clients must exercise any proxy voting directly. Notwithstanding the information above, an Equity Strategy client can direct Strategic Advisers to act as agent to vote proxies on the client’s behalf for the funds and other securities held in Program Accounts. For Fidelity Funds, clients who make such a direction must instruct Strategic Advisers to vote proxies of a Fidelity Fund in the same proportion as the vote of all other holders of such Fidelity Fund. For non-Fidelity funds and other securities, such clients must instruct Strategic Advisers to vote proxies pursuant to the directions provided by ISS, an unaffiliated third-party proxy advisory services provider. Please note that, unlike general proxy votes, Strategic Advisers and, for Bond Strategies, the appliable sub- advisor, generally treat certain voluntary corporate actions as subject to the exercise of their discretion as investment managers. Accordingly, Strategic Advisers and the applicable sub-advisor will make decisions with respect to voluntary corporate actions directly as part of the investment management services they provide to Program Accounts. However, clients retain the right to make elections with respect to voluntary corporate actions if they so choose; if a client would like to make an election with respect to a security subject to a voluntary corporate action, the client will need to contact us to transfer the security out of the client’s Program Account. In connection with this election, a client must acknowledge that Strategic Advisers or the applicable sub-advisor is acting solely at the client’s direction and does not exercise discretion with respect to the voting of any proxy. Clients receive information about ISS’ proxy voting policies in the summary of ISS’ proxy voting guidelines available at Fidelity.com/information. In some instances, ISS will be unable to provide proxy voting directions, in which case Strategic Advisers will not vote such proxy because it does not have discretion to determine how proxies are voted. To obtain a copy of ISS’ summary proxy voting guidelines or information on how investment proxies were voted, please contact a Fidelity representative. In addition, an Equity Strategy client can request that Strategic Advisers act as agent for receipt of certain legally required communications, including prospectuses, annual and semiannual reports, and proxy materials for mutual funds and ETPs that are not managed by FMRCo or an affiliate thereof, and other individual securities. Clients should be aware that, to the extent that a Program Account holds a fractional share of an ETP or individual security, they will not be able to vote the fractional share; however, where Strategic Advisers is acting as proxy voting agent on the client’s behalf, such fractional share can generally be voted. In addition, clients are not able to take any discretionary or voluntary corporate action with respect to any fractional share position. C L I E N T I N F O R M A T I O N P R O V I D E D T O P O R T F O L I O   M A N A G E R S Strategic Advisers has access to the relevant Program Account information, including certain Profile Information and, for accounts managed with tax-smart investing techniques, information on record with Strategic Advisers regarding the client’s tax situation and the tax characteristics of the securities in the client’s Program Account. Through Strategic Advisers, Bond Strategy sub-advisors have ongoing access to the relevant Program Account information, including certain Profile Information. The discretionary portfolio management services will be impacted by incomplete or inaccurate information. If changes to a client’s personal, financial, or tax situation occur, the client should promptly contact a Fidelity representative. Strategic Advisers does not provide client information to any of the Model Portfolio providers that provide models for certain Program Strategies. 31  C L I E N T C O N T A C T W I T H P O R T F O L I O M A N A G E R S Clients should contact a Fidelity representative regarding questions about their Program Accounts, to update their Profile Information, or to provide an update about their personal situation or any other information that could affect how their Program Accounts are managed. A Fidelity representative will act as a liaison between a client and Strategic Advisers’ investment professionals or the relevant sub-advisor and will help ensure appropriate management of the client’s Program Account by updating client Profile Information used by the investment professionals or sub-advisor in managing a Program Account. While Strategic Advisers or the sub-advisors could provide clients with information about the management of Program Accounts from time to time, they do not typically meet or communicate directly with Program clients. Model Portfolio providers do not meet with clients. A D D I T I O N A L I N F O R M A T I O N Custody Clients must establish and maintain a brokerage account with FBS to participate in the Program, and NFS serves as the qualified custodian for Program Accounts. Clients should carefully review all statements and other communications received from NFS and FBS. NFS and FBS are broker-dealers and affiliates of Strategic Advisers. Strategic Advisers is deemed to have custody under the Advisers Act because its affiliate NFS serves as qualified custodian for Program Accounts. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Strategic Advisers’ advisory business or the integrity of its management personnel. Other Financial Industry Activities and Affiliations Strategic Advisers is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is a wholly owned subsidiary of FMR LLC. FMR LLC is a Delaware limited liability company that, together with its affiliates and subsidiaries, is generally known to the public as Fidelity Investments or Fidelity. Various direct or indirect subsidiaries of FMR LLC are engaged in investment advisory, brokerage, banking, or insurance businesses. From time to time, Strategic Advisers and its clients will have material business relationships with any of the subsidiaries and affiliates of FMR LLC. In addition, the principal officers of Strategic Advisers serve as officers and/or employees of affiliated companies that are engaged in various aspects of the financial services industry. Strategic Advisers is not registered as a broker-dealer, futures commission merchant, or commodity trading advisor, nor does it have an application pending to register as such. Strategic Advisers is registered with the U.S. Commodity Futures Trading Commission (“CFTC”) under the Commodity Exchange Act of 1936, as amended (“CEA”), as a commodity pool operator (“CPO”) and is a member of the National Futures Association (“NFA”). Certain personnel of Strategic Advisers, FBS, and NFS share premises and have common supervision. Certain management persons of Strategic Advisers are registered representatives of FBS, a Strategic Advisers affiliate and a registered broker-dealer. In addition, Strategic Advisers has entered into an intercompany agreement with FBS, pursuant to which FBS provides to Strategic Advisers various operational, administrative, analytical, and technical services, and the personnel necessary for the performance of such services. Strategic Advisers has, and its clients could have, a material relationship with the following affiliated companies: Investment Companies and Investment Advisers • Fidelity Management & Research Company LLC (“FMRCo”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FMRCo provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated 32  and unaffiliated advisers. FMRCo acts as sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients and provides model portfolio recommendations and environmental filtering services to Strategic Advisers in connection with Strategic Advisers’ provision of discretionary portfolio management to certain clients. Strategic Advisers pays FMRCo an administrative fee for handling the business affairs of the registered investment companies advised by Strategic Advisers, and Strategic Advisers compensates FMRCo for making certain mutual funds available to managed account programs offered by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FMRCo. • Fidelity Institutional Wealth Adviser LLC (“FIWA”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FIWA provides nondiscretionary investment management services and sponsors the Fidelity Managed Account Xchange® and Fidelity Managed Account Xchange programs (turnkey asset management programs made available to financial intermediaries). Strategic Advisers provides model portfolio services to FIWA in connection with FIWA’s services to its institutional and intermediary clients, and FIWA compensates Strategic Advisers for such services. In addition, Strategic Advisers shares employees from time to time with FIWA. • FIAM LLC (“FIAM”), a wholly owned subsidiary of FIAM Holdings LLC, which in turn is wholly owned by FMR LLC, is a registered investment adviser under the Advisers Act and is registered with the Central Bank of Ireland. FIAM provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. Strategic Advisers has sub-advisory agreements with FIAM for certain registered investment companies advised by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FIAM. • FMR Investment Management (UK) Limited (“FMR UK”), an indirect, wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act, has been authorized by the U.K. Financial Conduct Authority to provide investment advisory and portfolio management services, and is registered with the Central Bank of Ireland. FMR UK provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR UK for certain registered investment companies advised by Strategic Advisers. • Fidelity Management & Research (Japan) Limited (“FMR Japan”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Japan Financial Services Agency (Kanto Local Finance Bureau) to provide investment advisory and discretionary investment management services. FMR Japan provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Japan for certain registered investment companies advised by Strategic Advisers. • Fidelity Management & Research (Hong Kong) Limited (“FMR Hong Kong”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Hong Kong Securities & Futures Commission to advise on securities, deal in futures contracts, provide asset management services, and conduct trading services. FMR Hong Kong provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Hong Kong for certain registered investment companies advised by Strategic Advisers. • Fidelity Diversifying Solutions LLC (“FDS”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FDS is registered with the CFTC under the CEA as a CPO and as a commodity trading advisor. FDS is a member of the NFA. FDS provides discretionary advisory and sub-advisory services. FDS acts as a sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients. 33  Broker-Dealers • Fidelity Distributors Company LLC (“FDC”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Securities Exchange Act of 1934 (the “Exchange Act”). FDC acts as principal underwriter of business development companies and the registered investment companies in the Fidelity group of funds, and also markets those funds and other products to third-party financial intermediaries and certain institutional investors. • National Financial Services LLC (“NFS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. NFS is a fully disclosed clearing broker-dealer that provides clearing, settlement, and execution services for other broker-dealers, including its affiliate FBS. Fidelity Capital Markets (“FCM”), a division of NFS, provides trade executions for Fidelity affiliates and other clients. Additionally, FCM operates CrossStream®, an alternative trading system (“ATS”) that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. CrossStream is used to execute transactions for investment company and other clients. NFS provides transfer agent or subtransfer agent services and other custodial services to certain Fidelity clients. • LeveL Markets, LLC, a registered broker-dealer and operator of two ATSs, the Luminex ATS and the LeveL ATS, which allow orders submitted by subscribers to be crossed against orders submitted by other subscribers. LeveL Holdings, LLC, owns LeveL Markets, LLC. Fidelity Global Brokerage Group, Inc., and FMR Sakura Holdings, Inc., each a wholly owned subsidiary of FMR LLC, have membership interests in LeveL Holdings, LLC, along with other members. LeveL Markets, LLC, charges a commission to both sides of each trade executed in the Luminex ATS and LeveL ATS. Luminex ATS and LeveL ATS are used to execute transactions for Fidelity affiliates’ investment company and other advisory clients. NFS serves as a clearing agent for transactions executed in the Luminex ATS and LeveL ATS. • Fidelity Brokerage Services LLC (“FBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act and provides brokerage products and services, including the sale of shares of registered investment companies in the Fidelity group of funds to individuals and institutions, including retirement plans, and acts as placement agent for certain privately offered investment funds advised by Strategic Advisers’ affiliates. In addition, along with Fidelity Insurance Agency, Inc. (“FIA”), FBS distributes variable insurance products that are issued by Fidelity Investments Life Insurance Company (“FILI”) and Empire Fidelity Investments Life Insurance Company® (“EFILI”), both Fidelity affiliates, as well as by third parties. FBS provides shareholder services to certain of Fidelity’s clients. FBS is the introducing broker for managed accounts offered by Strategic Advisers and places orders for execution with its affiliated clearing broker, NFS. • Digital Brokerage Services LLC (“DBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. DBS provides securities brokerage to retail customers through a digital mobile application–based brokerage platform. DBS receives remuneration from FMRCo for expenses incurred in servicing and marketing FMRCo products. Insurance Companies or Agencies • FILI, a wholly owned subsidiary of FMR LLC, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates. • EFILI, a wholly owned subsidiary of FILI, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates to residents of New York. • FIA, a wholly owned subsidiary of FMR LLC, is engaged in the business of selling life insurance and annuity products of affiliated and unaffiliated insurance companies. 34  Banking Institutions • Fidelity Management Trust Company (“FMTC”), a wholly owned subsidiary of FMTC Holdings LLC, which in turn is wholly owned by FMR LLC, is a limited-purpose trust company organized and operating under the laws of the Commonwealth of Massachusetts that provides nondiscretionary trustee and custodial services to employee benefit plans and IRAs through which individuals can invest in affiliated or unaffiliated registered investment companies. FMTC also provides discretionary investment management services to institutional clients. • Fidelity Personal Trust Company, FSB, a wholly owned subsidiary of Fidelity Thrift Holding Company, Inc., which in turn is wholly owned by FMR LLC, is a federal savings bank that offers fiduciary services that include trustee or co-trustee services, custody, principal and income accounting, investment management services, and recordkeeping and administration. Limited Partnerships and Limited Liability Company Investments Strategic Advisers provides discretionary investment management to partnerships and limited liability companies designed to facilitate acquisitions by mutual funds offered by Strategic Advisers. These funds are privately offered consistent with stated investment objectives. Strategic Advisers does not currently engage in borrowing, lending, purchasing securities on margin, short selling, or trading in commodities. Participating Affiliate Certain employees of Fidelity Strategic Advisers Ireland, Limited (“Strategic Ireland”), can from time to time provide certain services, including but not limited to research, operations, and investment management support services for Strategic Advisers, which Strategic Advisers could use for its clients. Strategic Ireland is not registered as an investment adviser under the Advisers Act and is deemed to be a “Participating Affiliate” of Strategic Advisers (as this term has been used by the SEC’s Division of Investment Management in various no-action letters granting relief from the Advisers Act’s registration requirement for certain affiliates of registered investment advisers). Strategic Advisers deems Strategic Ireland and each of the Strategic Ireland Associated Employees as “associated persons” of Strategic Advisers within the meaning of Section 202(a)(17) of the Advisers Act. Strategic Ireland Associated Employees and Strategic Ireland through such employees can contribute to Strategic Advisers’ research process and could have access to information concerning securities that are being selected for clients prior to the effective implementation of such selections. As a Participating Affiliate of Strategic Advisers, Strategic Ireland has agreed to submit itself to the jurisdiction of United States courts for actions arising under United States securities laws in connection with investment advisory activities conducted for Strategic Advisers’ clients. Strategic Advisers maintains a list of Strategic Ireland Associated Employees whom Strategic Ireland has deemed associated persons, and Strategic Advisers will make the list available to its current U.S. clients upon request. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Strategic Advisers has adopted a Code of Ethics for Personal Trading (the “Code of Ethics”). The Code of Ethics applies to all officers, directors, employees, and other supervised persons of Strategic Advisers and requires that they place the interests of Strategic Advisers’ clients above their own. The Code of Ethics establishes securities transaction requirements for all covered employees and their covered persons, including their spouses. More specifically, the Code of Ethics contains provisions requiring the following: • Standards of general business conduct reflecting the investment advisers’ fiduciary obligations; • Compliance with applicable federal securities laws; • Employees and their covered persons to move their covered accounts to FBS unless an exception exists or prior approval has been granted; • Reporting and review of personal securities transactions and holdings for persons with access to certain nonpublic information; 35  • Prohibition of purchasing securities in initial public offerings unless an exception has been approved; • Reporting of Code of Ethics violations; and • Distribution of the Code of Ethics to all supervised persons, documented through acknowledgments of receipt. Core features of the Code of Ethics generally apply to all Fidelity employees. The Code of Ethics also imposes additional restrictions and reporting obligations on certain advisory personnel, research analysts, and portfolio managers. Such restrictions and reporting obligations include the following: • The preclearing of transactions in covered securities with limited exceptions; • A prohibition on investments in limited offerings without prior approval; • A prohibition on personal trading by a portfolio manager within seven days before or after a trade in any covered security of the same issuer by a fund or account managed by such portfolio manager except in limited circumstances; • The reporting of transactions in covered securities on a quarterly basis with limited exceptions; • The reporting of securities accounts and holdings of covered securities at the time of hire and annually thereafter; and • The disgorgement of profits from short-term transactions with limited exceptions. Violation of the Code of Ethics requirements can also result in the imposition of remedial action. The Code of Ethics will generally be supplemented by other relevant Fidelity policies, including the Policy on Inside Information, Rules for Broker-Dealer Employees, and other written policies and procedures adopted by Fidelity and Strategic Advisers. A copy of the Code of Ethics will be provided to any client or prospective client on request. From time to time, Strategic Advisers and its related persons can buy or sell securities for themselves and recommend those securities to clients. The conflicts of interest involved in such activities are contemplated in the Code of Ethics and other relevant Fidelity policies. In particular, the Code of Ethics and other Fidelity policies are designed to make it clear to Fidelity personnel that they should never place their personal interests ahead of Fidelity’s clients in an attempt to benefit themselves or another party. The Code of Ethics and other Fidelity policies impose sanctions if these requirements are violated. From time to time, in connection with our business, certain supervised persons obtain material nonpublic information that is usually not available to other investors or the general public. In compliance with applicable laws, Strategic Advisers has adopted a comprehensive set of policies and procedures that prohibits the use of material nonpublic information by investment professionals or any other employees and that limits the transactions that Strategic Advisers can implement for Program Accounts. In addition, Fidelity has implemented a Corporate Gifts & Entertainment Policy intended to set standards for business entertainment and the giving or receiving of gifts, to help employees make sound decisions with respect to these activities, and to ensure that the interests of Strategic Advisers’ clients come first. Similarly, to support compliance with applicable “pay to play” laws, Fidelity has adopted a Personal Political Contributions & Activities Policy that requires employees to preclear any political contributions and activities. Fidelity also has a Global Anti-Corruption Policy regarding commercial bribery and bribery of government officials that prohibits directly or indirectly giving, offering, authorizing, promising, accepting, or receiving any bribe, facilitation payment, kickback, or payoff (whether in cash or any other form) with the intent to improperly obtain or retain business or any improper advantage. 36  B R O K E R A G E P R A C T I C E S Broker Selection and Transactions in Equity Strategy Program Accounts Strategic Advisers has a duty to seek best execution for transactions in client accounts. Strategic Advisers will place trades for Equity Strategy Program Accounts with affiliated or unaffiliated registered broker-dealers (“brokers”) and may choose to execute an order using electronic channels (including broker-sponsored algorithms) or by manually working an order with a broker. In selecting brokers, Strategic Advisers may consider a range of factors deemed relevant in the context of a particular trade, including but not limited to price; costs; the size, nature, and type of the order; speed of execution; financial condition and reputation of the broker; broker-specific considerations (e.g., not all brokers are able to execute all types of trades); broker willingness to commit capital; our trader’s assessment of whether and how closely the broker will follow our instructions; and confidentiality and the potential for information leakage. As described above in Fees and Compensation, the Program’s Advisory Fee includes the cost of commissions associated with transactions executed through affiliated brokers. As a result, most trades for Program Accounts that involve equity securities and other securities where commissions are charged will be executed with Strategic Advisers’ affiliated broker, NFS. However, Strategic Advisers has the authority to execute transactions with an unaffiliated broker (also referred to as “trading away”) consistent with its duty to seek best execution. While the Program’s Advisory Fee does not include the cost of commissions for transactions executed through unaffiliated brokers, Strategic Advisers or its affiliate is voluntarily assuming the cost of commissions for transactions executed by unaffiliated brokers. As a result, Program clients are not charged commissions for such transactions. Strategic Advisers and its affiliates reserve the right to stop assuming the cost of commissions associated with trading away, subject to prior notice to Program clients. The Program fee does not cover transaction charges for securities where the counterparty imposes a markup, markdown, and/or dealer spread. The net price of the security will include these transaction charges and Program Accounts will bear these costs. In seeking best execution for a transaction, Strategic Advisers will have no obligation to solicit competitive quotes for each transaction and Strategic Advisers will not necessarily select the broker that charges the lowest available price or commission rate; however, Strategic Advisers believes that its policies, taking into consideration the factors stated above, are designed to result in transaction processing that is favorable to Program clients. Strategic Advisers conducts periodic reviews of trade execution. Although it is Strategic Advisers’ policy to treat each client’s account in a fair and equitable manner over time, there can be no assurance that all Program Accounts will receive the same execution and certain Program Accounts will experience a more or less favorable execution depending on market conditions. Please see the Fees and Compensation section above for further information about Program fees, brokerage commissions, and additional fees for transactions in a Program Account. Broker Selection for Bond Strategy Program Accounts For Bond Strategies, the sub-advisors trade away for substantially all fixed income investments through brokers unaffiliated with Strategic Advisers. The Program fee does not cover transaction charges on trades placed for fixed income investments where the executing broker imposes a markup, markdown, and/or a dealer spread. The net price of the bond will include such transaction charges and Program Accounts enrolled in the Bond Strategies will bear these costs. These transaction charges are in addition to your Program fee and will not be listed as separate charges on your trade confirmation or account statement. Program Accounts enrolled in the Bond Strategies incur both transaction charges paid to the executing broker for trading away and transaction charges that are already included in the Program fee. Clients should consider the impact of trading away and the related transaction charges when enrolling in the Bond Strategies. Please see the relevant sub-advisor’s Form ADV Brochure for additional information regarding trading practices and selection of brokers in accordance with the sub-advisor’s best execution obligations. 37  Trade Aggregation and Allocation Strategic Advisers’ policy is to treat each client’s account in a fair and equitable manner over time when aggregating and allocating orders for the purchase and sale of securities. While Strategic Advisers is under no obligation to aggregate orders for Program Accounts, in general, Strategic Advisers will choose to aggregate trades for Program Accounts and/or aggregate Program Account trades with trades for other client accounts (including certain proprietary accounts of Strategic Advisers or its affiliates and Fidelity employee accounts managed by Strategic Advisers) when, in Strategic Advisers’ judgment, aggregation is in the best interest of all clients involved and it is operationally feasible to do so. Orders are aggregated into a “block trade” to facilitate seeking best execution, to negotiate more favorable commission rates, or to allocate equitably among clients the effects of any market fluctuations that might have otherwise occurred had these orders been placed independently. Aggregated orders are generally allocated on a pro rata basis among similarly situated client accounts participating in a block trade until the order is filled. Client accounts included in a block trade receive the same average price for the trade and shares are allocated according to the purchase and sale orders actually placed for each client account included in the block trade. Strategic Advisers can create multiple block trades for both buy and sell orders in the same security, and it is therefore possible that block trades will receive different prices depending on when the orders for each block trade are filled throughout the day. When a client account is not part of a block trade, that client account will receive a different price from the price obtained for Program Accounts that participate in the aggregated orders. If Strategic Advisers does not complete an order in a single day (e.g., when an aggregate order for client accounts exceeds the available supply or to minimize market impact), the partially filled order will be allocated on a pro rata basis among client accounts in the block. Strategic Advisers has adopted trade allocation policies for managing client accounts, including Program Accounts, designed to achieve fairness and not to purposefully disadvantage comparable client accounts over time when allocating purchases and sales. Cross Trades To the extent permitted by law and applicable policies and procedures, Strategic Advisers can (but is not obligated to) execute “agency cross trades” for Program Accounts. Agency cross trades are trades in which Strategic Advisers, or any person controlling, controlled by, or under common control with Strategic Advisers, acts as both investment adviser and broker for a client, and as broker for the party or parties on the other side of the trade. Agency cross trades will be executed in accordance with Section 206(3) of the Advisers Act, requiring written consent, confirmations of transactions, annual reporting, and compliance procedures. To the extent permitted by law and applicable policies and procedures, Strategic Advisers can (but is under no obligation to) execute “advisor cross trades” for Program Accounts when Strategic Advisers believes such trades are in the best interest of all clients involved. Advisor cross trades are trades in which Strategic Advisers, or an affiliate, acts as investment adviser to both clients involved in the trade. An advisor cross trade will be facilitated between client accounts either directly or through a broker-dealer, including FBS or NFS, and the relevant crossing value will be determined based on one or more third-party pricing services, actual market bids, and/or closing prices as reflected on a national securities exchange. Neither Strategic Advisers nor its affiliates will receive transaction-based compensation for advisor cross trades. There can be no assurance that agency or advisor cross trades will be executed, or that such transactions will be executed in a manner that is most favorable to each Program Account that is a party to such transaction. Not all Program Accounts participate in cross trades, and a client may opt out of cross trading by contacting a Fidelity representative. Cross trades can be beneficial to clients by reducing transaction costs, and Program Accounts excluded from cross trading could miss such potential benefits. Strategic Advisers and its affiliates will have a potentially conflicting division of loyalties and responsibilities regarding both parties to a crossing transaction, including with respect to the decision to enter into such transactions and the valuation and pricing of such transactions. Strategic Advisers has developed policies and procedures relating to such transactions and conflicts. 38  Account Transaction Information When Strategic Advisers trades in a Program Account, unless Fidelity Personal Trust Company, FSB, is acting as trustee or co-trustee with respect to the Program Account, clients will receive a confirmation of such transaction from NFS, except with respect to automatic investments, automatic withdrawals, dividend reinvestments, and transactions that involve the core Fidelity money market fund where a client’s account statement serves in lieu of a confirmation. Clients will receive statements from NFS that will provide holdings and transaction information, including trades, contributions, withdrawals, advisory fees, and estimated gain/loss and tax basis information. Statements and confirmations are also available online at Fidelity.com and by enrolling in the electronic delivery program. Clients should carefully review all statements and other communications received from FBS and NFS. Clients will also receive a prospectus for any new mutual fund or ETP not previously held, unless the client has elected to have Strategic Advisers act as agent for the receipt of any non-Fidelity prospectuses. The routing details of a particular order will be provided on request, and an explanation of order routing practices will be provided on an annual basis. In addition, from time to time, Fidelity will provide aggregated trade execution data to clients and prospective clients. Soft Dollars Strategic Advisers does not have a soft dollar program and therefore does not consider the provision of research or brokerage as a criterion for broker selection. Client-Directed Brokerage Activities Program Accounts are not available for brokerage activities outside of the activities directed by Strategic Advisers, including but not limited to margin trading or trading of securities by a client or any of the client’s designated agents. Review of Accounts Client Contact and Review of Personal Financial Situation We will contact Program clients at least annually to evaluate whether there have been any changes to their financial situation that could affect their Profile Information or the Program Services, including whether they wish to impose any reasonable restrictions on the management of the Program Account or reasonably modify any existing restrictions (the “Annual Review Process”). Clients should provide updated Profile Information any time there is a change to their goals, time horizon, tax situation, risk tolerance, or personal financial situation, even outside of the Annual Review Process. If we do not hear from a client during the Annual Review Process, we will update client information based on known information (e.g., client’s age, planned investment horizon, other date-relative elements of the client’s Profile Information, updated account balances of the client’s Program Accounts and other Fidelity accounts, as well as updated balances of certain outside accounts a client has provided), but we will otherwise assume that the client’s Profile Information has not changed. In some cases, the changes to this updated information will cause us to determine that a strategy account is no longer appropriate for the client. In these instances, we will notify the client and begin the process of terminating the client’s participation in the Program. Clients will receive prompt confirmations from NFS for any transactions in their Program Accounts; however, with respect to automatic investments, automatic withdrawals, dividend reinvestments, and transactions that involve the core Fidelity money market fund, a client’s account statement serves in lieu of a confirmation. In addition, clients receive statements from NFS that detail all holdings and transaction information, including trades, additions, withdrawals, shifts in investment allocations, advisory fees, and estimated gain/loss and tax basis information. Statements and confirmations are also available online at Fidelity.com and by enrolling in the electronic delivery program. Clients will not pay a different fee because of their decision to receive electronic statements or trade confirmations. Clients should carefully review all statements and other communications received from FBS and NFS. 39  There can be instances where we need to place a do-not-trade restriction on one or more Program Accounts, including when a client requests a security be transferred from a Program Account, when processing a trade correction, when we need to comply with a court order, when a client asks us to process a withdrawal and keep the proceeds from the sale of securities used to fund the withdrawal in the account until the client provides further instructions for the transfer of the proceeds, or when we need additional information from a client. For the period when a do-not-trade restriction is in effect, we generally will not trade or otherwise manage the Program Account until the do-not-trade restriction has been removed. To assist in the evaluation of the applicable sub-advisor’s performance, clients will have access to information about trading activity in their Program Account as well as information about the performance of their Program Accounts on a pretax basis. Pretax Program Account performance is calculated consistent with industry standards. Clients with taxable Program Accounts in strategies managed with tax-smart investing techniques will also be provided with performance information on an after-tax basis. After-tax Program Account performance is based on the pretax performance of the Program Account, and on an evaluation of the potential tax consequences of trading activity, dividends, income, and distributions in the Program Account. This after-tax performance information is based on information provided by the client about the client’s tax situation, the tax basis information related to the securities in the Program Account, and certain assumptions about the potential tax consequences of trading activity in the Program Account. Detailed information about the methodology and assumptions and their related risks and limitations, used in calculating after-tax performance of a Program Account is provided in each client’s periodic performance summary, or can be obtained by contacting a Fidelity representative. While performance information is reviewed by Strategic Advisers for accuracy and compliance with applicable procedures, performance information is not reviewed or approved by a third party. Ongoing Review and Adjustments of Program Accounts On a daily basis, Strategic Advisers will evaluate a Program Account with respect to a variety of factors to determine whether the account could benefit from trading that day. Common reasons clients can experience trading in their Program Accounts include changes in the model or index, market fluctuations, tax management opportunities, and client-requested activities, such as cash deposits or withdrawals. Please note that Strategic Advisers uses the prior trading day’s closing prices in determining whether a Program Account requires trading on a given day, and in general does not attempt to conduct ongoing intraday Program Account evaluations, nor attempt to time intraday price fluctuations in its decisions to buy or sell securities. Strategic Advisers does not anticipate that each Program Account will be traded each day. Each of the securities purchased in a Program Account will appear on a client’s account statement. Securities selected for Program Accounts can be individually tailored based on a client’s existing holdings and unique financial situation and, where applicable, on the tax attributes of the assets in a Program Account. A client can expect that the securities that compose their Program Account can vary, perhaps significantly, from the securities purchased for another client’s Program Account managed using the same strategy. Clients have periodic performance summaries or similar reports made available to them that detail the performance of a client’s Program Account and summarize the market activity during the period. Industry standards are applied when calculating performance information. Strategic Advisers also makes available account performance information on a password-protected website. Client Referrals and Other Compensation Strategic Advisers and its affiliates are compensated for providing services, including for investment management, distribution, transfer agency, servicing, and custodial services, to certain Fidelity and non- Fidelity mutual funds, ETPs, and other investments in which Program Accounts are invested or which a client could use to implement the Program’s financial planning recommendations. These affiliates include FMRCo and its affiliates as the investment adviser for the Fidelity Funds; FDC as the underwriter of the Fidelity Funds; and Fidelity Investments Institutional Operations Company LLC (“FIIOC”) as transfer agent for the Fidelity Funds, servicing agent for non-Fidelity funds, and recordkeeper of certain workplace savings plans. 40  Certain funds used in Program Accounts are available only to fee-based accounts offered by Fidelity. Unlike many other mutual funds, these funds do not charge fees or expenses for certain services provided by a Fidelity affiliate (but do charge fees for other services). Instead, compensation for such uncharged services is paid by Strategic Advisers or an affiliate. Strategic Advisers and its affiliates also receive compensation and other benefits in connection with portfolio transactions executed on behalf of the Fidelity and non-Fidelity mutual funds, ETPs, and other investments. FMRCo and its affiliates also obtain brokerage or research services, consistent with Section 28(e) of the Exchange Act, from broker-dealers in connection with the execution of the Fidelity Funds’ portfolio security transactions. FBS and NFS receive compensation for executing portfolio transactions and providing, among other things, clearance, settlement, custodial, and other services to Fidelity and non-Fidelity mutual funds, ETPs, and other investments, and NFS provides securities lending agent services to certain Fidelity Funds for which it receives compensation. FBS, NFS, and FIIOC also offer Fidelity’s mutual fund platform, FundsNetwork®, and provide shareholder and other services (including, for a limited number of participants on the platform, the sharing of certain aggregated data regarding ETF holdings in Program Accounts) to participating mutual funds and ETPs (or their sponsors) for which FBS, NFS, and FIIOC receive compensation, including with respect to those mutual funds and ETPs in which Program Accounts are invested. Neither FBS nor NFS receives any compensation in connection with directing equity trades for Program Accounts to market makers for execution. We can execute trades through alternative trading systems or national securities exchanges, including but not limited to ones in which a Fidelity affiliate has an ownership interest, such as Members Exchange, a registered national securities exchange. Any decision to execute a trade through an alternative trading system or exchange in which a Fidelity affiliate has an ownership interest would be made in accordance with applicable law, including best execution obligations. For trades placed on certain national securities exchanges, including ones in which a Fidelity affiliate has an ownership interest, Fidelity could receive exchange rebates from such trades for Program Accounts, and these rebates will be subject to the Credit Amount (as described in “Fees and Compensation”) and will be allocated, pro rata based on assets, among client Program Accounts. The compensation described above that is retained by Strategic Advisers or its affiliates as a direct result of investments by the Program Accounts in Fidelity and non-Fidelity mutual funds and ETPs will be included in the Credit Amount, which reduces the Gross Advisory Fee. However, to the extent that Strategic Advisers or its affiliates, including FBS, NFS, or FIIOC, receive compensation that is neither a direct result of, nor directly derived from, investments by the Program Accounts, such compensation is not included in the Credit Amount, does not reduce the Gross Advisory Fee, and will be retained by Strategic Advisers or its affiliates. Receipt of compensation in addition to the Gross Advisory Fee creates a financial incentive for Strategic Advisers and its affiliates to select investments that will increase such compensation. Strategic Advisers seeks to address this financial conflict of interest through the application of the Credit Amount, which will reduce the Gross Advisory Fee, as applicable, and through personnel compensation arrangements (including those of Strategic Advisers’ investment professionals and the Fidelity representatives) that are not differentiated based on the investments or share classes selected for Program Accounts. Strategic Advisers and its affiliates have also implemented processes reasonably designed to prevent the receipt of compensation from affecting the nature of the advice provided to Program Accounts. See “Fees and Compensation” for additional information. Client referrals are provided by affiliated entities, including FBS or other affiliates, pursuant to referral agreements where applicable. Additionally, Strategic Advisers refers clients to other independent investment advisers in connection with a referral program in which such independent investment advisers participate for a fee payable to Strategic Advisers. Financial Information Strategic Advisers does not solicit prepayment of client fees. Strategic Advisers is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. 41  FOR MORE INFORMATION, PLEASE CALL US TOLL-FREE AT 8 0 0 . 5 4 4 . 3 4 5 5 Monday through Friday, 8 a.m. to 7 p.m . Ea stern time Keep in mind that investing involves risk. The value of your investment will fluctuate over time, and you may gain or lose money. Diversification and asset allocation do not ensure a profit or guarantee against loss. Fidelity does not provide legal or tax advice, and the information provided is general in nature and should not be considered legal or tax advice. Consult an attorney, tax professional, or other advisor regarding your specific legal or tax situation. Indexes are unmanaged. It is not possible to invest directly in an index. The Fidelity U.S. Large Cap Index is a float-adjusted market capitalization–weighted index designed to reflect the performance of the stocks of the largest 500 U.S. companies based on float-adjusted market capitalization. The S&P 500 Index is a float-adjusted market capitalization–weighted index designed to reflect the performance of the stocks of the largest 500 U.S. companies based on float-adjusted market capitalization. The MSCI EAFE Index (Net MA Tax) is a float-adjusted market capitalization–weighted index designed to reflect the performance of the developed international equity market, including large-capitalization stocks. Index returns are adjusted for tax withholding rates applicable to U.S.-based mutual funds organized as Massachusetts business trusts. The Fidelity Developed International ex North America Focus Index (Net) is a float-adjusted market capitalization–weighted index designed to reflect the performance of the developed international equity market, including large-capitalization stocks. Index returns are adjusted for tax withholding rates applicable to U.S.-based mutual funds organized as Massachusetts business trusts. The Fidelity U.S. Total Investable Market Index is a float-adjusted market capitalization–weighted index designed to reflect the performance of U.S. equity market, including large-, mid- and small-capitalization stocks. The Fidelity U.S. Low Volatility Focus Index represents the performance of a broad range of U.S. equities that in the aggregate have lower volatility relative to the broader U.S. equity market. The Russell 3000 Index is a market capitalization–weighted index designed to measure the performance of the 3,000 largest companies in the U.S. equity market. The Dow Jones U.S. Total Stock Mark Index is a float-adjusted market capitalization–weighted index of all equity securities of U.S.-headquartered companies with readily available price data. Fidelity, Fidelity Investments, the Fidelity Investments logo, FundsNetwork, Fidelity Go, Fidelity Managed FidFolios, Fidelity Wealth Advisor Solutions, Empire Fidelity Investments Life Insurance Company, CrossStream, and Fidelity Managed Account Xchange are registered service marks of FMR LLC. Fidelity Brokerage Services LLC, Member NYSE, SIPC, 900 Salem Street, Smithfield, RI 02917 © 2026 FMR LLC. All rights reserved. 835689.12.0 03/26 1.9887735.111 

Fidelity Wealth Advisor Solutions® Form ADV, Part 2A Brochure Strategic Advisers LLC 155 Seaport Boulevard Boston, MA 02210-2698 800.544.3455 Fidelity.com March 30, 2026 This brochure was developed for those who are considering a referral from the Fidelity Wealth Advisor Solutions® program. It provides information about the qualifications and business practices of Strategic Advisers LLC (“Strategic Advisers”), a Fidelity Investments® company, as well as information about the Fidelity Wealth Advisor Solutions program. Throughout this brochure and related materials, Strategic Advisers refers to itself as a “registered investment adviser” or as being “registered.” These statements do not in any way imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 800.544.3455. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Strategic Advisers is available on the SEC’s website at adviserinfo.sec.gov.  S U M M A R Y OF M A TE R I A L C H A N GE S The SEC requires registered investment advisers to provide and deliver an annual summary of material changes to their advisory services program brochure (also referred to as the Form ADV, Part 2A Brochure). The section below highlights only material revisions that have been made to the Fidelity Wealth Advisor Solutions Form ADV, Part 2A Brochure from March 31, 2025, through March 30, 2026. Clients and prospective clients can obtain a copy of the Form ADV, Part 2A Brochure without charge by calling 800.544.3455, by visiting Fidelity.com/information, by visiting the SEC’s website at adviserinfo.sec.gov, or by contacting a Fidelity representative. Capitalized terms are defined herein in this Form ADV, Part 2A Brochure. Material Changes No material changes were made to the Fidelity Wealth Advisor Solutions Form ADV, Part 2A Brochure from March 31, 2025, through March 30, 2026. Other Changes “Information about Fidelity and Fidelity Representative Compensation” has been updated to provide further information about how Fidelity and its representatives are compensated. The chart in “Other Considerations” has been updated to provide further and updated information about the programs, accounts, and services available from Strategic Advisers and its affiliates. Certain minor revisions have been made to the text that describes affiliates of Strategic Advisers in “Other Financial Industry Activities and Affiliations.” 2  T A B L E O F C O NT E N T S SUMMARY OF MATERIAL CHANGES 2 ADVISORY BUSINESS 4 FEES AND COMPENSATION 5 PERFORMANCE -BASED FEES AND SIDE-BY-SIDE MANAGEMENT 10 TYPES OF CLIENTS 10 10 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS DISCIPLINARY INFORMATION 11 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 11 15 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING BROKERAGE PRACTICES 16 REVIEW OF ACCOUNTS 16 CLIENT REFERRALS AND OTHER COMPENSATION 16 CUSTODY 16 INVESTMENT DISCRETION 16 VOTING CLIENT SECURITIES 16 FINANCIAL INFORMATION 16 3  A D V I S O R Y B U S I N E SS Strategic Advisers (sometimes referred to as “we,” “our,” or “us” in this document) is a registered investment adviser under the Investment Advisers Act of 1940 (“Advisers Act”) and an indirect, wholly owned subsidiary of FMR LLC (collectively with Strategic Advisers and its affiliates, “Fidelity Investments” or “Fidelity”). Strategic Advisers was formed in 1977 and provides the referral services for the Fidelity Wealth Advisor Solutions program (herein, the “Service” or “WAS”). As of December 31, 2025, Strategic Advisers had total assets under management of $1,321,075,214,792 on a discretionary basis and $49,050,110,419 on a nondiscretionary basis. The Fidelity Wealth Advisor Solutions Program WAS is a referral service designed for current and prospective clients of Fidelity who seek to receive referrals to unaffiliated third-party independent investment advisory firms (each an “Advisor” and together “Advisors”) that can help those clients meet their asset management, wealth management, and/or financial planning needs. Participating Advisors can include other business names of the same operating Advisor that also participate in the Service. Based on the information you provide as part of the profiling process, we will identify two or more Advisors for you to consider. If requested within 90 days of executing a Referral Agreement and Acknowledgment, we can run additional analysis to provide you with information about other Advisors that align with your screening criteria. Alternatively, separate from the profiling process, you can request to be referred directly to a specific Advisor or Advisors. It is solely your responsibility to determine whether to meet with and/or retain any Advisor. We will provide you with documentation and information about each Advisor that is identified for a referral. The information has been provided to us by each Advisor, and we have not reviewed or verified the accuracy of such information. It is important that you understand that you have no obligation to contact or retain the services of any Advisor you learn about through the Service. You should interview and evaluate each Advisor you consider hiring to ensure that the Advisor and the advisory services each Advisor can provide are right for you. Each Advisor has its own account minimums and client restrictions. Advisors are identified from among a universe of registered investment advisers or are entities that are exempt from registration that (i) have a business relationship with affiliates of Strategic Advisers, including Fidelity Brokerage Services LLC (“FBS”) and National Financial Services LLC (“NFS”), and (ii) meet the participation criteria for the Service (as described below). Advisors are not affiliated with or agents of Fidelity, and Advisors pay a fee to Strategic Advisers for referrals as explained in more detail in the section below titled “Fees and Compensation.” Certain affiliates of Strategic Advisers, namely FBS and NFS, receive additional compensation from the Advisors and/or the Advisors’ clients for the clearing, custody, and other brokerage services associated with any accounts held or serviced by these affiliates. Additionally, other affiliates of Strategic Advisers can receive compensation for other services provided to the Advisors and/or the Advisors’ clients. The Referral Process A Fidelity representative will work with you to gather certain information including but not limited to your investing preferences, geographic preferences, the amount you anticipate investing with an Advisor, and the types of strategies and/or services you want to receive. To arrive at a list of Advisors that align with your criteria, the Fidelity representative will use our screening process to compare the profile information you have provided with the information provided by the Advisors. We have not verified the information provided by the Advisors, and we do not make any representation that any Advisor that aligns with your screening criteria offers certain expertise or experience in a given advisory service. Separate from the profiling process, you can request to be referred directly to a specific Advisor or Advisors and not receive a list based on your screening criteria. Such Advisor will still be considered a 4  referral for purposes of the Service. Following the execution of a Referral Agreement and Acknowledgment, along with the names of the referred Advisors, you will receive (i) a summary of the profile information provided and used to facilitate the referral and (ii) a firm profile for each Advisor, which includes a summary of relevant information provided by the Advisor. You should review all these documents carefully. In addition, we will typically provide your name and contact information to the Advisors referred along with the profile information you provided as part of the referral process. Please see the Referral Agreement for further details about sharing your contact information with the referred Advisors. Whether specifically directed by you or using the screening process, the Service does not constitute a recommendation with respect to any Advisor identified by the Service. In addition, Strategic Advisers does not provide investment advice or recommendations to buy or sell securities or other property in connection with the Service. Your Responsibility The decision as to which Advisor to hire, if any, is yours. If you decide to hire an Advisor, it is your responsibility to work with your Advisor to determine if the services it provides are appropriate for you. If you decide to give an Advisor trading discretion or other authority over your Fidelity account(s) and the Advisor directs transactions to affiliates of Strategic Advisers, such affiliates will act on the instructions received from the Advisor and will not review or evaluate the Advisor’s trading activity to determine if such trading is consistent with the Advisor’s investment strategies or is otherwise appropriate or suitable for you. We have no authority or control with respect to the assets under management at any Advisor, and we have no ongoing duty to you with respect to the Advisor’s management of such assets. It is also your responsibility to monitor your selected Advisor, including the Advisor’s management of your assets and the Advisor’s performance. All questions about your investment strategy, portfolio performance, and the Advisor’s activity should be directed to your selected Advisor. We will play no role in monitoring or evaluating any advisory services that you receive from any Advisor you choose to work with, and we have no duty to update you regarding any referred Advisor once you receive your referral, including whether such Advisor continues to participate in the Service. F E E S A N D C O M P E N S AT I ON Fees Paid to Strategic Advisers for Your Referral You do not directly pay any fee for participating in the Service. If you decide to hire an Advisor referred by the Service, you will pay fees to that Advisor based on the terms and conditions of any investment management and advisory agreements between you and the Advisor. Fees will be disclosed in the Advisor’s Form ADV, Part 2A Brochure. We are not acting as a fiduciary or providing investment advice within the meaning of the Employee Retirement Income Security Act of 1974, or the Internal Revenue Code, or regulations thereunder with respect to your account as a result of the Service. As described below, Advisors pay referral fees to Strategic Advisers to participate in the Service. The referral fees are separate from (i) any advisory fees you pay to an Advisor, (ii) any fees you pay to Strategic Advisers for investment management services, (iii) any fees paid to affiliates of Strategic Advisers, including FBS and NFS for brokerage services, and (iv) any other fees for products or services you pay to any other Fidelity Investments company. Advisors have agreed that the fees paid by the Advisor to Strategic Advisers pursuant to the WAS referral program will not impact the fees that the Advisor charges a referred client. Please see the Advisor’s Form ADV, Part 2A Brochure for information regarding the fees charged by the Advisor or discuss any questions you may have regarding fees that you will pay directly with the Advisor. 5  Advisors pay referral fees to Strategic Advisers for each client referral pursuant to the agreement between Strategic Advisers and each Advisor (“Participation Agreement”). The Participation Agreement provides that the Advisor will pay an annual $50,000 program fee (“Program Fee”) to participate in the Service and a fee based on the value of the assets in a referred client’s accounts opened or maintained with FBS, and custodied at NFS, that are managed or advised pursuant to an investment advisory agreement between that Advisor and a client or that client’s household members, which includes persons/entities sharing the same residence address as the Advisor’s client (collectively, “Client Accounts”). In the event that an Advisor or Strategic Advisers terminates the Participation Agreement prior to the end of a full calendar year, the Program Fee is prorated based on the number of completed quarters in which the Participation Agreement was in effect for such year, but the Advisor’s obligations to pay the asset-based referral fee will remain in effect. Each Advisor has agreed to pay Strategic Advisers an amount equal to the sum of (i) an annual percentage of 0.10% of “fixed-income and cash equivalent assets” (as defined by internal FBS systems) held in Client Accounts and (ii) an annual percentage of 0.25% of all other assets held in Client Accounts. In addition, if an Advisor’s client transfers custody of the assets held in Client Accounts to a financial institution not affiliated with Strategic Advisers, each Advisor has agreed to pay Strategic Advisers a one-time fee of 0.75% of the transferred assets (the “Non-Fidelity Custody Fee”). The Non-Fidelity Custody Fee could incentivize an Advisor to encourage clients to maintain custody of their assets with affiliates of Strategic Advisers rather than transferring custody to another financial institution. If you terminate your advisory agreement with an Advisor, the Advisor shall have no ongoing obligation to pay Strategic Advisers referral fees with respect to your Client Accounts. Under certain circumstances, Strategic Advisers can waive or reduce the referral fees payable to Strategic Advisers by an Advisor. Agreements, including the Participation Agreement, between Strategic Advisers and each Advisor are subject to change. The compensation received by Strategic Advisers and its affiliates from Advisors, both from within and outside the Service, creates conflicts of interest both when we select Advisors to participate in the Service and when we refer you to those Advisors. Strategic Advisers addresses these conflicts in several ways, including (i) establishing participation criteria (described below) and securing the Advisors’ agreement to adhere to those criteria before admission into the Service and on a periodic basis thereafter, (ii) excluding the revenue received by Strategic Advisers and its affiliates from consideration in the screening criteria used by the tool to align Advisors with clients, and (iii) periodically evaluating and overseeing the referral process for compliance with the policies and procedures governing the Service. In addition, as a result of an Advisor’s participation in the Service, it is likely that the Advisor will use affiliates of Strategic Advisers, namely FBS and NFS, to execute securities transactions for Client Accounts, which will generate brokerage commissions and other revenue for affiliates of Strategic Advisers, including FBS and NFS. There are different account options made available by affiliates of Strategic Advisers for Participating Advisors, including core sweep account options (i.e., money awaiting investment or withdrawal). Such core sweep account options could produce a higher or lower return than other options and certain core sweep account investment products can generate higher revenue for Strategic Advisers affiliates as compared with other investment products, which presents a conflict of interest. Please note, however, that Advisors are not required to maintain assets in any core sweep account position and may trade out of any such position at any time. Please see the FBS and NFS brokerage account client agreement for further details regarding the core sweep account and speak with the Advisor if you have any questions. 6  Other Considerations In evaluating the Service, please consider that Fidelity offers a variety of investment advisory services and brokerage offerings. These offerings are summarized below to assist you in understanding and comparing the services and offerings. For more detailed information regarding an investment advisory service, please review the respective Form ADV, Part 2A Brochures available to you at Fidelity.com/information or through a Fidelity representative. Refer to the “Guide to Brokerage and Investment Advisory Services at Fidelity Investments” (available at Fidelity.com/information) for more information regarding our roles and responsibilities when providing brokerage and advisory services. Please note that, other than the self- directed brokerage account offered by FBS, the advisory programs included in the chart below are each offered by Strategic Advisers. PRODUCT DESCRIPTION INVESTMENT GENERAL ELIGIBILITY FEE STRUCTURE Fidelity Go® No account minimum; $10 to invest Less than $25,000 invested: no advisory fee Portfolio based on a client’s investment profile and composed of a mix of zero expense ratio Fidelity mutual funds Asset-based advisory fee: 0.35% annually for $25,000 and above Invests in zero expense ratio Fidelity mutual funds that do not charge management fees (or with limited exceptions, fund expenses) Digitally provided discretionary investment management and planning; access to a team of phone-based representatives for one-on-one financial coaching for clients who maintain $25,000 or more in a Fidelity Go account and tax-loss harvesting for taxable accounts with $25,000 or more Fidelity Managed FidFolios® $5,000 minimum investment Asset-based advisory fee: 0.40% or 0.70% annually A mix of individual securities, either stocks or American Depositary Receipts, depending on the client’s selected strategy Digitally provided discretionary invest- ment management of a single asset class (including tax-smart investing techniques) Fidelity® Strategic Disciplines Asset-based advisory fee: 0.20%–0.70% annually for equity strategies and 0.35%– 0.40% annually for fixed income strategies, depending on the amount invested Discretionary investment management of a single asset class (including tax-smart investing techniques); planning and advice is provided through a dedicated representative A mix of individual securities, including but not limited to stocks, bonds, American Depositary Receipts, and/or exchange-traded products and mutual funds, depending on the client’s selected strategy Depending on strategy selected, account investment minimums of $100,000 (equity strategies) and $350,000 (bond strategies), each subject to qualification for support from a dedicated Fidelity representative, which is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) (effective in the second quarter of 2026, the account investment minimum will be $200,000 for taxable bond strategies and $250,000 for municipal bond strategies) 7  PRODUCT DESCRIPTION INVESTMENT FEE STRUCTURE GENERAL ELIGIBILITY Fidelity® Wealth Services $50,000 minimum investment Asset-based advisory fee: 1.10% annually, less a fee credit that reflects compensation retained by Fidelity as a direct result of a client’s investments Fidelity Advisory Services provides customized planning, advice, and discretionary investment management (including tax-smart investing techniques); planning and advice is provided by a centralized team of phone-based representatives A mix of Fidelity and non-Fidelity mutual funds and exchange-traded products invested using a dynamic asset allocation that can respond to changes in the economic business cycle; offered with multiple investment approaches and universes Wealth Management and Private Wealth Management provide customized planning, advice, and discretionary investment management (including tax-smart investing techniques); planning and advice is provided through a dedicated representative supported by a service team A mix of Fidelity and non-Fidelity mutual funds and exchange- traded products and, depending on a client’s preferences and investment profile, individual securities, invested using a dynamic asset allocation that can respond to changes in the economic business cycle; offered with multiple investment approaches and universes Asset-based advisory fee: 0.50%–1.50% annually, depending on the amount invested, less a fee credit that reflects compensation retained by Fidelity as a direct result of a client’s investments (additional fees of up to 0.40% for management of certain individual security strategies can also apply where advisory services are not provided solely by a Strategic Advisers affiliate) $50,000 minimum account investment for Wealth Management and $2 million minimum investment and $10 million investable assets for Private Wealth Management, each subject to qualification for support from a dedicated Fidelity representative, which is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) Fidelity Wealth Advisor Solutions® Investment vehicles will vary by unaffiliated investment advisor and strategy Investment minimums will vary by unaffiliated investment advisor and services provided Advisory fees will vary by unaffiliated investment advisor and services provided A referral network of unaffiliated investment advisors that provide customized wealth management and investment strategies Self-Directed Brokerage Account Transaction fees and investment expenses vary based on investment vehicle selected; no ongoing asset-based advisory fee charged by Strategic Advisers No minimum to open a brokerage account. Qualification for support from a dedicated Fidelity representative is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) Self-directed trading through FBS, with access to Fidelity’s online tools, planning, and resources, and support provided by brokerage representatives. A dedicated representative is available based on relationship Brokerage customers can choose from a wide variety of investments, including mutual funds, exchange-traded funds, stocks, bonds, and insurance and annuity products. Note that certain securities available through Strategic Advisers’ advisory services are not available in self- directed brokerage accounts As described in the chart above, FBS offers self-directed brokerage accounts and financial planning and can provide dedicated support from a Fidelity representative depending on a client’s overall relationship with Fidelity. In addition, a client could receive similar services through other advisors not participating in the Service. You should interview and evaluate any advisor you consider hiring to ensure the services are right for you. 8  Information about Fidelity and Fidelity Representative Compensation Fidelity representatives who support the Service are associated with Strategic Advisers and FBS. Educational information about the Service is provided by representatives acting on behalf of FBS. Once a client enrolls in the Service, the Fidelity representative will be providing services for Strategic Advisers. Separate and apart from the Service, Fidelity representatives, including those who support the Service, can provide clients with a variety of FBS services, including investment education and advice, financial analyses, and planning services. When providing services for FBS, these Fidelity representatives are acting solely as registered representatives of FBS. Fidelity representatives receive base pay based on their experience and role. In addition to base pay, Fidelity representatives are also eligible to receive either variable compensation or an annual bonus, and certain representatives are also eligible to receive longer-term compensation. Fidelity representatives who receive an annual bonus do not receive compensation based directly on the sale of any product or service, but they do have an indirect financial incentive to recommend products or services that pay more compensation to Fidelity because annual bonus funding is based in part on Fidelity’s financial performance. For Fidelity representatives who receive variable compensation, variable compensation depends on the representative’s role and can be impacted by client loyalty, the amount of assets a client transfers to Fidelity, the amount of assets invested initially and on an ongoing basis, referring potential clients to other Fidelity representatives who enroll the client in a Fidelity investment product or service, and client family members opening Fidelity accounts. Whether and how much each Fidelity representative receives in each component is generally determined based on the representative’s role, responsibilities, performance measures, and their manager’s assessment of the representative’s performance. Fidelity and the Fidelity representatives who support the Service and who are eligible to receive variable compensation receive different amounts of compensation depending on the type of product or service a client selects. The compensation received by Fidelity and those representatives in connection with FBS offerings (e.g., stocks, bonds, ETFs, mutual funds) is typically less than the compensation received in connection with a client choosing to participate in a Fidelity advisory program. A Fidelity representative will earn more compensation if a client enrolls in the Service than if a client enrolls in Fidelity Go, Fidelity Managed FidFolios, or the Fidelity Advisory Services service level of Fidelity Wealth Services. Products and services that generally require more time to engage with a client and/or that are more complex provide greater compensation to a representative and Fidelity. This compensation structure creates a financial incentive for Fidelity and its representatives to recommend investments in more complex and time-consuming products and services over others, and to recommend that a client maintain an investment in such products and services over time. Fidelity addresses these conflicts of interest by having processes in place that require our representatives to make recommendations that are in the best interest of clients, paying compensation based on the time and complexity of the relevant product or service, training and supervising our representatives, and disclosing these conflicts of interest to clients so that they can consider the conflicts when making their financial decisions. To see specific compensation levels for the managed account programs mentioned above and other products, including an example of compensation that can be earned by Financial Consultants, please see the “Fidelity Investments Compensation Disclosure” document (available at Fidelity.com/information) or contact a Fidelity representative. Clients should read the information contained in the “Fidelity Investments Compensation Disclosure” document carefully, and can ask a Fidelity representative at any time whether and how they are compensated with respect to a particular product or service and about the financial incentives and conflicts of interest that Fidelity has when making recommendations of products and services. 9  Additional Fee Information Affiliates of Strategic Advisers receive additional compensation for the clearing, custody, and other brokerage services associated with the Advisors’ Client Accounts maintained with FBS and/or NFS. As a result of an Advisor’s participation in the Service, it is likely that the Advisor will use affiliates of Strategic Advisers to execute securities transactions for your account(s) held at Fidelity, which will generate brokerage commissions and other revenue for affiliates of Strategic Advisers, including FBS and NFS, and creates conflicts of interest. In general, you have the ability to direct the Advisor to use any brokerage firm you choose to support your trading activity, and any such direction is between you and the Advisor. P E R F OR M A N C E - BA S E D F E E S A N D S I D E- BY-S I D E M A N A G E M E N T Strategic Advisers does not charge advisory fees, including performance-based advisory fees, under the Service. Strategic Advisers provides only referrals to unaffiliated third-party independent investment advisers under the Service, and is not responsible for discretionary management of accounts or assets through the Service. Therefore, Strategic Advisers has no opportunity to engage in side-by-side management. TY P E S OF C L I E N T S The Service is generally available to current and prospective clients of Strategic Advisers and its affiliates, including FBS, who inquire about receiving asset management, wealth management, or financial planning services from Advisors. In order to participate in the Service, you must be a U.S. person (including a U.S. resident alien), typically reside in the United States, and have a valid U.S. taxpayer identification number. We reserve the right to terminate your participation in the Service (or limit your rights to access any or all account features, products, or services) for any reason. The Service is not available to foreign investors, non- U.S. trusts, and government entities as defined by the SEC’s “pay to play” rule according to Rule 206(4)-5 under the Advisers Act. These include federal, state, or local governments, boards, commissions, public schools, colleges, universities, hospitals, health care organizations, and public entity retirement plans, such as Internal Revenue Code sections 403(b), 401(a), and 457 plans. ME T H ODS OF A N A LYS I S , I N V E S T M E N T S T R A TEG I E S A N D R I S K OF LOS S As directed by current or prospective clients or through the use of our screening process, we seek to refer current and prospective clients to Advisors based on a comparison of the information you share with us about your asset management, wealth management, and financial planning needs, with the information Advisors have provided to us about their firms and the types of advisory services they provide to their clients. In no event shall providing documentation and/or information by Strategic Advisers about any of the Advisors constitute a recommendation or opinion as to the quality of an Advisor’s investment products, services, or investment performance. We have relied on the information and representations of each Advisor as part of the Advisor’s eligibility to participate in the Service and to align the Advisor with your stated needs and preferences for the referral. All investment strategies employed by the Advisors that participate in the Service are subject to certain risks, including the risk of loss that each client should understand and be willing to bear. Please see the relevant Advisor’s Form ADV, Part 2A Brochure for additional information about risks associated with an Advisor’s investment strategies. 10  Advisors that participate in the Service are limited to unaffiliated third-party independent investment advisers or entities that are exempt from registration as an investment adviser that have business relationships with affiliates of Strategic Advisers, namely FBS and NFS. There could be other investment advisers, apart from those we make available to you through the Service, that are equally or more appropriate for your specific circumstances. We use the following objective factors, among others, to determine which Advisors are eligible to participate in the Service: 1. Federal Registration. A Participating Advisor must be an investment adviser registered and in good standing with the SEC and/or any applicable state securities regulatory authorities or an entity that is exempt from registration as an investment adviser pursuant to Section 202(a)(11) (A) under the Advisers Act. 2. Representative Registration. Representatives of a Participating Advisor who meet the definition of “Investment Adviser Representative” under Rule 203A-3 under the Advisers Act and who provide services to you must be registered/licensed appropriately in the required jurisdictions. 3. Fee-Based Compensation. Participating Advisors must charge fee-based, asset-based, or flat-rate investment advisory service fees (including hourly fees). 4. Assets Under Management. Participating Advisors must maintain a minimum of $1 billion in total regulatory assets under management, as reported in response to Item 5 in Part 1A of the Advisor’s Form ADV, throughout the duration of the Advisor’s participation in the Service. 5. Errors and Omissions Liability. Participating Advisors and all associated persons of the Advisor who manage client assets or who supervise such associated persons must at all times be covered through both errors and omissions liability insurance and fidelity bond coverage, with a minimum of $2 million in errors and omissions liability insurance and $1 million in fidelity bond coverage. 6. Principals and Employees. Participating Advisors must maintain a minimum of two principals as well as a minimum of five employees. We can, in our sole discretion, modify these criteria in whole or in part with respect to any Advisor at any time, and we reserve the right to suspend referrals to any Advisor or terminate an Advisor’s participation in the Service for any reason. While we have evaluated the referred Advisors based on the participation criteria for the Service, as noted above, we have not made an independent evaluation of any particular product, strategy, or service, including financial planning or wealth planning services, that is offered by any Advisor. DI S C I P L I N A R Y INFORMATION There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of the advisory business of Strategic Advisers or the integrity of its management personnel. OT H E R F I N A N C I A L I N D U S T R Y AC T I V I T I E S A N D A F F I L I A T I ONS Strategic Advisers is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is a wholly owned subsidiary of FMR LLC. FMR LLC is a Delaware limited liability company that, together with its affiliates and subsidiaries, is generally known to the public as Fidelity Investments or Fidelity. Various direct or indirect subsidiaries of FMR LLC are engaged in investment advisory, brokerage, banking, or insurance businesses. From time to time, Strategic Advisers and its clients will have material business relationships with any of the subsidiaries and affiliates of FMR LLC. In addition, the principal officers of Strategic Advisers serve as officers and/or employees of affiliated companies that are engaged in various aspects of the financial services industry. Strategic Advisers is not registered as a broker-dealer, futures commission merchant, or commodity 11  trading advisor, nor does it have an application pending to register as such. Strategic Advisers is registered with the U.S. Commodity Futures Trading Commission (“CFTC”) under the Commodity Exchange Act of 1936, as amended (“CEA”), as a commodity pool operator (“CPO”) and is a member of the National Futures Association (“NFA”). Certain personnel of Strategic Advisers, FBS, and NFS share premises and have common supervision. Certain management persons of Strategic Advisers are registered representatives of FBS, a Strategic Advisers affiliate and a registered broker-dealer. In addition, Strategic Advisers has entered into an intercompany agreement with FBS, pursuant to which FBS provides to Strategic Advisers various operational, administrative, analytical, and technical services, and the personnel necessary for the performance of such services. Strategic Advisers has, and its clients could have, a material relationship with the following affiliated companies: Investment Companies and Investment Advisers • Fidelity Management & Research Company LLC (“FMRCo”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FMRCo provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FMRCo acts as sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients and provides model portfolio recommendations and environmental filtering services to Strategic Advisers in connection with Strategic Advisers’ provision of discretionary portfolio management to certain clients. Strategic Advisers pays FMRCo an administrative fee for handling the business affairs of the registered investment companies advised by Strategic Advisers, and Strategic Advisers compensates FMRCo for making certain mutual funds available to managed account programs offered by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FMRCo. • Fidelity Institutional Wealth Adviser LLC (“FIWA”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FIWA provides nondiscretionary investment management services and sponsors the Fidelity Managed Account Xchange® and Fidelity Managed Account Xchange Essentials programs (turnkey asset management programs made available to financial intermediaries). Strategic Advisers provides model portfolio services to FIWA in connection with FIWA’s services to its institutional and intermediary clients, and FIWA compensates Strategic Advisers for such services. In addition, Strategic Advisers shares employees from time to time with FIWA. • FIAM LLC (“FIAM”), a wholly owned subsidiary of FIAM Holdings LLC, which in turn is wholly owned by FMR LLC, is a registered investment adviser under the Advisers Act and is registered with the Central Bank of Ireland. FIAM provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. Strategic Advisers has sub-advisory agreements with FIAM for certain registered investment companies advised by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FIAM. • FMR Investment Management (UK) Limited (“FMR UK”), an indirect, wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act, has been authorized by the U.K. Financial Conduct Authority to provide investment advisory and portfolio management services, and is registered with the Central Bank of Ireland. FMR UK provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR UK for certain registered investment companies advised by Strategic Advisers. • Fidelity Management & Research (Japan) Limited (“FMR Japan”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Japan Financial Services Agency (Kanto Local Finance Bureau) to provide investment advisory and discretionary investment management services. FMR Japan provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated 12  advisers. FIAM has sub-advisory agreements with FMR Japan for certain registered investment companies advised by Strategic Advisers. • Fidelity Management & Research (Hong Kong) Limited (“FMR Hong Kong”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Hong Kong Securities & Futures Commission to advise on securities, deal in futures contracts, provide asset management services, and conduct trading services. FMR Hong Kong provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Hong Kong for certain registered investment companies advised by Strategic Advisers. • Fidelity Diversifying Solutions LLC (“FDS”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FDS is registered with the CFTC under the CEA as a CPO and as a commodity trading advisor. FDS is a member of the NFA. FDS provides discretionary advisory and sub-advisory services. FDS acts as a sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients. Broker-Dealers • Fidelity Distributors Company LLC (“FDC”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Securities Exchange Act of 1934 (the “Exchange Act”). FDC acts as principal underwriter of business development companies and the registered investment companies in the Fidelity group of funds and also markets those funds and other products to third-party financial intermediaries and certain institutional investors. • National Financial Services LLC (“NFS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. NFS is a fully disclosed clearing broker-dealer that provides clearing, settlement, and execution services for the other broker-dealers, including its affiliate FBS. Fidelity Capital Markets (“FCM”), a division of NFS, provides trade executions for Fidelity affiliates and other clients. Additionally, FCM operates CrossStream®, an alternative trading system (“ATS”) that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. CrossStream is used to execute transactions for investment company and other clients. NFS provides transfer agent or sub–transfer agent services and other custodial services to certain Fidelity clients. • Fidelity Brokerage Services LLC (“FBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act and provides brokerage products and services, including the sale of shares of registered investment companies in the Fidelity group of funds to individuals and institutions, including retirement plans, and acts as placement agent for certain privately offered investment funds advised by Strategic Advisers’ affiliates. In addition, along with Fidelity Insurance Agency, Inc. (“FIA”), FBS distributes variable insurance products that are issued by Fidelity Investments Life Insurance Company (“FILI”) and Empire Fidelity Investments Life Insurance Company® (“EFILI”), both Fidelity affiliates, as well as by third-parties. FBS provides shareholder services to certain of Fidelity’s clients. FBS is the introducing broker for managed accounts offered by Strategic Advisers and places orders for execution with its affiliated clearing broker, NFS. • LeveL Markets, LLC, a registered broker-dealer and operator of two ATSs, the Luminex ATS and the LeveL ATS, which allow orders submitted by subscribers to be crossed against orders submitted by other subscribers. LeveL Holdings, LLC, owns LeveL Markets, LLC. Fidelity Global Brokerage Group, Inc., and FMR Sakura Holdings, Inc., each a wholly owned subsidiary of FMR LLC, have membership interests in LeveL Holdings, LLC, along with other members. LeveL Markets, LLC, charges a commission to both sides of each trade executed in the Luminex ATS and LeveL ATS. Luminex ATS and LeveL ATS are used to execute transactions for Fidelity affiliates’ investment company and other advisory clients. NFS serves as a clearing agent for transactions executed in the Luminex ATS and LeveL ATS. 13  • Digital Brokerage Services LLC (“DBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. DBS provide securities brokerage to retail customers through a digital mobile application-based brokerage platform. DBS receives remuneration from FMRCo for expenses incurred in servicing and marketing FMRCo products. Banking Institutions • Fidelity Management Trust Company (“FMTC”), a wholly owned subsidiary of FMTC Holdings LLC, which in turn is wholly owned by FMR LLC, is a limited-purpose trust company organized and operating under the laws of the Commonwealth of Massachusetts that provides nondiscretionary trustee and custodial services to employee benefit plans and IRAs through which individuals can invest in affiliated or unaffiliated registered investment companies. FMTC also provides discretionary investment management services to institutional clients. • Fidelity Personal Trust Company, FSB, a wholly owned subsidiary of Fidelity Thrift Holding Company, Inc., which in turn is wholly owned by FMR LLC, is a federal savings bank that offers fiduciary services that include trustee or co-trustee services, custody, principal and income accounting, investment management services, and recordkeeping and administration. Insurance Companies or Agencies • FILI, a wholly owned subsidiary of FMR LLC, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates. • EFILI, a wholly owned subsidiary of FILI, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates to residents of New York. • FIA, a wholly owned subsidiary of FMR LLC, is engaged in the business of selling life insurance and annuity products of affiliated and unaffiliated insurance companies. Limited Partnerships and Limited Liability Company Investments Strategic Advisers provides discretionary investment management to partnerships and limited liability companies designed to facilitate acquisitions by mutual funds offered by Strategic Advisers. These funds are privately offered consistent with stated investment objectives. Strategic Advisers does not currently engage in borrowing, lending, purchasing securities on margin, short selling, or trading in commodities. Participating Affiliate Certain employees of Fidelity Strategic Advisers Ireland, Limited (“Strategic Ireland”) can from time to time provide certain services, including but not limited to research, operations, and investment management support services for Strategic Advisers, which Strategic Advisers could use for its clients. Strategic Ireland is not registered as an investment adviser under the Advisers Act and is deemed to be a “Participating Affiliate” of Strategic Advisers (as this term has been used by the SEC’s Division of Investment Management in various no-action letters granting relief from the Advisers Act’s registration requirement for certain affiliates of registered investment advisers). Strategic Advisers deems Strategic Ireland and each of the Strategic Ireland Associated Employees as “associated persons” of Strategic Advisers within the meaning of Section 202(a)(17) of the Advisers Act. Strategic Ireland Associated Employees and Strategic Ireland through such employees can contribute to Strategic Advisers’ research process and could have access to information concerning securities that are being selected for clients prior to the effective implementation of such selections. As a Participating Affiliate of Strategic Advisers, Strategic Ireland has agreed to submit itself to the jurisdiction of United States courts for actions arising under United States securities laws in connection with investment advisory activities conducted for Strategic Advisers’ clients. Strategic Advisers maintains a list of Strategic Ireland Associated Employees whom Strategic Ireland has deemed associated persons, and Strategic Advisers will make the list available to its current U.S. clients upon request. 14  CODE OF ET H I C S , P A R T I C I P A T I ON OR I N T E R E S T I N C L I E N T T R A N S AC T I ONS A N D P E R S ON A L T R A D I N G Strategic Advisers has adopted a Code of Ethics for Personal Trading (the “Code of Ethics”). The Code of Ethics applies to all officers, directors, employees, and other supervised persons of Strategic Advisers and requires that they place the interests of Strategic Advisers’ clients above their own. The Code of Ethics establishes securities transaction requirements for all covered employees and their covered persons, including their spouses. More specifically, the Code of Ethics contains provisions requiring the following: • Standards of general business conduct reflecting the investment advisers’ fiduciary obligations; • Compliance with applicable federal securities laws; • Employees and their covered persons to move their covered accounts to FBS unless an exception exists or prior approval has been granted; • Reporting and review of personal securities transactions and holdings for persons with access to certain nonpublic information; • Prohibition of purchasing securities in initial public offerings unless an exception has been approved; • Reporting of Code of Ethics violations; and • Distribution of the Code of Ethics to all supervised persons, documented through acknowledgments of receipt. Core features of the Code of Ethics generally apply to all Fidelity employees. The Code of Ethics also imposes additional restrictions and reporting obligations on certain advisory personnel, research analysts, and portfolio managers. Such restrictions and reporting obligations include the following: • The preclearing of transactions in covered securities with limited exceptions; • A prohibition on investments in limited offerings without prior approval; • A prohibition on personal trading by a portfolio manager within seven days before or after a trade in any covered security of the same issuer by a fund or account managed by such portfolio manager except in limited circumstance; • The reporting of transactions in covered securities on a quarterly basis with limited exceptions, • The reporting of securities accounts and holdings of covered securities at the time of hire and annually thereafter; and • The disgorgement of profits from short-term transactions with limited exceptions. Violation of the Code of Ethics requirements can also result in the imposition of remedial action. The Code of Ethics will generally be supplemented by other relevant Fidelity policies, including the Policy on Inside Information, Rules for Broker-Dealer Employees, and other written policies and procedures adopted by Fidelity and Strategic Advisers. A copy of the Code of Ethics will be provided to any client or prospective client on request. From time to time, Strategic Advisers and its related persons can buy or sell securities for themselves and recommend those securities to clients. The conflicts of interest involved in such activities are contemplated in the Code of Ethics and other relevant Fidelity policies. In particular, the Code of Ethics and other Fidelity policies are designed to make clear to Fidelity personnel that they should never place their personal interests ahead of Fidelity’s clients in an attempt to benefit themselves or another party. The Code of Ethics and other Fidelity policies impose sanctions if these requirements are violated. From time to time, in connection with our business, certain supervised persons obtain material nonpublic information that is usually not available to other investors or the general public. In compliance with applicable laws, Strategic Advisers has adopted a comprehensive set of policies and procedures that prohibits the use of material nonpublic information by investment professionals or any other employees. In addition, Fidelity has implemented a Corporate Gifts & Entertainment Policy intended to set standards for 15  business entertainment and the giving or receiving of gifts, to help employees make sound decisions with respect to these activities, and to ensure that the interests of Strategic Advisers’ clients come first. Similarly, to support compliance with applicable “pay to play” laws, Fidelity has adopted a Personal Political Contributions & Activities Policy that requires employees to preclear any political contributions and activities. Fidelity also has a Global Anti-Corruption Policy regarding commercial bribery and bribery of government officials that prohibits directly or indirectly giving, offering, authorizing, promising, accepting, or receiving any bribe, facilitation payment, kickback, or payoff (whether in cash or any other form) with the intent to improperly obtain or retain business or any improper advantage. B R OK E R A GE P R A C T I C E S Strategic Advisers does not select or recommend broker-dealers for client transactions as part of the Service. However, as described above, an Advisor’s participation in the Service can create incentives for an Advisor to recommend the use of affiliates of Strategic Advisers, namely FBS and NFS, for the execution of brokerage transactions and/or the custody of their Client Accounts. R E V I E W OF ACCOU N T S Strategic Advisers does not conduct an ongoing review of accounts post-referral. Strategic Advisers has no discretionary authority or control with respect to the assets under management at any Advisor, and Strategic Advisers has no ongoing duty to you with respect to the management of any such assets. Strategic Advisers does not monitor or evaluate any advisory services that you receive from any Advisor you choose to work with, and Strategic Advisers has no duty to update you regarding the status of any Advisor in the Service once you receive your referral. C L I E N T R E F E R R A L S A N D OT H E R COM P E N S AT I ON As described herein, Strategic Advisers receives compensation from Advisors for referrals made through the Service. Client referrals are provided by affiliated entities, including FBS, pursuant to referral or other agreements where applicable. C U S T ODY As described herein, Strategic Advisers does not have custody of client securities or accounts with respect to the Service. Strategic Advisers and its affiliates, including NFS as described above, can have custody of client securities in connection with activities unrelated to the Service. Clients should carefully review statements they receive from their custodian regarding their accounts. I N V E S T M E N T DI S C R E T I ON Strategic Advisers does not exercise any investment discretion in connection with referrals made pursuant to the Service. VOT I N G C L I E N T S E C U R I T I E S Strategic Advisers does not acquire authority or exercise proxy voting on your behalf as part of the Service. F I N A N C I A L I N F OR M A T I ON Strategic Advisers does not solicit prepayment of client fees. Strategic Advisers is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. 16  FOR MORE INFORMATION, PLEASE CALL US TOLL-FREE AT 8 0 0 . 5 4 4 . 3 4 5 5 Monday through Friday, 8 a.m. to 7 p.m. Eastern time Fidelity Wealth Advisor Solutions, Fidelity Go, Fidelity Managed FidFolios, Fidelity, Fidelity Investments, the Fidelity Investments logo, Empire Fidelity Investments Life Insurance Company, Fidelity Managed Account Xchange, and CrossStream are registered service marks of FMR LLC. Fidelity Brokerage Services LLC, Member NYSE and SIPC, 900 Salem Street, Smithfield, RI 02917 © 2026 FMR LLC. All rights reserved. 629286.25.0 03/26 1.960529.120 17 

Fidelity® Wealth Services Form ADV, Part 2A Brochure Strategic Advisers LLC 155 Seaport Boulevard Boston, MA 02210-2698 617.563.7000 Fidelity.com March 30, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Strategic Advisers LLC (“Strategic Advisers”), a Fidelity Investments® company, as well as information about Fidelity Wealth Services. Throughout this brochure and related materials, Strategic Advisers refers to itself as a “registered investment adviser” or as being “registered.” These statements do not imply a certain level of skill or training. Please contact us at 800.544.3455 with any questions about the contents of this brochure. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Strategic Advisers is available on the SEC’s website at adviserinfo.sec.gov.  S U M M A R Y O F M A T E R I A L C H A N G E S The SEC requires registered investment advisers to provide and deliver an annual summary of material changes to their advisory services program brochure (also referred to as the Form ADV, Part 2A brochure). The section below highlights only material revisions that have been made to the Fidelity Wealth Services Form ADV, Part 2A brochure (the “Program Brochure”) from March 31, 2025, through March 30, 2026. Clients and prospective clients can obtain a copy of this Program Brochure without charge by calling 800.544.3455, by visiting Fidelity.com/information, by visiting the SEC’s website at adviserinfo.sec.gov, or by contacting a Fidelity representative. Capitalized terms are defined in this Program Brochure. Material Changes • New BlackRock Diversified Income Portfolio accounts are no longer available, and we expect to close all BlackRock Diversified Income Portfolio accounts by the end of 2026. BlackRock Diversified Income Portfolio clients can work with their Fidelity representative to reposition assets prior to account closure. Other Changes • The Advisory Services Team service level of the Program has been renamed as the Fidelity Advisory Services service level. References have been updated accordingly. • The chart in “Other Considerations” has been updated to provide further and updated information about the programs, accounts, and services available from Strategic Advisers and its affiliates. • “Information about Fidelity and Fidelity Representative Compensation” has been updated to provide further information about how Fidelity and its representatives are compensated. • The timing of liquidating trades and in-kind asset transfer instructions in “Withdrawals, Account Closure, and Program Termination” has been updated from five to seven business days. • “Additional Information about Strategic Advisers’ Investment Practices” in “Methods of Analysis, Investment Strategies, and Risk of Loss” has been updated to describe Strategic Advisers’ practices with respect to investing Program Accounts in mutual funds. • “Material Risks” has been updated to provide further information with respect to the efficacy of tax-smart investing techniques for Program clients in lower federal income tax brackets. • Certain minor revisions have been made to the text that describes Strategic Advisers’ affiliates in “Other Financial Industry Activities and Affiliations.” 2  T A B L E O F C O N T E N T S SUMMARY OF MATERIAL CHANGES 2 S ER VIC ES , F EES A ND COMPEN SATION 4 ACCOUNT REQUIREMENTS AN D T YPES OF CLIEN TS 15 PORTFOLIO MANAGER SELECTION AN D EVALUATION 18 CLIENT INFORMATION PROVIDED TO POR TFOLIO MAN AGERS 39 CLIENT CONTAC T WITH POR TFOLIO MAN AGERS 39 ADDITIONAL INFORMATION 39 3  S E R V I C E S , F E E S A N D C O M P E N S A T I O N Strategic Advisers is a registered investment adviser and an indirect, wholly owned subsidiary of FMR LLC (collectively with Strategic Advisers and its affiliates, “Fidelity Investments,” “Fidelity,” “us,” “our,” or “we”). Strategic Advisers was formed in 1977 and provides a variety of investment management services, including discretionary and nondiscretionary advisory services to retail and institutional clients. This Program Brochure provides information about Fidelity Wealth Services (the “Program”). For information about the additional services that Strategic Advisers provides, please see Strategic Advisers’ other Form ADV, Part 2A brochures. As described below, the Program offers three service levels that provide a range of (i) discretionary investment management services, (ii) access to financial planning, and (iii) assistance from one or more Fidelity representatives (together, the “Program Services”). The Program service levels are Fidelity Advisory Services (formerly the Advisory Services Team), Wealth Management, and Private Wealth Management. Discretionary investment management is provided through one or more Personalized Portfolios accounts (each a “Program Account”). Program Accounts can include tax-advantaged accounts (e.g., traditional, Roth, and SEP individual retirement accounts (“IRAs”), and health savings accounts, collectively, “Retirement Program Accounts”), taxable accounts that are managed using tax-smart investing techniques (each a “Tax-Smart Program Account”), and tax-advantaged and taxable BlackRock® Diversified Income Portfolio (“BDIP”) Program Accounts, which are not managed using tax-smart investing techniques. Program Accounts will be invested in mutual funds and/or exchange-traded products (“ETPs”). In addition, eligible Tax-Smart Program Accounts of certain asset levels can be invested in individual securities. Discretionary Investment Management Services Profile and Asset Allocation. As a first step in the delivery of Program Services, we obtain information regarding the client’s financial situation, investment goals and objectives, risk tolerance, planned investment time horizon, and other assets (“Profile Information”). Based on this Profile Information, we will propose an allocation among stock, bond, and short-term asset classes for one or more Program Accounts. These asset class exposures are referred to as an asset allocation, each of which is designed to correspond to a level of risk ranging from conservative (lower risk and return potential) to aggressive (higher risk and return potential). Subject to certain limitations, clients can select an asset allocation that differs from the allocation we propose. Clients should understand that the performance of the Program Account with a client-selected asset allocation could differ, at times significantly, from the performance of an account managed according to the asset allocation we proposed. Program Account Investment. Each Program Account will be invested on a discretionary basis to align with the identified asset allocation as well as investment approach and universe selected by the client for an account or goal. Program Accounts receive ongoing discretionary management and rebalancing, as appropriate, to generally maintain alignment with the target asset allocation. Mutual funds and ETPs selected for Program Accounts will typically hold investments in a combination of the primary asset classes: domestic stocks (U.S. equity securities), foreign stocks (non-U.S. equity securities), bonds (fixed income securities of all types and maturities, including lower-quality debt securities), and short-term assets (short-duration investments). Program Accounts can also hold shares of mutual funds and ETPs that invest in nontraditional and/or extended asset classes, including but not limited to real estate, inflation-protected debt securities, commodities, or other alternative investments. At times, investments in these asset classes could make up a substantial portion of a Program Account. As a result, a client’s exposure to the primary asset classes, particularly bond and short- term investments, can be reduced to gain exposure to these nontraditional and/or extended asset classes. It is important to note that the actual asset allocation of a Program Account can and will deviate from the target asset allocation based on market movements and investment decisions intended to increase potential returns or manage risk in response to our views of the economic business cycle. Mutual funds and ETPs used in the Program are managed by Fidelity, including Strategic Advisers, and/or third-party investment managers, and the mutual funds are selected from among those available through FundsNetwork®, Fidelity’s mutual fund platform. ETPs include exchange-traded funds (“ETFs”), exchange-traded notes, unit investment trusts, closed-end funds, master limited partnerships, and certain trusts. 4  The selection and allocation of assets to Fidelity Funds or to third-party funds that pay fees to Strategic Advisers’ affiliates creates conflicts of interest for Strategic Advisers. For funds managed by a Fidelity affiliate, these affiliates receive fees for services, including management and administration of the fund. For any third- party fund, Strategic Advisers’ affiliates receive fees in connection with the fund’s FundsNetwork participation. Strategic Advisers seeks to address these conflicts through the application of the Credit Amount, which is described in “Fees and Compensation” below, and through personnel compensation arrangements, which are not differentiated based on the investments selected for Program Accounts. Retirement Program Accounts are generally invested in a portfolio composed of mutual funds and/or ETPs. Tax- Smart Program Accounts are invested in a portfolio of mutual funds and/or ETPs, and, for certain eligible Tax- Smart Program Accounts, individual securities through separately managed account sleeves (“SMA Sleeves”), which are discussed below. Investment Approaches and Universes. After selecting an asset allocation, clients select either a Total Return or a Defensive investment approach for their Program Accounts. The Total Return investment approach seeks to enhance total return for a given level of risk through broad diversification across asset classes. The Defensive investment approach seeks to temper downside risk in an effort to provide a smoother investment experience over the long term (as compared with a Total Return approach) by implementing “defensive” strategies. Clients also select from the following investment universes for their Total Return Program Accounts (please note that only the Blended investment universe is available for Defensive Program Accounts): • the Blended and Sustainable Blended investment universes each use both Fidelity and non- Fidelity investments; • the Fidelity-Focused and Sustainable Fidelity-Focused investment universes each have a preference for investments from Fidelity, as available and appropriate; and • the Index-Focused and Sustainable Index-Focused investment universes each use both Fidelity and non- Fidelity investments and have a preference for index-based investments, as available and appropriate. Clients should expect that, depending on the investment approach and universe selected and whether the account is managed with tax-smart investing techniques, a significant percentage, which can be substantially all of the assets in a Program Account, will be invested in Fidelity mutual funds and ETPs. It is possible that non-Fidelity investments may outperform Fidelity mutual funds and ETPs. Clients should refer to their account statements or investment proposal documentation for more information about the funds held, or proposed to be held, in a Program Account. Please see “About the Investment Approaches and Universes” below for more information. Tax-Smart Investing Techniques and SMA Sleeves. Tax-Smart Program Accounts are managed using investing techniques that seek to enhance after-tax returns, including, without limitation, harvesting tax losses, analyzing tax lots, and managing exposure to mutual fund distributions. Certain qualified Wealth Management and Private Wealth Management Program Accounts can have tax-smart investing techniques applied across a group of designated Program Accounts associated with a single goal, referred to as household tax-smart strategies, including the use of asset location strategies to position assets within the type of account that could help enhance marginal federal after-tax returns. The specific tax-smart investing techniques used will depend on the service level selected by the client, the type and size of the account, and the asset allocation selected. Tax- smart investing can invest in mutual funds and/or ETPs, and, if elected by an eligible Wealth Management or Private Wealth Management client, individual securities in an SMA Sleeve. The SMA Sleeves can be invested using investment models provided by a Strategic Advisers’ affiliate or a third-party investment adviser (together, “Model Providers”). Please note that there is an additional fee of up to 0.40% (the “SMA Sleeve Fee”) for SMA Sleeves (or a portion thereof) where a Model Provider that is unaffiliated with Strategic Advisers (“Unaffiliated Model Provider”) is used (see “Fees for SMA Sleeves” below). There is no SMA Sleeve Fee for SMA Sleeves where the investment models are provided solely by an affiliated Model Provider. SMA Sleeves can be actively managed or index-based and focus on either domestic or foreign stocks, and the particular SMA Sleeves used vary according to the investment approach and universe selected by the client. Please note that BDIP Program 5  Accounts are not managed using tax-smart investing techniques and that SMA Sleeves and household tax-smart strategies are not currently available for Program Accounts using the Sustainable investment universes. Please see “About Tax-Smart Investing Techniques” and “About the SMA Sleeves” below for more information. Please note: We believe that appropriate asset allocation and diversification are of primary importance, and we apply tax-smart investing techniques as a secondary consideration in managing a Tax-Smart Program Account. Tax-smart investing techniques can involve trading that triggers taxable gains if the securities traded have appreciated in value since they were purchased. Accordingly, clients should understand that they can have significant tax consequences as a result of the management of a Tax-Smart Program Account. In addition, in a given year, a client can receive varying levels of taxable fund distributions within a Tax-Smart Program Account. Tax-Smart Program Accounts are actively managed for federal income taxes but are not managed in consideration of state or local taxes; foreign taxes; federal tax rules applicable to entities; or estate, gift, or generation-skipping transfer taxes. BlackRock Diversified Income Portfolio. Wealth Management and Private Wealth Management clients are eligible to hold tax-advantaged and taxable Program Account assets in a BDIP Program Account, for which BlackRock Investment Management LLC (“BlackRock”) serves as the Model Provider. As applicable to all Program Accounts, discretionary investment management is provided by Strategic Advisers, and BlackRock does not have any discretionary authority over any BDIP Program Account. BDIP Program Accounts are not managed according to an asset allocation, are not subject to the investment universes or approaches, and do not use the tax-smart investing techniques described above. BlackRock seeks to generate a higher yield and a lower risk profile for its model portfolio than that of a balanced portfolio that holds 50% equity investments and 50% investment-grade fixed income (including short-term assets), but BlackRock has wide flexibility in the relative investment weightings identified for each asset class and typically identifies an asset allocation that is 20%–80% equity and 80%–20% fixed income (including high-yield and short-term investments). In constructing the model portfolio for BDIP, BlackRock seeks to identify ETPs and mutual funds that can provide risk-adjusted income in response to prevailing market conditions, and will primarily identify mutual funds and ETPs offered by BlackRock or its affiliates. See “About BDIP Program Accounts” below for more information. Please note that new BDIP accounts are no longer available, and we expect to close all BDIP accounts by the end of 2026. Clients can work with their Fidelity representative to reposition those assets prior to account closure. More information will be provided to clients prior to the end of 2026. Personalizations and Investment Restrictions. A client can elect to personalize a Program Account by imposing reasonable restrictions on the management of the Program Account, or by modifying the asset allocation of the account (other than a BDIP Program Account) by increasing or decreasing the exposure to foreign stocks within certain limits. Reasonable restrictions can include limitations on the purchase of a particular fund, individual security, industry, or sub–asset class, subject to our initial and ongoing review and approval. Please note that Program Accounts managed using household tax-smart strategies must have personalizations and restrictions consistently applied within the same goal. It is important to understand that imposing an investment restriction can delay the start of discretionary management on a Program Account and can impact the performance of a Program Account, at times significantly, as compared with the performance of a Program Account managed without personalizations and/or restrictions, possibly producing lower overall results. Program Account personalizations and restrictions should be requested through a Fidelity representative. Access to a Fidelity Representative Each Program client has access to one or more Fidelity representatives who can work with the client to help evaluate the Program and how it can help meet the client’s financial goals and objectives, provide assistance with enrolling in the Program, deliver Program Services, and also provide general assistance with products and services provided by Fidelity outside of the Program. Clients enrolled in the Fidelity Advisory Services service level have access to assistance provided by a centralized team of phone-based Fidelity representatives. Clients enrolled in the Wealth Management service level have access to a dedicated Fidelity representative who is supported by a service team. Clients enrolled in the Private Wealth Management service level have access to a dedicated Fidelity representative, a dedicated service team, and an investment specialist along with a team of 6  advanced planners who specialize in multigenerational financial planning and engagement. It is important to understand that each Fidelity representative also acts in the capacity of a registered representative of Fidelity Brokerage Services LLC (“FBS”), Strategic Advisers’ affiliated broker-dealer. Any financial planning a client receives from a Fidelity representative prior to us accepting the client’s Program Client Agreement is provided by FBS and is not part of the Program Services. Access to Financial Planning Services At a client’s request, a Fidelity representative can provide nondiscretionary financial planning services to help evaluate the client’s ability to meet identified goals. We use various financial planning analytics and applications to provide financial planning services; the specific analysis provided to a client will be based on the assets allocated to a goal and the complexity of the client’s financial situation. Typically, financial planning begins by understanding needs and goals related to a Program Account as well as any “Other Assets” a client has identified (e.g., assets held in other Fidelity programs or accounts, or at a third party, that are aligned with the same goal as a Program Account). If requested, financial planning can also include goals unrelated to a Program Account. We then work with the client to obtain information regarding the client’s financial situation. Next, we will review a client’s information and prepare an analysis. Our financial planning services typically include asset allocation modeling, which helps clients evaluate their ability to meet an identified goal based on their current asset allocation and can also provide recommendations for changes to an asset allocation. In general, our asset allocation recommendations will include allocations to stock, bond, and short-term asset classes. Our financial planning services do not include initial or ongoing advice regarding specific securities or other investments, any financial analysis provided outside this Program (including prior to enrolling in the Program), or any financial planning that a client engages in on their own in a financial planning tool that is made available online. Depending on the client’s service level within the Program, the complexity of the financial situation, and/or assets held in a Fidelity program, we can also help a client evaluate other financial planning needs, such as retirement planning, education funding, insurance planning, employee benefits planning (e.g., equity compensation arrangements), and consideration of tax and estate planning strategies. Please note that financial planning services are available to Program Accounts owned by a natural person, but typically are not provided to an entity, such as a corporation, limited liability company, or trust. Clients enrolled in the Fidelity Advisory Services service level generally will not have access to certain advanced planning capabilities intended for clients with more complex financial planning needs, such as the consideration of the potential effect of certain employee benefits, tax, or estate planning strategies; instead, the financial planning services available to Fidelity Advisory Services clients are focused on retirement and retirement income planning needs. Other than with respect to Program Accounts, which are managed on a discretionary basis through the Program, whether and how to implement any asset allocation or other recommendations provided as a component of our financial planning services is the responsibility of each client and is separate and distinct from the Program Services. Specifically, Other Assets are not managed as part of the Program and are subject to separate and distinct terms, conditions, and, as applicable, fees. In addition, if a client chooses to implement some or all of the asset allocation or other recommendations provided as part of the Program’s financial planning services through Fidelity, a Fidelity entity will act as a broker-dealer or investment adviser depending on the products or services selected, and the client will be subject to separate, applicable charges, fees, or expenses. For more information, please see the “Guide to Brokerage and Investment Advisory Services at Fidelity Investments” available at Fidelity.com/information, or speak with a Fidelity representative. It is important to understand that there can be significant differences between the asset allocation modeling shown in a financial plan and the performance a client will actually experience. Asset allocation modeling is performed at the asset class level, assumes broad diversification within each asset class, relies on certain estimates about the performance of the securities markets, and is not designed to predict the future performance of any particular security or investment product. In addition, our assumptions and methodologies used in financial planning are adjusted from time to time, which can have an impact on the results obtained. 7  It is important to understand that the modeling provided in conjunction with our financial planning services is hypothetical in nature; is for illustrative purposes only; does not reflect actual investment, tax, or other planning results; and is not a guarantee of future investment outcomes. The modeling results shown will vary with each use and over time. Responsibility of Clients We rely on client information to provide the Program Services. It is the responsibility of clients to advise us of changes to their goals (including the alignment and allocation of an account with a goal), time horizon, tax situation, risk tolerance, expected account funding amounts, expected investment of Other Assets, and personal financial situation. Such changes can result in modification of an asset allocation or the tax-smart investing techniques used for a Program Account. For clients who have engaged us to plan for one or more Program Accounts and Other Assets associated with a single goal, our financial planning analysis and our management of Program Accounts associated with such a goal depends on a client’s agreement to make planned changes with respect to the management of any Other Assets associated with the goal and on a client completing all planned funding of Program Accounts. Clients should contact their Fidelity representative if there are delays in implementing any previously agreed-to changes with respect to Other Assets or the funding of Program Accounts, as this can impact the investment decisions that are made for Program Accounts. Clients with multiple relationships with Fidelity should understand that updating information about a Program Account does not update information about an account enrolled in another advisory service or one that is self-directed. Accordingly, clients should ensure that their personal, financial, and other important information is independently updated for each respective service or account. Fees and Compensation Advisory Fees—Gross and Net of Credit Amount. The Program charges an annual Gross Advisory Fee that includes the Program Services as well as the brokerage, clearing, and custody services provided by Strategic Advisers’ affiliates. The amount of the Gross Advisory Fee differs depending on the service level selected by the client and is payable after the end of each quarter. The following fees are in addition to the Gross Advisory Fee: (i) any fees associated with investment through an SMA Sleeve where an Unaffiliated Model Provider is used (see below); (ii) underlying mutual fund and ETP expenses charged at the individual fund level for any such investments in a Program Account; (iii) certain charges resulting from transactions executed with or through broker-dealers that are not affiliates of Strategic Advisers; (iv) markups and markdowns, transfer taxes, exchange fees, regulatory fees, odd-lot differentials, handling charges, electronic fund and wire transfer fees, or any other charges imposed by law or otherwise agreed to with regard to a Program Account; or (v) any additional expenses, including trading fees and management expenses, a client incurs with respect to any non-Program account. Strategic Advisers or an affiliate can voluntarily assume the cost of certain commissions for equity transactions executed with or through broker-dealers that are not affiliates of Strategic Advisers; clients will not be charged commissions for such transactions. Fund expenses, which vary by fund and class, are expenses that all mutual fund and ETP shareholders pay. Details of mutual fund or ETP expenses can be found in each mutual fund’s or ETP’s respective prospectus. These expenses are not separately itemized or billed; rather, the published returns of mutual funds and ETPs are shown net of their expenses. Some of these underlying mutual fund and ETP expenses are paid to Strategic Advisers or its affiliates and will be included in a Credit Amount as described below. Advisory Fees—Credit Amount. The Gross Advisory Fee applied to a Program Account is reduced by a Credit Amount. The Credit Amount is intended to address the conflicts of interest that arise in selecting investments that generate revenue for Fidelity by reducing the advisory fees paid to Strategic Advisers by the amount of compensation, if any, Strategic Advisers or its affiliates retain that is derived as a direct result of investments by Program Accounts, as detailed below. A Credit Amount is applied after the end of each quarter. To the extent applicable, a Credit Amount will be calculated for each mutual fund or ETP held by Program Accounts as follows: 8  • For Fidelity Funds and ETPs, the Credit Amount will equal the underlying investment management and any other fees or compensation Strategic Advisers or its affiliates retain from these funds and ETPs as a direct result of investments by Program Accounts. • For non-Fidelity funds and ETPs, the Credit Amount will equal the distribution fees, shareholder servicing fees, and any other fees or compensation Strategic Advisers or its affiliates retain from these funds and ETPs (or their affiliates) as a direct result of investments by Program Accounts. An aggregate Credit Amount is then allocated to each Program Account to arrive at the Net Advisory Fee. In addition, amounts held in the core position in a short-term position sleeve of a Tax-Smart Program Account (used in connection with periodic withdrawal requests) are considered for purposes of the breakpoints described below but are not managed on a discretionary basis and are not assessed a Gross Advisory Fee or subject to the Credit Amount calculation. It is important to understand that Strategic Advisers’ affiliates receive compensation for providing a variety of services to mutual funds and ETPs, as described below in “Client Referrals and Other Compensation.” Such compensation is included in the Credit Amount only to the extent that it is retained as a direct result of investment by Program Accounts. Compensation that is not directly derived from Program Account assets is not included in the Credit Amount. Credit Amounts for non-Fidelity funds and ETPs are calculated one month in arrears. As a result, when a Program Account is closed, certain Credit Amounts for non-Fidelity funds and ETPs will not be applied against the Gross Advisory Fee for any partial period during the month in which a Program Account is closed. In such circumstances, Credit Amounts not applied to a closed Program Account are allocated, pro rata based on assets, among the open Program Accounts in the Program at the time the Credit Amount is applied. In addition, certain de minimis revenue received by Strategic Advisers’ affiliates could be donated to charity (rather than included in the Credit Amount) or could be allocated, pro rata based on assets, among the open Program Accounts in the Program. This operational process results in credits that would otherwise be attributable to one Program Account being received by another Program Account. Net Advisory Fee = Gross Advisory Fee – Credit Amount Please see the table below for the Gross Advisory Fees charged to Program Accounts. Please note that all fees are subject to change and that Strategic Advisers has the ability to negotiate advisory fees for certain accounts. ANNUAL ADVISORY FEE SCHEDULE FOR PROGRAM ACCOUNTS Average Daily Assets* Gross Advisory Fee Fidelity Advisory Services All Average Daily Assets 1.10% Less Credit Amount Equals Net Advisory Fee Wealth Management and Private Wealth Management If Average Daily Assets total $500,000 or less, then: 1.50% (up to a maximum of $6,250) For Average Daily Assets from $0 to $500,000 If Average Daily Assets total more than $500,000, then: 1.25% For the first $500,000 in Average Daily Assets For the next $500,000 or portion thereof in Average Daily Assets 1.10% Less Credit Amount Equals Net Advisory Fee For the next $1,000,000 or portion thereof in Average Daily Assets 0.90% For the next $3,000,000 or portion thereof in Average Daily Assets 0.70% For Average Daily Assets in excess of $5,000,000 0.50% * Average Daily Assets of Program Accounts are determined on the last business day of the quarter. Subject to applicable limitations, clients can aggregate the assets of multiple Program Accounts to take advantage of the reduced Gross Advisory Fee breakpoints shown in the chart above. Upon account opening, we automatically aggregate certain account registrations that share the same tax reporting identification number (such as IRA, Roth IRA, SEP IRA, individual, joint, and certain trust account registrations). To aggregate other accounts not eligible for automatic aggregation, including those with immediate family members (the client’s legal spouse, or the client’s ancestor, descendant, or sibling (or their legal spouse)), or to request aggregation of accounts after account opening, clients must complete an Account Aggregation Form or contact a Fidelity representative. Clients are responsible for verifying that all eligible accounts have been aggregated appropriately. 9  Clients should be aware that the Gross Advisory Fee for Fidelity Advisory Services accounts will be higher than the Gross Advisory Fee for Wealth Management and Private Wealth Management accounts when Fidelity Advisory Services account balances exceed $1.375 million in Average Daily Assets individually or when aggregated with other eligible accounts. Fees for SMA Sleeves. No SMA Sleeve Fee is charged for an investment model provided with respect to an SMA Sleeve solely by an affiliated Model Provider. However, for the SMA Sleeves where an Unaffiliated Model Provider provides an investment model (Strategic Advisers Equity Growth SMA Sleeve, Strategic Advisers Equity Value SMA Sleeve, and Fidelity Strategic Advisers Blended International Equity SMA Sleeve), an additional fee of up to 0.35% (domestic stock SMA Sleeves) or 0.40% (foreign stock SMA Sleeves) is charged to cover the costs associated with obtaining and implementing the model(s). The SMA Sleeve Fee is based on the blended rate of the fees charged by the Unaffiliated Model Providers who provide investment recommendations. The SMA Sleeve Fee can change on a quarterly basis as a result of (i) changes in the number of Unaffiliated Model Providers used for these SMA Sleeves or (ii) changes in the asset levels assigned to a Model Provider for a given SMA Sleeve. The SMA Sleeve Fee will be equal to the blended rate for the relevant calendar quarter. While the fee level can vary among Model Providers, the total SMA Sleeve Fee will not exceed the amounts reflected above. The Credit Amount identified above is applicable to the SMA Sleeve Fee only to the extent that the SMA Sleeve holds mutual funds or ETPs for which Strategic Advisers or an affiliate retains compensation. Additional Fee for Complex Financial Planning. Where a client has a highly complex financial situation, in addition to the Net Advisory Fee and any applicable SMA Sleeve Fee (in the aggregate, the “Program Fee”), a fee can be assessed for financial planning services. This fee will be negotiated with the client. Standalone Financial Planning. The nondiscretionary financial planning services described above under “Access to Financial Planning Services” could be made available separately through the Program for qualifying clients who do not want to retain Strategic Advisers to provide discretionary investment management services (“Standalone Planning”). Standalone Planning is generally available to clients with a net worth or assets with Fidelity of $3,000,000 or more, as well as to employees of business entities that have retained Strategic Advisers to provide Standalone Planning to such employees. Clients will be required to enter into a written agreement with Strategic Advisers that identifies the Standalone Planning services to be provided, the time period over which such services will be provided, and the fees to be charged for those services. Unless we have agreed otherwise in writing, a Standalone Planning engagement will be complete upon the delivery of, and consultation with the client regarding, our Standalone Planning services. Unless we have agreed otherwise, we are not obligated to update any analysis provided or monitor a client’s progress toward an investment and/or other financial planning goal. Where we have agreed to provide Standalone Planning on an annual basis, we will contact the client to evaluate whether there have been any changes to the client’s personal financial situation that would make it appropriate to update or revise our Standalone Planning analysis. The fee for Standalone Planning will vary based on a number of factors that include but are not limited to the complexity of the client’s situation, the number of financial planning focus areas analyzed, the scope of our engagement, and the nature and amount of the client’s assets. Typically, the maximum annual fee that will be charged for Standalone Planning is $20,000. Trust Accounts Where Fidelity Personal Trust Company, FSB, Serves as Trustee or Co-Trustee. For Program Accounts where Fidelity Personal Trust Company, FSB (“FPTC”), serves as trustee or co-trustee, FPTC can provide additional services, including management of certain assets held by the trust but not included in the trust’s Program Account. All trust accounts where FPTC serves as trustee or co-trustee will be subject to a trust administration fee that is separate from, and in addition to, the Program Fee described above. Please see FPTC’s separate fee schedule for a complete listing of its fees. These accounts will not directly participate in the financial planning services described herein. Also, when FPTC is acting as the trustee or co-trustee for Program Accounts, references to “client” throughout this Program Brochure refer to FPTC acting as trustee or co-trustee of the applicable trust. 10  Billing. The Program Fee and, if applicable, any trust administration fees will be deducted, pro rata, from a client’s Program Account or another Fidelity account identified by the client for this purpose after the end of each quarter. Certain assets in a Program Account could be liquidated to pay the fees; this liquidation could generate a taxable gain or loss in a taxable Program Account. Additional Fee Information. All fees are subject to change. In rare circumstances, Strategic Advisers negotiates the Program Fee for certain accounts. Strategic Advisers could also agree to waive fees, in whole or in part, in its sole discretion, including but not limited to in connection with promotional efforts and other programs (including situations designed to facilitate transitions between advisory programs), or for certain current and former employees of Fidelity. This will result in certain clients paying less than the standard fee. Please note that any negotiated advisory fee, fee waiver, or fee discount will not be applied if a client moves to a different service level in the Program. If a waived or discounted fee results in a Credit Amount that is greater than the Gross Advisory Fee for a Program Account, the excess credits will not be allocated to the Program Account but will instead be allocated, pro rata based on assets, among the other Program Accounts in the Program at the time the Credit Amount is applied. Generally, except as described above, clients will not pay any commissions, transaction fees, or sales loads on the securities purchased in a Program Account. Clients are responsible for any fees resulting from the sale of securities used to fund their investment in a Program Account (whether such sale is inside or outside a Program Account) and any subsequent withdrawals that the client initiates. If a fund purchased for a client account incurs a redemption or other administrative fee as a result of not being held for a minimum time period, Fidelity can, in its sole discretion, choose to pay any such redemption fees on behalf of Program clients but is under no obligation to do so. The Program Fee does not cover costs associated with implementing any recommendations provided as part of our financial planning services, other than the discretionary services provided through the Program. The Program Fee does not include amounts charged with respect to a regulatory fee that applies to all sales of securities and which varies over time. This charge is estimated and assessed in advance; this process could lead to overestimating or underestimating the actual regulatory fee. To the extent that such estimated amount is greater than the actual regulatory fee, Fidelity will retain the excess. These charges will be reflected on statements and/or trade confirmations. Strategic Advisers’ affiliates sponsor promotional offers that provide clients with the ability to receive cash compensation or a reduced advisory fee for opening and funding or maintaining certain accounts. Accounts opened through the Program are, from time to time, included in the list of account types and investment solutions eligible for such promotional offers. The Program’s eligibility for such promotional offers creates a conflict of interest, as Strategic Advisers and its affiliates are incentivizing clients to use the Program rather than Strategic Advisers’ other managed account programs or self-directed investment options available through FBS. Strategic Advisers can also, from time to time, provide cash compensation to Program clients for taking qualifying actions with respect to their Program Account, such as certain interactions with Program features. Any compensation will be deposited into the client’s Program Account, will be subject to the Program Fee, and may have tax consequences. A promotional offer is not a recommendation to implement any asset allocation strategy or select a particular account type or investment solution. Also, during the time a client is enrolled in the Program, the client could be eligible to receive certain services offered by Strategic Advisers’ affiliates based, in whole or in part, on the amount invested with the Program. It is important to understand that such services are not part of the Program Services for which the Program Fee is paid. In addition, while enrolled in the Program, a client could receive information about how to access financial wellness and/or professional support resources and services that are offered by entities unaffiliated with Fidelity, some of which pay compensation to Fidelity as a result of the client’s use of such resources or services. Such resources and services are not included as part of the Program Services, and any applicable costs associated with enrolling in or subscribing to these resources or services would be in addition to the Program Fee. 11  Other Considerations. In evaluating the Program, please consider that Fidelity offers a variety of investment advisory services and brokerage offerings. These offerings are summarized below to assist clients in understanding and comparing the services and offerings. For more detailed information regarding an investment advisory service, please review the respective Form ADV, Part 2A brochure available at Fidelity.com/information or through a Fidelity representative. Refer to the “Guide to Brokerage and Investment Advisory Services at Fidelity Investments” (available at Fidelity.com /information) for more information regarding our roles and responsibilities when providing brokerage and advisory services. Please note that, other than the self-directed brokerage account offered by FBS, the advisory programs included in the chart below are each offered by Strategic Advisers. PRODUCT DESCRIPTION INVESTMENT GENERAL ELIGIBILITY FEE STRUCTURE Fidelity Go® No account minimum; $10 to invest Less than $25,000 invested: no advisory fee Portfolio based on a client’s investment profile and composed of a mix of zero expense ratio Fidelity mutual funds Asset-based advisory fee: 0.35% annually for $25,000 and above Invests in zero expense ratio Fidelity mutual funds that do not charge management fees (or with limited exceptions, fund expenses) Digitally provided discretionary investment management and planning; access to a team of phone-based representatives for one-on-one financial coaching for clients who maintain $25,000 or more in a Fidelity Go account and tax-loss harvesting for taxable accounts with $25,000 or more Fidelity Managed FidFolios® $5,000 minimum investment Asset-based advisory fee: 0.40% or 0.70% annually Digitally provided discretionary invest- ment man agement of a single asset class (including tax-smart investing techniques) A mix of individual securities, either stocks or American Depositary Receipts, depending on the client’s selected strategy Fidelity® Strategic Disciplines Asset-based advisory fee: 0.20%–0.70% annually for equity strategies and 0.35%– 0.40% annually for fixed income strategies, depending on the amount invested Discretionary investment management of a single asset class (including tax-smart investing techniques); planning and advice is provided through a dedicated representative A mix of individual securities, including but not limited to stocks, bonds, American Depositary Receipts, and/or exchange-traded products and mutual funds, depending on the client’s selected strategy Depending on strategy selected, account investment minimums of $100,000 (equity strategies) and $350,000 (bond strategies), each subject to qualification for support from a dedicated Fidelity representative, which is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) (effective in the second quarter of 2026, the account investment minimum will be $200,000 for taxable bond strategies and $250,000 for municipal bond strategies) 12  PRODUCT DESCRIPTION INVESTMENT GENERAL ELIGIBILITY FEE STRUCTURE Fidelity® Wealth Services $50,000 minimum investment Asset-based advisory fee: 1.10% annually, less a fee credit that reflects compensation retained by Fidelity as a direct result of a client’s investments Fidelity Advisory Services provides customized planning, advice, and discretionary investment management (including tax-smart investing techniques); planning and advice is provided by a centralized team of phone-based representatives A mix of Fidelity and non-Fidelity mutual funds and exchange-traded products invested using a dynamic asset allocation that can respond to changes in the economic business cycle; offered with multiple investment approaches and universes Wealth Management and Private Wealth Management provide customized planning, advice, and discretionary investment management (including tax-smart investing techniques); planning and advice is provided through a dedicated representative supported by a service team A mix of Fidelity and non-Fidelity mutual funds and exchange- traded products and, depending on a client’s preferences and investment profile, individual securities, invested using a dynamic asset allocation that can respond to changes in the economic business cycle; offered with multiple investment approaches and universes Asset-based advisory fee: 0.50%–1.50% annually, depending on the amount invested, less a fee credit that reflects compensation retained by Fidelity as a direct result of a client’s investments (additional fees of up to 0.40% for management of certain individual security strategies can also apply where advisory services are not provided solely by a Strategic Advisers affiliate) $50,000 minimum account investment for Wealth Management and $2 million minimum investment and $10 million investable assets for Private Wealth Management, each subject to qualification for support from a dedicated Fidelity representative, which is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) Fidelity Wealth Advisor Solutions® Investment vehicles will vary by unaffiliated investment advisor and strategy Investment minimums will vary by unaffiliated investment advisor and services provided Advisory fees will vary by unaffiliated investment advisor and services provided A referral network of unaffiliated investment advisors that provide customized wealth management and investment strategies Self-Directed Brokerage Account Transaction fees and investment expenses vary based on investment vehicle selected; no ongoing asset-based advisory fee charged by Strategic Advisers Self-directed trading through FBS, with access to Fidelity’s online tools, planning, and resources, and support provided by brokerage representatives. A dedicated representative is available based on relationship No minimum to open a brokerage account. Qualification for support from a dedicated Fidelity representative is based on a variety of factors (for example, a client with at least $500,000 invested in an eligible Fidelity account would typically qualify) Brokerage customers can choose from a wide variety of investments, including mutual funds, exchange-traded funds, stocks, bonds, and insurance and annuity products. Note that certain securities available through Strategic Advisers’ advisory services are not available in self- directed brokerage accounts As described in the chart above, FBS offers self-directed brokerage accounts and financial planning, and can provide dedicated support from a Fidelity representative depending on a client’s overall relationship with Fidelity. A client could, therefore, invest directly in the individual securities, ETPs, and certain mutual funds available through the Program through a Fidelity brokerage account or a brokerage account at another firm without incurring the Program Fee charged by the Program. In addition, the investment strategies available through the Program’s SMA Sleeves, while designed for the Program, could be similar to a mutual fund or other product available for direct investment by the client, and the operating expenses of such a mutual fund or other product will likely differ from that of the Program. Finally, a client could purchase planning services 13  separately from another firm, plan independently using the tools and analytics that are used to support the financial planning services provided through the Program that are also made available by FBS at Fidelity.com without a fee, or, if the client qualifies for dedicated support from a Fidelity representative, work with the Fidelity representative to receive planning services offered by FBS without a fee. However, while clients can obtain similar products and services from Fidelity or other firms without enrolling in the Program, the same combination of services would not be provided, certain investment products used by the Program are not available for purchase outside of the Program, investments could be subject to sales loads or transaction and redemption charges that are generally waived as part of the Program, and the overall cost of purchasing the products and services separately will most likely differ from the Program Fee. Factors that bear on the cost of the Program in relation to the cost of the same or similar products and services purchased separately include, among other things, the amount of brokerage trades executed through Fidelity-affiliated broker-dealers (the charges for which are included in the Program Fee) as compared with the brokerage trades executed through other broker-dealers (the charges for which are not included in the Program Fee), and the number and range of supplementary advisory and other services provided to the Program Account. Clients should consider the value of these advisory services when making such comparisons. Information about Fidelity and Fidelity Representative Compensation. Fidelity representatives who support the Program are associated with Strategic Advisers and FBS. Fidelity representatives act on behalf of FBS when recommending an advisory program offered by Strategic Advisers. Once a client enrolls in the Program, the Fidelity representative will be providing Program Services. Separate and apart from the Program, Fidelity representatives, including those who support the Program, can provide clients with a variety of FBS services, including investment education and advice, financial analyses, financial planning services, and help with implementing any nondiscretionary recommendations provided as part of the Program’s financial planning services. When providing services for FBS, these Fidelity representatives are acting solely as registered representatives of FBS, and the Program Fee is not related to those FBS services. Fidelity representatives receive base pay based on their experience and role. In addition to base pay, Fidelity representatives are also eligible to receive either variable compensation or an annual bonus, and certain representatives are also eligible to receive longer-term compensation. Fidelity representatives who receive an annual bonus do not receive compensation based directly on the sale of any product or service, but they do have an indirect financial incentive to recommend products or services that pay more compensation to Fidelity because annual bonus funding is based in part on Fidelity’s financial performance. For Fidelity representatives who receive variable compensation, variable compensation depends on the representative’s role and can be impacted by client loyalty, the amount of assets a client transfers to Fidelity, the amount of assets invested initially and on an ongoing basis, referring potential clients to other Fidelity representatives who enroll the client in a Fidelity investment product or service, and client family members opening Fidelity accounts. Whether and how much each Fidelity representative receives in each component is generally determined based on the representative’s role, responsibilities, performance measures, and their manager’s assessment of the representative’s performance. Fidelity and the Fidelity representatives who support the Program and who are eligible to receive variable compensation receive different amounts of compensation depending on the type of product or service a client selects. Fidelity and those representatives will earn more compensation if a client (i) enrolls in any service level of Fidelity Wealth Services than if a client enrolls in Fidelity Go or Fidelity Managed FidFolios, or (ii) enrolls in the Wealth Management or Private Wealth Management service level of Fidelity Wealth Services than if a client enrolls in the Fidelity Advisory Services service level of Fidelity Wealth Services. Please note that Fidelity representatives do not earn variable compensation with respect to Standalone Planning. The compensation received by Fidelity and those representatives in connection with FBS offerings (e.g., stocks, bonds, ETFs, mutual funds) is typically less than the compensation received in connection with a client choosing to participate in a Fidelity advisory program. Products and services that generally require more time to engage with a client and/or that are more complex provide greater compensation to a representative and Fidelity. This compensation structure creates a financial incentive for Fidelity and its representatives to recommend 14  investments in more complex or time-consuming products and services over others, and to recommend that a client maintain an investment in such products and services over time. Fidelity addresses these conflicts of interest by having processes in place that require our representatives to make recommendations that are in the best interest of clients, paying compensation based on the time and complexity of the relevant product or service, training and supervising our representatives, and disclosing these conflicts of interest to clients so that they can consider the conflicts when making financial decisions. To see specific compensation levels for the managed account programs mentioned above and other products, including an example of compensation that can be earned by Financial Consultants, please see the “Fidelity Investments Compensation Disclosure” document (available at Fidelity.com/information), or contact a Fidelity representative. Clients should read the information contained in the “Fidelity Investments Compensation Disclosure” document carefully, and can ask a representative at any time whether and how they are compensated with respect to a particular product or service and about the financial incentives and conflicts of interest that Fidelity has when making recommendations of products or services. A C C O U N T R E Q U I R E M E N T S A N D T Y P E S O F C L I E N T S The Program is generally available to individuals, trusts, and certain corporate entities. To participate in the Program, a client must be a U.S. person (including a U.S. resident alien), typically reside in the U.S., and have a valid U.S. taxpayer identification number. The Program is not available to non-U.S. trusts and foreign investors. Strategic Advisers can, in its sole discretion, decline to permit participation in the Program for any reason. The Program’s minimum investment starts at $50,000 per Program Account. Wealth Management clients must generally qualify for support from a dedicated Fidelity representative, which is based on a variety of factors, including Program Account investment levels, assets held at Fidelity outside of the Program, and the complexity of the client’s financial situation. Private Wealth Management clients are subject to a qualification and acceptance process and must typically invest at least $2 million, in the aggregate, in Program Accounts (or combined with assets invested in Fidelity® Strategic Disciplines) and have investable assets of at least $10 million. Access to SMA Sleeves is available only for eligible Wealth Management and Private Wealth Management Tax-Smart Program Accounts and is generally determined based on account balance. In general, new accounts for business entities, including irrevocable trusts, can only be opened in the Wealth Management service level. Strategic Advisers can, in its sole discretion, change or waive an identified Program minimum at any time. Program Accounts that fall below a required minimum can be removed from the Program. Once the client has agreed to the terms of the Program Client Agreement, the client will have 120 days to fund the Program Account with the applicable minimum investment. If the client has not reached the applicable Program minimum within 120 days, Fidelity can terminate the client’s participation in the Program. In general, clients in the Fidelity Advisory Services service level of the Program are not eligible to invest in the Fidelity Strategic Disciplines program. Clients typically can have Program Accounts in only one Program service level, and qualifying clients can move between service levels upon request. With respect to a client’s Retirement Program Account, the Program Fee is solely attributable to Program Services provided to that Program Account. In addition, certain limitations apply to the management of a Retirement Program Account holding defined benefit plan assets. Generally, only single-participant defined benefit plan assets will be managed (except in the case of a Retirement Program Account holding defined benefit plan assets where the plan benefits only the owner of the business sponsoring the plan and the owner’s spouse), and they will be treated as if they were in a defined contribution plan. Plan-specific provisions and any plan-related documents will not be considered in the discretionary management of these assets. To enroll in the Program, a client must agree to the Program Client Agreement, which details the terms and conditions under which the client appoints Strategic Advisers to provide the Program Services. Our advisory relationship with a client begins when we accept the client’s Program Client Agreement. Except with respect to a Program investment proposal, preliminary discussions or recommendations made before we accept a Program Client Agreement are not intended as investment advice or financial planning provided by Strategic 15  Advisers. The Program Client Agreement requires that clients delegate discretionary authority to Strategic Advisers to provide discretionary portfolio management for their Program Account, which includes the authority to determine which securities to purchase or sell, the total amount of such purchases and sales, and the brokers or dealers through which transactions are executed in Program Accounts, subject to certain Program and regulatory limitations and Strategic Advisers’ internal policies and procedures. Clients also acknowledge through the Program Client Agreement that Strategic Advisers may, but is not obligated to, retain one or more sub-advisors with respect to the management of Program Accounts. The Program Client Agreement also establishes a brokerage account with FBS, a registered broker-dealer, affiliate of Strategic Advisers, and a member of NYSE and SIPC. During a client’s participation in the Program, the client’s Program Account will not be available for the client’s self-directed brokerage activities. Another affiliate of Strategic Advisers, National Financial Services LLC (“NFS”), a registered broker-dealer and a member of NYSE and SIPC, has custody of client assets and will perform certain account services, including the implementation of discretionary management instructions, as well as custodial and related services. Certain personnel of Strategic Advisers, FBS, and NFS share premises and have common supervision. Opening and Funding a Program Account Clients can fund Program Accounts with cash and/or securities acceptable to us. These securities must be held free and clear of any liens, pledges, or other legal or contractual restrictions. Fidelity will determine, in its sole discretion, which securities will be eligible to fund a Program Account. A Fidelity representative can provide information as to whether a specific mutual fund, ETP, or other security is eligible to be managed in a Program Account. At times, Fidelity will not accept individual securities that are otherwise generally available to fund a Program Account due to internal guidelines or state or federal regulations. If a client elects to transfer ineligible securities into a Program Account, Fidelity will liquidate those securities as soon as reasonably practicable, and the transfer of such securities into a Program Account is deemed a directive by the client to Fidelity to sell any such securities upon transfer. Fidelity also reserves the right to transfer an ineligible security back to the account from which the client transferred the assets or to another like-registered account held at Fidelity. We do not consider the potential tax consequences of the sale of ineligible securities in any Program Account, and do not consider the potential tax consequences of the sale of eligible securities in BDIP Program Accounts. While we do consider the potential tax consequences of the sale of eligible securities in a Tax-Smart Program Account, we believe that appropriate asset allocation and diversification are of primary importance, and we apply tax-smart investing techniques as a secondary consideration in managing such accounts. Accordingly, clients who fund a Tax-Smart Program Account with appreciated securities should understand that we could sell such securities notwithstanding that the sale could trigger significant tax consequences. Sales of eligible and ineligible transferred securities will be subject to redemption and other applicable fees, including commissions on sales of securities; however, under certain circumstances, the Program can voluntarily assume the costs of certain commissions. In addition, where securities are purchased in a taxable Program Account, the client could receive taxable distributions out of earnings that have accrued before purchase (a situation referred to as buying a dividend). As described above, a Fidelity representative will work with a client to collect Profile Information and will also assist the client with the account opening process, which includes but is not limited to funding the Program Account with cash and/or eligible securities, the sale of the ineligible securities used to fund the Program Account, and our receipt of tax basis information described below for Tax-Smart Program Accounts. Once we receive all required information and the account opening process, including the sale of ineligible securities and the receipt of sufficient funding (which may be our per account minimum or a different amount included in the client’s account documentation), is complete, a Program Account will be reviewed for investment and will typically begin trading within seven business days. In general, the Program Fee will begin to accrue once a Program Account has been deemed in good order for management purposes. 16  Clients who have engaged us to plan for and invest multiple Program Accounts associated with a single goal should discuss Program Account investment timing with their Fidelity representative. Such clients should note that in some instances we will delay investment of those Program Accounts until account funding has been substantially completed; in other instances, we could begin investing those Program Accounts before the completion (or substantial completion) of all client-initiated funding transfers into the Program Accounts associated with the goal. In addition, such clients should be aware that if we are unable to manage one or more of the multiple Program Accounts associated with a single goal or plan, we may not be able to manage any of the other Program Accounts associated with the goal or plan. For initial funding or subsequent deposits to a Tax-Smart Program Account, Fidelity must be provided with tax basis information for all securities that will be managed. Discretionary portfolio management will not occur for a Tax-Smart Program Account until the completed tax basis information has been received. We will rely on the tax information provided by the client and will not verify the tax basis information provided; clients are able to update such tax basis information by contacting a Fidelity representative. If securities received by the client as a gift are deposited into a Program Account, we will use the tax basis information provided to us in connection with the gift. Wealth Management and Private Wealth Management clients can request to have concentrated funding positions in a Tax-Smart Program Account potentially sold off over time (over a maximum of three successive tax years), subject to acceptance by us and our ability to accelerate the sale of such concentrated positions if we believe it is more appropriate to do so based on asset allocation and diversification considerations. Such requests should be made through a Fidelity representative. For all Fidelity Advisory Services clients, and for Wealth Management and Private Wealth Management clients who do not elect to have funding positions sold off over time, concentrated funding positions will generally be sold within the first 90 days after funding. Additional deposits of cash or securities can be made to a Program Account at any time. Discretionary management of additional deposits will generally occur as soon as reasonably practicable but could be delayed for various reasons, including time needed to liquidate securities, special handling instructions, or because the additional deposit might not necessitate trading in all cases. In general, the Program Fee will begin to accrue with respect to additional deposits once those assets have been received into the Program Account and have been deemed in good order for management purposes. Wealth Management clients who are eligible and have elected to have one or more Program Accounts included in a goal-based plan are required to alter the terms pursuant to which they previously granted (or in the future will grant) someone else with authority over their Program Accounts. Such clients who wish to have their Program Accounts included in a goal-based plan with Program Accounts they do not jointly own are also required to grant us an authorization to accept certain instructions from any Program Account owner regarding the management of these Program Accounts. Please see the Program Client Agreement and Program documentation or contact a Fidelity representative for more information. Withdrawals, Account Closure, and Program Termination A client can request a withdrawal from a Program Account, elect to close one or more Program Accounts, or elect to close all Program Accounts and terminate Program enrollment, including with respect to the receipt of financial planning services. Generally, all closure and termination instructions must be processed through a Fidelity representative. Strategic Advisers reserves the right to terminate a client’s Program Services (or limit the client’s rights to access any or all account features, products, or services) for any reason, including (i) if any authorized person on a Program Account resides outside the U.S., (ii) if the balance of a client’s Program Account falls below the minimum investment level, or (iii) if the Program is deemed no longer appropriate for a client. Should either party terminate the investment advisory relationship, the Program Fee will be prorated from the beginning of any unbilled quarter to the termination date, which is defined as the date when we no longer manage the Program Account on a discretionary basis. 17  Clients will be required to provide instructions to be used in the event of withdrawals or Program Account closure. Clients have the option of electing that assets either be liquidated and the proceeds sent to the client by check or transferred to a bank account (or other account) or be transferred in kind to another account. Clients should understand that if they close their Program Account but do not provide further instructions, certain mutual funds that cannot be held outside of the Program will generally be liquidated, and the remaining assets will be held in the account (but not managed) until the client provides instructions. While the timing of trading and settlement can vary, liquidating trades for partial and full withdrawal requests will typically be placed within the next seven business days of the request. In-kind asset transfer instructions will typically be placed within seven business days of such a request. For partial withdrawal requests, Fidelity will generally reinvest the cash proceeds of any sales into the client’s discretionarily managed Program Account after 30 days if transfer instructions are not provided. Note that liquidation of assets in taxable accounts could have adverse tax consequences. It is important to understand that Program Accounts can hold certain mutual funds that clients would not be able to purchase directly or that are able to be held only as part of an advisory program. In general, if an investor ceases to be a Program client or requests a transfer of such funds, shares of those funds will be redeemed, subject to the terms and conditions specified in the applicable fund’s prospectus. There can be instances where we need to place a “do-not-trade” restriction on one or more Program Accounts, including when a client requests a security be transferred from a Program Account, when processing a trade correction, when we need to comply with a court order, when a client asks us to process a withdrawal and keep the proceeds from the sale of securities used to fund the withdrawal in the account until the client provides further instructions for the transfer of the proceeds, when a client closes (including through withdrawal) an account that is invested along with other Program Accounts associated with a single goal, or when we need additional Profile Information from a client. For the period when a do-not-trade restriction is in effect, we generally will not trade or otherwise manage the Program Account until the do-not-trade restriction is removed. Clients continue to have access to financial planning services and their Fidelity representative(s) during the time when a do-not-trade restriction is in place. With respect to taxable Program Accounts, a client can elect to have all dividends, interest, and capital gains on eligible holdings set aside for automatic distribution by completing and submitting an Earnings Automatic Withdrawal Plan form on Fidelity.com or by speaking with a Fidelity representative. Please note that upon a client providing these instructions to Fidelity, the amounts awaiting distribution will not be subject to Fidelity’s discretionary authority. Where Strategic Advisers elects to close a Program Account that has fallen below a required minimum, all securities held in the Program Account can be sold and the proceeds will be made available to the client. The sale of securities can result in capital gains for taxable Program Accounts. Clients can avoid the liquidating sale of all securities held in the Program Account by electing to close their Program Account when notified by Strategic Advisers (though certain funds that clients are not able to hold outside of the Program will be sold upon account closure) or by adding funds to the account such that it meets the minimum required balance. P O R T F O L I O M A N A G E R S E L E C T I O N A N D   E V A L U A T I O N Strategic Advisers offers the Program and provides discretionary investment management services to Program Accounts directly and, therefore, does not evaluate or select other portfolio managers to provide services directly to Program Accounts. Strategic Advisers does, however, evaluate and select Model Providers to provide investment models for the BDIP Program Accounts and SMA Sleeves. Prior to selecting a Model Provider for the Program, Strategic Advisers performs a comprehensive review of the Model Provider and its investment style and approach. Strategic Advisers’ review generally includes, among other things, assessing information about the Model Provider and its investment strategy collected from third-party sources and information received directly from the Model Provider. In selecting a Model Provider, Strategic Advisers will consider a 18  variety of factors, including but not limited to investment approach, portfolio characteristics, and total assets of the Model Provider. Strategic Advisers will evaluate information from both quantitative and qualitative analyses, including but not limited to the Model Provider’s investment strategy and ability to adhere to the investment guidelines, credit research capabilities, security coverage, experience, growth of assets under management, stability of management, governance program, and trading and operational capabilities. Strategic Advisers evaluates a Model Provider’s adherence to the investment strategy not less than semiannually based on the factors described above. A model portfolio provided by a Model Provider for an SMA Sleeve or a BDIP Program Account could reflect trading decisions previously made by the Model Provider for its discretionary client accounts. As a result, such Program Accounts could receive prices that are more favorable or less favorable than the prices obtained by the Model Provider’s discretionary client accounts, particularly with respect to thinly traded securities. In addition, aggregate holding limits and other investment limits applicable to such prior trading decisions, and collectively to the discretionary accounts of Strategic Advisers and its affiliates generally, could result in investment opportunities not being included in a model portfolio. Performance-Based Fees and Side-By-Side Management Strategic Advisers does not currently charge performance-based management fees for any of its advisory services and, therefore, does not engage in side-by-side management. Methods of Analysis, Investment Strategies and Risk of Loss Mutual funds and ETPs used in the Program are managed by Fidelity and/or non-Fidelity advisers and could include mutual funds managed by Strategic Advisers or an affiliate that have been developed specifically for use in programs offered or managed by Strategic Advisers or an affiliate (the “Fidelity Program Dedicated Funds”) and/or other funds that are not available for investment directly to retail investors (together with Fidelity Program Dedicated Funds, “Program Only Funds”). The Fidelity Program Dedicated Funds can invest in individual equity and fixed income securities, mutual funds, ETPs, and derivatives, and engage the use of Fidelity and non-Fidelity sub-advisors (“Fund Sub-advisors”). The selection and allocation of assets to Fidelity Funds or to third-party funds that pay fees to Strategic Advisers’ affiliates creates conflicts of interest for Strategic Advisers. For funds managed by a Fidelity affiliate, these affiliates receive fees for services, including management and administration of the fund. For any third-party fund, Strategic Advisers’ affiliates receive fees in connection with the fund’s FundsNetwork participation. Strategic Advisers seeks to address these conflicts through the application of the Credit Amount, described in “Fees and Compensation” above, and through personnel compensation arrangements that are not differentiated based on the investments selected for Program Accounts. Strategic Advisers also establishes internal limits, and can be subject to external limits, on how much it will invest client accounts in a particular security. Strategic Advisers generally uses both fundamental and quantitative investment strategies to manage Program Accounts. Strategic Advisers uses sophisticated research tools to gauge when certain primary and extended asset classes should be used. This involves both evaluating characteristics, such as sector weightings, duration, valuation, and market capitalization, as well as focusing on key economic indicators and trends. When determining how to allocate assets among underlying mutual funds and ETPs, Strategic Advisers considers a variety of objective and subjective factors, including but not limited to proprietary fundamental and quantitative fund research, a manager’s experience and investment style, fund company infrastructure, fund availability, current public information about a fund, such as expense ratio, performance history, asset size, and portfolio turnover, and overall fit within Program Accounts. Strategic Advisers’ investment professionals will obtain and use information from various sources to assist in making allocation decisions among asset classes, as well as decisions regarding the purchase and sale of specific mutual funds, ETPs, and individual securities. Sources of information used include publicly available information and performance data on mutual funds and ETPs, individual securities, equity markets, fixed income markets, foreign markets, and broad-based economic indicators. Strategic Advisers will use both primary sources (e.g., talking directly with fund companies and managers) and secondary sources (reports prepared by fund 19  companies and other sources that provide data on specific fund investment strategies, portfolio management teams, fund positioning, portfolio risk characteristics, performance attribution, and historical fund returns) as inputs into its investment process. In general, Strategic Advisers will evaluate the mutual funds available on the FundsNetwork platform and make fund investment determinations based on investment methodology. Strategic Advisers will review the share classes offered by identified funds and seek to choose the share class of a fund that is appropriate for clients after the application of the Credit Amount. Strategic Advisers generally chooses share classes of the funds it invests in on a Program-wide basis, and generally does not vary its share class selections among Program Accounts or modify its share class selections for clients who receive fee waivers (primarily Fidelity employees) or discounts. On an annual basis, Strategic Advisers will assess whether the mutual funds held in Program Accounts offer less expensive share classes (after the application of the Credit Amount) and, if so, will make appropriate conversions thereafter. Clients should understand that a Program Account can hold a more expensive share class of a fund for an extended amount of time until the share class review and conversion process is complete. Investors who hold a more expensive share class will pay higher fees over time—and earn lower investment returns—than investors who hold a less expensive share class of the same fund. About the Investment Approaches and Universes The Program offers the following two investment approaches and six investment universes for the management of Program Accounts, other than BDIP Program Accounts, to accommodate investor preferences. Clients select either the Total Return or the Defensive investment approach. The Total Return investment approach seeks to enhance total return for a given level of risk through broad diversification across asset classes. The Defensive investment approach seeks to temper downside risk in an effort to provide a smoother investment experience over the long term (as compared with a Total Return approach) by implementing “defensive” strategies. Defensive Program Accounts will have increased exposures to defensive investments that, in the judgment of Strategic Advisers, could cause the account to have lower sensitivity to broader market price movements. These defensive investments include conservative equity (those with stable earnings growth, low financial leverage, and a high return on equity; or those that are expected to have lower volatility and to rise and fall in price less than the market generally), which can be combined with increased exposure to longer-term high- quality bonds to help reduce variability in returns and reduce some of the equity and credit risk associated with the other investments used in Defensive Program Accounts. As part of its evaluation of the business cycle, Strategic Advisers can manage Defensive Program Accounts to have lower equity exposure than the identified long-term asset allocation, with the amount of variation expected to be greater in Defensive Program Accounts with higher long-term allocations to equity. There is no guarantee that the defensive strategies used in managing Defensive Program Accounts will produce the desired results, and clients should be aware that this approach is generally expected to limit a client’s gains during rising market environments. Please note that only the Blended investment universe is available for Defensive Program Accounts. Blended, Sustainable Blended, Fidelity-Focused, and Sustainable Fidelity-Focused Program Accounts seek to enhance risk-adjusted returns through broad diversification across asset classes. Blended and Sustainable Blended Program Accounts use both Fidelity and non-Fidelity investments. Fidelity-Focused and Sustainable Fidelity-Focused Program Accounts primarily use investments from Fidelity. Blended, Sustainable Blended, Fidelity-Focused, and Sustainable Fidelity-Focused Program Accounts will generally invest in actively managed investments, but can also invest in index-based investments based on market conditions, risk management, and trading considerations, and the availability of actively managed and index-based investments used to gain exposure to a particular asset or sub–asset class, in each case in the judgment of Strategic Advisers. Index-Focused and Sustainable Index-Focused Program Accounts also seek to enhance risk-adjusted returns through broad diversification across asset classes, but will have a preference for index-based investments. Index-Focused and Sustainable Index-Focused Program Accounts use both Fidelity and non-Fidelity investments. Index-Focused and Sustainable Index-Focused Program Accounts can also invest in non-index- 20  based investments when deemed appropriate by the investment team, based on market conditions and the availability of actively managed and index-based investments used to gain exposure to a particular asset or sub–asset class, in each case in the judgment of Strategic Advisers. In general, for Index-Focused and Sustainable Index-Focused Program Accounts, the investment management team can use actively managed investments to gain exposure to certain fixed income asset classes, including municipal and high-yield bonds, though this could change in the future depending on the availability and appropriateness of index-based investments with exposure to certain asset or sub–asset classes. Accordingly, Index-Focused and Sustainable Index-Focused Program Accounts that are taxable or that have a more conservative asset allocation can hold a higher percentage of actively managed investments than other accounts with the same asset allocation or investment universe. Strategic Advisers expects that Retirement Program Accounts will more quickly achieve desired allocations to investments identified as part of the investment universe than comparable Tax-Smart Program Accounts, due to the consideration of the tax impact of selling securities that have appreciated since purchase. For the Sustainable Blended, Sustainable Fidelity-Focused, and Sustainable Index-Focused investment universes (together, the “Sustainable Universes”), Strategic Advisers applies its fundamental research processes to identify mutual funds and ETPs that, in its judgment, have meaningfully integrated sustainability practices into the mutual fund’s or ETP’s investment research and decision-making processes (such mutual funds and ETPs are referred to herein as “Sustainable Funds”). The Sustainable Universes will have a preference for Sustainable Funds, but will also invest in non-Sustainable Funds when deemed appropriate by the investment team, based on market conditions and the availability of Sustainable Funds used to gain exposure to a particular asset or sub–asset class. Except as provided below with respect to mutual funds or ETPs that invest primarily in debt securities issued by governmental entities, Strategic Advisers generally reviews a mutual fund’s or ETP’s manager as part of its fundamental research process to identify Sustainable Funds in an effort to determine (i) the extent to which the manager has integrated environmental, social, and governance (“ESG”) criteria into its investment processes; (ii) the extent to which the manager engages with issuers of securities in which it invests regarding ESG criteria; and (iii) the extent to which the mutual fund’s or ETP’s investment holdings appear to be consistent with an investment approach based on ESG criteria. In assessing a potential Sustainable Fund as part of its fundamental research process, Strategic Advisers can review a number of factors that can include but are not limited to the extent to which the fund’s manager has demonstrated capabilities and management- level commitment to sustainable investing, evidence of support and consistency of approach across the fund’s investment team, the level of resources of the fund’s manager has dedicated to sustainable investing, the fund manager’s proxy voting record with respect to ESG issues, the fund’s underlying investments in securities based on ESG factors, and the fund’s demonstrated differences relative to a benchmark that does not consider ESG factors. With respect to mutual funds or ETPs that invest primarily in debt securities issued by governmental entities, Strategic Advisers generally relies on third-party ratings (including by its affiliates) of the governmental issuer to determine whether the fund is a Sustainable Fund. Strategic Advisers generally looks for mutual fund and ETP managers who assess security issuers based on multiple ESG factors. With respect to environmental factors, Strategic Advisers generally looks for managers who assess issuers based on factors that include but are not limited to the issuer’s carbon and toxic emissions, water management, waste management, vulnerability to the physical impacts of climate change, and research and investment into products, services, and energies that reduce emissions and/or provide opportunities to achieve a low carbon transition. With respect to social factors, Strategic Advisers generally looks for managers who assess issuers based on factors that include but are not limited to the issuer’s approach to diversity and inclusion, human capital management, data privacy, product safety, and human rights. With respect to governance factors, Strategic Advisers generally looks for managers who assess issuers based on factors that include but are not limited to the independence and diversity of the issuer’s board, the issuer’s compensation practices, and the issuer’s board’s oversight of critical ESG issues. The evaluation of index-based mutual funds and ETPs generally centers on the index that the fund’s manager has selected to track and the manager’s ability to adhere to the index. Some factors, such as engagement practices, can be less relevant for index-based funds or those with quantitative investment processes. 21  In addition, for the Sustainable Index-Focused universe, Strategic Advisers will prioritize index-based investments offered by BlackRock or its affiliates over other index-based investments. It is possible that non- BlackRock index-based funds will outperform mutual funds and ETPs offered by BlackRock or its affiliates (“BlackRock funds”). As described in “Client Referrals and Other Compensation” below, affiliates of Strategic Advisers and BlackRock have a marketing relationship. While this marketing relationship does not apply to the services offered by Strategic Advisers, and employees responsible for selecting investments for Program Accounts are not compensated based on the investments selected for Program Accounts, clients should be aware of this conflict of interest. Strategic Advisers’ determination as to whether a mutual fund or ETP will be considered a Sustainable Fund is based on a subjective, qualitative assessment made based on the judgment of the Strategic Advisers investment team; none of the categories of review performed as part of an assessment is dispositive, and the weighting Strategic Advisers gives to ESG criteria can differ. Strategic Advisers generally expects that the ESG criteria it evaluates in determining whether a mutual fund or ETP is a Sustainable Fund can differ depending on the availability of data regarding underlying ESG criteria, or the mutual fund’s or ETP’s exposure to specific asset classes, sub–asset classes, sectors, industries, or investment styles. Strategic Advisers’ review of these fund managers can be based on its own proprietary research as well as data provided by third parties, and the ESG criteria it considers as well as Strategic Advisers’ assessment of a Sustainable Fund can change over time. Please note that Strategic Advisers can, based on its subjective, qualitative assessment, determine that a mutual fund or ETP is a Sustainable Fund even if the mutual fund or ETP is not categorized as such by the mutual fund’s or ETP’s manager. Clients should be aware that Strategic Advisers’ assessment of a mutual fund or ETP does not capture all possible ESG criteria, and there is no common industry standard relating to the development and application of ESG criteria. The subjective value that an investor assigns to certain types of ESG criteria can differ substantially from that of Strategic Advisers, and reasonable investors can differ in their views of what constitutes positive or negative ESG characteristics. As a result, clients should not assume that a Sustainable Universe account will necessarily invest in mutual funds or ETPs that reflect their own ESG beliefs and values. The application of Strategic Advisers’ ESG criteria will cause an account invested using a Sustainable Universe to forgo certain investment opportunities, which will cause such an account to perform differently, perhaps significantly, compared with an account that does not exclude mutual funds and ETPs based on such criteria. As described below in “Voting Client Securities,” clients can direct Strategic Advisers to act as agent to vote proxies with respect to the investments held in a Program Account pursuant to instructions provided in advance by the client. Please note that the Sustainable Universe Program Accounts do not evaluate or consider proxy voting of securities held in a Program Account in attempting to reach their objectives. Accordingly, it is possible that proxy votes will be inconsistent with, or contrary to, the sustainable goal of a Sustainable Universe Program Account. About Tax-Smart Investing Techniques Strategic Advisers believes appropriate asset allocation and diversification are of primary importance to the portfolio management of all Program Accounts. The application of tax-smart investing techniques to provide portfolio management services to clients in a more tax-sensitive manner is a secondary consideration in managing Tax-Smart Program Accounts. Strategic Advisers cannot guarantee the effectiveness of its tax-smart investing techniques in serving to reduce or minimize a client’s overall tax liability or the tax results of a given transaction, and Strategic Advisers does not take direction from a client on when to take gains or losses from the client’s Tax-Smart Program Account. If, based on information the client provides, Strategic Advisers determines that the client’s Tax-Smart Program Account requires modification to its asset allocation, it will generally make such changes as soon as reasonably possible, even if such changes would trigger significant tax consequences. The potential federal income tax consequences of holding, buying, and selling securities are considered as part of the investment services provided to Tax-Smart Program Accounts, but we do not consider state or local taxes; foreign taxes, including 22  those applied to dividends and any potential reclaim; federal tax rules applicable to entities; or estate, gift, or generation-skipping transfer taxes. The tax-smart investing techniques Strategic Advisers uses when it makes trading decisions to buy, hold, or sell mutual funds, ETPs, or other types of securities for a client’s Tax-Smart Program Account will vary depending on the service level selected by the client, the type and size of the Program Account, and the investment strategy selected. The tax-smart investing techniques referenced throughout this Program Brochure refer to one or more of the following: Ability to harvest tax losses. Individual mutual fund, ETP, stock, or bond positions can experience price declines, possibly below a client’s adjusted tax basis in the security (as determined by the tax basis information on record for the client’s Tax-Smart Program Account). In such instances, losses can be realized in the client’s Tax-Smart Program Account for tax purposes. In cases where a position is sold to realize a capital loss for tax purposes, the position usually will be replaced with one or a combination of investments we believe will maintain comparable market exposure. In harvesting tax losses, Strategic Advisers does not attempt to harvest every potential tax loss that occurs in the client’s Tax-Smart Program Account and will consider factors such as investment risk, available comparable investment alternatives, and potential wash sales in the account(s) that Strategic Advisers monitors for wash sales when deciding whether to harvest tax losses. For the Sustainable Universes, the general priority is to attempt to preserve exposure to Sustainable Funds while harvesting tax losses. However, the Sustainable Universes have fewer available comparable investment alternatives than the other investment universes, which can result in Strategic Advisers selecting investment alternatives that do not conform to the other aspects of the investment universe selected by the client (such as a focus on Fidelity Funds or index-based investments) in order to maintain exposure to Sustainable Funds. Strategic Advisers considers the potential application of the wash-sale rules when evaluating transactions in Tax-Smart Program Accounts. However, clients should understand that Strategic Advisers does not prevent or avoid wash sales in all cases. The wash-sale rule requires taxpayers to defer losses that would otherwise be realized if the taxpayer acquires a substantially identical investment 30 days before or after the sale. While Strategic Advisers considers whether its trading in Tax-Smart Program Accounts may trigger the wash-sale rules, we will nevertheless engage in transactions that are potentially subject to the wash-sale rules if we determine that such transactions are consistent with the Program Account’s asset allocation. Strategic Advisers will monitor for wash sales within Tax-Smart Program Accounts. However, the wash-sale rule not only applies to investment transactions occurring in a Tax-Smart Program Account, but also to transactions occurring in other investment accounts, whether maintained at Fidelity or at another financial institution, which are held by the client, the client’s spouse, and certain entities controlled by the client and/or a spouse. As a result, clients can have wash sales arising from transactions within Tax-Smart Program Accounts as well as other accounts (whether maintained at Fidelity or another institution). The wash-sale rule is complex, and while Strategic Advisers seeks to monitor wash sales in Tax-Smart Program Accounts, clients are ultimately responsible for determining whether the wash-sale rules apply to any particular transaction in their Program Accounts or in their other investment accounts. Clients should consult their tax advisors with respect to the application of the wash-sale rules based on their individual facts and circumstances. A client can work with a Fidelity representative to identify their other accounts enrolled in the managed account programs offered by Strategic Advisers (whether the account is owned by the client or the client’s spouse) to review which accounts could be eligible related accounts for wash-sale monitoring. Clients should contact a Fidelity representative with any questions regarding how to provide relevant tax information for their Program Accounts. Eligible Wealth Management and Private Wealth Management Program Accounts included in a goal-based plan can have wash-sale monitoring applied to trading activity occurring across the Program Accounts, including SMA Sleeves, associated with a goal (see “Household tax-smart strategies” below). Opportunities to avoid and/or postpone capital gain realizations. If there are specific lots of securities (a block of shares bought at a particular time at a particular price) in a client’s Tax-Smart Program Account, they are reviewed and the potential federal income tax burden associated with selling a specific lot is weighed against 23  the potential investment merits of the sale, such as performance potential, added diversification, and support of risk-management strategies. Once Strategic Advisers decides to sell an eligible security, it will attempt to sell the lots that will generate the lowest overall federal income tax burden (or generate a loss for tax purposes) using the tax basis and holding period information on record, with a preference for long-term capital gains over short-term capital gains. Seeking to manage exposure to fund distributions. After taking other factors into consideration, Strategic Advisers seeks to manage exposure to taxable fund distributions by considering historical and projected dividend and capital gain distributions when selecting and trading funds for the Program Account. It is important to understand that in a given year, due to investment decisions or market conditions, a client could receive varying levels of taxable fund distributions within a Tax-Smart Program Account. In general, Strategic Advisers will not sell a fund merely to avoid a taxable fund distribution, but rather looks at the overall portfolio to determine the most appropriate action. Purchasing municipal bond funds based on factors including tax bracket and estimated tax-equivalent yields. When appropriate, Program Accounts will be invested in state-specific municipal bond funds (as alternatives to comparable taxable bond funds) to seek to generate income generally exempt from federal income taxes (and state income taxes, if the client is a resident of the issuer’s state or another exemption applies). When consistent with overall portfolio objectives, Program Accounts will also invest in non-state-specific (i.e., national) municipal bond funds to seek to generate income generally exempt from federal income taxes. Household tax-smart strategies. For eligible Wealth Management and Private Wealth Management clients with both Tax-Smart and Retirement Program Accounts, Strategic Advisers can apply tax-smart strategies across a group of designated Program Accounts associated with a single goal. These strategies include the use of asset location strategies that seek to strategically position assets within the type of account (taxable, tax-deferred, or tax-exempt) that could help enhance marginal after-tax returns. Generally, this means locating more tax- efficient investments in a Tax-Smart Program Account and less tax-efficient investments in a Retirement Program Account. Health savings accounts are treated as tax-exempt for asset location purposes. In addition, having at least one Tax-Smart and one Retirement Program Account associated with a goal also allows Strategic Advisers to coordinate decisions around transitioning securities used to fund a Program Account, rebalancing, and satisfying client-initiated withdrawal needs, in an effort to enhance the tax-smart strategies applied in managing the Program Accounts. Funding with a concentrated position. If a client funds a Tax-Smart Program Account with eligible equity securities that Strategic Advisers considers to be a concentrated position, Strategic Advisers will generally sell down such positions within the first 90 days after funding in an effort to appropriately diversify the Program Account, and, accordingly, a client will incur tax gains or losses as a result of such sales. A Wealth Management or Private Wealth Management client can elect to have Strategic Advisers seek to spread the capital gain over a longer period of time by selling the concentrated positions on a more gradual schedule, subject to Strategic Advisers’ determinations regarding appropriate asset allocation and diversification. Such requests should be made through a Fidelity representative. Clients who elect the gradual sell-down schedule should understand that Strategic Advisers could sell a significant portion of a concentrated position within a short period of time after account funding consistent with Strategic Advisers’ prioritization of asset allocation and diversification considerations over the amount of taxable gain associated with selling the concentrated position. Thereafter, Strategic Advisers will sell any remaining concentrated positions opportunistically over a maximum of three successive tax years to defer the realization of taxable gains associated with the client’s concentrated positions. Please note that Strategic Advisers uses its discretion in determining how much of a concentrated position will be sold in each of the three successive tax years, and clients should not expect that any associated tax gains will be spread out equally over the three tax year period. As noted above, tax considerations are secondary to asset allocation and diversification considerations, and clients who elect to have concentrated positions sold off over time should understand that Strategic Advisers will accelerate the sale of such concentrated positions if Strategic Advisers believes it is more appropriate to do so based on asset allocation and diversification considerations. 24  Target capital gain amount. Clients in the Private Wealth Management service level can provide Strategic Advisers with a target capital gain amount for the year and Strategic Advisers will take this into consideration in managing these clients’ Tax-Smart Program Accounts; however, there is no guarantee that Strategic Advisers will achieve this target. About the SMA Sleeves If a Wealth Management or Private Wealth Management client’s Tax-Smart Program Account qualifies, a portion of the account can be invested in the SMA Sleeves offered by Strategic Advisers. These SMA Sleeves provide an additional layer of tax-smart investing techniques within a Tax-Smart Program Account. Strategic Advisers uses its discretion in allocating a client’s assets between mutual funds/ETPs and the SMA Sleeves, and within and among the SMA Sleeves. Strategic Advisers reserves the right to remove, consolidate, or make additional SMA Sleeves available from time to time. Once a client has agreed to the use of SMA Sleeves within one of the primary asset classes, we will have the discretion to use any such additional SMA Sleeve from that primary asset class within a client’s Tax-Smart Program Account, provided that Strategic Advisers will provide advance notice regarding the use of an SMA Sleeve for which there is an additional SMA Sleeve fee. A client can impose a restriction on the use of SMA Sleeves entirely, or on the use of certain SMA Sleeves, by contacting a Fidelity representative. Domestic Stock SMA Sleeves The Strategic Advisers Tax-Managed U.S. Large Cap SMA Sleeve invests in stocks and seeks to approximate the pretax risk and return characteristics of the Fidelity U.S. Large Cap IndexSM while actively trading holdings in an attempt to enhance after-tax returns through the use of tax-smart investing techniques. The Fidelity U.S. Large Cap Index is a float-adjusted market capitalization–weighted index designed to reflect the performance of the stocks of the largest 500 U.S. companies based on float-adjusted market capitalization. While this SMA Sleeve looks to approximate the pretax risk and return characteristics of the Fidelity U.S. Large Cap Index, it will purchase only a subset of the stocks that make up the index. The Strategic Advisers Equity Growth SMA Sleeve and the Strategic Advisers Equity Value SMA Sleeve are each actively managed to seek additional opportunities for return and tax-smart investing, as compared with the Russell 1000® Growth Index and Russell 1000® Value Index, respectively. The Russell 1000 Growth Index is an unmanaged market capitalization–weighted index of those stocks of the 1,000 largest U.S.-domiciled companies that exhibit growth-oriented characteristics. The Russell 1000 Value Index is an unmanaged market capitalization–weighted index of those stocks of the 1,000 largest U.S.-domiciled companies that exhibit value-oriented characteristics. These SMA Sleeves will invest in stocks that are designed to complement the Strategic Advisers Tax-Managed U.S. Large Cap SMA Sleeve, which provides core market exposure. Each of these SMA Sleeves will hold a subset of the stocks that make up their respective indexes, but can also invest in stocks not included in their respective benchmark indexes, in each case selected by Strategic Advisers based on the portfolio recommendations of multiple Model Providers. The Model Providers are selected by Strategic Advisers to have complementary investment styles and can be affiliated or unaffiliated with Strategic Advisers. Strategic Advisers then blends those stock portfolio recommendations for each of these SMA Sleeves. These SMA Sleeves can also invest in American Depositary Receipts (“ADRs”), real estate investment trusts (“REITs”), and ETPs. The Fidelity Strategic Advisers U.S. Large Cap Equity SMA Sleeve invests in stocks and seeks capital appreciation and to outperform the S&P 500® Index over a full market cycle. This SMA Sleeve primarily invests in U.S. large-cap stocks but can also invest in securities not included in its index, including non-U.S. large-cap stocks, ADRs, REITs, and ETPs, in each case selected by Strategic Advisers based on the portfolio recommendations of the affiliated Model Provider. The S&P 500 Index is a market capitalization–weighted index of 500 common stocks chosen for market size, liquidity, and industry group representation to represent U.S. equity performance. This SMA Sleeve will have a blend of equity exposures (e.g., growth, value, and core domestic equity), based on Strategic Advisers’ view of market cycle implications and overall positioning. 25  International Stock SMA Sleeves The Fidelity Strategic Advisers Blended International Equity SMA Sleeve and the Fidelity Strategic Advisers International Equity SMA Sleeve each seek the potential for capital appreciation and to outperform the MSCI® EAFE® Index (Net MA Tax) over a full market cycle. The MSCI EAFE Index (Net MA Tax) is an unmanaged market capitalization–weighted index that is designed to measure the investable equity market performance for global investors in developed markets, excluding the U.S. and Canada, and its returns are adjusted for tax withholding rates applicable to U.S.-based mutual funds organized as Massachusetts business trusts. Each SMA Sleeve invests primarily in ADRs and a mutual fund designed for use in Program Accounts that invests in foreign securities to obtain foreign exposures where Strategic Advisers believes ADRs are either unavailable or inappropriate. Strategic Advisers will blend model portfolios for international equity exposure provided by the Model Providers at its discretion, based on market cycle implications and overall positioning. The Model Provider(s) for the Fidelity Strategic Advisers International Equity SMA Sleeve will be affiliated with Strategic Advisers, while the Model Provider(s) for the Fidelity Strategic Advisers Blended International Equity SMA Sleeve will include at least one Model Provider that is unaffiliated with Strategic Advisers. The Fidelity Strategic Advisers Tax-Managed International Equity Index SMA Sleeve seeks to approximate the pretax risk and return characteristics of the Fidelity Developed International ex North America Focus Index (Net) by investing primarily in ADRs and ETPs while actively trading holdings in an attempt to enhance after- tax returns through the use of tax-smart investing techniques. The Fidelity Developed International ex North America Focus Index (Net) is a float-adjusted market capitalization–weighted index designed to reflect the performance of the developed international equity market, including large-capitalization stocks. While this SMA Sleeve looks to approximate the pretax risk and return characteristics of the Fidelity Developed International ex North America Focus Index (Net), it will purchase only a subset of the securities that make up the index. For additional information about the Model Providers who provide stock portfolio recommendations to Strategic Advisers, please contact a Fidelity representative. At any time, Strategic Advisers, in its discretion, can change the weight allocated to a particular Model Provider’s stock portfolio recommendations within client accounts. In addition, Strategic Advisers can, in its discretion, replace the Model Providers from which it receives stock portfolio recommendations, or can contract with additional Model Providers to provide stock portfolio recommendations. Where Strategic Advisers uses more than one investment model with respect to a particular SMA Sleeve, Strategic Advisers uses its discretion to blend those investment models. If deemed appropriate, Strategic Advisers can substitute other securities or ETPs for securities identified by a Model Provider. Strategic Advisers can also use ETPs to obtain certain exposures within an SMA Sleeve while implementing a client- imposed investment restriction. The number of securities used by Strategic Advisers within an SMA Sleeve will vary over time. There is expected to be an overlap among the securities held in each of the SMA Sleeves associated with a particular asset class. Each of the securities purchased in the SMA Sleeves will appear on the account statement and on Fidelity.com. Securities selected for the SMA Sleeves are individually tailored based on a client’s existing holdings and unique financial situation, and on the tax attributes of the assets in the client’s Tax-Smart Program Account. A client can expect that the securities that make up the SMA Sleeves can vary, perhaps significantly, from the securities purchased for other clients in the Program. When determining the appropriateness of implementing SMA Sleeves, Strategic Advisers considers the trade- offs inherent in managing a client’s Tax-Smart Program Account toward the appropriate risk and return while monitoring the potential tax consequences. This could mean that the implementation of the SMA Sleeves might not happen on the first set of trades, and indeed could happen in small amounts over the course of months or even years from the start date. In some circumstances, a client’s account could have such large, embedded gains that it is not in the client’s best interest to sell their existing mutual fund or ETP holdings to invest in SMA Sleeves. In the future, Strategic Advisers might offer additional SMA Sleeves. These SMA Sleeves can be managed by Strategic Advisers or by affiliated or unaffiliated third-party registered investment advisers retained by Strategic Advisers. If such additional SMA Sleeves become available, Strategic Advisers will consider whether these SMA Sleeves are appropriate for a client’s Tax-Smart Program Account and could offer these additional SMA Sleeves to a client. 26  About the Fidelity Program Dedicated Funds and Program Only Funds Fidelity Program Dedicated Funds enable Strategic Advisers to choose from an expanded group of Fidelity and non-Fidelity mutual funds and ETPs and Fund Sub-advisors. All Fidelity Program Dedicated Funds are considered to be Fidelity Funds; however, these funds can have a blend of both affiliated and unaffiliated mutual funds, ETPs, and Fund Sub-advisors, or a preference for affiliated mutual funds, ETPs, and Fund Sub-advisors. One way that Strategic Advisers deals with potential fund capacity issues is to use the Fidelity Program Dedicated Funds. Certain of these funds are structured so that, within one fund, Strategic Advisers can hire and/or fire Fund Sub-advisors who will purchase equity or fixed income securities for the fund, and buy and sell mutual funds, ETPs, and certain types of derivatives. This structure is designed to simplify Program Accounts and provide Strategic Advisers with greater visibility into the underlying holdings of the funds. Regulatory restrictions limit the amount that one fund can invest in another, which means that the Fidelity Program Dedicated Funds are limited in the amount they can invest in any particular fund. For more information on the investment strategies employed by the Fidelity Program Dedicated Funds, please see the prospectuses for those funds. Fidelity Program Dedicated Funds can be used in any Program Account and are available only to clients of certain of Fidelity’s managed account programs. A significant portion (up to 100%) of the assets in a Program Account, other than Tax-Smart and BDIP Program Accounts, could be invested in the Fidelity Program Dedicated Funds. If an investor ceases to be a client of the Program, in general, Strategic Advisers will redeem any and all Program Only Fund shares as well as shares of other funds that can no longer be held by the client due to other restrictions, such as minimum balance requirements, and a client could incur gains or losses as a result of such redemptions. About BDIP Program Accounts Wealth Management and Private Wealth Management clients can select the BDIP strategy, which seeks an attractive level of investment income for an appropriate level of risk by investing in mutual funds and ETPs that invest in (or track) the following primary asset classes: domestic stocks, foreign stocks, investment-grade and high-yield bonds, and short-term investments. Strategic Advisers has retained BlackRock as the Model Provider for this strategy. Strategic Advisers can select investments for a BDIP Program Account that differ from BlackRock’s model portfolio, but could also implement BlackRock’s model portfolio without change. Strategic Advisers is responsible for portfolio management, trading, and supervision of BDIP Program Accounts. BlackRock is not acting as an investment adviser or portfolio manager with respect to BDIP Program Accounts. Mutual funds and ETPs included in the model portfolio are identified by BlackRock based on a variety of objective and subjective factors, including but not limited to performance, expenses, quality, history of portfolio management, understanding of style consistency, asset size, availability, trading characteristics, current public information on the investment and its management, and overall fit within the model portfolio. BDIP Program Accounts are not intended to provide a complete investment program. Clients are responsible for appropriate diversification of assets outside BDIP Program Accounts to help guard against the risk of loss. Cash flows from dividend distributions or interest payments will be reinvested in the portfolio unless a client elects otherwise. In selecting mutual funds and ETPs for inclusion in the model portfolio provided to Strategic Advisers, BlackRock will primarily select BlackRock funds. These investments pay fees and other compensation to BlackRock (or one of its affiliates) and include iShares® ETPs. It is possible that non-BlackRock funds will outperform BlackRock funds. As described in “Client Referrals and Other Compensation” below, affiliates of Strategic Advisers and BlackRock have a marketing relationship. While this marketing relationship does not apply to the services offered by Strategic Advisers, and employees responsible for selecting investments for Program Accounts are not compensated based on the investments selected for Program Accounts, clients should be aware of this conflict of interest. BlackRock can also include mutual funds or ETPs advised by third parties, including Strategic Advisers or its affiliates, if BlackRock determines, in its sole discretion, that a BlackRock fund might not achieve the investment objective. The mutual funds and ETPs included in the model portfolio provided by 27  BlackRock will vary in their exposure to different asset classes as well as to different styles (e.g., investing for capital appreciation or income). Strategic Advisers has designed investment guidelines for the mutual funds and ETPs held in BDIP Program Accounts. These guidelines can change from time to time. BlackRock can provide a similar model portfolio to, or manage accounts using a similar investment strategy for, its other clients and could provide the model to such accounts or clients before providing it to Strategic Advisers. BlackRock seeks to generate a higher yield and a lower risk profile for its model portfolio than that of a balanced portfolio that holds 50% equity investments and 50% investment-grade fixed income (including short-term assets). However, in constructing the model portfolio, BlackRock has wide flexibility in the relative investment weightings given to each asset class and generally can allocate from 20% to 80% to equity investments and correspondingly from 80% to 20% to fixed income investments (including high-yield and short-term assets). BlackRock seeks to balance income and risk in the model portfolio by targeting lower volatility over a rolling three-year period that is in line with a balanced portfolio (as measured by the annualized standard deviation of monthly returns). Please note that new BDIP accounts are no longer available, and we expect to close all BDIP accounts by the end of 2026. Clients can work with their Fidelity representative to reposition those assets prior to account closure. More information will be provided to clients prior to the end of 2026. Fractional Share Investing Clients should be aware that the use of fractional shares could result in the receipt of fewer dividends. Please note that any dividends received that are valued at less than $0.01 but that round up to $0.01 will be credited to a Program Account, but amounts that do not round up to $0.01 will not be distributed to the Program Account that held the fractional share; this operational process results in dividend amounts that could otherwise be received by a Program Account being received by another Program Account. If any amount is not distributed and the aggregate value is less than or equal to $1.00 per security, it will be retained by NFS, and when it exceeds $1.00, it will be escheated to the state of Delaware. Also, with respect to proxy voting, clients are not able to vote a fractional share of an individual security; however, if clients elect to appoint Strategic Advisers as proxy voting agent on their behalf, such fractional shares can generally be voted. Please see “Voting Client Securities” below for information regarding the voting of client securities. In addition, clients are not able to take any discretionary or voluntary corporate action with respect to any fractional share position. Fractional shares cannot be transferred to an account outside of Fidelity; in such situations, the fractional shares would need to be sold and a taxable gain or loss incurred. Additional Information about Strategic Advisers’ Investment Practices In managing Program Accounts, Strategic Advisers will obtain information from various sources. Strategic Advisers will use both primary sources (e.g., talking directly with fund companies and fund managers) and secondary sources (e.g., analysts’ reports from fund companies that will provide data on the investment strategies, risk profiles, and historical returns). Secondary sources also include a variety of publicly available market and economic information and third-party research as well as proprietary research generated by Strategic Advisers. Strategic Advisers will analyze this information to assist in making allocation decisions among asset classes as well as in making purchase and sale decisions. Strategic Advisers does not seek access to material nonpublic information on any investment used by the Program. With respect to Fidelity mutual funds or ETPs used by the Program, the investment team at Strategic Advisers that manages Program Accounts does not have access to material nonpublic information of the Fidelity mutual funds or ETPs. Strategic Advisers has internal limits on how much it will invest Program Accounts in a mutual fund or ETP, and such limits typically apply in the aggregate across all client accounts. Strategic Advisers can also consult fund managers to understand the manager’s guidelines or policies, if any, concerning fund share ownership limits. Strategic Advisers will invest Program Accounts in mutual funds available through FundsNetwork, Fidelity’s mutual fund platform, and ETPs available for sale through Fidelity. Strategic Advisers does not have a predetermined allocation to Fidelity or non-Fidelity mutual funds or ETPs, other than the exclusive use of 28  Fidelity money market funds. Similarly, Strategic Advisers does not have a predetermined allocation with respect to the use of affiliated or Unaffiliated Model Providers for the SMA Sleeves. The application of the Credit Amount, lack of additional fees associated with the use of affiliated Model Providers, and that Strategic Advisers’ investment professionals are not compensated based on the amount of Fidelity or non-Fidelity mutual funds or ETPs used in the Program mitigates Strategic Advisers’ economic conflict in choosing between Fidelity and non-Fidelity mutual funds, ETPs, and Model Providers. However, Strategic Advisers will achieve greater efficiencies and economies of scale with respect to the research and management services that it provides to clients when it invests in Fidelity mutual funds, ETPs, and Model Providers and can consider these efficiencies when selecting investments for Program Accounts. From time to time, Strategic Advisers and/or its affiliates can determine that, as a result of regulatory requirements that apply to Strategic Advisers and/or its affiliates due to investments in a particular country or in an issuer operating in a particular regulated industry, investments in the securities of issuers domiciled or listed on trading markets in that country or operating in that regulated industry above certain thresholds are impractical or undesirable. The foregoing limits and thresholds can apply at the Program Account level or in the aggregate across all accounts (or certain subsets of accounts) managed, sponsored, or owned by, or otherwise attributable to Strategic Advisers and its affiliates. For investment risk management and other purposes, Strategic Advisers and its affiliates also generally apply internal aggregate limits on the amount of a particular issuer’s securities that can be owned by all such accounts. In such instances, the adviser can limit or exclude a client’s investment in a particular issuer, which can also include investment in related derivative instruments, and investment flexibility will be restricted. To the extent that a Program Account already owns securities that directly or indirectly contribute to an ownership threshold being exceeded, securities held in such a Program Account could be sold to bring account-level and/or aggregate ownership below the relevant threshold. In the event that any such sales result in realized losses for a Program Account, that Program Account will bear such losses depending on the particular circumstances. Additionally, many of the mutual funds Strategic Advisers invests in have policies that restrict excessive trading. As a result, a fund can reject trade orders if they are deemed to represent excessive trading. In general, a fund will restrict future trade activity if it deems the excessive trading policy, as outlined in the fund prospectus, has been violated (for example, a purchase and sale within a 30-day period). As a result, to comply with a fund’s trading policies, Strategic Advisers will be required to suspend investment management of a Program Account. Strategic Advisers will cease to manage a Program Account as soon as reasonably practicable. The imposition of any such order can take up to one business day to implement, and will stop any trading activity that is occurring in a Program Account. Material Risks Risks Associated with Financial Planning. The projections and other analyses presented to a client in the course of providing our financial planning services are not guarantees. In particular, projections are hypothetical in nature; are for illustrative purposes only; do not reflect actual investment, tax, or other planning results; and are not guarantees of future outcomes. The modeling results shown will vary with each use and over time. In addition, our assumptions and methodologies used in financial planning are adjusted from time to time, which can have an impact on the results obtained. The financial planning analyses provided through the Program are based on the information provided by clients and certain static assumptions—e.g., fixed return rates, fixed life expectancies, and fixed rates of income or cash flow. In reality, these variables will not be static—market fluctuation will affect overall asset performance, and uncertain life expectancy could cause clients to outlive their resources or fail to accumulate necessary resources. Financial planning analyses include probabilistic modeling, whereby the probability of success varies based on differing assumptions and on changing circumstances and market information. In addition, financial planning analyses do not model the individual return characteristics of the securities or investments a client owns. Instead, our analyses model the return characteristics of asset classes, and, as a result, the modeling process is subject to significant variability based on the differences in performance between the securities actually owned by a client and the assumptions used in the modeling process with respect to asset classes. 29  A client may own securities or investments for which we cannot determine an appropriate asset class classification; in some cases, we may assign an asset class and in others we may be unable to model the return characteristics of such a security or investment. Our financial planning analyses assume that the diversification within each asset class is consistent with broadly diversified market indexes. In addition, where our management of one or more Program Accounts is based on information a client has told us about Other Assets assigned to a particular goal, our coordinated management of the Program Accounts assumes that the diversification of the Other Assets is consistent with broadly diversified market indexes. To the extent that the characteristics of a client’s assets vary significantly from those of the broadly diversified asset class assumptions used, actual performance can deviate significantly from the projections provided as a component of our financial planning services. Unless otherwise indicated, the financial planning analyses assume that the asset allocation of the accounts associated with a goal, when aggregated, will generally reflect the asset allocation recommended for the goal. Accordingly, the asset allocation recommended with respect to a particular goal can differ from the asset allocation identified for discretionary management services provided to a Program Account associated with that goal, and clients are responsible for implementing the asset allocation of any Other Assets associated with a goal. If the actual aggregated asset allocation for all of a client’s accounts associated with a goal does not match the asset allocation recommended for that goal, the differential can have a significant impact. Although Fidelity can consider the potential effect of certain estate or tax strategies, Fidelity does not provide tax, accounting, or legal advice. Accordingly, any information presented in conjunction with the Program, including in providing the financial planning services, about tax considerations affecting financial transactions or estate arrangements is provided for informational purposes only. Clients should consult their tax and legal advisors regarding their particular circumstances. As part of the financial planning services, we can identify certain account types or account structures that are generally designed to help investors reach their goals, including the use of tax-deferred or tax-free retirement, insurance, and educational savings accounts. There is no guarantee that a client’s use of these account structures will be beneficial in helping the client reach their goals. In addition, the legal and tax treatment of these types of accounts could change in the future, leading to unexpected consequences for any such accounts, and we are under no obligation to update clients about potential changes in the tax law or the tax treatment of any account. Each financial planning analysis provides detailed information regarding the analysis, including risks and limitations. Risks Associated with Investment Strategies. The discretionary investment management strategies implemented for clients in the Program, including conservative investments, involve risk of loss. Investments in a Program Account are not bank deposits and are not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed, and the value of a client’s assets will fluctuate due to market conditions and other factors. A client could lose money by investing in mutual funds, ETPs, and/or individual securities. A client could lose money by investing in a Program Account. Many factors affect each investment’s or Program Account’s performance and potential for loss. Strategies that pursue investments in equities will be subject to stock market volatility and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Strategies that pursue fixed income investments (such as bond or money market funds) will see values fluctuate in response to changes in interest rates, inflation and prepayment risks, as well as default risks for both issuers and counterparties; changing interest rates, including rates that fall below zero, can have unpredictable effects on markets and can result in heightened market volatility. Developments that disrupt global economies and financial markets, such as wars, acts of terrorism, the spread of infectious illness or other public health issues, recessions, or other events, can magnify factors that affect performance. These strategies are also affected by impacts to the individual issuers, such as changes in an issuer’s credit quality, or changes in tax, regulatory, market, or economic developments. 30  In addition, investments in certain bond structures are less liquid than other investments and, therefore, are more difficult to trade effectively. Municipal bond funds carry additional risks, which are discussed below. Nearly all investments or accounts are subject to volatility in non-U.S. markets, through either direct exposure or indirect effects in U.S. markets from events abroad. Those investments and accounts that are exposed to emerging markets are potentially subject to heightened volatility from greater social, economic, regulatory, and political uncertainties, as the extent of economic development, political stability, market depth, infrastructure, capitalization, and regulatory oversight can be less than in more developed markets. Nondiversified funds, SMA Sleeves, and accounts that invest in a smaller number of individual issuers can be more sensitive to these changes, and funds, SMA Sleeves, or accounts that pursue strategies that concentrate in particular industries or are otherwise subject to particular segments of the market (e.g., money market funds’ exposure to the financial services industry, municipal funds’ exposure to the municipal bond market, or foreign or emerging markets funds’ exposure to a particular country or region) could be significantly impacted by events affecting those industries or markets. Strategies that lead funds, SMA Sleeves, or accounts to invest in other funds bear all the risks inherent in the underlying investments in which those funds invest, and strategies that pursue leveraged risk, including investment in derivatives—such as swaps (interest rate, total return, and credit default) and futures contracts— and forward-settling securities, magnify market exposure and losses. It is important to understand that a Program Account’s actual asset allocation can deviate from the identified asset allocation for reasons that include market movement and investment decisions that seek to increase potential returns or reduce risks. Subject to certain limitations, clients can select an asset allocation that differs from the allocation we propose. Clients should understand that the performance of a Program Account with a client-selected asset allocation could differ, at times significantly, from the performance of an account managed according to the asset allocation we proposed. In addition, please note that the composition of Program Accounts managed using the same model portfolio can differ for a variety of reasons, including but not limited to the timing of client investments and withdrawals, and any client-imposed investment restrictions. In addition to the risks identified above, a summary of additional risks follows: Investing in Mutual Funds and ETPs. A Program Account bears all the risks of the investment strategies employed by the mutual funds and ETPs held in the Program Account, including the risk that a mutual fund or ETP will not meet its investment objectives. For the specific risks associated with a mutual fund or ETP, please see its prospectus. An ETP is a security that trades on an exchange and can seek to track an index, a commodity, or a basket of assets. ETPs can be actively or passively managed. ETPs trade on secondary markets or exchanges and are exposed to market volatility and the risks of the ETP’s underlying securities. ETP share trading can be halted or the security could cease to trade on an exchange. Trading volume and liquidity can vary and could affect the ability to buy or sell ETP shares, or could cause the market price of shares to experience significant premiums or discounts relative to the value of the assets underlying the shares. Because ETPs trade on exchanges, buyers and sellers experience a spread between the bidding price and the asking price, and the size of these spreads can vary significantly. Stock Investments. Stock markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Different parts of the market can react differently to these developments. Value and growth stocks can perform differently from other types of stocks. Growth stocks can be more volatile. Value stocks can continue to be undervalued by the market for long periods of time. In addition, stock investments are subject to risk related to market capitalization as well as company- specific risk. Bond Investments. In general, the bond market is volatile, and fixed income securities carry interest rate risk. As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer- term securities. During periods of very low or negative interest rates, we could be unable to maintain positive returns on bond investments. Very low or negative interest rates can magnify interest rate risk for the markets 31  as a whole and for individual bond investments. Changing interest rates, including rates that fall below zero, can also have unpredictable effects on markets, and can result in heightened market volatility. The ability of an issuer of a bond to repay principal before a security’s maturity can cause greater price volatility, and, if a bond is prepaid, a bond fund could have to invest the proceeds in securities with lower yields. Fixed income securities also carry inflation risk as well as credit and default risks for both issuers and counterparties. The interest payments of inflation-protected bonds are variable and usually rise with inflation and fall with deflation. Unlike individual bonds, most bond funds do not have a maturity date, so holding them until maturity to avoid losses caused by price volatility is not possible. In addition, investments in certain bond structures are less liquid than other investments and, therefore, are more difficult to trade effectively. Credit Risk. Changes in the financial condition of an issuer or counterparty, and changes in specific economic or political conditions that affect a particular type of security or issuer, can increase the risk of default by an issuer or counterparty, which can affect a security’s or instrument’s credit quality or value. Lower-quality debt securities and certain types of other securities involve greater risk of default or price changes due to changes in the credit quality of the issuer. Municipal Bonds. The municipal market can be significantly affected by adverse tax, legislative, or political changes, and by the financial condition of the issuers of municipal securities. Municipal bond funds normally seek to earn income and pay dividends that are expected to be exempt from federal income tax. If a fund investor is a resident in the state of issuance of the bonds held by the fund, interest dividends could also be exempt from state and local income taxes. Income exempt from regular federal income tax (including distributions from municipal and money market funds) can be subject to state, local, or federal alternative minimum tax. Certain funds normally seek to invest only in municipal securities generating income exempt from both federal income taxes and the federal alternative minimum tax; however, outcomes cannot be guaranteed, and the funds sometimes generate income subject to these taxes. For federal tax purposes, a fund’s distribution of gains attributable to a fund’s sale of municipal or other bonds is generally taxable as either ordinary income or long-term capital gains. Redemptions, including exchanges, can result in a capital gain or loss for federal and/or state income tax purposes. Tax code changes could impact the municipal bond market. Tax laws are subject to change, and the preferential tax treatment of municipal bond interest income could be removed or phased out for investors at certain income levels. Because many municipal bonds are issued to finance similar projects, especially those relating to education, health care, transportation, and utilities, conditions in those sectors can affect the overall municipal market. Budgetary constraints of local, state, and federal governments on which the issuers are relying for funding can also impact municipal bonds. In addition, changes in the financial condition of an individual municipal insurer can affect the overall municipal market, and market conditions can directly impact the liquidity and valuation of municipal bonds. Foreign Exposure. Investing in foreign securities and securities of U.S. entities with substantial foreign operations are subject to interest rate, currency exchange rate, economic, tax, operational, regulatory, and political risks, all of which are likely to be greater in emerging markets. These risks are particularly significant for investment strategies that focus on a single country or region or emerging markets, or for clients who elect to increase foreign stock exposure. Foreign markets can be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile. Foreign markets can also offer less protection to investors than U.S. markets. For example, foreign issuers are generally not bound by uniform accounting, auditing, and financial reporting requirements and standards of practice comparable to those applicable to U.S. issuers. Adequate public information on foreign issuers might not be available, and it could be difficult to secure dividends and information regarding corporate actions on a timely basis. Regulatory enforcement can be influenced by economic or political concerns, and investors could have difficulty enforcing their legal rights in foreign countries. Foreign governments may decide to seize or confiscate securities held by foreign investors or assets held by foreign issuers, restrict an investor’s ability to sell or redeem securities, suspend or limit an issuer’s ability to make dividend or interest payments, and/or limit 32  or entirely restrict repatriation of invested capital, profits, and dividends. Furthermore, investments in securities of foreign entities can result in clients owning an interest in a passive foreign investment company (“PFIC”). Clients holding an interest in a PFIC could be subject to additional tax liabilities and filing requirements as a result of such investments. The rules regarding investments in PFICs are complex, and clients are urged to consult their tax advisors. Risks of Investing in ADRs. ADRs are certificates evidencing ownership of shares of an underlying foreign issuer that are issued by depositary banks and generally trade on an established market in the U.S. or elsewhere. ADRs are alternatives to directly purchasing the underlying foreign securities in their national markets and currencies. However, ADRs are subject to many of the risks associated with investing directly in foreign securities. The depositary bank can charge fees for various services, including forwarding dividends and interest, and for corporate actions. In addition, certain ADRs are not traded on a national securities exchange, can be less liquid than other investments, and could, therefore, be more difficult to trade effectively. Investing in ADRs can make it more difficult for U.S. persons to benefit from applicable treaty rates that could otherwise reduce withholding on any distributions from the underlying foreign issuer. Recovery of any extra foreign tax withheld can be costly and complex, and recovery might not be available for certain registration types such as individual retirement accounts. Money Market Funds. Cash balances in a Program Account will be invested in the core Fidelity money market fund, the cash sweep vehicle for a Program Account. A client could lose money by investing in a money market fund. Although a money market fund seeks to preserve the value of a client’s investment at $1.00 per share, it cannot guarantee it will do so. An investment in a money market fund is not a bank account and is not insured or guaranteed by the FDIC or any other government agency. Fidelity, the sponsor of Fidelity’s money market funds, is not required to reimburse money market funds for losses, and a client should not expect that Fidelity will provide financial support to a Fidelity money market fund at any time, including during periods of market stress. Fidelity’s government and U.S. Treasury money market funds will not impose a fee upon the sale of a client’s shares. Alternative Investments. Alternative investments are classified as assets whose investment characteristics and/ or performance differ substantially from the primary asset classes (stocks, bonds, and short-term investments) and, therefore, offer opportunities for additional diversification and returns, but that also offer increased volatility and risk of loss due to their nontraditional or complex investment strategies. Strategic Advisers does not invest in unregistered privately offered alternative investment vehicles such as private equity, hedge funds, or similar investments (referred to as “private funds”) directly in Program Accounts; however, Strategic Advisers can invest in publicly available registered funds (referred to as “public funds”) that invest significantly in private funds and, therefore, clients could have indirect exposure to these types of investments. Generally speaking, public funds offer more investor protections as compared with private funds, including limits on illiquid investments and the use of leverage and derivatives, diversification requirements, daily pricing and liquidity features, regular reporting of fund holdings, and enhanced portfolio security valuation requirements. However, clients should understand that while public funds that invest in alternative investments offer greater investment protections as compared with private funds, both public and private funds that invest in alternative investments offer enhanced risks that clients should be aware of. Alternative investment strategies are not appropriate for all clients. The performance of alternative investments can be volatile and private funds can have extremely limited liquidity opportunities. Such investments often have concentrated positions, invest in illiquid investments, and can carry higher risks. Clients should understand that some alternative investment products often engage in leveraging and other speculative investment practices, including the use of derivatives (described below), that can magnify the risk of investment loss and volatility regardless of whether they are used for speculative investment purposes or for the hedging of risk. In addition, private funds are not required to provide periodic pricing or valuation information to investors and can involve complex tax structures and delays in distributing important tax information. In many cases, the alternative investments underlying both public and private funds are not transparent and are known only to the investment manager of the alternative investment fund. Please refer to the applicable private or public fund’s offering documents or prospectus for additional information on the alternative investments used by the fund and their related risks. 33  Derivatives. Certain funds and ETPs used by Strategic Advisers contain derivatives. Generally speaking, a derivative is a financial contract whose value is based on the value of a financial asset (such as a stock, bond, or currency), a physical asset (such as gold, oil, or wheat), or a market index (such as the S&P 500 Index). Investments in derivatives subject these funds to risks different from, and possibly greater than, those of the underlying securities, assets, or market indexes. Funds that invest in derivatives could experience losses if the underlying securities, assets, or market indexes do not perform as anticipated, and changes in the value of a derivative might not correlate as anticipated with the underlying securities, assets, or market indexes, thereby reducing their effectiveness. Some forms of derivatives, such as exchange-traded futures and options on securities, commodities, or indexes, have been trading on regulated exchanges for decades. These types of derivatives are standardized contracts that can easily be bought and sold, and whose market values are determined and published daily. Nonstandardized derivatives (such as swap agreements), on the other hand, tend to be more specialized or complex, can be more difficult to value, and are illiquid. Derivatives could involve leverage because they can provide investment exposure in an amount exceeding the initial investment; certain derivatives require low margin deposits, which make it possible for a fund to employ a high degree of leverage. As a result, the use of derivatives can cause these funds to be more volatile, because leverage tends to exaggerate the effect of any increase or decrease in the value of a fund’s portfolio securities. Leverage can magnify investment risks and cause losses to be realized more quickly, and a small change in the underlying security, asset, or market index can lead to significant losses for a fund. Certain derivatives have the potential for unlimited losses, regardless of the size of the initial investment. Derivative investments are subject to credit risks associated with the issuer of, or counterparty to, the derivative investment. Real Estate. Real estate is a cyclical industry that is sensitive to interest rates, economic conditions (both nationally and locally), property tax rates, and other factors. Changes in real estate values or economic downturns can have a significant negative effect on issuers in the real estate industry. Commodity-Linked Investing. Commodity-linked investments can be leveraged and can be more volatile and less liquid than the underlying commodity, instruments, or measures. The performance of commodity-linked investments can be affected by the performance of individual commodities and the overall commodities markets, as well as by weather, political, tax, and other regulatory and market developments. A commodity- linked investment is subject to credit risks associated with the issuer of, or counterparty to, the commodity- linked investment. The commodities industries can be significantly affected by the level and volatility of commodity prices; the rate of commodity consumption; world events including international monetary and political developments; import controls, export controls, and worldwide competition; exploration and production spending; and tax and other government regulations and economic conditions. Currency Exposure. Certain funds and ETPs used by Strategic Advisers can be exposed to foreign currencies and, as a result, could experience losses based solely on the weakness of foreign currencies versus the U.S. dollar and changes in the exchange rates between foreign currencies and the U.S. dollar. Currency transactions tied to emerging markets can present market, credit, liquidity, legal, political, and other risks different from, or greater than, the risks of currency transactions tied to developed foreign countries. Illiquid Investments. Illiquid securities sometimes trade infrequently in the secondary market. As a result, valuing an illiquid security can be more difficult, and buying and selling an illiquid security at an acceptable price can be more difficult or delayed. Difficulty in selling an illiquid security can result in a loss. The relative liquidity of any investment, particularly those that trade on exchanges, can vary, at times significantly. Sustainable Investing. Because of the subjective nature of investing based on sustainable criteria, there can be no guarantee that any of the sustainable investment preferences and the related ESG criteria used by Strategic Advisers will reflect the beliefs or values of any particular client. Clients should understand that the application of ESG criteria does not mean that a Program Account invested using one of the sustainable investment universes will exclude any and all mutual funds or ETPs that are deemed to have negative ESG characteristics; rather, the application of ESG criteria in Strategic Advisers’ fundamental research process is intended to include mutual funds and ETPs in Program Accounts that Strategic Advisers believes have meaningfully integrated sustainability practices into their investment research and decision-making processes. 34  Investing based on ESG criteria could cause a Program Account invested in a sustainable investment universe to forgo certain investment opportunities available to strategies that do not use such criteria. An account could underperform other investments that do not assess ESG criteria or that use a different methodology to identify and/or incorporate ESG criteria. Information regarding ESG practices is obtained through voluntary or third- party reporting, which could be inaccurate or incomplete. Information used to evaluate ESG criteria may not be readily available, complete, or accurate, and can vary across providers, issuers, and regions as ESG investing is not uniformly defined. As a result, there is a risk that Strategic Advisers could incorrectly assess a mutual fund or ETP based on ESG criteria. There could be limitations with respect to the readiness of ESG data for certain mutual funds or ETPs, as well as limited availability of investments with relevant ESG characteristics in certain asset classes or sectors. Strategic Advisers can change the ESG criteria it uses to assess mutual funds and ETPs over time. There is no assurance that an investment strategy using an ESG focus will be successful. Growth Investing. Growth stocks can react differently to issuer, political, market, and economic developments than the market as a whole and other types of stocks. Growth stocks tend to be more expensive relative to their earnings or assets compared with other types of stocks. As a result, growth stocks tend to be sensitive to changes in their earnings and more volatile than other types of stocks. Value Investing. Value stocks can react differently to issuer, political, market, and economic developments than the market as a whole and other types of stocks. Value stocks tend to be inexpensive relative to their earnings or assets compared with other types of stocks. However, value stocks can continue to be inexpensive for long periods of time and, as a result, might never realize their full expected value. Quantitative Investing. Funds or securities selected using quantitative analysis can perform differently from the market as a whole as a result of the factors used in the analysis, the weight placed on each factor, changes to the factors’ behavior over time, market volatility, or the quantitative model’s assumption about market behavior. In addition, Strategic Advisers’ quantitative investment strategies rely on algorithmic processes, and, therefore, are subject to the risks described below under the heading, “Operational Risks.” To the extent that the quantitative models fail to adequately match the risk and return profile of a reference index used in managing a particular strategy, a Program Account could perform differently; it could underperform or outperform the corresponding reference index on a pretax basis. In addition, to the extent that the components of the corresponding reference index perform in a highly correlated fashion—such as most stocks in the index rising or falling at the same time— the strategy could be less effective at harvesting the tax losses on which the after-tax portion of the strategy relies. Investing for Volatility Management. The ability of Defensive and BDIP Program Accounts to manage the overall level of account volatility in response to market volatility depends on Strategic Advisers’ ability (and, for BDIP Program Accounts, BlackRock’s ability as model provider to Strategic Advisers) to correctly estimate the volatility of the investments it chooses relative to the broader market. Volatility could be higher than anticipated, and the specific investments used to manage volatility might not be as correlated or uncorrelated with the broader market as expected. There can be no guarantee of success in managing the overall level of volatility. These accounts might not realize the anticipated benefits from the volatility management process or could realize losses because of the investment techniques used to manage volatility, or because of the limitations of volatility management processes in periods of extremely high or low volatility. Under certain market conditions, the use of volatility management processes could also result in less favorable performance than if such processes had not been used. The volatility management strategies used in managing these accounts can cause them to underperform when markets rise, and there can be no guarantee that these strategies will help mitigate losses when markets fall. Risks and Limitations Associated with Tax-Smart Investing Techniques. For Tax-Smart Program Accounts, clients should understand that there are risks and limitations associated with the use of tax-smart investing techniques, and these limitations can result in tax-inefficient trades. Strategic Advisers believes appropriate asset allocation and diversification are of primary importance, and we will make changes to a Tax-Smart Program Account’s asset allocation even if such changes trigger significant tax consequences, including but not limited to wash sales or the realization of short- and/or long-term capital gains. Clients should consult their tax and/or legal advisor prior 35  to enrolling in a Tax-Managed Program Account as well as on an ongoing basis to determine whether the wash- sale rule or other special tax rules could apply to their tax situation, and to determine the efficacy of the tax- smart investing techniques to their current and future tax situation. Strategic Advisers relies on information a client provides in applying tax-smart investing techniques and does not offer tax advice. Strategic Advisers actively manages for federal income taxes, but does not manage in consideration of state or local taxes; foreign taxes, including those applied to dividends and any potential reclaim; federal tax rules applicable to entities; or estate, gift, or generation-skipping transfer taxes. In harvesting tax losses, Strategic Advisers does not attempt to harvest every potential tax loss that occurs in a Tax-Smart Program Account. Clients should also be aware that, in cases where a position is sold to realize a capital loss for tax purposes, Strategic Advisers can replace that position with one or a combination of investments designed to provide comparable market exposure, and it is important to understand that in a given year, due to investment decisions or market conditions, a client could receive varying levels of taxable distributions within a Tax-Smart Program Account. In general, Strategic Advisers will not sell a fund merely to avoid a taxable fund distribution but, in fact, looks at the overall portfolio to determine the most appropriate action. A Tax-Smart Program Account will generally trade more frequently than other Program Accounts that are not managed using tax-smart investing techniques. There are implicit trading opportunity costs associated with the additional turnover, which can affect the returns of a client’s Program Account. It is important to note that the performance of any replacement investments will not be the same as that of the investment sold, and any replacement investments can perform worse than the investment that was sold. In addition, any tax-related benefits resulting from tax-smart investing techniques can be offset or even outweighed by investment losses and/or missed gains (realized and unrealized). Furthermore, there are not clear guidelines on what constitutes a “substantially identical” security for purposes of the wash-sale rule. As such, there can be no guarantee that a replacement investment selected by Strategic Advisers will not be deemed “substantially identical” for purposes of the wash-sale rule. Although Tax-Smart Program Accounts seek to enhance after-tax returns, tax-smart investing techniques may not take into account all of the tax rules, regulations, and limitations applicable to a client’s particular facts and circumstances, which, in certain circumstances, will reduce the effectiveness of tax-smart investing techniques. For example, if a Tax-Smart Program Account is held by an entity treated as a corporation for U.S. federal income tax purposes, the tax-smart investing techniques used will not take into account all the tax rules applicable to that entity, such as rules limiting the use of capital losses, the potential expiration of unused capital losses from prior years, and the corporate tax rate applicable to capital gains and losses. Clients should understand that the benefits derived from any tax-smart investing techniques will likely be greater for clients in higher tax brackets. Since the value of offsetting capital gains or ordinary income is directly tied to the applicable federal capital gains or ordinary income tax rates, clients in lower federal capital gains and ordinary income tax rates experience reduced benefits relative to those in higher federal capital gains and ordinary income tax rates. Legislative and Regulatory Risk. Investments in a Program Account could be adversely affected by new (or revised) laws or regulations. Changes to laws or regulations could impact the securities markets as a whole, specific industries, or individual issuers of securities. Generally, the impact of these changes will not be fully known for some time. Investment Research Risks and Limitations. The investment research process employed by Strategic Advisers includes gathering, cleaning, culling, and analyzing large amounts of data from external public sources and/ or third-party data providers, including, in some instances, through the use of generative artificial intelligence (“AI”) and large language models (“LLM”). It is not possible or practicable, however, to factor all relevant, available data into economic forecasts or trading decisions. In addition, due to the automated nature of this data gathering and the fact that much of this data comes from third-party sources, it is inevitable that not all desired or relevant data will be available to, or processed by, Strategic Advisers at all times. Clients should be aware that there is no guarantee that the data used in generating forecasts or making trading decisions will be the most accurate data available or even free of errors. Furthermore, the use of AI and LLMs may require training of the models to be used in the research process and proper engagement by analysts in order to yield 36  the desired outcome. There can be no guarantee that LLMs can be trained to address all scenarios or that they will provide complete and accurate responses in all situations. AI and LLMs are subject to various risks, including (i) the data used to train LLMs suffers inaccuracies, biases, or flaws that may cause the AI model to respond other than as intended; (ii) weak controls in the development and use of AI allow it to be deployed for use cases for which it was not intended; and (iii) the AI may provide inaccurate or fabricated responses to queries it is unable to process. Fidelity has adopted a Generative AI policy and governance framework so that the use of AI and LLMs is targeted and limited, and that AI and LLMs are trained using known and appropriate data sources and are subject to controls and oversight, which helps ensure that the use of AI and LLMs is but one input into the research process. Clients should assume that the foregoing limitation and risks associated with gathering, cleaning, culling, and analyzing of large amounts of data from third parties and other external sources, and the use of AI and LLMs, are an inherent part of investing. There may also be incidents where data fails to load or internal systems fail to retrieve or capture the data, for example, because of changes in the vendor’s or our system configurations due to upgrades, enhancements, maintenance, or errors, or that LLMs provide incorrect information in response to certain prompts. Clients should assume that these data errors, like other system implementation errors, and their ensuing risks and impact are an inherent part of investing. Accordingly, unless otherwise required to do so, Strategic Advisers does not expect to disclose discovered data errors to clients. Cybersecurity Risks. With the increased use of technologies to conduct business, Strategic Advisers and its affiliates are susceptible to operational, information security, and related risks. These risks could include events that are wholly or partially beyond our control and may have a negative effect on our ability to conduct business activities. We believe that we have taken reasonable steps to mitigate these risks, but do not believe that we can eliminate them altogether. In general, cyber incidents can result from deliberate attacks or unintentional events that can arise from external or internal sources. Cyberattacks include but are not limited to gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software coding) for purposes of misappropriating assets or sensitive information; corrupting data, equipment, or systems; and causing operational disruption. Cyberattacks can also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). Cyber incidents affecting Strategic Advisers, its affiliates, or any other service providers (including but not limited to accountants, custodians, transfer agents, and financial intermediaries used by Fidelity or by an issuer of securities) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, interference with the ability to calculate asset prices, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities in which an account invests, counterparties with which an account engages in transactions, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. Operational Risks. Operational risks can include risk of loss arising from failures in internal processes, people, or systems, such as routine processing incidents or major systems failures, or from external events, such as exchange outages. In addition, algorithms are used in providing the Program Services and contribute to operational risks. For example, algorithms are used as part of the process whereby Strategic Advisers recommends an appropriate asset allocation that corresponds to a level of risk consistent with a client’s Profile Information. In providing financial planning services, algorithms are also used in analyzing the potential for success of a client’s financial plan. Strategic Advisers uses algorithms in support of its discretionary portfolio management process. There is a risk that the data input into the algorithms could have errors, omissions, or imperfections, or that the algorithms do not operate as intended (generally referred to as “processing incidents”). Any decisions made in reliance on incorrect data or algorithms that do not operate as intended can expose Program Accounts to potential risks. Issues in the algorithm are often extremely difficult to detect and could go undetected for long periods of time or never be detected. These risks are mitigated by testing and human oversight of the algorithms and their 37  output. We believe that the oversight and testing performed on our algorithms and their output will enable us to identify and address issues appropriately. However, there is no assurance that the algorithms will always work as intended. In general, we will not assess each Program Account individually, nor will we override the outcome of the algorithm with respect to any particular Program Account. Not all processing incidents arising from operational failures, including those resulting from the mistakes of third parties, will be compensable by Strategic Advisers to clients. Strategic Advisers maintains policies and procedures that address the identification and resolution of processing incidents, consistent with applicable standards of care, to ensure that clients are treated fairly when a processing incident has been detected. The determination of whether, and how, to address a processing incident is made by Strategic Advisers or its affiliates, in their sole discretion. Processing incidents will be reviewed to determine whether there was a financial impact on a client’s Program Account based on, among other things, the relevant investment strategy, and to evaluate the materiality of the impact. If we determine that a material financial impact has occurred, we will make an appropriate correction or otherwise reimburse the Program Account in an amount Strategic Advisers or its affiliates determines is appropriate based on all relevant circumstances. Typically, processing incidents that result in a financial impact of less than $10 per Program Account are not considered material. Other examples of impact that could affect the performance of a Program Account but would likely not be material include impacts arising from computer, communications, data processing, network, cloud computing, backup, business continuity or other operating, information, or technology systems, including those we outsource to other providers, failing to operate as planned or becoming disabled, overloaded, or damaged as a result of a number of factors. These factors could include events that are wholly or partially beyond our control and could have a negative impact on our ability to conduct business activities. Though losses arising from operating, information, or technology systems failures could adversely affect the performance of a Program Account, such losses would likely not be reimbursable under Strategic Advisers’ policies and procedures. Past performance is not a guarantee of future returns. Investing in securities and other investments involves a risk of loss that a client should understand and be willing to bear. Clients are encouraged to discuss these risks with a Fidelity representative. Voting Client Securities Strategic Advisers does not generally acquire authority for, or exercise, proxy voting on a client’s behalf in connection with managing Program Accounts. Unless a client directs Strategic Advisers otherwise pursuant to the paragraph below, the client will receive proxy materials directly from the funds, the issuer of the individual security (or their service providers), or NFS. Strategic Advisers will not advise clients on the voting of proxies. Clients must exercise any proxy voting directly. Notwithstanding the information above, during the account opening process or at any time thereafter at a client’s election, a client can direct Strategic Advisers to act as agent to vote proxies on the client’s behalf for the funds and other securities held in Program Accounts. For Fidelity Funds, clients who make such a direction must instruct Strategic Advisers to vote proxies of a Fidelity Fund in the same proportion as the vote of all other holders of such Fidelity Fund (referred to as “echo voting”). For non-Fidelity funds and other securities, such clients must instruct Strategic Advisers to vote proxies pursuant to the directions provided by Institutional Shareholder Services Inc. (“ISS”), an unaffiliated third-party proxy advisory services provider. Please note that, unlike general proxy votes, Strategic Advisers generally treats certain voluntary corporate actions as subject to the exercise of its discretion as an investment manager. Accordingly, Strategic Advisers will make decisions with respect to voluntary corporate actions directly as part of the investment management services it provides to Program Accounts. However, a client retains the right to make elections with respect to voluntary corporate actions if they so choose; if a client would like to make an election with respect to a security subject to a voluntary corporate action, the client will need to contact us to transfer the security out of the client’s Program Account. 38  In connection with this election, a client must acknowledge that Strategic Advisers is acting solely at the client’s direction, and does not exercise discretion with respect to the voting of any proxy. Clients receive information about ISS’ proxy voting policies in the summary of ISS’ proxy voting guidelines available at Fidelity.com/ information. In some instances, ISS will be unable to provide proxy voting directions, in which case Strategic Advisers will not vote such proxy because it does not have discretion to determine how proxies are voted. To obtain a copy of ISS’ summary proxy voting guidelines or information on how investment proxies were voted, please contact a Fidelity representative. In addition, a client can request that Strategic Advisers act as agent for receipt of certain legally required communications, including prospectuses, annual and semiannual reports, and proxy materials for mutual funds and ETPs that are not managed by FMRCo or an affiliate thereof, and other individual securities. C L I E N T I N F O R M A T I O N P R O V I D E D T O   P O R T F O L I O   M A N A G E R S Strategic Advisers has access to the relevant Program Account information, including certain Profile Information and, for Tax-Smart Program Accounts, information on record regarding the client’s tax situation and the tax characteristics of the securities in a client’s Tax-Smart Program Account. The discretionary portfolio management services will be impacted by incomplete or inaccurate information. If changes to a client’s personal, financial, or tax situation occur, the client should promptly contact a Fidelity representative. Strategic Advisers does not provide client information to any of the Model Providers. C L I E N T C O N T A C T W I T H P O R T F O L I O M A N A G E R S Clients should contact a Fidelity representative regarding questions about their Program Accounts, to update their Profile Information, or to provide an update about their personal situation or any other information that could affect how their Program Accounts are managed. A Fidelity representative will act as a liaison between a client and Strategic Advisers’ investment professionals, and will help ensure appropriate management of the client’s Program Account by updating client Profile Information used by the investment professionals in managing a Program Account. While Strategic Advisers could provide clients with information about the management of Program Accounts from time to time, Strategic Advisers typically does not meet or communicate directly with Program clients. The Model Providers do not meet with clients. A D D I T I O N A L I N F O R M A T I O N Custody Clients must establish and maintain a brokerage account with FBS to participate in the Program, and NFS serves as the qualified custodian for Program Accounts. Clients should carefully review all statements and other communications received from NFS and FBS. NFS and FBS are broker-dealers and affiliates of Strategic Advisers. Strategic Advisers is deemed to have custody under the Investment Advisers Act of 1940 (“Advisers Act”) because its affiliate, NFS, serves as qualified custodian for Program Accounts. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Strategic Advisers’ advisory business or the integrity of its management personnel. Other Financial Industry Activities and Affiliations Strategic Advisers is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is a wholly owned subsidiary of FMR LLC. FMR LLC is a Delaware limited liability company that, together with its affiliates and subsidiaries, is generally known to the public as Fidelity Investments or Fidelity. Various direct or indirect subsidiaries of FMR LLC are engaged in investment advisory, brokerage, banking, or insurance businesses. 39  From time to time, Strategic Advisers and its clients will have material business relationships with any of the subsidiaries and affiliates of FMR LLC. In addition, the principal officers of Strategic Advisers serve as officers and/or employees of affiliated companies that are engaged in various aspects of the financial services industry. Strategic Advisers is not registered as a broker-dealer, futures commission merchant, or commodity trading advisor, nor does it have an application pending to register as such. Strategic Advisers is registered with the U.S. Commodity Futures Trading Commission (“CFTC”) under the Commodity Exchange Act of 1936, as amended (“CEA”), as a commodity pool operator (“CPO”) and is a member of the National Futures Association (“NFA”). Certain personnel of Strategic Advisers, FBS, and NFS share premises and have common supervision. Certain management persons of Strategic Advisers are registered representatives of FBS, a Strategic Advisers affiliate and a registered broker-dealer. In addition, Strategic Advisers has entered into an intercompany agreement with FBS, pursuant to which FBS provides to Strategic Advisers various operational, administrative, analytical, and technical services, and the personnel necessary for the performance of such services. Strategic Advisers has, and its clients could have, a material relationship with the following affiliated companies: Investment Companies and Investment Advisers • Fidelity Management & Research Company LLC (“FMRCo”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FMRCo provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FMRCo acts as sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients and provides model portfolio recommendations and environmental filtering services to Strategic Advisers in connection with Strategic Advisers’ provision of discretionary portfolio management to certain clients. Strategic Advisers pays FMRCo an administrative fee for handling the business affairs of the registered investment companies advised by Strategic Advisers, and Strategic Advisers compensates FMRCo for making certain mutual funds available to managed account programs offered by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FMRCo. • Fidelity Institutional Wealth Adviser LLC (“FIWA”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FIWA provides nondiscretionary investment management services and sponsors the Fidelity Managed Account Xchange® and Fidelity Managed Account Xchange Essentials programs (turnkey asset management programs made available to financial intermediaries). Strategic Advisers provides model portfolio services to FIWA in connection with FIWA’s services to its institutional and intermediary clients, and FIWA compensates Strategic Advisers for such services. In addition, Strategic Advisers shares employees from time to time with FIWA. • FIAM LLC (“FIAM”), a wholly owned subsidiary of FIAM Holdings LLC, which in turn is wholly owned by FMR LLC, is a registered investment adviser under the Advisers Act and is registered with the Central Bank of Ireland. FIAM provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. Strategic Advisers has sub-advisory agreements with FIAM for certain registered investment companies advised by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FIAM. • FMR Investment Management (UK) Limited (“FMR UK”), an indirect, wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act, has been authorized by the U.K. Financial Conduct Authority to provide investment advisory and portfolio management services, and is registered with the Central Bank of Ireland. FMR UK provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR UK for certain registered investment companies advised by Strategic Advisers. 40  • Fidelity Management & Research (Japan) Limited (“FMR Japan”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Japan Financial Services Agency (Kanto Local Finance Bureau) to provide investment advisory and discretionary investment management services. FMR Japan provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Japan for certain registered investment companies advised by Strategic Advisers. • Fidelity Management & Research (Hong Kong) Limited (“FMR Hong Kong”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Hong Kong Securities & Futures Commission to advise on securities, deal in futures contracts, provide asset management services, and conduct trading services. FMR Hong Kong provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Hong Kong for certain registered investment companies advised by Strategic Advisers. • Fidelity Diversifying Solutions LLC (“FDS”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FDS is registered with the CFTC under the CEA as a CPO and as a commodity trading advisor. FDS is a member of the NFA. FDS provides discretionary advisory and sub-advisory services. FDS acts as a sub-advisor to Strategic Advisers in providing discretionary portfolio management to certain clients. Broker-Dealers • Fidelity Distributors Company LLC (“FDC”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Securities Exchange Act of 1934 (the “Exchange Act”). FDC acts as principal underwriter of business development companies and the registered investment companies in the Fidelity group of funds, and also markets those funds and other products to third-party financial intermediaries and certain institutional investors. • National Financial Services LLC (“NFS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. NFS is a fully disclosed clearing broker-dealer that provides clearing, settlement, and execution services for other broker-dealers, including its affiliate FBS. Fidelity Capital Markets (“FCM”), a division of NFS, provides trade executions for Fidelity affiliates and other clients. Additionally, FCM operates CrossStream®, an alternative trading system (“ATS”) that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. CrossStream is used to execute transactions for investment company and other clients. NFS provides transfer agent or subtransfer agent services and other custodial services to certain Fidelity clients. • LeveL Markets, LLC, a registered broker-dealer and operator of two ATSs the Luminex ATS and the LeveL ATS, which allow orders submitted by subscribers to be crossed against orders submitted by other subscribers. LeveL Holdings, LLC, owns LeveL Markets, LLC. Fidelity Global Brokerage Group, Inc., and FMR Sakura Holdings, Inc., each a wholly owned subsidiary of FMR LLC, have membership interests in LeveL Holdings, LLC, along with other members. LeveL Markets, LLC, charges a commission to both sides of each trade executed in the Luminex ATS and LeveL ATS. Luminex ATS and LeveL ATS are used to execute transactions for Fidelity affiliates’ investment company and other advisory clients. NFS serves as a clearing agent for transactions executed in the Luminex ATS and LeveL ATS. • Fidelity Brokerage Services LLC (“FBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act and provides brokerage products and services, including the sale of shares of registered investment companies in the Fidelity group of funds to individuals and institutions, including retirement plans, and acts as placement agent for certain privately offered investment funds advised by Strategic Advisers’ affiliates. In addition, along with Fidelity Insurance Agency, Inc. (“FIA”), FBS distributes variable insurance products 41  that are issued by Fidelity Investments Life Insurance Company (“FILI”) and Empire Fidelity Investments Life Insurance Company® (“EFILI”), both Fidelity affiliates, as well as by third parties. FBS provides shareholder services to certain of Fidelity’s clients. FBS is the introducing broker for managed accounts offered by Strategic Advisers and places orders for execution with its affiliated clearing broker, NFS. • Digital Brokerage Services LLC (“DBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act. DBS provides securities brokerage to retail customers through a digital mobile application–based brokerage platform. DBS receives remuneration from FMRCo for expenses incurred in servicing and marketing FMRCo products. Insurance Companies or Agencies • FILI, a wholly owned subsidiary of FMR LLC, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates. • EFILI, a wholly owned subsidiary of FILI, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates to residents of New York. • FIA, a wholly owned subsidiary of FMR LLC, is engaged in the business of selling life insurance and annuity products of affiliated and unaffiliated insurance companies. Banking Institutions • Fidelity Management Trust Company (“FMTC”), a wholly owned subsidiary of FMTC Holdings LLC, which in turn is wholly owned by FMR LLC, is a limited-purpose trust company organized and operating under the laws of the Commonwealth of Massachusetts that provides nondiscretionary trustee and custodial services to employee benefit plans and IRAs through which individuals can invest in affiliated or unaffiliated registered investment companies. FMTC also provides discretionary investment management services to institutional clients. • Fidelity Personal Trust Company, FSB, a wholly owned subsidiary of Fidelity Thrift Holding Company, Inc., which in turn is wholly owned by FMR LLC, is a federal savings bank that offers fiduciary services that include trustee or co-trustee services, custody, principal and income accounting, investment management services, and recordkeeping and administration. Limited Partnerships and Limited Liability Company Investments Strategic Advisers provides discretionary investment management to partnerships and limited liability companies designed to facilitate acquisitions by mutual funds offered by Strategic Advisers. These funds are privately offered consistent with stated investment objectives. Strategic Advisers does not currently engage in borrowing, lending, purchasing securities on margin, short selling, or trading in commodities. Participating Affiliate Certain employees of Fidelity Strategic Advisers Ireland, Limited (“Strategic Ireland”), can from time to time provide certain services, including but not limited to research, operations, and investment management support services for Strategic Advisers, which Strategic Advisers could use for its clients. Strategic Ireland is not registered as an investment adviser under the Advisers Act and is deemed to be a “Participating Affiliate” of Strategic Advisers (as this term has been used by the SEC’s Division of Investment Management in various no-action letters granting relief from the Advisers Act’s registration requirement for certain affiliates of registered investment advisers). Strategic Advisers deems Strategic Ireland and each of the Strategic Ireland Associated Employees as “associated persons” of Strategic Advisers within the meaning of Section 202(a)(17) of the Advisers Act. Strategic Ireland Associated Employees and Strategic Ireland through such employees can contribute to Strategic Advisers’ research process and could have access to information concerning securities that are being selected for clients prior to the effective implementation of such selections. As a Participating 42  Affiliate of Strategic Advisers, Strategic Ireland has agreed to submit itself to the jurisdiction of United States courts for actions arising under United States securities laws in connection with investment advisory activities conducted for Strategic Advisers’ clients. Strategic Advisers maintains a list of Strategic Ireland Associated Employees whom Strategic Ireland has deemed associated persons, and Strategic Advisers will make the list available to its current U.S. clients upon request. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Strategic Advisers has adopted a Code of Ethics for Personal Trading (the “Code of Ethics”). The Code of Ethics applies to all officers, directors, employees, and other supervised persons of Strategic Advisers and requires that they place the interests of Strategic Advisers’ clients above their own. The Code of Ethics establishes securities transaction requirements for all covered employees and their covered persons, including their spouses. More specifically, the Code of Ethics contains provisions requiring the following: • Standards of general business conduct reflecting the investment advisers’ fiduciary obligations; • Compliance with applicable federal securities laws; • Employees and their covered persons to move their covered accounts to FBS unless an exception exists or prior approval has been granted; • Reporting and review of personal securities transactions and holdings for persons with access to certain nonpublic information; • Prohibition of purchasing securities in initial public offerings unless an exception has been approved; • Reporting of Code of Ethics violations; and • Distribution of the Code of Ethics to all supervised persons, documented through acknowledgments of receipt. Core features of the Code of Ethics generally apply to all Fidelity employees. The Code of Ethics also imposes additional restrictions and reporting obligations on certain advisory personnel, research analysts, and portfolio managers. Such restrictions and reporting obligations include the following: • The preclearing of transactions in covered securities with limited exceptions; • A prohibition on investments in limited offerings without prior approval; • A prohibition on personal trading by a portfolio manager within seven days before or after a trade in any covered security of the same issuer by a fund or account managed by such portfolio manager except in limited circumstances; • The reporting of transactions in covered securities on a quarterly basis with limited exceptions; • The reporting of securities accounts and holdings of covered securities at the time of hire and annually thereafter; and • The disgorgement of profits from short-term transactions with limited exceptions. Violation of the Code of Ethics requirements can also result in the imposition of remedial action. The Code of Ethics will generally be supplemented by other relevant Fidelity policies, including the Policy on Inside Information, Rules for Broker-Dealer Employees, and other written policies and procedures adopted by Fidelity and Strategic Advisers. A copy of the Code of Ethics will be provided to any client or prospective client on request. From time to time, Strategic Advisers and its related persons can buy or sell securities for themselves and recommend those securities to clients. The conflicts of interest involved in such activities are contemplated in the Code of Ethics and other relevant Fidelity policies. In particular, the Code of Ethics and other Fidelity policies are designed to make it clear to Fidelity personnel that they should never place their personal interests ahead of Fidelity’s clients in an attempt to benefit themselves or another party. The Code of Ethics and other Fidelity policies impose sanctions if these requirements are violated. 43  From time to time, in connection with our business, certain supervised persons obtain material nonpublic information that is usually not available to other investors or the general public. In compliance with applicable laws, Strategic Advisers has adopted a comprehensive set of policies and procedures that prohibits the use of material nonpublic information by investment professionals or any other employees and that limits the transactions that Strategic Advisers can implement for Program Accounts. In addition, Fidelity has implemented a Corporate Gifts & Entertainment Policy intended to set standards for business entertainment and the giving or receiving of gifts, to help employees make sound decisions with respect to these activities, and to ensure that the interests of Strategic Advisers’ clients come first. Similarly, to support compliance with applicable “pay to play” laws, Fidelity has adopted a Personal Political Contributions & Activities Policy that requires employees to preclear any political contributions and activities. Fidelity also has a Global Anti-Corruption Policy regarding commercial bribery and bribery of government officials that prohibits directly or indirectly giving, offering, authorizing, promising, accepting, or receiving any bribe, facilitation payment, kickback, or payoff (whether in cash or any other form) with the intent to improperly obtain or retain business or any improper advantage. Brokerage Practices Clients will receive prompt confirmations from NFS for any transactions in their Program Accounts; however, with respect to automatic investments, automatic withdrawals, dividend reinvestments, and transactions that involve the core Fidelity money market fund, a client’s account statement serves in lieu of a confirmation. In addition, clients receive statements from NFS that detail all holdings and transaction information, including trades, additions, withdrawals, shifts in investment allocations, advisory fees, and estimated gain/loss and tax basis information. Statements and confirmations are also available online at Fidelity.com and by enrolling in the electronic delivery program. Clients will not pay a different fee because of their decision to receive electronic statements or trade confirmations. Clients should carefully review all statements and other communications received from FBS and NFS. Broker Selection and Transactions in Program Accounts Strategic Advisers has a duty to seek best execution for transactions in client accounts. Strategic Advisers will place trades for Program Accounts with affiliated or unaffiliated registered broker- dealers (“brokers”) and may choose to execute an order using electronic channels (including broker-sponsored algorithms) or by manually working an order with a broker. In selecting brokers, Strategic Advisers may consider a range of factors deemed relevant in the context of a particular trade, including but not limited to price; costs; the size, nature, and type of the order; speed of execution; financial condition and reputation of the broker; broker-specific considerations (e.g., not all brokers are able to execute all types of trades); broker willingness to commit capital; our trader’s assessment of whether and how closely the broker will follow our instructions; and confidentiality and the potential for information leakage. As described above in Fees and Compensation, the Program Fee includes the cost of commissions associated with transactions executed through affiliated brokers. As a result, most trades for Program Accounts that involve equity securities and other securities where commissions are charged will be executed with Strategic Advisers’ affiliated broker, NFS. However, Strategic Advisers has the authority to execute transactions with an unaffiliated broker (also referred to as “trading away”) consistent with its duty to seek best execution. While the Program Fee does not include the cost of commissions for transactions executed through unaffiliated brokers, Strategic Advisers or its affiliate is voluntarily assuming the cost of commissions for transactions executed by unaffiliated brokers. As a result, Program clients are not charged commissions for such transactions. Strategic Advisers and its affiliates reserve the right to stop assuming the cost of commissions associated with trading away, subject to prior notice to Program clients. The Program Fee does not cover transaction charges for securities where the counterparty imposes a markup, markdown, and/or dealer spread. The net price of the security will include these transaction charges and Program Accounts will bear these costs. 44  In seeking best execution for a transaction, Strategic Advisers will have no obligation to solicit competitive bids for each transaction and Strategic Advisers will not necessarily select the broker that charges the lowest available price or commission rate; however, Strategic Advisers believes that its policies, taking into consideration the factors stated above, are designed to result in transaction processing that is favorable to Program clients. Strategic Advisers conducts periodic reviews of trade execution. Although it is Strategic Advisers’ policy to treat each client’s account in a fair and equitable manner over time, there can be no assurance that all Program Accounts will receive the same execution and certain Program Accounts will experience a more or less favorable execution depending on market conditions. Please see the Fees and Compensation section above for further information about the Program Fee, brokerage commissions, and additional fees for transactions in a Program Account. Trade Aggregation and Allocation Strategic Advisers’ policy is to treat each client’s account in a fair and equitable manner over time when aggregating and allocating orders for the purchase and sale of securities. While Strategic Advisers is under no obligation to aggregate orders for Program Accounts, in general, Strategic Advisers will choose to aggregate trades for Program Accounts and/or aggregate Program Account trades with trades for other client accounts (including certain proprietary accounts of Strategic Advisers or its affiliates and Fidelity employee accounts managed by Strategic Advisers) when, in Strategic Advisers’ judgment, aggregation is in the best interest of all clients involved and it is operationally feasible to do so. Orders are aggregated into a “block trade” to facilitate seeking best execution, to negotiate more favorable commission rates, or to allocate equitably among clients the effects of any market fluctuations that might have otherwise occurred had these orders been placed independently. Aggregated orders are generally allocated on a pro rata basis among similarly situated client accounts participating in a block trade until the order is filled. Client accounts included in a block trade receive the same average price for the trade and shares are allocated according to the purchase and sale orders actually placed for each client account included in the block trade. Strategic Advisers can create multiple block trades for both buy and sell orders in the same security, and it is therefore possible that block trades will receive different prices depending on when the orders for each block trade are filled throughout the day. When a client account is not part of a block trade, that client account will receive a different price from the price obtained for Program Accounts that participate in the aggregated orders. If Strategic Advisers does not complete an order in a single day (e.g., when an aggregate order for client accounts exceeds the available supply or to minimize market impact), the partially filled order will be allocated on a pro rata basis among client accounts in the block. Strategic Advisers has adopted trade allocation policies for managing client accounts, including Program Accounts, designed to achieve fairness and not to purposefully disadvantage comparable client accounts over time when allocating purchases and sales. Cross Trades To the extent permitted by law and applicable policies and procedures, Strategic Advisers can (but is not obligated to) execute “agency cross trades” for Program Accounts. Agency cross trades are trades in which Strategic Advisers, or any person controlling, controlled by, or under common control with Strategic Advisers, acts as both investment adviser and broker for a client, and as broker for the party or parties on the other side of the trade. Agency cross trades will be executed in accordance with Section 206(3) of the Advisers Act, requiring written consent, confirmations of transactions, annual reporting, and compliance procedures. To the extent permitted by law and applicable policies and procedures, Strategic Advisers can (but is not obligated to) execute “advisor cross trades” for Program Accounts when Strategic Advisers believes such trades are in the best interest of all clients involved. Advisor cross trades are trades in which Strategic Advisers, or an affiliate, acts as investment adviser to both clients involved in the trade. An advisor cross trade will be facilitated 45  between client accounts either directly or through a broker-dealer, including FBS or NFS, and the relevant crossing value will be determined based on one or more third-party pricing services, actual market bids, and/ or closing prices as reflected on a national securities exchange. Neither Strategic Advisers nor its affiliates will receive transaction-based compensation for advisor cross trades. There can be no assurance that agency or advisor cross trades will be executed, or that such transactions will be executed in a manner that is most favorable to each Program Account that is a party to such transaction. Not all Program Accounts participate in cross trades, and a client may opt out of cross trading by contacting a Fidelity representative. Cross trades can be beneficial to clients by reducing transaction costs, and Program Accounts excluded from cross trading could miss such potential benefits. Strategic Advisers and its affiliates will have a potentially conflicting division of loyalties and responsibilities regarding both parties to a crossing transaction, including with respect to the decision to enter into such transactions and the valuation and pricing of such transactions. Strategic Advisers has developed policies and procedures relating to such transactions and conflicts. Account Transaction Information When Strategic Advisers trades in a Program Account, unless FPTC is acting as trustee or co-trustee with respect to the Program Account, clients will receive a confirmation of such transaction from NFS, except with respect to automatic investments, automatic withdrawals, dividend reinvestments, and transactions that involve the core Fidelity money market fund where a client’s account statement serves in lieu of a confirmation. Clients will receive statements from NFS that will provide holdings and transaction information, including trades, contributions, withdrawals, advisory fees, and estimated gain/ loss and tax basis information. Statements and confirmations are also available online at Fidelity.com and by enrolling in the electronic delivery program. Clients should carefully review all statements and other communications received from FBS and NFS. Clients will also receive a prospectus for any new mutual fund or ETP not previously held, unless the client has elected to have Strategic Advisers act as agent for the receipt of any non-Fidelity prospectuses. The routing details of a particular order will be provided on request, and an explanation of order routing practices will be provided on an annual basis. In addition, from time to time, Fidelity will provide aggregated trade execution data to clients and prospective clients. Soft Dollars Strategic Advisers does not have a soft dollar program and, therefore, does not consider the provision of research or brokerage as a criterion for broker selection. Client-Directed Brokerage Activities Program Accounts are not available for brokerage activities outside of the activities directed by Strategic Advisers, including but not limited to margin trading or trading of securities by a client or any of the client’s designated agents. Review of Accounts Client Contact and Review of Personal Financial Situation Strategic Advisers will contact Program clients at least annually to evaluate whether there have been any changes to their personal financial situation that could affect their Profile Information or the Program Services, including whether the client wishes to impose any reasonable restrictions on the management of the Program Account or reasonably modify any existing restrictions (the “Annual Review Process”). Clients should provide updated Profile Information any time there is a change to their goals (including significant changes in the amount of assets assigned to a goal), time horizon, tax situation, risk tolerance, management of Other Assets (including significant changes to the amount of risk exposure in Other Assets), or personal financial situation, even outside of the Annual Review Process. If a client indicates a change to any Profile Information, either as part of the Annual Review Process or otherwise, this can result in a proposed change to the client’s asset allocation recommendation. If we do not hear from a client during the Annual Review Process, we will update 46  client information based on known information (e.g., client’s age, planned investment time horizon, other date-relative elements of the client’s Profile Information, updated account balances and asset allocations of the client’s Program Accounts and other Fidelity accounts as well as updated balances and asset allocations of certain outside accounts a client has provided) or Fidelity-estimated values, such as withdrawal needs, but we will otherwise assume that the client’s Profile Information has not changed. In some cases, the changes to this updated information will result in a proposed change to the client’s asset allocation recommendation. We will not implement the proposed asset allocation change for a Program Account until the client has agreed to such change. Clients should refer to the Program documentation provided in connection with the Annual Review Process for more information. Ongoing Review and Adjustments of Program Accounts Strategic Advisers monitors Program Accounts and their investments periodically. Market conditions and/ or an upturn or downturn in a particular security will at times cause a “drift” in a client’s investment portfolio away from the asset allocation associated with the client’s Program Account. Strategic Advisers can choose to rebalance a client’s Program Account to bring it back in line with the asset allocation. The number of times a Program Account is rebalanced will vary based on economic and market conditions as well as changes in the attractiveness or appropriateness of specific funds or managers. Strategic Advisers can also modify the funds held in a Program Account to accommodate new fund allocations and fund closures. In managing Program Accounts, Strategic Advisers could decide to adjust allocations for a number of reasons, including but not limited to the following: • The weighting of a particular asset class, sector, mutual fund, ETP, or individual security that Strategic Advisers believes has too much or too little representation in a Program Account; • Changes in the fundamental attractiveness or appropriateness of a particular mutual fund, ETP, or security; • Changes in a client’s Profile Information and any consequent changes to an associated investment strategy; • Deposit or withdrawal of cash or securities into or from a Program Account; • Accommodating mutual fund or ETP closures; • Internal or external investment limits; • Mutual fund liquidity or capacity issues; or • For Tax-Smart Program Accounts, certain changes in the client’s tax situation or in the tax treatment of the investments in the Tax-Smart Program Account. For Program Accounts other than Tax-Smart and BDIP Program Accounts, Strategic Advisers’ investment management team will make decisions regarding reallocations within the model portfolio on which such Program Account is invested. These decisions are based on the investment management team’s assessment of market and economic conditions and potential investment opportunities. Each model portfolio will be rebalanced periodically. Strategic Advisers will generally trade a Program Account when the model portfolio to which it is aligned is changed, subject to any restrictions a client requests. The Fidelity Program Dedicated Funds are reviewed daily and assets within the Fidelity Program Dedicated Funds are reallocated based on the discretion of the applicable fund’s portfolio managers. As a result, reallocation activity applicable to such a Program Account’s assets invested in the Fidelity Program Dedicated Funds could take place at the fund level, rather than directly in a client’s Program Account. Strategic Advisers can work closely with fund managers to minimize the impact of its reallocation activities. There are certain situations when fund investments and redemptions can be accomplished over an extended period of time as a result of operational considerations, legal considerations, or input from underlying fund managers. Generally, Strategic Advisers reviews and adjusts account holdings in Tax-Smart Program Accounts as needed, based on the criteria listed above, with additional consideration given to the potential impact of federal income taxes. Periodically, Strategic Advisers will evaluate a client’s Tax-Smart Program Account with respect to a variety of factors to determine whether the Tax-Smart Program Account could benefit from trading that 47  day. Strategic Advisers does not anticipate that each Tax-Smart Program Account will be traded each day. Rather, Strategic Advisers’ proprietary account evaluation system monitors each Tax-Smart Program Account periodically to identify those accounts that could benefit from trading, and Strategic Advisers then evaluates those Tax-Smart Program Accounts to determine if trading is required. In determining whether a Program Account requires trading on a given day, Strategic Advisers relies on the prior trading day’s closing values of the securities held in a Program Account. In general, Strategic Advisers does not attempt to conduct intraday account evaluations, and Strategic Advisers does not generally attempt to time intraday price fluctuations in its decisions to buy or sell securities. To assist in the evaluation of the performance of their Program Accounts, clients will have access to information about trading activity in their Program Accounts as well as information about the performance of their Program Accounts on a pretax basis and, for Tax-Smart Program Accounts, on an after-tax basis. Pretax Program Account performance is calculated consistent with industry standards. After-tax Program Account performance is based on the pretax performance of the Program Account and the application of our methodology to consider the impact of U.S. federal income taxes. Detailed information about the methodology and assumptions, and their related risks and limitations, used in calculating after-tax performance of a Program Account is provided in each client’s periodic performance summary. While performance information is reviewed by Strategic Advisers for accuracy and compliance with applicable procedures, performance information is not reviewed or approved by a third party. Client Referrals and Other Compensation Strategic Advisers and its affiliates are compensated for providing services, including for investment management, distribution, transfer agency, servicing, and custodial services, to certain Fidelity and non- Fidelity mutual funds, ETPs, and other investments in which Program Accounts are invested or which a client could use to implement the Program’s financial planning recommendations. These affiliates include FMRCo and its affiliates as the investment advisers for the Fidelity Funds; FDC as the underwriter of the Fidelity Funds; and Fidelity Investments Institutional Operations Company LLC (“FIIOC”) as transfer agent for the Fidelity Funds, servicing agent for non-Fidelity funds, and recordkeeper of certain workplace savings plans. Certain funds used in Program Accounts are available only to fee based accounts offered by Fidelity. Unlike many other mutual funds, these funds do not charge fees or expenses for certain services provided by a Fidelity affiliate (but do charge fees for other services). Instead, compensation for such uncharged services is paid by Strategic Advisers or an affiliate. Strategic Advisers’ affiliates also receive compensation and other benefits in connection with portfolio transactions executed on behalf of the Fidelity and non-Fidelity mutual funds, ETPs, and other investments. FMRCo and its affiliates also obtain brokerage or research services, consistent with Section 28(e) of the Exchange Act, from broker-dealers in connection with the execution of the Fidelity Funds’ portfolio security transactions. FBS and NFS receive compensation for executing portfolio transactions and providing, among other things, clearance, settlement, custodial, and other services to Fidelity and non-Fidelity mutual funds, ETPs, and other investments, and NFS provides securities lending agent services to certain Fidelity Funds for which it receives compensation. FBS, NFS, and FIIOC also offer FundsNetwork, Fidelity’s mutual fund platform, and provide shareholder and other services (including, for a limited number of participants on the platform, the sharing of certain aggregated data regarding ETF holdings in Program Accounts) to participating mutual funds and ETPs (or their sponsors) for which FBS, NFS, and FIIOC receive compensation, including with respect to those mutual funds and ETPs in which Program Accounts are invested. Neither FBS nor NFS receives any compensation in connection with directing equity trades for Program Accounts to market makers for execution. We can execute trades through alternative trading systems or national securities exchanges, including but not limited to ones in which a Fidelity affiliate has an ownership interest, such as Members Exchange, a registered national securities exchange. Any decision to execute a trade through an alternative trading system or exchange in which a Fidelity affiliate has an ownership interest would be made in accordance with applicable law, including best execution obligations. For trades placed on certain national 48  securities exchanges, including ones in which a Fidelity affiliate has an ownership interest, Fidelity could receive exchange rebates from such trades for Program Accounts, and these rebates will be subject to the Credit Amount (as described in “Fees and Compensation”) and will be allocated, pro rata based on assets, among Program Accounts. Fidelity receives compensation from BlackRock Fund Advisors, an affiliate of BlackRock, in connection with an exclusive, long-term marketing program that includes promotion of ETFs advised by BlackRock (or an affiliate) and inclusion of the funds in certain FBS platforms and investment programs. Additional information about the sources, amounts, and terms of compensation is provided in the ETF’s prospectus and related documents. Fidelity does not retain additional compensation as a direct result of a Program Account holding BlackRock funds. The compensation described above that is retained by Strategic Advisers or its affiliates as a direct result of investments by the Program Accounts in Fidelity and non-Fidelity mutual funds and ETPs will be included in the Credit Amount (described in “Fees and Compensation”), which reduces the Gross Advisory Fee. However, to the extent that Strategic Advisers’ affiliates, including FBS, NFS, or FIIOC, receive compensation that is neither a direct result of, nor directly derived from, investments by the Program Accounts, such compensation is not included in the Credit Amount, does not reduce the Gross Advisory Fee, and will be retained by Strategic Advisers or its affiliates. Receipt of compensation in addition to the Gross Advisory Fee creates a financial incentive for Strategic Advisers and its affiliates to select investments that will increase such compensation. Strategic Advisers seeks to address this financial conflict of interest through the application of the Credit Amount, which will reduce the Gross Advisory Fee, as applicable, and through personnel compensation arrangements (including those of Strategic Advisers’ investment professionals and the Fidelity representatives) that are not differentiated based on the investments or share classes selected for Program Accounts. Strategic Advisers and its affiliates have also implemented processes reasonably designed to prevent the receipt of compensation from affecting the nature of the advice provided to Program clients. See “Fees and Compensation” for additional information. Client referrals are provided by affiliated entities, including FBS, pursuant to referral agreements where applicable. Additionally, Strategic Advisers refers clients to other independent investment advisers in connection with a referral program in which such independent investment advisers participate for a fee payable to Strategic Advisers. Financial Information Strategic Advisers does not solicit prepayment of client fees. Strategic Advisers is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. 49  FOR MORE INFORMATION, PLEASE CALL US TOLL-FREE AT 8 0 0 . 5 4 4 . 3 4 5 5 Monday through Friday, 8 a.m. to 7 p.m . Ea stern time Keep in mind that investing involves risk. The value of your investment will fluctuate over time, and you may gain or lose money. Diversification and asset allocation do not ensure a profit or guarantee against loss. Fidelity does not provide legal or tax advice, and the information provided is general in nature and should not be considered legal or tax advice. Consult an attorney, tax professional, or other advisor regarding your specific legal or tax situation. BlackRock Investment Management, LLC ( “BlackRock”), is an independent entity that is not affiliated with any Fidelity Investments company. Strategic Advisers is the portfolio manager for BlackRock Diversified Income Portfolio Program Accounts and implements trades for the accounts based on the model portfolio of investments it receives from BlackRock. Strategic Advisers can select investments for an account that differ from BlackRock’s model. For iShares® ETFs, Fidelity receives compensation from the ETF sponsor and/or its affiliates in connection with an exclusive, long-term marketing program that includes promotion of iShares® ETFs and inclusion of iShares® funds in certain FBS platforms and investment programs. Additional information about the sources, amounts, and terms of compensation can be found in the ETF’s prospectus and related documents. Fidelity can add or waive commissions on ETFs without prior notice. BlackRock and iShares® are registered trademarks of BlackRock, Inc., and its affiliates. The Fidelity U.S. Large Cap IndexSM is a float-adjusted market capitalization–weighted index designed to reflect the performance of the stocks of the largest 500 U.S. companies based on float-adjusted market capitalization. The Russell 1000® Growth Index is a market capitalization–weighted index designed to measure the performance of the large-cap growth segment of the U.S. equity market. The Russell 1000® Value Index is a market capitalization–weighted index designed to measure the performance of the large-cap value segment of the U.S. equity market. The S&P 500® Index is a float-adjusted market capitalization–weighted index designed to reflect the performance of the stocks of the largest 500 U.S. companies based on float-adjusted market capitalization. The MSCI EAFE Index (Net MA Tax) is a float-adjusted market capitalization–weighted index designed to reflect the performance of the developed international equity market, including large-capitalization stocks. Index returns are adjusted for tax withholding rates applicable to U.S.-based mutual funds organized as Massachusetts business trusts. The Fidelity Developed International ex North America Focus Index (Net) is a float-adjusted market capitalization– weighted index designed to reflect the performance of the developed international equity market, including large- capitalization stocks. Index returns are adjusted for tax withholding rates applicable to U.S.-based mutual funds organized as Massachusetts business trusts. Indexes are unmanaged. It is not possible to invest directly in an index. Fidelity, Fidelity Investments, the Fidelity Investments logo, FundsNetwork, Fidelity Go, Fidelity Managed FidFolios, Fidelity Wealth Advisor Solutions, Empire Fidelity Investments Life Insurance Company, CrossStream, and Fidelity Managed Account Xchange are registered service marks of FMR LLC. Fidelity Brokerage Services LLC, Member NYSE, SIPC, 900 Salem Street, Smithfield, RI 02917 © 2026 FMR LLC. All rights reserved. 833404.12.0 03/26 1.9887736.112 50 

Strategic Advisers LLC Form ADV, Part 2A Brochure 155 Seaport Boulevard Boston, MA 02210-2698 617.563.7000 Fidelity.com March 30, 2026 This brochure provides information about the qualifications and business practices of Strategic Advisers LLC (“Strategic Advisers”), a Fidelity Investments company. Throughout this brochure and related materials, Strategic Advisers refers to itself as a “registered investment adviser” or as “being registered.” These statements do not imply a certain level of skill or training. Please contact us at 1.800.544.3455 with any questions about the contents of this brochure. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Strategic Advisers is available on the SEC’s website at www.adviserinfo.sec.gov. 1  SUMMARY OF MATERIAL CHANGES The SEC requires registered investment advisers to provide and deliver an annual summary of material changes to their Form ADV, Part 2A brochure (the “Brochure”). Material Changes No material changes were made to the Strategic Advisers LLC Form ADV, Part 2A Brochure from September 10, 2025 through March 30, 2026. Other Changes Certain minor revisions have been made to the text that describes Strategic Advisers’ affiliates in "Other Financial Industry Activities and Affiliations." 2  TABLE OF CONTENTS SUMMARY OF MATERIAL CHANGES 2 ADVISORY BUSINESS 4 FEES AND COMPENSATION 5 PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT 8 TYPES OF CLIENTS 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 9 DISCIPLINARY INFORMATION 20 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 20 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING 24 BROKERAGE PRACTICES 26 REVIEW OF ACCOUNTS 26 CLIENT REFERRALS AND OTHER COMPENSATION 27 CUSTODY 28 INVESTMENT DISCRETION 28 VOTING CLIENT SECURITIES 29 FINANCIAL INFORMATION 31 3  ADVISORY BUSINESS Strategic Advisers LLC (“Strategic Advisers”) is a registered investment adviser and an indirect, wholly owned subsidiary of FMR LLC (collectively with Strategic Advisers and its affiliates, “Fidelity Investments,” “Fidelity,” “us,” “our,” or “we”). Strategic Advisers was formed in 1977 and provides a variety of investment management services, including discretionary portfolio management services and non-discretionary advisory services to retail and institutional clients. The non- discretionary advisory services include, but are not limited to, developing and maintaining asset allocation, methodologies, and model portfolios for use by its affiliates. This Brochure covers the following Strategic Advisers products and services: Fidelity® Charitable Gift Fund, registered investment companies, and management, consulting, and model delivery services. For information about the additional services that Strategic Advisers provides, please see Strategic Advisers’ other Form ADV, Part 2A brochures. Fidelity Investments® Charitable Gift Fund ("Charitable Gift Fund" or “CGF”) Strategic Advisers performs discretionary and non-discretionary investment management services for IRS-qualified charitable organizations, including the Charitable Gift Fund, by recommending affiliated and unaffiliated mutual funds for investment portfolios composed of irrevocable contributions from individual and institutional donors. In this capacity, Strategic Advisers acts as adviser to the charitable organization and not as adviser to any donor to such organization. Strategic Advisers Mutual Funds (collectively, the “Strategic Advisers Funds” or “Funds”) Strategic Advisers serves as adviser to investment companies registered under the Investment Company Act of 1940 (“1940 Act”). Strategic Advisers acts as adviser to Funds that use both a multi- manager and fund-of-funds investment structure. The fund-of-funds managed by Strategic Advisers primarily invest in a combination of underlying affiliated and unaffiliated equity, fixed-income, and short-term mutual funds; real estate investment trusts (“REITs”); exchange-traded funds (“ETFs”); and funds that have commodity exposure. The Funds that use a multi-manager and a fund-of-funds investment structure are also permitted to invest directly in securities through one or more affiliated or unaffiliated sub-advisers. The Strategic Advisers Funds are offered only to clients of Strategic Advisers who have granted discretionary authority to Strategic Advisers to invest in a portfolio of mutual funds. To the extent permitted by its advisory contracts, Strategic Advisers is authorized to delegate investment discretion to affiliated or unaffiliated sub-advisers that manage all or a portion of the assets within a Fund. Management, Consulting, and Model Delivery Services Management and consulting services offered by Strategic Advisers are designed to meet various investment needs of certain institutional clients and Strategic Advisers affiliates. Strategic Advisers provides services to its affiliates offering products and services to their clients or customers, that 4  include, but are not limited to, methodologies, algorithms, tools, asset allocation, risk modeling and portfolio analysis, due diligence, and oversight services. Strategic Advisers also constructs non- discretionary model portfolios for use by affiliates. The scope and duration of such services are negotiated for each engagement. FIWA Model Portfolio Delivery Strategic Advisers has been retained by its affiliate, Fidelity Institutional Wealth Adviser LLC (“FIWA”), to provide non-discretionary model portfolios (“Model Portfolios”) that are constructed from the universe of mutual funds and exchange-traded products (“ETPs”), including exchange-traded funds (“ETFs”), selected for consideration by FIWA (“Investable Universe”). FIWA distributes Model Portfolios to financial institutions, such as banks, broker-dealers, and other investment advisers (each, an “Intermediary” and collectively, the “Intermediaries”). Strategic Advisers does not have an advisory relationship with an Intermediary or any of the Intermediaries clients who access the Model Portfolios. Assets Under Management As of December 31, 2025, Strategic Advisers’ total assets under management were $1,321,075,214,792 on a discretionary basis and $49,050,110,419 on a non-discretionary basis. FEES AND COMPENSATION Charitable Gift Fund Fees and terms for investment advisory services provided to charitable institutions, including the Charitable Gift Fund, are negotiated on a case-by-case basis and generally based on assets under management or advisement. With respect to the Charitable Gift Fund, if such services are terminated during any period for which Strategic Advisers has or has not been compensated, the fee due to Strategic Advisers for such period shall be prorated to the date of termination. Strategic Advisers’ affiliate, National Charitable Services Corporation (“NCS”), a Fidelity Investments company, will generally receive compensation for administrative and investment services provided to CGF under a separate Master Services Agreement. In the absence of any other arrangements, Strategic Advisers’ compensation for its discretionary and non-discretionary investment advisory services shall be paid to Strategic Advisers out of the aggregate NCS administrative services fee payable under the Master Services Agreement, pursuant to an arrangement between Strategic Advisers and NCS. The Charitable Gift Fund will pay the mutual fund expenses associated with the respective mutual funds recommended or selected by Strategic Advisers as investments for the pools advised by Strategic Advisers. Fund expenses, which vary by fund and share class, are expenses that mutual fund shareholders typically pay. Details of a mutual fund’s expenses can be found in its prospectus. These expenses are not separately itemized or billed; rather, the published returns of mutual funds are shown net of their expenses. The overall revenue received by affiliates of Strategic Advisers will vary based on the funds suggested or selected by Strategic Advisers; accordingly, Strategic Advisers has an 5  economic incentive and a potential conflict of interest to suggest funds that pay more revenue to its affiliates. However, for the non-discretionary assets that Strategic Advisers oversees, the investments to be used are reviewed and approved by the CGF Board of Trustees as part of the investment mandate for such non-discretionary pools prior to the inclusion of any such fund. In addition, for both non-discretionary assets overseen by Strategic Advisers and the discretionary assets that Strategic Advisers manages as part of CGF, the portfolio managers with responsibility for the investment recommendations and management of the assets and related portfolio management staff are compensated based on the performance of the underlying investments recommended or selected, and no portion of the compensation of these Strategic Advisers personnel is based on the percentage of affiliated funds used in CGF or the revenue that Strategic Advisers or its affiliates derive from the purchase of any underlying affiliated or unaffiliated fund by CGF. Furthermore, all investments used in both the discretionary and non-discretionary portfolios are reviewed with the CGF Board of Trustees on a periodic basis. Strategic Advisers Funds For the Strategic Advisers Funds, Strategic Advisers receives a management fee based on a Fund’s average net assets. For Funds that employ sub-advisers, sub-advisory fees are paid by the Funds, based on contractual terms with such sub-advisers. In certain circumstances, Strategic Advisers either charges no management fee or, from time to time, will voluntarily or contractually agree to reimburse certain of its mutual fund clients for management fees and other expenses above a specified limit. Strategic Advisers retains the ability to be repaid by such clients if expenses fall below the specified limit prior to the end of the client fiscal year. Reimbursement arrangements can decrease a Fund’s expenses and enhance its performance. Voluntary reimbursement arrangements can be discontinued by Strategic Advisers at any time. In the case of the Funds, the advisory contract with Strategic Advisers is subject to approval by the Board of Trustees for the relevant Fund, including trustees who are not interested persons of each Fund (as defined in the 1940 Act, the “Independent Trustees”). Strategic Advisers’ fees for providing these services are negotiated on an individual basis and vary significantly among Funds. Fees charged to mutual fund clients are subject to negotiation prior to the initiation of Strategic Advisers’ services. Compensation to Strategic Advisers is deducted from a Fund’s assets and payable on a monthly basis at the end of the month or on such other terms as Strategic Advisers and the particular Fund from time to time agree. In accordance with the Investment Company Act of 1940, any investment advisory agreement concerning a Fund will terminate within two years of the effective date of the investment advisory agreement unless renewed by the Fund in a manner permitted by Section 15 of the 1940 Act. Any such agreement shall also terminate upon assignment or upon sixty (60) days advance written notice by any party to the agreement or by the Fund concerned. In addition to any management fee payable to Strategic Advisers and the fees payable to the transfer agent and pricing and bookkeeping agent, and the costs associated with securities lending, most funds in the Fidelity group of funds or classes thereof, as applicable, pay all of their expenses that are not assumed by those parties. Most Funds pay for the typesetting, printing, and mailing of their proxy materials to shareholders; legal expenses; and the fees of the custodian, auditor, and Independent Trustees. Most Funds’ management contracts further provide that the Fund will pay for typesetting, printing, and mailing of prospectuses, statements of additional information, notices, and reports to 6  shareholders; however, under the terms of Strategic Advisers’ transfer agent agreement, the transfer agent bears these costs. Other expenses paid by a Fund include interest, taxes, brokerage commissions, the Fund’s proportionate share of insurance premiums and Investment Company Institute dues, and the costs of registering shares under federal securities laws and making necessary filings under state securities laws. A Fund is also liable for such non-recurring expenses that arise, including costs of any litigation to which the Fund is a party, and any obligation the Fund must indemnify its officers and trustees with respect to litigation. For information regarding Strategic Advisers’ brokerage arrangements with respect to the Funds, please see the section entitled “Brokerage Practices.” Management, Consulting, and Model Delivery Services Fees and terms for asset management, model portfolio services, and risk modeling services to institutions are negotiated on a case-by-case basis and are generally based on assets under management. Fees and terms for the other management, consulting, and non-discretionary services to institutional clients and affiliates will vary and are negotiated on a case-by-case basis. Strategic Advisers is compensated by its affiliates for the development and delivery of model portfolios. Fidelity also has arrangements to receive compensation from other third-party ETP sponsors for making certain ETPs available on Fidelity’s brokerage platform commission free. If a model portfolio includes such third-party ETPs in the model portfolio, Fidelity is entitled to receive compensation from the ETP sponsor for any accounts custodied on Fidelity’s brokerage platform that elect to invest in such model portfolios. Additional information about the sources, amounts, and terms of compensation is described in the ETP's prospectus and related documents. The mutual fund share classes for a given model portfolio fund to be used in such model portfolios are selected by Strategic Advisers’ affiliates based on various considerations including revenue yield to such affiliates and other affiliates of Strategic Advisers. FIWA Model Portfolio Delivery As part of the Model Portfolio arrangement with FIWA, certain Model Portfolios include Fidelity mutual funds, ETFs, and ETPs, which are subject to fees, as provided for in the prospectus to each such mutual fund, ETF or ETP (“Fidelity Funds”). In addition, ETFs advised by BlackRock Investment Management, LLC (or one of its affiliates, collectively “BlackRock”), such as iShares® ETFs, can be included in the Investable Universe. The fees received from Fidelity Funds will be shared by various affiliates of Strategic Advisers involved in distributing and advising the Fidelity Funds. Each Fidelity Fund incurs advisory, administrative, and custodial fees, as well as other fees and expenses that it pays out of the assets of each mutual fund or ETP, meaning such costs are indirectly borne by the shareholders of each applicable mutual fund or ETP. Additional information about the expense ratio of any specific Fidelity Fund is available in the applicable prospectus. Within a given Model Portfolio, the cost to shareholders and benefits to Strategic Advisers’ affiliates across the Model Portfolio will vary. As a result, an economic incentive exists for Strategic Advisers when constructing model portfolios to include allocations to underlying mutual funds and ETPs that pay additional revenue to its affiliates. However, conflicts of interest associated with this potential incentive are mitigated as further described in this Brochure. Strategic Advisers does not select the 7  investment universe for Model Portfolios and Model Portfolios are constructed by Strategic Advisers’ portfolio management team using a systematic approach, in conjunction with a quantitative methodology. In addition, the amount paid to Strategic Advisers and its employees under the services does not vary based on the underlying funds and ETPs selected when constructing the Model Portfolios and the compensation arrangements for Strategic Advisers’ investment professionals do not vary based on the underlying funds and ETPs selected for such Model Portfolios. Strategic Advisers is compensated by FIWA for the development and delivery of Model Portfolios in connection with the model portfolio services provided by FIWA. Intermediaries who utilize the Model Portfolios do not pay any compensation to Strategic Advisers. As further described in “Client Referrals and Other Compensation” below, Fidelity receives compensation from BlackRock in connection with a marketing program. The applicable share classes for a given Fidelity Fund included in the Investable Universe for the Model Portfolios are limited to the share classes selected by FIWA. FIWA does not always seek to include mutual funds or share classes in the Investable Universe that are necessarily the least expensive. Other affiliated funds have different fees and expenses, which could be lower than the fees and expenses of the Fidelity Funds and mutual fund share classes included in the Investable Universe. In some cases, the mutual fund share classes for a Fidelity Fund have a lower cost share class available on a stand-alone basis for purchase or are available to other types of investors. Investors who hold a less-expensive share class of a fund will pay lower fees over time – and earn higher investment returns – than investors who hold a more expensive share class of the same fund. PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT Strategic Advisers does not currently charge performance-based management fees for any of its advisory services and, therefore, does not engage in side-by-side management. TYPES OF CLIENTS Charitable Gift Fund Strategic Advisers provides discretionary and non-discretionary investment advice to the Charitable Gift Fund, an IRS-qualified charitable organization, by recommending affiliated and unaffiliated mutual funds and ETFs for investment portfolios composed of irrevocable contributions from individual and institutional donors. Strategic Advisers Funds Strategic Advisers offers investment management services on listed equities, ETPs, mutual fund shares, bonds, derivatives, or other securities in connection with its service as adviser to the Strategic Advisers Funds. 8  Management, Consulting, and Model Delivery Services Strategic Advisers provides management, consulting, and model delivery services to its affiliates. Management and consulting arrangements can include asset allocation, risk modeling and portfolio analysis, due diligence, and oversight services. Strategic Advisers develops and delivers a range of methodologies and model portfolios services, and provides resources to affiliates offering non- discretionary investment advisory services. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Charitable Gift Fund Through an Investment Management Agreement with CGF, Strategic Advisers renders discretionary and non-discretionary investment management services by investing in and/or recommending Fidelity and non-Fidelity mutual funds and ETFs it deems appropriate for use in a number of investment portfolios composed of CGF assets derived from irrevocable and tax-deductible contributions from individual and institutional donors. Strategic Advisers relies on both proprietary fundamental and quantitative fund research in managing or providing investment advice. Factors considered when investing in underlying funds include fund performance, a fund manager’s experience and investment style, fund company infrastructure, and fund characteristics such as expense ratio, asset size, and portfolio turnover. With respect to the sub- portfolios where Strategic Advisers provides discretionary investment management services, Strategic Advisers pursues a disciplined, benchmark-guided approach to portfolio construction, and monitors and adjusts allocations to underlying funds as necessary to attempt to control overall fund risk and pursue appropriate returns. With respect to investments made for CGF, the available investment universe for each sub-portfolio is determined by contract in conjunction with CGF. Strategic Advisers has implemented oversight processes and controls designed to achieve an appropriate level of supervision of the selected funds’ activities and reports out to the CGF Board of Trustees on these processes and controls. While Strategic Advisers selects the underlying funds of the sub-portfolios and has implemented a program to provide ongoing oversight of their activities, the funds’ managers make the day-to-day investment decisions for the funds they manage. With respect to the discretionary management services provided to CGF, Strategic Advisers will review the share classes offered by identified funds and seek to choose the appropriate share class that is available for purchase by CGF. Strategic Advisers Funds Strategic Advisers is authorized to invest (depending on the specific product or fund) a Fund’s assets in a combination of securities, including derivatives (e.g., futures contracts); affiliated (e.g., Fidelity funds) and unaffiliated domestic and international equity funds; investment grade, high- yield and international fixed- income funds; short-term funds; alternative investment class funds; and ETFs and closed-end funds. In general, Strategic Advisers will evaluate the mutual funds available through Fidelity’s mutual fund platform, FundsNetwork®, and make mutual fund investment determinations 9  based on investment methodology. To the extent permitted by its advisory contracts, Strategic Advisers is authorized to delegate investment discretion to affiliated and unaffiliated sub-advisers for management of all or part of the Fund. Multi-manager and fund-of-funds structures. Strategic Advisers’ multi-manager funds and fund-of- funds allow Strategic Advisers to choose from an expanded group of Fidelity and non-Fidelity money managers, taking advantage of Fidelity’s scale to provide the potential for improved pricing through the use of sub-advisers. The multi-manager funds and fund-of-funds are structured so that Strategic Advisers can hire sub-advisers to manage sub-portfolios of individual securities, buy and sell mutual funds and ETFs, and hold all these securities within one Fund. A Strategic Advisers portfolio manager manages each multi-manager fund and fund-of-funds by allocating the Fund’s assets between Fidelity and non-Fidelity sub-advisers, mutual funds, ETFs, and derivatives. In managing the Funds that use a multi-manager and fund-of-funds investment structure, Strategic Advisers considers a variety of factors when determining how to allocate the respective Funds’ assets among sub-advisers, funds, and/or other securities, including, but not limited to, investment approach, portfolio characteristics, performance patterns in different market environments, and the total assets of the fund. While Strategic Advisers selects the sub-advisers and has implemented a program to provide ongoing oversight of their activities, the sub-advisers of the Fund make the day-to-day investment decisions for the portions of the Fund they manage. Strategic Advisers is authorized to allocate each Fund’s assets among any number of sub-advisers or underlying funds at any time. Regulatory restrictions limit the amount that one fund can invest in another, which means that the Funds are limited in the amount they can invest in any particular underlying fund. For more information on the investment strategies employed by the multi-manager funds and fund-of-funds, please see the prospectuses for those Funds. With respect to the discretionary management services provided to the Funds, Strategic Advisers will review the share classes offered by identified funds and seek to choose the share class of a fund that is appropriate for clients after the application of a credit amount that is applicable to clients in the Fidelity Wealth Services program. The credit amount is intended to address the conflicts of interest that arise in selecting investments that generate revenue for Fidelity by reducing the advisory fees paid to Fidelity by the amount of compensation, if any, Strategic Advisers or its affiliates retain that is derived as a direct result of the investments by Fidelity Wealth Services program accounts. Please see the Fidelity Wealth Services Form ADV, Part 2A brochure for additional information about the fees and credit amount applicable to that managed account program. FIWA Model Portfolios Strategic Advisers constructs the Model Portfolios from an Investable Universe of mutual funds, ETPs, and ETFs provided by FIWA. The Model Portfolios are portfolios designed to implement specified strategies and can be aligned to specified fixed income/equity allocations. In certain cases, the Model Portfolios include an allocation to cash. 10  The Fidelity Funds used in the Model Portfolios represent only a subset of all affiliated mutual funds, affiliated ETPs, and third-party funds/ETPs. The universe of Fidelity Funds has been selected by FIWA for inclusion based on eligibility for the mutual funds or ETPs to be distributed as part of the model portfolio services provided by FIWA to their Intermediary clients, as well as other measures designed to be consistent with the model parameters around the asset allocation goals of the model, expenses, asset classes, internal guidelines, and the interests of Intermediaries and whether such products result in compensation to Fidelity. Affiliates of Strategic Advisers manage mutual funds and ETPs that can be similar to the Fidelity Funds but have different fees and expenses that are not available for investment through the model portfolio service offered by FIWA. Model portfolios provided to FIWA are constructed by Strategic Advisers’ portfolio management team using a systematic approach, in conjunction with a quantitative methodology, for selecting mutual funds and ETPs from the Investable Universe. When constructing certain model portfolios, Strategic Advisers uses an algorithmic approach to combine a set of investment options whose overall risk characteristics, when viewed as a portfolio, are designed to be similar to those of an appropriate asset allocation strategy for a particular risk profile. An important objective of this process is to enhance expected risk-adjusted returns while adhering to this set of risk constraints. These strategies use a series of long-term asset allocation benchmarks as a basis for portfolio construction; these benchmarks consist of weighted market index benchmarks designed to represent an appropriate asset- class mix for a given investor profile, from conservative to aggressive growth. Using the outcome of the evaluation described above, the portfolio construction process identifies the model portfolio based on the long-term asset allocation benchmarks for stock, bond, and/or short-term asset classes. For certain other model portfolios, Strategic Advisers uses an algorithmic approach to combine a set of investment options designed to maximize yield for a particular risk profile. As noted above, in selecting third-party ETPs for inclusion in model portfolios, Strategic Advisers will select among ETPs advised by BlackRock, including iShares® ETFs and ETPs managed by other third parties. Each mutual fund and/or ETP included in the asset allocation model portfolios bears the risks as described in that fund’s registration statement. Equity and fixed income securities included in model portfolios include securities in various markets, including the U.S. and foreign markets, which are subject to the risks described below. Additional General Information Strategic Advisers establishes internal limits, and can be subject to external limits, on how much it will invest client accounts in Fidelity and non-Fidelity mutual funds or ETPs. Strategic Advisers can also consult fund managers to understand the manager’s guidelines or policies, if any, concerning fund share ownership limits. Strategic Advisers can work closely with fund managers to minimize the impact of its reallocation activities. There are certain situations when fund investment and redemptions can be accomplished over an extended period of time as a result of operational considerations, legal considerations, or input from underlying fund managers. Due to regulatory and issuer-specific limits that apply to the ownership of securities of certain issuers, Strategic Advisers and its affiliates could limit investments in the securities of such issuers. Similar limitations could apply to futures and derivatives, such as options. In addition, Strategic Advisers 11  and/or its affiliates can from time to time determine that, because of regulatory requirements that apply to Strategic Advisers and/or its affiliates due to investments in a particular country or in an issuer operating in a particular regulated industry, investments in the securities of issuers domiciled or listed on trading markets in that country or operating in that regulated industry above certain thresholds are impractical or undesirable. The foregoing limits and thresholds could apply at the account level or in the aggregate across all accounts (or certain subsets of accounts) managed, sponsored, owned by, or otherwise attributable to Strategic Advisers and its affiliates. For investment risk management and other purposes, Strategic Advisers and its affiliates also generally apply internal aggregate limits on the amount of a particular issuer’s securities that can be owned by all such accounts. In connection with the foregoing limits and thresholds, Strategic Advisers can limit or exclude clients’ investment in a particular issuer, future, derivative, and/or other instrument (or limit the exercise of voting or other rights), and investment flexibility will be restricted. In addition, to the extent that client accounts already own securities that directly or indirectly contribute to such an ownership threshold being exceeded, Strategic Advisers could sell securities held in such accounts in order to bring account-level and/or aggregate ownership below the relevant threshold. In the event that any such sales result in realized losses for client accounts, those client accounts will bear such losses depending on the particular circumstances. Strategic Advisers or its affiliates provide certain investment management personnel to, or use the investment management personnel of, certain affiliated investment advisers under personnel sharing arrangements or other inter-company agreements. MATERIAL INVESTMENT RISKS Risk of loss. Many factors affect each investment or account’s performance and potential for loss. Strategies that pursue investments in equities will be subject to stock market volatility and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Strategies that pursue fixed-income investments (such as bond or money market funds) will see values fluctuate in response to changes in interest rates, inflation and prepayment risks, as well as default risks for both issuers and counterparties; changing interest rates, including rates that fall below zero, can have unpredictable effects on markets and can result in heightened market volatility. Developments that disrupt global economies and financial markets, such as war, acts of terrorism, the spread of infectious illness or other public health issues, recessions, or other events, can magnify factors that affect performance. These strategies are also affected by impacts to the individual issuers, such as changes in an issuer’s credit quality, or changes in tax, regulatory, market, or economic developments. In addition, investments in certain bond structures are less liquid than other investments and, therefore, are more difficult to trade effectively. Non-diversified funds and accounts that invest in a smaller number of individual issuers can be more sensitive to these changes. Nearly all investments or accounts are subject to volatility in non-U.S. markets, either through direct exposure or indirect effects on U.S. markets from events abroad including fluctuations in foreign currency exchange rates and, in the case of less-developed markets, currency illiquidity. Those investments and accounts that are exposed to emerging markets are potentially subject to heightened volatility from greater social, economic, regulatory, and political uncertainties, as the extent of economic development, political stability, market depth, infrastructure, capitalization, and regulatory oversight can be less than in more developed markets. 12  Trading, settlement, and custodial practices (including those involving securities settlement where fund or account assets could be released prior to receipt of payment) in non-U.S. markets could be less developed than those in U.S. markets and could result in increased investment or valuation risks, increased counterparty exposure, or substantial delays (including those arising from failed trades or the insolvency of, or breach of duty by, a broker-dealer, securities depository, sub-custodian, clearinghouse, or other party). Additionally, investments or accounts that pursue debt exposure are subject to risks of prepayment or default, and funds or accounts that pursue strategies that concentrate in particular industries or are otherwise subject to particular segments of the market (e.g., money market funds’ exposure to the financial services industry, municipal funds’ exposure to the municipal bond market, or foreign or emerging markets funds’ exposure to a particular country or region) can be significantly impacted by events affecting those industries or markets. Strategies that lead funds or accounts to invest in other funds bear all the risks inherent in the underlying investments in which those funds invest, and strategies that pursue leveraged risk, including investment in derivatives – such as swaps (interest rate, total return, and credit default), futures contracts – and forward-settling securities, magnify market exposure and losses. Ultimately, an investment or account’s share price and/or net asset value changes daily based on changes in market conditions, foreign currency exchange rates, and interest rates, and in response to other economic, political, or financial developments. An investment or account’s reaction to these events will be affected by the types of securities in which the mutual fund, ETP, or account invests; the financial condition, industry and economic sector, and geographic location of an issuer; and the level of investment in the securities of that issuer. An investment in such securities involves risk of loss that clients of the mutual fund, ETP, or account would, and should, be prepared to bear. When a shareholder sells or redeems shares in the mutual fund or ETP, the shares could be worth more or less than what the shareholder paid for them, which means that the shareholder could lose money by investing in the fund or ETP. Similarly, an account owner could lose money due to a decline in the account’s net asset value. With respect to Strategic Advisers’ mutual funds, more detailed information relating to the methods and strategies and their associated risk are set forth in that fund or account’s prospectus and registration statement filed with the SEC or other applicable offering document. Cybersecurity Risks. With the increased use of technologies to conduct business, Strategic Advisers and its affiliates are susceptible to operational, information security, and related risks. These risks could include events that are wholly or partially beyond our control and may have a negative effect on our ability to conduct business activities. We believe that we have taken reasonable steps to mitigate these risks, but do not believe we can eliminate them altogether. In general, cyber incidents can result from deliberate attacks or unintentional events that may arise from external or internal sources. Cyberattacks include but are not limited to gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software coding) for purposes of misappropriating assets or sensitive information; corrupting data, equipment, or systems; and causing operational disruption. Cyberattacks can also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). Cyber incidents affecting Strategic Advisers, its affiliates, or any other service providers 13  (including but not limited to accountants, custodians, transfer agents, and financial intermediaries used by Fidelity or by an issuer of securities) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, interference with the ability to calculate asset prices, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities in which an account invests, counterparties with which an account engages in transactions, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. Operational Risks. Operational risks can include risk of loss arising from failures in internal processes, people, or systems, such as routine processing incidents or major systems failures, or from external events, such as exchange outages. Strategic Advisers uses algorithms in support of its discretionary portfolio management process. There is a risk that the data input into the algorithms could have errors, omissions, imperfections, or that the algorithms do not operate as intended. Any decisions made in reliance on incorrect data or algorithms that do not operate as intended can expose clients to potential risks. Issues in the algorithms are often extremely difficult to detect and could go undetected for long periods of time or never be detected. These risks are mitigated by testing and human oversight of the algorithms and their output. We believe that the oversight and testing of our algorithms and their output will enable us to identify and address issues appropriately. However, there is no assurance that the algorithms will always work as intended. In general, we will not assess each account individually, nor will we override the outcome of any algorithm with respect to any particular account. Not all incidents arising from operational failures, including those resulting from the mistakes of third parties, will be compensable by Strategic Advisers to a client. Strategic Advisers maintains policies and procedures that address the identification and correction of errors, consistent with the applicable standards of care, to ensure that clients are treated fairly when an error has been detected. The determination of how to assess an incident, and whether it constitutes an error, is made by Strategic Advisers or its affiliates, in their sole discretion. Incidents will be reviewed to determine whether there was a financial impact on accounts, and to evaluate the materiality of the impact. If we determine that a material financial impact has occurred, we will make an appropriate correction or otherwise reimburse the account in an amount Strategic Advisers or its affiliates determines is appropriate based on all relevant circumstances. Unless prohibited by applicable regulation or a specific agreement with the client, we can net a client’s gains and losses from the error or a series of related errors with the same root cause and compensate clients for the net loss. This corrective action could result in financial or other restitution to an account, or inadvertent gains being reversed out of the account. Examples on impact that could affect the performance of an account but would not be material include impacts arising from computer, communications, data processing, network, cloud computing, backup, business continuity or other operating, information, or technology systems, including those we outsource to other providers, could fail to operate properly or become disabled, overloaded or 14  damaged as a result of a number of factors. These factors could include events that are wholly or partially beyond our control and could have a negative impact on our ability to conduct business activities. Though losses arising from operating, information, or technology systems failures could adversely affect the performance of a client account, such losses would likely not be reimbursable under Strategic Advisers’ policies and procedures. Typically, incidents or errors that result in a financial impact of less than $10 per account are not considered material. In such cases, we have instituted controls designed to prevent Fidelity from receiving economic benefits from limiting the correction of such errors. All errors requiring reimbursement to a Fidelity affiliated mutual fund of $100,000 or more must be reported to the Compliance Committee (or other applicable Committee) of the fund’s Board of Trustees at its next scheduled meeting. Underlying investments recommended or purchased by Strategic Advisers are subject to the following material investment risks: Investing in Mutual Funds and ETPs. An individual account bears all the risks of the investment strategies employed by the mutual funds and ETPs held in the account, including the risk that a mutual fund or ETP will not meet its investment objectives. For the specific risks associated with a mutual fund or ETP, please see its prospectus. An ETP is a security that trades on an exchange and can seek to track an index, a commodity, or a basket of assets. ETPs can be actively or passively managed. ETPs trade on secondary markets or exchanges and are exposed to market volatility and the risks of the ETP’s underlying securities. ETP share trading can be halted or the security could cease to trade on an exchange. Trading volume and liquidity can vary and could affect the ability to buy or sell shares or could cause the market price of shares to experience significant premiums or discounts relative to the value of the assets underlying the shares. Because ETPs trade on exchanges, buyers and sellers experience a spread between the bidding price and the asking price, and the size of these spreads can vary significantly. Money Market Funds. An investor could lose money by investing in a money market fund. Although the money market fund seeks to preserve the value of an investment at $1.00 per share, it cannot guarantee it will do so. An investment in a money market fund is not a bank account and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Fidelity, the sponsor of Fidelity’s money market funds, is not required to reimburse money market funds for losses, and a client should not expect that Fidelity will provide financial support to a Fidelity money market fund, at any time, including during periods of market stress. Fidelity’s government and U.S. Treasury money market funds will not impose a fee upon the sale of a client’s shares. Quantitative Investing. Funds or securities selected using quantitative analysis can perform differently from the market as a whole as a result of the factors used in the analysis, the weight placed on each factor, changes to the factors’ behavior over time, market volatility, or the quantitative model’s assumption about market behavior. In addition, Strategic Advisers’ quantitative investment strategies rely on algorithmic processes, and, therefore, are subject to the risks described above under the heading, “Operational Risks.” 15  Stock Investments. Stock markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Different parts of the market can react differently to these developments. Value and growth stocks can perform differently from other types of stocks. Growth stocks can be more volatile. Value stocks can continue to be undervalued by the market for long periods of time. In addition, stock investments are subject to risk related to market capitalization, as well as company-specific risk. Bond Investments. In general, the bond market is volatile, and fixed-income securities carry interest rate risk. As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities. During periods of very low or negative interest rates, we could be unable to maintain positive returns on bond investments. Very low or negative interest rates can magnify interest rate risk for the markets as whole and for individual bond investments. Changing interest rates, including rates that fall below zero, can also have unpredictable effects on markets, and can result in heightened market volatility. The ability of an issuer of a bond to repay principal prior to a security’s maturity can cause greater price volatility, and if a bond is prepaid, a bond fund could have to invest the proceeds in securities with lower yields. Fixed-income securities also carry inflation risk, as well as credit and default risks for both issuers and counterparties. The interest payments of inflation-protected bonds are variable and usually rise with inflation and fall with deflation. Unlike individual bonds, most bond funds do not have a maturity date, so holding them until maturity to avoid losses caused by price volatility is not possible. In addition, investments in certain bond structures are less liquid than other investments and, therefore, are more difficult to trade effectively. Foreign Exposure. Investing in foreign securities and securities of U.S. entities with substantial foreign operations are subject to interest rate, currency exchange rate, economic, tax, operational, regulatory, and political risks, all of which are likely to be greater in emerging markets. These risks are particularly significant for investment strategies that focus on a single country or region or emerging markets, or for clients who elect to increase foreign stock exposure. Foreign markets can be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile. Foreign markets can also offer less protection to investors than U.S. markets. For example, foreign issuers are generally not bound by uniform accounting, auditing, and financial reporting requirements and standards of practice comparable to those applicable to U.S. issuers. Adequate public information on foreign issuers might not be available, and it could be difficult to secure dividends and information regarding corporate actions on a timely basis. Regulatory enforcement can be influenced by economic or political concerns, and investors could have difficulty enforcing their legal rights in foreign countries. Foreign governments may decide to seize or confiscate securities held by foreign investors or assets held by foreign issuers, restrict an investor's ability to sell or redeem securities, suspend or limit an issuer's ability to make dividend or interest payments, and/or limit or entirely restrict repatriation of invested capital, profits, and dividends. Furthermore, investments in securities of foreign entities can result in clients owning an interest in a “passive foreign investment company” (“PFIC”). Clients holding an interest in a PFIC could be subject to additional tax liabilities and filing requirements as a result of such investments. The rules regarding investments in PFICs are complex, and clients are urged to consult with their tax advisors. 16  Credit Risk. Changes in the financial condition of an issuer or counterparty, and changes in specific economic or political conditions that affect a particular type of security or issuer, can increase the risk of default by an issuer or counterparty, which can affect a security or instrument’s credit quality or value. Lower-quality debt securities and certain types of other securities involve greater risk of default or price changes due to changes in the credit quality of the issuer. Derivatives. Certain funds and ETPs used by Strategic Advisers contain derivatives. Generally speaking, a derivative is a financial contract whose value is based on the value of a financial asset (such as a stock, bond, or currency), a physical asset (such as gold, oil, or wheat), or a market index (such as the S&P 500 Index). Investments in derivatives subject these funds to risks different from, and possibly greater than, those of the underlying securities, assets, or market indexes. Funds that invest in derivatives could experience losses if the underlying securities, assets, or market indexes do not perform as anticipated, and changes in the value of a derivative might not correlate as anticipated with the underlying securities, assets, or market indexes, thereby reducing their effectiveness. Some forms of derivatives, such as exchange traded futures and options on securities, commodities, or indexes, have been trading on regulated exchanges for decades. These types of derivatives are standardized contracts that can easily be bought and sold and whose market values are determined and published daily. Nonstandardized derivatives (such as swap agreements), on the other hand, tend to be more specialized or complex, can be more difficult to value, and are illiquid. Derivatives could involve leverage, because they can provide investment exposure in an amount exceeding the initial investment; certain derivatives require low margin deposits, which make it possible for a fund to employ a high degree of leverage. As a result, the use of derivatives can cause these funds to be more volatile, because leverage tends to exaggerate the effect of any increase or decrease in the value of a fund’s portfolio securities. Leverage can magnify investment risks and cause losses to be realized more quickly, and a small change in the underlying security, asset, or market index can lead to significant losses for a fund. Certain derivatives have the potential for unlimited losses, regardless of the size of the initial investment. Derivative investments are subject to credit risks associated with the issuer of, or counterparty to, the derivative investment. Alternative Investments. Alternatives are classified as assets whose investment characteristics and/or performance differ substantially from the primary asset classes (stocks, bonds, and short-term investments) and, therefore, offer opportunities for additional diversification and returns, but that also offer increased volatility and risk of loss due to their non-traditional or complex investment strategies. Strategic Advisers does not invest in unregistered privately offered alternative investment vehicles such as private equity, hedge funds, or similar investments (referred to as “private funds”) directly in Program Accounts; however, Strategic Advisers can invest in publicly available registered funds (referred to as “public funds”) that invest significantly in private funds and, therefore, clients could have indirect exposure to these types of investments. Generally speaking, public funds offer more investor protections as compared with private funds, including limits on illiquid investments and the use of leverage and derivatives, diversification requirements, daily pricing and liquidity features, regular reporting of fund holdings, and enhanced portfolio security valuation requirements. However, clients should understand that while public funds that invest in alternative investments offer greater protections as compared with private funds, both public and private funds that invest in alternative investments offer enhanced risks that clients should be aware of. Alternative investment strategies are not appropriate for all clients. 17  The performance of alternative investments can be volatile and private funds have extremely limited liquidity opportunities. Such investments often have concentrated positions, invest in illiquid investments, and can carry higher risks. Clients should understand that some alternative investment products often engage in leveraging and other speculative investment practices, including the use of derivatives, that can magnify the risk of investment loss and volatility regardless of whether they are used for speculative investment purposes or for the hedging of risk. In addition, private funds are not required to provide periodic pricing or valuation information to investors and can involve complex tax structures and delays in distributing important tax information. In many cases, the alternative investments underlying both public and private funds are not transparent and are known only to the investment manager of the alternative investment fund. Please refer to the applicable private or public fund’s offering documents or prospectus for additional information on the alternative investments used by the fund and their related risks. Real Estate. Real estate is a cyclical industry that is sensitive to interest rates, economic conditions (both nationally and locally), property tax rates, and other factors. Changes in real estate values or economic downturns can have a significant negative effect on issuers in the real estate industry. Commodity-Linked Investing. Commodity-linked investments can be leveraged and can be more volatile and less liquid than the underlying commodity, instruments, or measures. The performance of commodity-linked investments can be affected by the performance of individual commodities and the overall commodities markets, as well as by weather, political, tax, and other regulatory and market developments. A commodity-linked investment is subject to credit risks associated with the issuer of, or counterparty to, the commodity-linked investment. The commodities industries can be significantly affected by the level and volatility of commodity prices; the rate of commodity consumption; world events including international monetary and political developments; import controls, export controls, and worldwide competition; exploration and production spending; and tax and other government regulations and economic conditions. Currency Exposure. Certain funds and ETPs used by Strategic Advisers can be exposed to foreign currencies and, as a result, could experience losses based solely on the weakness of foreign currencies versus the U.S. dollar and changes in the exchange rates between foreign currencies and the U.S. dollar. Currency transactions tied to emerging markets can present market, credit, liquidity, legal, political, and other risks different from, or greater than, the risks of currency transactions tied to developed foreign countries. Illiquid Investments. Illiquid securities sometimes trade infrequently in the secondary market. As a result, valuing an illiquid security can be more difficult, and buying and selling an illiquid security at an acceptable price can be more difficult or delayed. Difficulty in selling an illiquid security can result in a loss. The relative liquidity of any investment, particularly those that trade on exchanges, can vary, at times significantly. Growth Investing. Growth stocks can react differently to issuer, political, market, and economic developments than the market as a whole and other types of stocks. Growth stocks tend to be more expensive relative to their earnings or assets compared with other types of stocks. As a result, growth stocks tend to be sensitive to changes in their earnings and more volatile than other types of stocks. 18  Value Investing. Value stocks can react differently to issuer, political, market, and economic developments than the market as a whole and other types of stocks. Value stocks tend to be inexpensive relative to their earnings or assets compared with other types of stocks. However, value stocks can continue to be inexpensive for long periods of time and, as a result, might never realize their full expected value. Legislative and Regulatory Risk. Investments could be adversely affected by new (or revised) laws or regulations. Changes to laws or regulations can impact the securities markets as a whole, specific industries, and individual issuers of securities. Generally, the impact of these changes will not be fully known for some time. Investment Research Risks and Limitations. The investment research process employed by Strategic Advisers includes gathering, cleaning, culling, and analyzing large amounts of data from external public sources and/or third-party data providers, including, in some instances, through the use of generative artificial intelligence ("AI") and large language models ("LLM"). It is not possible or practicable, however, to factor all relevant, available data into economic forecasts or trading decisions. In addition, due to the automated nature of this data gathering and the fact that much of this data comes from third-party sources, it is inevitable that not all desired or relevant data will be available to, or processed by, Strategic Advisers at all times. Clients should be aware that there is no guarantee that the data used in generating forecasts or making trading decisions will be the most accurate data available or even free of errors. Furthermore, the use of AI and LLMs may require training of the models to be used in the research process and proper engagement by analysts in order to yield the desired outcome. There can be no guarantee that LLMs can be trained to address all scenarios or that they will provide complete and accurate responses in all situations. AI and LLMs are subject to various risks, including (1) the data used to train LLMs suffers inaccuracies, biases, or flaws that may cause the AI model to respond other than as intended; (2) weak controls in the development and use of AI allow it to be deployed for use cases for which it was not intended; and (3) the AI may provide inaccurate or fabricated responses to queries it is unable to process. Fidelity has adopted a Generative AI policy and governance framework so that the use of AI and LLMs is targeted and limited, and that AI and LLMs are trained using known and appropriate data sources and are subject to controls and oversight, which helps ensure that the use of AI and LLMs is but one input into the research process. Clients should assume that the foregoing limitation and risks associated with gathering, cleaning, culling and analyzing of large amounts of data from third parties and other external sources, and the use of AI and LLMs, are an inherent part of investing. There may also be incidents where data fails to load or internal systems fail to retrieve or capture the data, for example, because of changes in the vendor’s or our system configurations due to upgrades, enhancements, maintenance, or errors, or that LLMs provide incorrect information in response to certain prompts. Clients should assume that these data errors, like other system implementation errors, and their ensuing risks and impact are an inherent part of investing. Accordingly, unless otherwise required to do so, Strategic Advisers does not expect to disclose discovered data errors to clients. 19  DISCIPLINARY INFORMATION There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Strategic Advisers’ advisory business or the integrity of its management personnel. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Strategic Advisers is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is a wholly owned subsidiary of FMR LLC. FMR LLC is a Delaware limited liability company that, together with its affiliates and subsidiaries, is generally known to the public as Fidelity Investments or Fidelity. Various direct or indirect subsidiaries of FMR LLC are engaged in investment advisory, brokerage, banking, or insurance businesses. From time to time, Strategic Advisers and its clients will have material business relationships with any of the subsidiaries and affiliates of FMR LLC. In addition, the principal officers of Strategic Advisers serve as officers and/or employees of affiliated companies that are engaged in various aspects of the financial services industry. Strategic Advisers is not registered as a broker-dealer, futures commission merchant, or commodity trading advisor, nor does it have an application pending to register as such. Strategic Advisers is registered with the U.S. Commodity Futures Trading Commissions (“CFTC”) under the Commodity Exchange Act of 1936, as amended (“CEA”), as a commodity pool operator (“CPO”) and is a member of the National Futures Association (“NFA”). Certain personnel of Strategic Advisers, FBS, and National Financial Services share premises and have common supervision. In addition, certain management persons of Strategic Advisers are registered representatives of Fidelity Brokerage Services LLC (“FBS”) and Fidelity Distributions Company LLC (“FDC”), both Strategic Advisers affiliates and registered broker-dealers. In addition, Strategic Advisers has entered into an intercompany agreement with FBS, pursuant to which FBS provides to Strategic Advisers various operational, administrative, analytical, and technical services, and the personnel necessary for the performance of such services. Strategic Advisers has, and its clients could have, a material relationship with the following affiliated companies: Investment Companies and Investment Advisers • Fidelity Management & Research Company LLC (“FMRCo”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FMRCo provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FMRCo acts as sub- adviser to Strategic Advisers in providing discretionary portfolio management to certain clients and provides model portfolio recommendations and environmental filtering services to Strategic Advisers in connection with Strategic Advisers’ provision of discretionary portfolio management to certain clients. Strategic Advisers pays FMRCo an administrative fee for handling the business affairs of the registered investment companies advised by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FMRCo. 20  • Fidelity Institutional Wealth Adviser LLC (“FIWA”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FIWA provides non- discretionary investment advice to financial institutions in connection with the provision of model asset allocation portfolios (“Fidelity Model Portfolios”) and model-delivered separately managed accounts (“Fidelity Institutional Model SMAs”). FIWA also offers Fidelity Managed Account Xchange® and Fidelity Managed Account Xchange® Essentials, turn-key asset management programs, to financial intermediaries and provides separately managed account services to clients (“Fidelity Institutional Custom SMAs”). In addition, Strategic Advisers shares employees from time to time with FIWA. • FIAM LLC (“FIAM”), a wholly owned subsidiary of FIAM Holdings LLC, which in turn is wholly owned by FMR LLC, is a registered investment adviser under the Advisers Act, and is registered with the Central Bank of Ireland. FIAM provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. Strategic Advisers has sub-advisory agreements with FIAM for certain registered investment companies advised by Strategic Advisers. In addition, Strategic Advisers shares employees from time to time with FIAM. • FMR Investment Management (UK) Limited (“FMR UK”), an indirect, wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act, has been authorized by the U.K. Financial Conduct Authority to provide investment advisory and portfolio management services, and is registered with the Central Bank of Ireland. FMR UK provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR UK for certain registered investment companies advised by Strategic Advisers. • Fidelity Management & Research (Japan) Limited (“FMR Japan”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act and has been authorized by the Japan Financial Services Agency (Kanto Local Finance Bureau) to provide investment advisory and discretionary investment management services. FMR Japan provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub- advisory agreements with FMR Japan for certain registered investment companies advised by Strategic Advisers. • Fidelity Management & Research (Hong Kong) Limited (“FMR Hong Kong”), a wholly owned subsidiary of FMRCo, is a registered investment adviser under the Advisers Act, and has been authorized by the Hong Kong Securities & Futures Commission to advise on securities, deal in futures contracts, provide asset management services, and conduct trading services. FMR Hong Kong provides investment management services, including to registered investment companies in the Fidelity group of funds and to clients of other affiliated and unaffiliated advisers. FIAM has sub-advisory agreements with FMR Hong Kong for certain registered investment companies advised by Strategic Advisers. 21  • Fidelity Diversifying Solutions LLC (“FDS”) is a wholly owned subsidiary of FMR LLC and a registered investment adviser under the Advisers Act. FDS is registered with the CFTC under the CEA as a CPO and as a commodity trading advisor. FDS is a member of the NFA. FDS provides discretionary advisory and sub-advisory services. FDS acts as a sub-adviser to Strategic Advisers in providing discretionary portfolio management to certain clients. Broker-Dealers • FDC, a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Securities Exchange Act of 1934 (the “Exchange Act”). FDC acts as principal underwriter of business development companies and the registered investment companies in the Fidelity group of funds, and also markets those funds and other products to third-party financial intermediaries and certain institutional investors. • National Financial Services LLC (“NFS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker- dealer under the Exchange Act. NFS is a fully disclosed clearing broker-dealer that provides clearing, settlement, and execution services for other broker-dealers, including its affiliate FBS. Fidelity Capital Markets (“FCM”), a division of NFS, provides trade executions for Fidelity affiliates and other clients. Additionally, FCM operates CrossStream®, an alternative trading system ("ATS") that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. CrossStream is used to execute transactions for investment company and other clients. NFS provides transfer agent or subtransfer agent services and other custodial services to certain Fidelity clients. • LeveL Markets, LLC, a registered broker-dealer and operator of two alternative trading systems (“ATSs”), operates the Luminex ATS and the Level ATS, which allow orders submitted by subscribers to be crossed against orders submitted by other subscribers. LeveL Holdings, LLC, a Delaware LLC and holding company owns LeveL Markets, LLC. Fidelity Global Brokerage Group, Inc., and FMR Sakura Holdings, Inc., each a wholly owned subsidiary of FMR LLC, have membership interests in LeveL Holdings, LLC, along with other members. LeveL Markets, LLC charges a commission to both sides of each trade executed in the Luminex ATS and Level ATS. Luminex ATS and Level ATS are used to execute transactions for Fidelity affiliates’ investment company and other advisory clients. NFS serves as a clearing agent for transactions executed in the Luminex ATS and Level ATS. • Fidelity Brokerage Services LLC (“FBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker- dealer under the Exchange Act and provides brokerage products and services, including the sale of shares of registered investment companies in the Fidelity group of funds to individuals and institutions, including retirement plans, and acts as placement agent for certain privately offered investment funds advised by Strategic Advisers' affiliates. In addition, along with Fidelity Insurance Agency, Inc. (“FIA”), FBS distributes variable insurance products that are 22  issued by Fidelity Investments Life Insurance Company (“FILI”) and Empire Fidelity Investments Life Insurance Company® (“EFILI”), both Fidelity affiliates, as well as by third parties. FBS provides shareholder services to certain of Fidelity’s clients. FBS is the introducing broker for managed accounts offered by Strategic Advisers and places orders for execution with its affiliated clearing broker, NFS. • Digital Brokerage Services LLC (“DBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker- dealer under the Exchange Act. DBS provides securities brokerage to retail customers through a digital/mobile application-based brokerage platform. DBS receives remuneration from FMRCo for expenses incurred in servicing and marketing FMRCo products. Insurance Companies or Agencies • FILI, a wholly owned subsidiary of FMR LLC, is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates. • EFILI is a wholly owned subsidiary of FILI and is engaged in the distribution and issuance of life insurance and annuity products that offer shares of registered investment companies managed by Fidelity affiliates to residents of New York. • FIA, a wholly owned subsidiary of FMR LLC, is engaged in the business of selling life insurance and annuity products of affiliated and unaffiliated insurance companies. Banking Institutions • Fidelity Management Trust Company (“FMTC”), a wholly owned subsidiary of FMTC Holdings LLC, which in turn is wholly owned by FMR LLC, is a limited-purpose trust company organized and operating under the laws of the Commonwealth of Massachusetts that provides non-discretionary trustee and custodial services to employee benefit plans and individual retirement accounts through which individuals can invest in affiliated or unaffiliated registered investment companies. FMTC also provides discretionary investment management services to institutional clients. • Fidelity Personal Trust Company, FSB, a wholly owned subsidiary of Fidelity Thrift holding Company, Inc., which in turn is wholly owned by FMR LLC, is a federal savings bank that offers fiduciary services that include trustee or co‐trustee services, custody, principal and income accounting, investment management services, and recordkeeping and administration. Limited Partnerships and Limited Liability Company Investments Strategic Advisers provides discretionary investment management to partnerships and limited liability companies designed to facilitate acquisitions by mutual funds offered by Strategic Advisers. These 23  funds are privately offered consistent with stated investment objectives. Strategic Advisers does not currently engage in borrowing, lending, purchasing securities on margin, short selling, or trading in commodities. Participating Affiliate Certain employees of Fidelity Strategic Advisers Ireland, Limited (“Strategic Ireland”) can from time to time provide certain services, including but not limited to research, operations, and investment management support services for Strategic Advisers, which Strategic Advisers can use for its clients. Strategic Ireland is not registered as an investment adviser under the Advisers Act and is deemed to be a “Participating Affiliate” of Strategic Advisers (as this term has been used by the SEC’s Division of Investment Management in various no-action letters granting relief from the Advisers Act’s registration requirement for certain affiliates of registered investment advisers). Strategic Advisers deems Strategic Ireland and each of the Strategic Ireland Associated Employees as “associated persons” of Strategic Advisers within the meaning of Section 202(a)(17) of the Advisers Act. Strategic Ireland Associated Employees and Strategic Ireland through such employees, can contribute to Strategic Advisers’ research process and could have access to information concerning securities that are being selected for clients prior to the effective implementation of such selections. As a Participating Affiliate of Strategic Advisers, Strategic Ireland has agreed to submit itself to the jurisdiction of United States courts for actions arising under United States securities laws in connection with investment advisory activities conducted for Strategic Advisers’ clients. Strategic Advisers maintains a list of Strategic Ireland Associated Employees whom Strategic Ireland has deemed associated persons, and Strategic Advisers will make the list available to its current U.S. clients upon request. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Strategic Advisers has adopted a Code of Ethics for Personal Trading (the “Code of Ethics”). The Code of Ethics applies to all officers, directors, employees and other supervised persons of Strategic Advisers and requires that they place the interests of Strategic Advisers’ clients above their own. The Code of Ethics establishes securities transaction requirements for all covered employees and their covered persons, including their spouses. More specifically, the Code of Ethics contains provisions requiring the following: • Standards of general business conduct reflecting the investment advisers’ fiduciary obligations; • Compliance with applicable federal securities laws; • Employees and their covered persons to move their covered accounts to FBS unless an exception exists or prior approval has been granted; • Reporting and review of personal securities transactions and holdings for persons with access to certain nonpublic information; • Prohibition of purchasing of securities in initial public offerings unless an exception has been approved; • Reporting of Code of Ethics violations; and • Distribution of the Code of Ethics to all supervised persons, documented through acknowledgements of receipt. 24  Core features of the Code of Ethics generally apply to all Fidelity employees. The Code of Ethics also imposes additional restrictions and reporting obligations on certain advisory personnel, research analysts, and portfolio managers. Such restrictions and reporting obligations include: • The preclearing of transactions in covered securities with limited exceptions, • A prohibition on investments in limited offerings without prior approval, • A prohibition on personal trading by a portfolio manager within seven days before or after a trade in any covered security of the same issuer by a fund or account managed by such portfolio manager except in limited circumstances, • The reporting of transactions in covered securities on a quarterly basis with limited exceptions, • The reporting of securities accounts and holdings of covered securities at the time of hire and annually thereafter, and • Disgorgement of profits from short-term transactions with limited exceptions. Violation of the Code of Ethics requirements can also result in the imposition of remedial action. The Code of Ethics will generally be supplemented by other relevant Fidelity policies, including the Policy on Inside Information, Rules for Broker-Dealer Employees, and other written policies and procedures adopted by Fidelity and Strategic Advisers. A copy of the Code of Ethics will be provided to any client or prospective client on request. From time to time, Strategic Advisers and its related persons can buy or sell securities for themselves and recommend those securities to clients. The conflicts of interest involved in such activities are contemplated in the Code of Ethics and other relevant Fidelity policies. In particular, the Code of Ethics and other Fidelity policies are designed to make clear to Fidelity personnel that they should never place their personal interests ahead of Fidelity’s clients in an attempt to benefit themselves or another party. The Code of Ethics and other Fidelity policies impose sanctions if these requirements are violated. From time to time, in connection with our business, certain supervised persons obtain material nonpublic information that is usually not available to other investors or the general public. In compliance with applicable laws, Strategic Advisers has adopted a comprehensive set of policies and procedures that prohibit the use of material non-public information by investment professionals or any other employees and that limit the transactions that Strategic Advisers can implement for accounts. In addition, Fidelity has implemented a Corporate Gifts & Entertainment Policy intended to set standards for business entertainment and the giving or receiving of gifts, to help employees make sound decisions with respect to these activities and to ensure that the interests of Strategic Advisers’ clients come first. Similarly, to support compliance with applicable “pay-to-play” laws, Fidelity has adopted a Personal Political Contributions & Activities policy that requires employees to preclear any political contributions and activities. Fidelity also has a Global Anti-Corruption Policy regarding commercial bribery and bribery of government officials that prohibits directly or indirectly giving, offering, authorizing, promising, accepting, or receiving any bribe, facilitation payment, kickback, or payoff (whether in cash or any other form) with the intent to improperly obtain or retain business or any improper advantage. 25  BROKERAGE PRACTICES Strategic Advisers Funds and Charitable Gift Fund On behalf of the Strategic Advisers Funds, Strategic Advisers invests in a combination of Fidelity and non-Fidelity mutual funds, derivative securities (e.g., futures contracts), and ETFs. On behalf of the Charitable Gift Fund, Strategic Advisers invests in, or recommends, a combination of Fidelity and non-Fidelity mutual funds, ETPs, and ETFs. Trades for the Charitable Gift Fund and trades for Strategic Advisers Funds that are not managed by a sub-adviser are placed with the trading desks of its affiliate and delegate, FMRCo and then executed with unaffiliated broker dealers. The FMRCo trading desk is permitted to direct futures and ETF trades to an affiliated broker dealer. The FMRCo trading desk's policies and procedures apply to orders for the Strategic Advisers Funds and Charitable Gift Fund that are executed on the FMRCo trading desks. FMRCo does not consider, in selecting or recommending broker-dealers, whether Strategic Advisers or a related person to Strategic Advisers receives client referrals from a broker-dealer or third party. FMRCo is authorized to allocate brokerage transactions to brokers who are not affiliates of Strategic Advisers who have entered into arrangements with Strategic Advisers or its affiliates under which the broker, using predetermined methodology, rebates a portion of the compensation paid by the fund to offset that fund’s expenses, which is paid to Strategic Advisers or its affiliates. Not all brokers with whom a fund trades have been asked to participate in brokerage commission recapture. For a complete description of FMRCo trading policies and procedures, including trade allocation, please refer to the FMRCo Form ADV, Part 2A Brochure found at www.adviserinfo.sec.gov. Sub-advisers of the Strategic Advisers Funds are authorized to place portfolio transactions with Strategic Advisers’ affiliated broker-dealers in accordance with regulatory guidelines. Sub- adviser orders placed for the purchase and sale of securities, including ETFs, will be subject to the individual sub-adviser’s trade allocation policy. Strategic Advisers does not maintain a soft dollar program. Some sub-advisers to the Strategic Advisers Funds use soft dollar or other commission-sharing arrangements in connection with transactions effected for those Funds. Sub-advisers could, pursuant to their policies and procedures, direct brokerage transactions of sub-advised funds to broker-dealers in exchange for research-related or brokerage-related goods or services, provided that such arrangements meet the requirements of Section 28(e) of the Exchange Act. REVIEW OF ACCOUNTS Charitable Gift Fund For the institutional advisory services provided to CGF, Strategic Advisers’ portfolio managers review each portfolio regularly and make appropriate investment changes in CGF’s portfolios or make recommendations to CGF as market conditions warrant. Portfolios are managed or advised in accordance with the governing investment management agreements. For CGF, the client’s governing body (the CGF Board) is supplied periodic reports providing performance data, and, among other 26  items, information on changes to the composition of the underlying investments within the investment pools. Strategic Advisers Funds Fund manager assignments are made based on a number of factors including the experience and seniority of the managers, the complexity of the Funds, and similarities between Funds assigned to a manager. Strategic Advisers and its affiliates might organize investment activity on a group basis, with fund managers of similar funds forming these groups. The group establishes general policy and coordinates advice and recommendations for the Funds within the groups. Managers review their Funds on a regular basis, with the group leader reviewing the Funds periodically. Management, Consulting Services, and Model Delivery Services Given the customized nature of such management and consulting arrangements, Strategic Advisers develops a management and oversight process for each such arrangement to best fit the circumstances of the arrangement. With respect to Strategic Advisers model portfolio services, Strategic Advisers reviews the model portfolios on a periodic basis, making adjustments as necessary in alignment with the mandate for any such portfolios. CLIENT REFERRALS AND OTHER COMPENSATION Strategic Advisers and its affiliates are compensated for providing services, including for investment management, distribution, transfer agency, servicing, and custodial services, to certain Fidelity and non-Fidelity mutual funds, ETPs, and other investments. These entities include Strategic Advisers; FMRCo and their affiliates as the investment advisers for the Fidelity funds; FDC as the underwriter of the Fidelity funds; and Fidelity Investments Institutional Operations Company LLC. (“FIIOC”) as transfer agent for the Fidelity funds, servicing agent for non-Fidelity funds, and recordkeeper of certain workplace savings plans. Strategic Advisers’ affiliates also receive compensation and other benefits in connection with portfolio transactions effected on behalf of the Fidelity and non-Fidelity mutual funds, ETPs, and other investments. FMRCo and its affiliates also obtain brokerage or research services, consistent with Section 28(e) of the Exchange Act, from broker-dealers in connection with the execution of the Fidelity funds’ portfolio security transactions. FBS and NFS receive compensation for executing portfolio transactions and providing, among other things, clearance, settlement, custodial, and other services to Fidelity and non-Fidelity mutual funds, ETPs, and other investments, and NFS provides securities lending agent services to certain Fidelity funds for which it receives compensation. FBS, NFS, and FIIOC also offer FundsNetwork, Fidelity’s mutual fund platform, and provide shareholder and other services to participating mutual funds for which FBS, NFS and FIIOC receive compensation, including with respect to those mutual funds in which client accounts are invested. Fidelity receives compensation from BlackRock or its affiliate in connection with a marketing program that includes promotion of iShares® ETFs and inclusion of the funds in certain Fidelity platforms and investment programs. Additional information about the sources, amounts, and terms of compensation is provided in these ETFs’ prospectuses and related documents. 27  Strategic Advisers seeks to address any potential financial conflicts of interest through personnel compensation arrangements (including those of Strategic Advisers’ investment professionals and the Fidelity representatives) that are not differentiated based on the investments or share classes selected for client accounts. Strategic Advisers and its affiliates have also implemented processes reasonably designed to prevent the receipt of compensation from affecting the nature of the advice provided to client accounts. Client referrals are provided by affiliated entities, including FBS, or other affiliates, pursuant to referral agreements where applicable. CUSTODY Strategic Advisers is deemed to have custody under the Advisers Act in certain circumstances, including when its affiliate serves as a qualified custodian of client assets. In circumstances where NFS serves as qualified custodian of client assets, investments will be held in street name by NFS (or at a securities depository on its behalf). Affiliates of Strategic Advisers, including NFS, FBS, or FIIOC, perform custodial or brokerage services for compensation with respect to client assets. Clients should carefully review statements, reports and other communications from those Fidelity entities. INVESTMENT DISCRETION Charitable Gift Fund and Strategic Advisers Funds Strategic Advisers’ investment management services generally include discretionary authority to determine which securities to purchase or sell, the total amount of such purchases and sales, and the brokers or dealers through which transactions are effected. However, Strategic Advisers’ discretionary authority is subject to certain limits, including the applicable investment objectives, policies, and restrictions. These limitations are based on a variety of factors, such as regulatory constraints as well as those imposed by the client and agreed on by Strategic Advisers in accordance with applicable laws. In addition, Strategic Advisers does not have investment discretion with respect to assets managed by sub-advisers to the Strategic Funds. In general, Strategic Advisers manages investments in Fidelity and non-Fidelity mutual funds on a discretionary basis. In the case of CGF, Strategic Advisers provides non-discretionary investment advice to certain portfolios based on its agreements with CGF. For CGF accounts where Strategic Advisers maintains discretion, Strategic Advisers has authority to allocate assets among various mutual funds, ETPs, and ETFs, subject to certain product-specific conditions. Strategic Advisers will decide to buy or sell individual securities and mutual fund shares for a number of reasons, including but not limited to the need to respond to the weighting of a particular asset class, industry sector, mutual fund peer group, or individual security that Strategic Advisers believes has too much representation in an account; diversification needs based on a client’s objectives and on market conditions; and a change in the fundamental attractiveness of a particular security or mutual fund. 28  When investing in Fidelity-managed funds, Strategic Advisers could from time to time consult FMRCo, the investment manager, to understand FMRCo’s guidelines or policies, if any, on the aggregate percentage of Fidelity mutual fund’s shares that can be held under management by Strategic Advisers on behalf of all its clients. The Strategic Advisers Funds invest in mutual funds, individual securities, derivatives securities (e.g., futures contracts), ETFs, and other securities, including affiliated and unaffiliated sub-advisers. Strategic Advisers manages Strategic Advisers Funds by allocating the fund’s assets between Fidelity and/or non-Fidelity sub-advisers and mutual funds, ETFs, or other securities. While Strategic Advisers selects the sub-advisers and provides ongoing oversight of their activities, the sub-advisers of the fund make the day-to-day investment decisions for the portions of the fund they manage, and Strategic Advisers does not exercise investment discretion for this sub-advised portion of assets. Management and Consulting Services For its management and consulting services, Strategic Advisers’ level of investment discretion is negotiated by contract and generally is customized to suit the particular arrangement. Strategic Advisers does not typically exercise any investment discretion in connection with respect to the provision of model portfolios services. However, pursuant to an agreement with FIWA, Strategic Advisers provides discretionary investment management services for certain nominal seed accounts of proprietary assets for the FIWA Model Portfolios solely for the purpose of FIWA generating and maintaining a performance track record. The nominal seed accounts can trade in the same ETPs as client accounts. Strategic Advisers has oversight practices in place to ensure that the trading and allocations for such nominal seed accounts do not disadvantage any other client accounts. VOTING CLIENT SECURITIES CGF and Management and Consulting Services Strategic Advisers generally does not acquire authority for, or exercise or advise on, proxy voting with respect to the services provided to CGF or management and consulting services as described herein. Proxies are provided to clients by the relevant custodian or service provider. Strategic Advisers will not advise clients on the voting of proxies. However, FIWA has delegated to Strategic Advisers the authority to vote proxies for nominal seed accounts of proprietary assets for the FIWA Model Portfolios, as described above, pursuant to Strategic Advisers’ policies and procedures and according to Strategic Advisers’ proxy voting guidelines as further described below. Strategic Advisers Funds The Board of Trustees of the Strategic Advisers Funds has delegated to Strategic Advisers the authority to vote shares owned by the Strategic Advisers Funds, except as otherwise delegated to the funds’ sub-advisers. Strategic Advisers or its affiliates generally cast votes on behalf of the Strategic Advisers Funds by proxy at shareholder meetings of issuers in which Strategic Advisers or its affiliates invest the funds’ assets. Strategic Advisers has established proxy voting guidelines (the “Guidelines”) that are designed to ensure that proxies on behalf of the Strategic Advisers Funds are 29  voted in a manner consistent with the best interests of the funds. Strategic Advisers has also adopted these Guidelines as part of its proxy voting policies and procedures in accordance with Rule 206(4)-6 under the Advisers Act. Strategic Advisers casts its votes on behalf of the Strategic Advisers Funds in accordance with the Guidelines through Investment Proxy Research Group (“IPR”), which is part of its affiliates’ Investment Operations department. Strategic Advisers generally intends to vote shares of underlying funds held by a Strategic Advisers Fund (except where Strategic Advisers has delegated investment management to a sub-adviser) in the same proportion as all other voting shareholders of the underlying funds (this is known as “echo voting”). When a Strategic Advisers Fund holds individual securities (i.e., non-fund shares), Strategic Advisers will vote in accordance with the Guidelines. Strategic Advisers will vote on proposals not specifically addressed by the Guidelines based on an evaluation of a proposal’s likelihood to enhance the long-term economic returns or profitability of the company or to maximize long-term shareholder value. The Board of Trustees of the Strategic Advisers Funds has delegated to each sub-adviser the authority to vote proxies relating to the portfolio securities of the sub-advised funds in accordance with the respective sub-adviser’s own proxy voting policies and procedures. Each sub-adviser certifies to Strategic Advisers that proxy votes cast on behalf of the relevant sub-advised funds were voted in accordance with the sub-adviser’s proxy voting policies and procedures. For any securities not managed by a sub-adviser to the Strategic Adviser Funds, Strategic Advisers will vote in accordance with the Guidelines. Information on how the Strategic Advisers Funds’ proxies were voted is available at www.fidelity.com/about-fidelity/proxy-voting-overview. Conflicts of Interest Voting of shares is conducted in a manner consistent with the best interests of the Strategic Advisers Funds. In other words, securities of a company generally will be voted in a manner consistent with the Guidelines and without regard to any other Fidelity companies' business relationships. For example, Strategic Advisers’ affiliates manage or administer employee benefit plans, or provide brokerage, underwriting, insurance, or banking services to companies whose management is soliciting proxies. Strategic Advisers or its affiliates could also have business or personal relationships with participants in proxy contests, corporate directors, or candidates for directorships. Strategic Advisers or its affiliates vote shares in a manner consistent with the Guidelines and without regard to any other relationship, business or otherwise, that Strategic Advisers or its affiliates have with companies in which Strategic Advisers, or its affiliates invest client assets. Strategic Advisers takes its responsibility to vote shares in the best interests of the Strategic Advisers Funds seriously and has implemented policies and procedures to address actual and potential conflicts of interest. IPR is charged with administering the Guidelines as agent to facilitate the voting of proxies. IPR votes proxies without regard to any other Fidelity companies’ relationship, business or otherwise, with that portfolio company. Like other Fidelity employees, IPR employees have a fiduciary duty to never place their own personal interest ahead of the interests of fund shareholders or clients. In the event of 30  a conflict of interest, IPR employees, like other Fidelity employees, are required to follow the escalation process included in Fidelity’s corporate policy on conflicts of interest. FINANCIAL INFORMATION Strategic Advisers does not solicit pre-payment of client fees. Furthermore, there are no financial conditions that are reasonably likely to impair Strategic Advisers’ ability to meet any of its contractual commitments to its clients. 31  Keep in mind that investing involves risk. The value of your investment will fluctuate over time, and you may gain or lose money. Diversification and asset allocation do not ensure a profit or guarantee against loss. Fidelity does not provide legal or tax advice, and the information provided is general in nature and should not be considered legal or tax advice. Consult an attorney, tax professional, or other advisor regarding your specific legal or tax situation. BlackRock Investment Management, LLC is an independent entity that is not affiliated with any Fidelity Investments company. BlackRock and iShares® are registered trademarks of BlackRock Inc., and its affiliates. Strategic Advisers LLC is a registered investment adviser and a Fidelity Investments company. Fidelity, Fidelity Investments, the Fidelity Investments, FundsNetwork, Empire Fidelity Investments Life Insurance Company, Fidelity Managed Account Xchange, Fidelity Advisor and CrossStream are registered service marks of FMR LLC. Fidelity Brokerage Services LLC, Member NYSE and SIPC, 900 Salem Street, Smithfield, RI 02917 National Financial Services LLC, 245 Summer Street, Boston, MA 02210. The mailing address for NFS is One Destiny Way, Mail Zone WA1M, Westlake, TX 76262 © 2026 FMR LLC. All rights reserved. 922189.11.0 32