March 29, 2018

Effective July 16, 2018, Fidelity will bring together multiple services. A new registered investment adviser called Fidelity Personal and Workplace Advisors LLC will unify services such as discretionary investment management, financial planning, and support from Fidelity representatives under a new advisory offering: Fidelity® Wealth Services.

This change affects your existing Fidelity managed account(s), including any Fidelity Portfolio Advisory Service® accounts, Fidelity® Personalized Portfolios accounts, Fidelity® Personalized Portfolios for Trusts accounts, BlackRock® Diversified Income Portfolio accounts, and/or Fidelity Private Client Group AdvisorySM accounts.

The advisory services you currently receive for these accounts will continue to be provided under the new Fidelity Wealth Services program sponsored by Fidelity Personal and Workplace Advisors LLC. “Portfolio Advisory Services” will be used as the name for all accounts managed through Fidelity Wealth Services. Strategic Advisers LLC will continue as the investment manager for all client accounts.

The Program Fundamentals valid until July 16, 2018, are enclosed for your review. We have also enclosed the Program Fundamentals effective as of July 16, 2018, for both Fidelity Personal and Workplace Advisors LLC and Strategic Advisers LLC, along with your amended Client Agreement. These materials provide detailed information about Fidelity Wealth Services and your Portfolio Advisory Services account(s).

We will be introducing a new, simplified pricing schedule. If the new pricing schedule results in an increase to the gross advisory fee on your existing accounts, a discount will be applied to avoid an increase. Information about how we will calculate the discount for existing accounts can be found under “Predecessor Services” in the Fidelity Personal and Workplace Advisors LLC Program Fundamentals for Fidelity® Wealth Services. The new pricing schedule will be applied to any new accounts you open with Fidelity® Wealth Services.

Important Information About Changes To Your Advisory Service

838014.1.0

Program Fundamentals:

Fidelity Portfolio Advisory Service®

Strategic Advisers LLC

245 Summer Street, V5D

Boston, MA 02210

1-800-544-3455

March 29, 2018

On behalf of Fidelity, we thank you for the opportunity to professionally manage your portfolio. This brochure was developed for our clients as well as those who are considering a managed account with Fidelity. It provides information about the qualifications and business practices of Strategic Advisers LLC (“Strategic Advisers”), as well as information about one of Fidelity’s Portfolio Advisory Services offerings, Fidelity Portfolio Advisory Service®.

This brochure should be read carefully by all clients and those considering becoming a client. Throughout this brochure and related materials, Strategic Advisers may refer to itself as a “registered investment adviser” or “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 contact us at 1-800-544-3455. 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 www.adviserinfo.sec.gov.

2

S U M M A R Y O F M AT E R I A L C H A N G E S

The SEC requires 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). The section below highlights only material revisions that have been made to the Fidelity Portfolio Advisory Service® Program Fundamentals from March 24, 2017, through March 29, 2018. Please contact a Fidelity representative regarding questions associated with your account at 1-800-544-3455. For Fidelity Private Wealth Management® clients, please contact your Wealth Management Adviser.

IMPORTANT INFORMATION ABOUT STRATEGIC ADVISERS

Strategic Advisers, Inc. has transitioned from a corporation to a limited liability company. All references to Strategic Advisers, Inc. are deemed to refer to Strategic Advisers LLC. Client Agreements entered into with Strategic Advisers, Inc. shall continue in full force and effect as if entered into with Strategic Advisers LLC.

IMPORTANT INFORMATION ABOUT CHANGES TO YOUR ADVISORY SERVICE

Effective July 16, 2018, Strategic Advisers LLC (“Strategic Advisers”) will assign all existing Fidelity Portfolio Advisory Service® (the “Service”) Client Agreements to its affiliate, Fidelity Personal and Workplace Advisors LLC (“FPWA”). FPWA will succeed Strategic Advisers as the sponsor of the Service and, simultaneously, the Service will be transitioned into a new advisory program, Fidelity® Wealth Services. The Client Agreement will be amended accordingly. Strategic Advisers will continue to provide discretionary portfolio management services for accounts as sub-advisor to FPWA. Please review the Fidelity® Wealth Services Program Fundamentals and Client Agreement that accompany this Service brochure, and speak to a Fidelity representative for more information.

For clients who enroll in the Service on or after the date of this Service Program Fundamentals: by enrolling in the Service, you consent to the assignment and amendment of the Client Agreement as described above.

3

TA B L E O F C O N T E N T S

SUMMARY OF MATERIAL CHANGES 2

SERVICES, FEES, AND COMPENSATION 4

ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS 10

PORTFOLIO MANAGER SELECTION AND EVALUATION 14

CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS 25

CLIENT CONTACT WITH PORTFOLIO MANAGERS 25

ADDITIONAL INFORMATION 25

4

S E R V I C E S , F E E S , A N D C O M P E N S AT I O N

ADVISORY SERVICES

Strategic Advisers LLC (“Strategic Advisers,” or sometimes referred to as “we” or “us” throughout this document), 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 incorporated in 1977 and acts as sponsor and investment manager to all Fidelity managed accounts offered by Fidelity’s Portfolio Advisory Services.

Fidelity’s Portfolio Advisory Services includes discretionary investment management services for individuals, joint account holders, certain retirement plans, Individual Retirement Accounts (“IRAs”) as well as certain trusts, estates, business entities, and charitable organizations. Fidelity’s Portfolio Advisory Services’ offerings include Fidelity Portfolio Advisory Service® (also referred to as the “Service”), which offers you discretionary investment management for accounts of $50,000 or more (generally $200,000 for corporate accounts). If you participate in Fidelity Wealth Management AdvisorySM, a high net worth financial planning program, Strategic Advisers may propose that you enroll in one of the managed account products offered by Fidelity’s Portfolio Advisory Services.

There are eight primary investment strategies, or long-term asset allocations, available under the Service, ranging from the most conservative (lower risk/lower return potential) to the most aggressive (higher risk/higher return potential). Depending on your investment preference (as discussed below), not all primary investment strategies may be available for each investment preference. Strategic Advisers will suggest which strategy best aligns with your goals based on the information you provide through the completed Investor Profile Questionnaire (“IPQ”), including your time horizon, risk tolerance, and financial situation. Strategic Advisers has constructed model portfolios of investments to correspond to each of these investment strategies, and the investments in your Service account (“Account”) will generally match the applicable model portfolio, subject to any restrictions you may request. Depending on your investment preferences (as discussed below), your Account may be invested in a mix of mutual funds managed by Fidelity Management & Research Company (“FMRCo”) and its affiliates (“Fidelity Funds”), exchange-traded funds (“ETFs”) managed by FMRCo and its affiliates (“Fidelity ETFs”), mutual funds managed by unaffiliated investment advisers (“Non-Fidelity Funds”), and exchange-traded funds managed by unaffiliated investment advisers (“Non-Fidelity ETFs,” and together with Fidelity Funds, Fidelity ETFs and Non-Fidelity Funds, “funds”).

The Service offers four investment preferences for the management of your Account. You will be able to choose among the four investment preferences based on your preference for the management of your Account. The Service provides these four preferences to accommodate the varying preferences of our clients and, as such, Strategic Advisers does not recommend one preference over another. The Blended Preference uses both Fidelity and Non-Fidelity Funds and will generally invest in actively managed mutual funds. The All Fidelity Preference is offered for clients who would like to hold only Fidelity Funds and also will generally invest in actively managed mutual funds. While Index-Focused Preference Accounts will be managed with a preference for passively managed funds, Strategic Advisers may use a mix of actively and passively managed funds. The Defensive Strategy Preference is offered for clients who would like to mitigate the extreme volatility of the markets. The Defensive Strategy Preference is designed to mitigate market lows and highs in an effort to provide a consistent investment experience over the long term for a level of long-term risk and return consistent with the selected investment strategy (long-term asset allocation). Accounts with the Defensive Strategy Preference will be invested in Fidelity and Non-Fidelity Funds and Fidelity and Non-Fidelity ETFs. Defensive Strategy Preference Accounts will invest in

5

both active and passively managed funds. The use of actively or passively managed investments is based on what Strategic Advisers believes is most appropriate based on market conditions, trading considerations, and the availability of passively and actively managed funds to be used to gain exposure to a particular asset or sub-asset class. The Service may also invest your Account in mutual funds managed by Strategic Advisers that have been developed specifically for use in the Service (the “Strategic Advisers Funds”). For Blended Preference Accounts, the Strategic Advisers Funds will be key building blocks for your Account.

The Blended Preference and Defensive Strategy Preference have the same fee schedule while the All Fidelity Preference and Index-Focused Preference each has its own separate fee schedule — please see “Fees and Compensation” for more information about the advisory fees associated with each preference. In general, Strategic Advisers and its affiliates will receive more compensation for the management of the Blended, All Fidelity and Defensive Strategy Preferences available through the Service, based on the higher gross advisory fees associated with those preferences. We will prepare an investment proposal (“Investment Proposal”) based on the information you provide in your IPQ, and information about your investment strategy, your selection of one of the four investment preferences discussed above, and any reasonable investment restrictions on the management of your Account can be found in your Investment Proposal.

Please note that if you are enrolling in the Service as an underlying account associated with Fidelity Wealth Management AdvisorySM, your Investment Proposal will be assessed based on the information you provide as part of Fidelity Wealth Management Advisory’s overall wealth planning process. For purposes of this brochure, if you are a Fidelity Wealth Management Advisory customer, references to your IPQ shall also refer to the Fidelity Wealth Management Advisory wealth planning process.

If you decide to invest, due to the active, ongoing management of the model portfolios, the actual securities purchased for your Account may differ from those listed in the Investment Proposal that we prepared based on your information. Although Strategic Advisers will not offer investment management services regarding assets outside your Account, if you indicate that you hold such assets in your IPQ, then Strategic Advisers may consider those assets in providing your Investment Proposal.

Once your completed and signed application has been received, a brokerage account will be opened on your behalf at Fidelity Brokerage Services LLC (“FBS”), Member NYSE, SIPC. Thereafter, once the account funding process is complete, Strategic Advisers will begin to manage your Account on a discretionary basis according to your proposed long-term asset allocation. For more information, see the section entitled “Identifying, Monitoring, and Maintaining Your Asset Allocation.”

FEES AND COMPENSATION

Advisory Fees — Gross Advisory Fee

Your Account charges a Gross Advisory Fee that covers the ongoing management of your Account, including investment selection, asset allocation, brokerage, clearing and custody services provided by Strategic Advisers’ affiliates, the communications program associated with your Account, and the personal service you receive from certain FBS employees, including the Wealth Management Advisers supporting Fidelity Private Wealth Management, who serve as investment adviser representatives of Strategic Advisers (“Fidelity representatives”). For purposes of this brochure, references to “your Fidelity representative” include, as appropriate, your dedicated representative, your team of Fidelity representatives, or your Wealth Management Adviser.

6

Your Gross Advisory Fee does not include underlying fund expenses charged at the individual fund level for any funds in your Account. These fund expenses, which vary by fund and class, are expenses all fund shareholders pay. Some of these underlying fund expenses may be paid to Strategic Advisers or its affiliates and will be included in a Credit Amount, described below.

Advisory Fee — Credit Amount

The annual Gross Advisory Fee applied to your Account is reduced by a Credit Amount. The purpose of the Credit Amount is to reduce your annual advisory fee by the amount of compensation, if any, Strategic Advisers or its affiliates receive from the underlying funds or their affiliates as a result of investments by your Account, as detailed below. This Credit Amount is calculated daily and applied quarterly in arrears.

To the extent applicable, a Credit Amount will be calculated for each fund held in your Account:

• For Fidelity Funds and ETFs, including Strategic Advisers Funds, the Credit Amount will equal the underlying investment management and any other fees or compensation Strategic Advisers or its affiliates receive from these funds as a result of investments by your Account.

o With respect to investments by your Account in Strategic Advisers Funds, the Credit Amount will also include revenue that Strategic Advisers and its affiliates receive as a result of investments in funds by the Strategic Advisers Funds.

• For Non-Fidelity Funds and ETFs, the Credit Amount will equal the distribution fees, the shareholder servicing fees, and any other fees or compensation Strategic Advisers or its affiliates receive from these funds or their affiliates as a result of investments by your Account.

These are added together to arrive at your total Credit Amount.

Net Advisory Fee = Gross Advisory Fee – Credit Amount

Please see the chart below for the fees charged on your Fidelity Portfolio Advisory Service® Account. Please note that all fees are subject to change.

ANNUAL ADVISORY FEE SCHEDULE FOR FIDELITY PORTFOLIO ADVISORY SERVICE® ACCOUNT

Average Daily Assets*

Annual Gross

Advisory Fee for All

Fidelity Models

Annual Gross

Advisory Fee for Blended

Models

Annual Gross

Advisory Fee for

Defensive Strategy Models

Annual Gross

Advisory Fee for Index-Focused Models

Variable Net Advisory Fee

For accounts with assets less than $200,000 1.70% 1.48% 1.48% 1.10%

}Less

Credit Amount†

=

Resulting Net

Advisory Fee

For the first $200,000 1.60% 1.38% 1.38% 1.10%

For the next $100,000 or portion thereof 1.40% 1.18% 1.18% 1.00%

For the next $200,000 or portion thereof 1.30% 1.08% 1.08% 0.90%

For the next $500,000 or portion thereof 1.10% 0.88% 0.88% 0.70%

For the next $1,000,000 or portion thereof 1.00% 0.78% 0.78% 0.60%

For the portion over $2,000,000 0.85% 0.63% 0.63% 0.60%

For total assets of $3 million or more‡ Flat Rate for Whole Account Based on Schedule Below

N/A

7

SPECIAL ANNUAL ADVISORY FEE SCHEDULE FOR FIDELITY PORTFOLIO ADVISORY SERVICE® ACCOUNTS OF $3 MILLION OR MORE

Average Daily Assets*

Annual Gross

Advisory Fee for All

Fidelity Models

Annual Gross

Advisory Fee for Blended

Models

Annual Gross

Advisory Fee for

Defensive Strategy Models

Annual Gross

Advisory Fee for Index-Focused Models

Variable Net Advisory Fee

$3,000,000 to $3,999,999 0.98% 0.76% 0.76% N/A

} Less Credit Amount†

=

Resulting Net Advisory Fee

$4,000,000 to $4,999,999 0.95% 0.73% 0.73% N/A

$5,000,000 to $5,999,999 0.92% 0.70% 0.70% N/A

$6,000,000 to $6,999,999 0.90% 0.68% 0.68% N/A

$7,000,000 to $7,999,999 0.88% 0.66% 0.66% N/A

$8,000,000 or more 0.85% 0.63% 0.63% N/A

* Average daily assets of Fidelity’s Portfolio Advisory Services accounts are determined on the last business day of the quarter. Clients can request to aggregate their Account balances with certain other Fidelity’s Portfolio Advisory Services account balances in order to arrive at the reduced fee rates applicable to different levels of account balances. In addition, certain individually owned accounts with the same tax reporting number will be automatically aggregated for fee calculation purposes. Fidelity Strategic Disciplines account balances cannot be aggregated for a reduced fee rate. To aggregate accounts for fee discounts, please contact your Fidelity representative for details of the account aggregation policy, including any other account that may meet the eligibility requirements, and to learn more about the different methods of aggregation.Minimum investment amount for corporate accounts is generally $200,000. † Your Gross Advisory Fee is reduced by a Credit Amount (as defined above). ‡Accounts of $3,000,000 or more in Index-Focused Models are not subject to a Special Annual Advisory Fee Schedule.

Cash balances in your Account will be invested in the core Fidelity money market fund, the cash sweep vehicle for the Account. Any such cash or cash investments in the Account will result in a negative yield to the extent the quarterly advisory fee exceeds the rates of return for the core Fidelity money market fund. Please ask a Fidelity representative about current performance of the core Fidelity money market fund.

Fund Expenses

Underlying fund expenses still apply to the funds in your Account. These are the standard expenses that all fund shareholders pay. Details of a fund’s expenses can be found in its prospectus. These expenses are not separately itemized or billed; rather, the published returns of funds are shown net of their expenses.

Sales Loads and Transaction Fees

You generally will not pay any sales loads or transaction fees on the funds purchased in your Account. A special sales load waiver may enable Strategic Advisers’ investment professionals to purchase funds for your Account without incurring additional sales loads or transaction fees on fund sales.

Redemption Fees

In order to protect the interests of long-term shareholders, funds may impose redemption or other administrative fees if shares are not held for a minimum time period. Strategic Advisers or its affiliates, at their sole discretion, may choose to bear any such redemption fees on your behalf, but are under no obligation to do so. In addition, you are responsible for any short-term trading fees that result from the sale of your existing investments (if any) to fund your initial investment in the Service (whether inside or outside your Account) and any subsequent withdrawals that you initiate.

8

Miscellaneous Fees

The advisory fee also does not cover charges resulting from trades effected with or through broker-dealers other than affiliates of Strategic Advisers, markups or markdowns by broker-dealers, 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 your Account. One such charge applies to sales of securities made for Accounts—an industry-wide assessment mandated by the Securities and Exchange Commission (“SEC”) totaling a few cents per $1,000 of securities sold. Please note that the amount of this regulatory fee may vary over time, and because variations may not be immediately known to Fidelity, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, Fidelity may retain the excess. These charges will be reflected on your monthly statements and/or trade confirmations.

Billing

Fidelity Portfolio Advisory Service® assesses annual advisory fees in connection with an investment in the Service. The net advisory fees, which accrue daily, will be deducted from your Account or another Fidelity account that you have identified for this purpose, in arrears on a quarterly basis. Certain assets in your Account may be liquidated to pay the fee; this liquidation may generate a taxable gain or loss. A statement of your fee may be provided upon request. Please contact your Fidelity representative to discuss paying the advisory fee from an alternative account or to pay by check. Should either party terminate the investment advisory relationship, Fidelity’s Portfolio Advisory Services will prorate the fees due from the beginning of the last quarter to the termination date, which is defined as the date when Strategic Advisers is no longer actively managing the assets in your Account.

Information about Representative Compensation and Fidelity’s Compensation

Fidelity representatives who sell and support the Service receive compensation as a result of your participation, which may include compensation for both sales of new accounts and retention of assets in the Service. In many cases, this compensation is greater than what the representative would receive if you participated in other programs or paid separately for investment management, brokerage, and other services. Wealth Management Advisers supporting Fidelity Private Wealth Management clients receive a salary and a bonus; the bonus is based in part on the quality of the client experience provided, program and business development contributions, and functional leadership work, among other considerations. Wealth Management Advisers do not receive compensation related to any particular Fidelity products or services, including the Service.

In addition, some Fidelity representatives who sell and support the Service may participate in sales contests and may earn additional rewards based on sales criteria, including, but not limited to, the number of solicitations for advisory services they make, gross sales on Service accounts, or retention of assets in the Service and similar programs. Therefore, some Fidelity representatives who distribute and support the Service may have a financial incentive to sell or suggest continued participation in the Service over other programs or services.

However, you are required to complete a questionnaire to assist in determining whether the Service is appropriate for you, and only clients who meet the criteria outlined in the questionnaire are offered participation in the Service. For additional information about how Fidelity compensates its representatives in connection with the sale of this Service and other products, you should see the representative’s compensation disclosure document that is included with your application materials, contact your representative or visit Fidelity.com.

9

The Fidelity representatives who sell and support the Service are representatives of both Strategic Advisers and FBS. Separate and apart from the Service, a Fidelity representative may provide you with investment education, research, and guidance offered by FBS. When acting in that capacity, the Fidelity representative is acting solely as a representative of FBS, and not as a representative of Strategic Advisers or the Service, and any fees related to the Service are not related to those additional services provided by the Fidelity representative.

Strategic Advisers may offer other discretionary managed account products at a lower cost to different types of clients. Please contact your Fidelity representative for more information.

ADDITIONAL INFORMATION ABOUT FEES

Fee Changes

All fees are subject to change. We will notify you in writing of any changes in advisory fee schedules. You will have the ability to object to any fee schedule changes by writing to Fidelity’s Portfolio Advisory Services within 30 days from the date of the notification. If we do not hear from you in writing, you will be deemed to have approved of such fee changes upon the end of the 30-day period.

Fee Negotiations

In rare circumstances, we may agree to negotiate the advisory fee for certain accounts. This may result in certain clients paying less than the standard fee. We may waive the advisory fee, in whole or in part, at our sole discretion, including those in connection with promotional efforts and other programs. In addition, we may waive, in whole or in part, the fee for certain current and former employees of Fidelity Investments. In certain circumstances, Strategic Advisers may manage accounts in a manner substantially similar to Fidelity’s Portfolio Advisory Services accounts under arrangements that may include negotiated terms and conditions that depart from the standard service offering. All rights and obligations are generally governed under an investment management agreement and may include investment guidelines.

Nondiscretionary Options

You may invest directly in some of the funds available through the Service in another account, without incurring an advisory fee charged by the Service. In this case, however, you would not receive the asset allocation and professional management services offered through the Service, and you may be subject to the sales loads, transaction fees, and redemption charges that are generally waived as part of the Service. Furthermore, certain investment products used by Fidelity Portfolio Advisory Service®, such as the Strategic Advisers Funds, and certain other funds offered by specialty third-party fund managers, may not be available for purchase nor may they be held outside the Service.

Participation in Fidelity Portfolio Advisory Service® may cost more or less than if you were to purchase the services separately. Several factors, including trading activity and investment fees, influence the cost of the Service.

10

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

Fidelity Portfolio Advisory Service® is generally available to individuals, joint account holders, certain retirement plans, IRAs, certain trusts, estates, business entities, and charitable organizations.

The minimum initial investment is generally $50,000 per account. The minimum investment amount for a corporate account is generally $200,000. Additional accounts opened by you or other members of your household must also meet the $50,000 minimum per account registration. In certain limited circumstances, Strategic Advisers may exempt accounts from the minimum initial investment requirement. Note that certain Fidelity Portfolio Advisory Services account balances may be aggregated with certain other Fidelity Portfolio Advisory Services account balances in order to arrive at a reduced fee rate. See the fee schedule for details or speak with a Fidelity representative. Fidelity Portfolio Advisory Service® accounts are generally serviced by a team of Fidelity representatives. Depending on your overall relationship with Fidelity, your account may be serviced by a dedicated representative. Accounts will be reviewed on a periodic basis to determine continued eligibility, and Strategic Advisers reserves the right to determine eligibility in its sole discretion. The Service is not available to foreign investors. In order to open an Account, you must be a U.S. person (including a U.S. resident alien), reside in the U.S., have a valid U.S. permanent mailing address, 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) if any authorized person on the Account resides outside the U.S. In addition, Strategic Advisers reserves the right to terminate your participation in the Service if the balance of your Account falls below a certain level. If we have been unable to reach you for an extended period of time to confirm or update your IPQ responses, or if we feel the Service is no longer appropriate for you, Strategic Advisers may terminate your participation in the Service upon notice. Strategic Advisers reserves the right to terminate, modify, or make exceptions to these policies. If your participation in the Service terminates, Strategic Advisers will generally redeem any and all Fidelity Funds, including Strategic Advisers Funds and, in general, other third-party funds held in your Account that are not eligible to be held outside an account managed by Strategic Advisers, and this redemption may generate a taxable gain or loss and significantly change the asset allocation of your Account.

Certain limitations apply to our ability to manage Accounts holding defined benefit plan assets. Generally, Strategic Advisers will manage investments only for a single participant defined benefit plan (except in the case of an Account holding defined benefit plan assets where the plan benefits only the owner of the business sponsoring the plan and his or her spouse), and will treat the defined benefit plan as if it were a defined contribution plan. Strategic Advisers will not include or otherwise take into consideration plan-specific provisions, or any plan-related documents, in its investment management approach.

OPENING AND FUNDING YOUR ACCOUNT

Once your application and funding have been accepted, a Fidelity Portfolio Advisory Service® Account will be opened at FBS on your behalf and the brokerage account will be allocated to investments aligned with the proposed model portfolio. You may fund a Blended Preference Account or an All Fidelity Preference Account with cash or certain mutual funds. You may fund an Index-Focused Preference Account or Defensive Strategy Preference Account with cash, certain mutual funds, and most ETFs, excluding leveraged and inverse ETFs. Because Accounts are actively managed and change over time, actual investments and associated asset class allocations may vary from those listed in your Investment Proposal, which you received prior to enrolling.

11

When funding your Fidelity Portfolio Advisory Service® Account, any funds that are not part of your proposed model portfolio will be sold and you may be charged a redemption fee, as specified in the prospectus for each mutual fund, or any other fees as applicable to the redemption or sale of such funds or to the brokerage account from which funds are being liquidated or transferred. The selling may result in a taxable gain or loss in your brokerage account. When funding involves a transfer in kind of a fund that is also in your proposed model portfolio, your Account may not be invested in accordance with the Investment Proposal until we receive all funding, including the transferred shares, for your Account. Discretionary management of your account may not begin until we have received all funding. At times, Strategic Advisers may not accept ETFs that are used to fund your Index-Focused Preference Account or Defensive Strategy Preference Account. These ETFs may have been eligible at the time of funding, but due to aggregate holding limitations, as defined by Fidelity Investments’ internal guidelines (as a consolidation of companies) or by regulations (state and federal), they are no longer eligible.

ADDITIONAL DEPOSITS

Subsequent investments to existing Accounts may be made for as little as $250. Investment amounts of less than $250 may be accepted, but may be held in a core cash position. Minimums for initial and subsequent investments may be lowered at the sole discretion of Strategic Advisers, including those in connection with promotional efforts.

WITHDRAWALS

All trading and monetary transactions in your Account must be processed through a Fidelity representative, who can be reached via Fidelity’s Portfolio Advisory Services’ toll-free number, through written instructions by you (on the necessary forms if appropriate) and sent to a local Investor Center, Fidelity mailing address, or through Fidelity’s Portfolio Advisory Services’ client website (certain limitations may apply to Web transactions and are detailed on the site). Requests can also be provided verbally at a local Investor Center.

Under normal circumstances, Strategic Advisers will use its best efforts to process and execute withdrawal requests as follows:

• For Blended Preference Accounts, requests for withdrawals must be received in good order by 12 p.m. Eastern time (ET), on a day that the New York Stock Exchange (NYSE) is open for business (“business day”), in order for the withdrawal request to be processed on the same business day. Such requests received after 12 p.m. ET are processed on the next business day.

• For All Fidelity Preference Accounts, requests for withdrawals must be received in good order by 4 p.m. ET on a business day in order for the withdrawal request to be processed on the same business day. Requests received after 4 p.m. ET are processed on the next business day.

• For Index-Focused Preference and Defensive Strategy Preference Accounts, depending on the nature of your request, requests for withdrawals may take up to 10 business days, depending on the securities to be sold/transferred.

If the NYSE closes before 4 p.m. ET, the cutoff time for withdrawal requests will be adjusted earlier in the day to allow sufficient time to process the transactions. For written requests received not in good order or if other trading activity is taking place within the Account on the day of a withdrawal request, it may take an additional day or days to process the withdrawal.

12

For withdrawals and Account closures, you may request that:

• A check be sent to you.

• Assets be transferred in-kind into another account. (Please note: Certain funds, including the Strategic Advisers Funds, cannot be transferred and must be liquidated before leaving your Account.)

• Money be wired or transferred electronically via electronic funds transfer (EFT) to your bank or other account.

Depending on the type of Account and the exact dollar amount you wish to withdraw, more information may be necessary before the withdrawal can occur. For withdrawal requests that do not include instructions for a destination account, Strategic Advisers reserves the right to place a temporary do-not-trade instruction on the Account until instructions are provided. If such instructions are not provided within 30 days of the initial request date, Strategic Advisers may reinvest the pending cash back into the asset allocation strategy. Please note: A signature guaranteed letter of instruction is required if the withdrawn amount is going to an address that is not reflected on the account.

The mutual funds Strategic Advisers invests in may have policies that restrict excessive trading. As a result, a fund may reject trade orders if they are deemed to represent excessive trading. In general, a fund may restrict future trade activity if it deems the excessive trading policy, as outlined in the fund prospectus, has been violated (e.g., a purchase and sale within a 30-day period). As a result, in order to comply with a fund’s trading policies, Strategic Advisers may be required to suspend investment management of your Account. Strategic Advisers will cease to manage your Account as soon as reasonably practicable. However, the imposition of any such order may take up to one business day to implement and may stop any trading activity that is occurring in your Account.

As a feature of the Account, certain clients with nonretirement accounts may elect to have all dividends and capital gains from eligible holdings set aside for automatic distribution by completing and submitting to FBS an Earnings Automatic Withdrawal Plan form. Please note that upon providing these instructions to FBS, these amounts set aside awaiting distribution are no longer managed by or subject to the investment discretion of Strategic Advisers. It may take three to five business days for this Account feature change to take effect.

ACCOUNT CLOSURES

At any time, you can request to terminate your participation in the Service and close your Account. If you terminate the advisory agreement with Strategic Advisers you must also instruct Strategic Advisers to either (i) liquidate your Account assets and send the proceeds to you or to a different account specified by you, or (ii) transfer your Account assets to another account. In order to meet the trading deadlines below, all trading and monetary transactions associated with your Account closure must be processed through your Fidelity representative. Under normal circumstances, Strategic Advisers will use its best efforts to process and execute requests for full Account liquidations or full Account closeouts via transfer in kind (collectively, “full closeouts”) as follows:

• For Blended Preference Accounts, requests for full closeouts must be received in good order by 12 p.m. ET on a business day in order for the full closeout request to be processed on the same business day. Requests received after 12 p.m. are processed on the next business day.

• For All Fidelity Preference Accounts, requests for full closeouts must be received in good order by 4 p.m. ET on a business day in order for the full closeout request to be processed on the same business day. Requests received after 4 p.m. ET are processed on the next business day.

13

• For Index-Focused Preference and Defensive Strategy Preference Accounts, requests for full closeouts must be received in good order by 4 p.m. ET on a business day in order for the full closeout request to be processed on the next business day. Requests received after 4 p.m. ET will generally be processed two or more business days after the request is made.

If the NYSE closes before 4 p.m. ET, the cutoff time for full closeout requests will be adjusted to earlier in the day to allow sufficient time to process the transactions. For written requests received not in good order or if other trading activity is taking place within the Account on the day of a full closeout request, it may take an additional day or days to process the Account closure.

When closing your Account, Strategic Advisers will assess any unpaid advisory fees from prior quarters and, as needed, will prorate and assess the advisory fees from the beginning of the final quarter the Account is open to the termination date, which is defined as the date when Strategic Advisers is no longer actively managing the assets in the Account. Additionally, note that once the Account is closed, additional deposits to the Account will be rejected and any account features such as automated withdrawal plans will be terminated.

There may be mutual funds held in your Account that otherwise may not be available to you as a retail investor. In general, if you cease to be a client of Fidelity’s Portfolio Advisory Services, Strategic Advisers will redeem any and all shares of such funds and/or turn off dividend reinvestment, and you may incur a gain or loss as a result. If these shares are transferred to an account other than a Strategic Advisers’ managed account, you will be subject to the terms and conditions specified in that fund’s prospectus.

Strategic Advisers may terminate your participation in the Service for withdrawing cash from your Account that brings your account balance below the minimum, for failure to maintain a valid mailing address, or for any other reason, in Strategic Advisers’ sole discretion. Before terminating you from the Service, Strategic Advisers will provide at least 30 days’ notice; provided, however, that in order to comply with applicable law, rule, or regulation, there may be situations when Strategic Advisers does not provide such notice. Depending on the reason for the termination, you may have the opportunity to resolve the issue, but if you are unable to do so, the Service will cease and the Account will be restricted from trading pending your liquidation or transfer instructions. Liquidation of assets in taxable accounts may have adverse tax consequences.

ADDITIONAL INFORMATION ABOUT TRANSACTIONS IN YOUR ACCOUNT

Mutual funds in your Account may include the Strategic Advisers Funds and other funds that are available only to clients of Fidelity Portfolio Advisory Service.® The Strategic Advisers Funds may invest in individual equity and fixed income securities, mutual funds, ETFs, and derivatives, and engage the use of Fidelity and non-Fidelity sub-advisers (“Sub-Advisers”). If you cease to be a client of Fidelity Portfolio Advisory Service®, Strategic Advisers generally will redeem any and all Strategic Advisers Fund shares and shares of other funds either made available only to clients of Fidelity Portfolio Advisory Service® or due to other account restrictions, such as minimum balance requirements, held in your Account, and you may incur taxable gains or losses as a result of such redemptions.

14

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 VA L U AT I O N

STRATEGIC ADVISERS’ INVESTMENT APPROACH

Strategic Advisers generally uses both fundamental and quantitative investment strategies to manage your Account. The Service offers multiple model portfolios to satisfy a wide variety of investor needs, ranging from the most aggressive portfolios (e.g., model portfolios that may be invested entirely in equities) to more conservative portfolios (e.g., model portfolios that may include only 20% exposure to equities). Strategic Advisers will apply its proprietary methodology to propose an appropriate investment strategy, or long-term asset allocation, that corresponds to a level of risk consistent with your individual financial situation, investment objectives, risk tolerance, planned investment time horizon, and other information provided for the specific Account through the completed IPQ. Strategic Advisers will allow any reasonable investment restrictions on your Account. At any time, due to market movements and active management, your Account’s holdings may not match the long-term asset allocation associated with the proposed investment strategy. To the extent that your Account is related to a relationship with Fidelity Wealth Management AdvisorySM, the long-term asset allocation used to manage your Account may be provided by Strategic Advisers as part of that service. For more information, see Identifying, Monitoring, and Maintaining Your Asset Allocation that follows. Information about your investment strategy and model portfolio can be found in your Investment Proposal.

Strategic Advisers will manage your Account to align with a model portfolio of Fidelity and Non-Fidelity Funds for the Blended Preference, Fidelity Funds for the All Fidelity Preference, or Fidelity and Non-Fidelity Funds and Fidelity and Non-Fidelity ETFs for the Index-Focused Preference and the Defensive Strategy Preference. In general, each model portfolio’s assets will be allocated to funds that invest in four major asset classes:

1. Domestic stocks (U.S. equity securities)

2. Foreign stocks (non-U.S. equity securities)

3. Bonds (fixed income securities of all types and maturities, including lower-quality debt securities)

4. Short-term assets (short-duration investments)

Strategic Advisers may also invest in funds that invest in nontraditional and/or extended asset classes, such as real estate, inflation-protected debt securities, commodities, or other alternative investments. The allocation of the investments in your Account will depend on your proposed or selected asset allocation, may change over time, and may deviate from the asset allocation shown as your long-term asset allocation. A change in your asset allocation will result in your Account transitioning to another model portfolio, which may result in taxable gains or losses.

Blended Preference and All Fidelity Preference Accounts are managed using Strategic Advisers’ investment manager research process in an effort to select mutual funds that offer the opportunity to outperform their applicable market indices, and will generally invest in actively managed mutual funds. When deemed appropriate by the investment team, Blended Preference and All Fidelity Preference Accounts may also invest in passively managed mutual funds that seek to replicate the performance of their applicable market indices. Blended Preference and All Fidelity Preference Accounts will generally invest in passively managed mutual funds based on market conditions, risk management and trading considerations, and the availability of actively and passively managed mutual funds to be used to gain exposure to a particular asset or sub-asset class, in each case in the judgment of Strategic Advisers.

15

Index-Focused Preference Accounts are also managed using Strategic Advisers’ investment manager research process, but will have a preference for passively managed funds. Index-Focused Preference Accounts may also invest in actively managed funds when deemed appropriate by the investment team. Index-Focused Preference Accounts will invest in actively managed funds based on market conditions and the availability of actively and passively managed funds to be 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 Preference Accounts, the investment management team expects to use actively managed funds to gain exposure to certain fixed income asset classes, including municipal bonds, high yield, short term bonds and money market, though this may change in the future depending on the availability and appropriateness of passively managed funds with exposure to certain asset or sub-asset classes. Accordingly, Index-Focused Preference Accounts that are taxable or that have a more conservative investment and risk profile will typically hold a higher percentage of actively managed funds than other Accounts with the same investment strategy or preference, respectively.

Defensive Strategy Preference Accounts are also managed using Strategic Advisers’ investment management research process, but will generally have increased sub-asset class exposures to investments that, in the judgment of Strategic Advisers, may cause the Account to have lower sensitivity to broader market price movements, thus helping to mitigate the extreme volatility of the markets. These investments may include conservative equity (those with stable earnings growth, low financial leverage and a high return on equity, or those that are expected to rise and fall in price less/more slowly than the market generally), which may be combined with increased exposure to longer-term high quality bonds. Strategic Advisers believes these conservative equity investments may have lower variability in returns than the equity market as a whole, and that the longer-term high quality bonds may help reduce some of the equity and credit risk associated with the other investments used in Defensive Strategy Preference Accounts. The Defensive Strategy Preference is designed to mitigate the extreme volatility of the markets by seeking to buffer against market lows and highs in an effort to provide a consistent investment experience over the long term. Based on the judgment of Strategic Advisers, the Defensive Strategy Preference Accounts will invest in both active and passive funds based on market conditions.

Strategic Advisers will take the following steps in managing your Account:

• Strategic Advisers will research, analyze, and select funds appropriate for your Account in the model portfolio.

• Strategic Advisers will determine the amount of assets that should be allocated to each fund within the model portfolio.

• Within each Strategic Advisers Fund, Strategic Advisers will also determine the amount of assets allocated to each fund, ETF, derivative, or Sub-Adviser used in the Service.

• Strategic Advisers will monitor and rebalance your Account to help ensure that it remains in line with your targeted risk profile.

IDENTIFYING, MONITORING, AND MAINTAINING YOUR ASSET ALLOCATION

Strategic Advisers will apply its proprietary methodology to propose an investment strategy, or long-term asset allocation, that corresponds to a level of risk consistent with your financial situation, investment objectives, planned investment time horizon, investment restrictions, and risk tolerance, provided through the completed IPQ. Please note that if you are enrolling in the Service as an underlying account associated with Fidelity Wealth Management AdvisorySM, your asset allocation will

16

be assessed as part of that service’s overall wealth planning process. Upon the review of the proposed investment strategy from Strategic Advisers, you may select a long-term asset allocation that you believe is most appropriate, subject to constraints defined by Strategic Advisers. If you have selected a long-term asset allocation different from that proposed by Strategic Advisers, you understand and acknowledge that you are directing Strategic Advisers to manage your Account according to such long-term asset allocation and that you, not Strategic Advisers, are responsible for such direction. In such circumstances, Strategic Advisers will provide discretionary management consistent with the long-term asset allocation you have selected. You should be aware that the performance of your Account will differ from the performance of an account managed according to the long-term asset allocation originally proposed by Strategic Advisers. Additionally, your ability to select a different investment strategy is subject to constraints defined by Strategic Advisers. For additional information about the long-term asset allocation you have selected, please refer to your Investment Proposal. You continue to be responsible for notifying Strategic Advisers of any changes to your personal circumstances or long-term goals. As your investment strategy is designed to be a long-term asset allocation, please note that if you change your direction as to asset allocation frequently, Strategic Advisers may require that you close your Account.

Strategic will allocate your Account across various primary and extended asset classes in a manner that is consistent with your financial goals while also managing the overall risk profile. We use sophisticated research tools to gauge when certain asset and extended asset classes should be used to help benefit the model portfolio. This involves both evaluating the model portfolio’s characteristics such as sector weightings, duration, valuation, and market capitalization, as well as focusing on key economic indicators and trends. The goal of this focus on asset allocation is to ensure that the model portfolio stays positioned in an appropriate manner for your financial situation, investment objectives, investment time horizon, and risk tolerance.

When determining how to allocate a model portfolio’s assets among underlying funds, Strategic Advisers considers a variety of factors, including, but not limited to, proprietary fundamental and quantitative fund research, 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. 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 fund companies and 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).

Strategic Advisers may decide to buy or sell fund shares for a number of reasons, including, but not limited to, the need to respond to:

1. The weighting of a particular asset class, industry sector, and/or fund peer group;

2. Any individual fund becoming too large relative to your overall Account;

3. Changes in your IPQ and consequent changes to your associated investment strategy;

4. A change in the fundamental attractiveness of a particular fund;

17

5. Rebalancing your Account to bring it back in line with its targeted risk level due to a “drift” in the model portfolio caused by market movement; and/or

6. Accommodating fund closures or limitations.

Periodically, market movement may cause “drift” in the model portfolio away from its targeted risk level. Strategic Advisers may choose to rebalance the model portfolio to bring it back in line with its targeted risk level, which may in turn lead to a corresponding rebalancing of your Account. The number of times your 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.

When Strategic Advisers places trades in your Account, you will receive notification that a change has been made via a transaction confirmation; provided, however, with respect to automatic investments, automatic withdrawals, dividend reinvestments, and transactions that involve your core Fidelity money market fund, your account statement will serve in lieu of a confirmation. You will also receive a prospectus for any new fund not previously held, unless you have elected to have Strategic Advisers act as your agent for the receipt of any Non-Fidelity Fund or ETF prospectuses. Account statements will be sent to you or your designee monthly, either by U.S. mail or electronically at your election, which will detail the holdings in your Account and transaction information for the period covered.

THE STRATEGIC ADVISERS FUNDS

For more information on the investment strategies employed by the Strategic Advisers Funds, please see the prospectuses for those funds. For the Blended Preference, the Strategic Advisers Funds are key building blocks for your Account. These funds are available only to Fidelity Portfolio Advisory Service® clients and allow Strategic Advisers to choose from an expanded group of Fidelity and Non-Fidelity Funds and Sub-Advisers. All Strategic Advisers Funds are considered to be Fidelity Funds; however, most are a blend of both affiliated and unaffiliated mutual funds, ETFs, and Sub-Advisers, and can be held in the Blended, All Fidelity, Index-Focused, and Defensive Strategy Preferences. These funds are structured so that, within one fund, Strategic Advisers can hire and/or fire Sub-Advisers who will purchase equity or fixed income securities for the fund, and buy and sell mutual funds, ETFs, and certain types of derivatives. This structure is designed to simplify your Account and provide Strategic Advisers with greater visibility into the underlying holdings of the funds. At any given time, a significant portion of the assets in your Account, and up to 100% of your Account, may be invested in the Strategic Advisers Funds. If you cease to be a client of Fidelity Portfolio Advisory Service®, in general, Strategic Advisers will redeem any and all Strategic Advisers Fund shares and shares of other funds either made available only to clients of Fidelity Portfolio Advisory Service® or due to other account restrictions, such as minimum balance requirements, held in your Account, and you may incur gains or losses as a result of such redemptions.

A Strategic Advisers portfolio manager manages each Strategic Advisers Fund by allocating the fund’s assets among Fidelity and non-Fidelity Sub-Advisers, ETFs, mutual funds, and certain types of derivatives. 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 security-level investment decisions for the portions of the fund they manage. Strategic Advisers may allocate each fund’s assets among any number of Sub-Advisers, underlying mutual funds, ETFs, or certain types of derivatives at any time. Strategic Advisers will also allocate assets among the various Strategic Advisers Funds. This will be done according to your proposed investment strategy, and the allocation may change over time.

18

The fees charged by the Strategic Advisers Funds may be higher or lower than other funds that may be purchased by the Service; however, as noted above, the revenue received by Strategic Advisers and its affiliates as a result of investments by your Account in the Strategic Advisers Funds will be included in the Credit Amount applied to your Gross Advisory Fee.

RESEARCH: SELECTING MANAGERS AND FUNDS

The role of the research team within Strategic Advisers is to provide comprehensive analysis that will guide the investment and manager selection process. “Managers” researched by the team include both fund managers as well as Sub-Advisers. Sub-Advisers are investment professionals who are hired by Strategic Advisers to manage a sleeve of assets in a Strategic Advisers Fund according to a specific mandate. Strategic Advisers’ research process is both qualitative and quantitative and is designed to ensure that Strategic Advisers has a clear picture of the manager being researched. Strategic Advisers evaluates various data points about a Sub-Adviser and/or fund, including:

• Their asset allocation, risk exposure, and performance attribution

• How they perform in various market cycles

• How they will contribute to a diversified portfolio of managers

Strategic Advisers seeks to confirm that each manager selected has a sound and repeatable investment philosophy and process that is strictly adhered to throughout various types of markets.

ADDITIONAL INFORMATION ABOUT STRATEGIC ADVISERS’ INVESTMENT PRACTICES AND MANAGER SELECTION PROCESS

When investing in funds, Strategic Advisers may from time to time consult 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 Strategic Advisers on behalf of all its clients. Funds are not required to accept investments and may limit how much Strategic Advisers can purchase. One way the Service deals with potential capacity issues is to use the Strategic Advisers Funds instead of third-party funds. Additionally, Strategic Advisers may establish internal limits on how much it may invest in any one fund across the programs it manages. Regulatory restrictions also may limit the amount that one fund can invest in another, which means that Strategic Advisers or the Strategic Advisers Funds may be limited in the amount they can invest in any particular fund.

Strategic Advisers will work closely with fund management to minimize the impact of the Fidelity Portfolio Advisory Service® reallocation activity on acquired funds. In certain situations, liquidating positions in underlying funds may be accomplished over an extended period of time as a result of operational considerations, legal considerations, or input from underlying fund managers.

Strategic Advisers does not seek access to material nonpublic information on any mutual funds. With respect to Fidelity Funds and ETFs used by the Service, the investment managers at Strategic Advisers who manage the Service do not have access to the proprietary or material nonpublic information of the investment advisers to the Fidelity Funds and ETFs.

MATERIAL INVESTMENT RISKS

As discussed above, the Service offers multiple asset allocations to satisfy a wide variety of investor needs, ranging from the most aggressive portfolios (i.e., portfolios that are assigned entirely to equity) to the most conservative portfolios (i.e., portfolios that include only 20% exposure to equity). All investment strategies, including the strategies employed in the Service, pose risks, and many factors affect each fund’s or account’s performance. Strategies that pursue investments in equities will be

19

subject to stock market volatility, and strategies that pursue fixed-income investments (such as bond or money market funds) will see values fluctuate in response to changes in interest rates. All strategies are ultimately affected by impacts to the individual issuers, such as changes in an issuer’s profitability and credit quality, or changes in tax, regulatory, market or economic developments.

Nondiversified funds and accounts that invest in a smaller number of individual issuers can be more sensitive to these changes. Nearly all funds and accounts are subject to volatility in non-U.S. markets, either through direct exposure or indirect effects in U.S. markets from events abroad. Those funds 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.

Additionally, funds or accounts that pursue debt investments 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 the international or emerging markets funds’ exposure to a particular country or region) may 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 funds 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. Additionally, funds and accounts may be subject to operational risks, which can include risks of loss arising from failures in internal processes, people, or systems, such as routine processing errors or major systems failures, or from external events, such as exchange outages.

Risk of Loss. All investment strategies employed by Strategic Advisers in the Service involve risk of loss (even the Conservative model portfolio will fluctuate in value over time and you may lose money). You should be prepared to bear such losses in connection with investments through the Service. Investments in your Account are not a deposit of a bank and are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. You may lose money by investing in mutual funds, ETFs, and derivatives. You may lose money by investing in the Service.

Investing in Mutual Funds and ETFs. Your Account bears all the risks of the investment strategies employed by the funds held in your Account, including the risk that they will not meet their investment objectives. Different funds have different risks. For the specific risks associated with any fund used by Strategic Advisers in your Account, please see the fund’s prospectus.

In addition, the funds used by Strategic Advisers, including the Strategic Advisers Funds, may be subject to the risks below.

Money Market Fund Risk. You could lose money by investing in a money market fund. Although the fund seeks to preserve the value of your investment at $1.00 per share, it cannot guarantee it will do so. An investment in the fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Fidelity Investments and its affiliates, the fund’s sponsor, have no legal obligation to provide financial support to money market funds and you should not expect that the sponsor will provide financial support to the fund at any time.

20

Fidelity’s government and U.S. Treasury money market funds will not impose a fee upon the sale of your shares, nor temporarily suspend your ability to sell shares if the fund’s weekly liquid assets fall below 30% of its total assets because of market conditions or other factors.

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 may be subject to risk related to market capitalization as well as company-specific risk.

Foreign Exposure. Foreign securities are subject to interest rate, currency exchange rate, economic, regulatory, and political risks, all of which may be greater in emerging markets. These risks are particularly significant for mutual funds/ETFs that focus on a single country or region or emerging markets. Foreign markets may 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.

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.) The ability of an issuer of a bond to repay principal prior to a security’s maturity can cause greater price volatility if interest rates change, and if a bond is prepaid a bond fund may have to invest the proceeds in securities with lower yields. Fixed income securities also carry inflation risk and 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 may be less liquid than other investments, and therefore may be more difficult to trade effectively.

Municipal Market Volatility. Municipal bonds can be significantly affected by political changes as well as uncertainties in the municipal market related to taxation, legislative changes, or the rights of municipal security holders. 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 may be relying for funding may 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 may directly impact the liquidity and valuation of municipal bonds. Interest income generated by municipal bonds is generally expected to be exempt from federal income taxes and, if the municipal bonds are held by an investor with legal residence in the state of issuance, state and local income taxes. Such interest income may be subject to federal and/or state alternative minimum taxes. 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 may be removed or phased out for investors at certain income levels.

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.

Inflation-Protected Debt Securities. The interest payments of inflation-protected debt securities are variable and usually rise with inflation and fall with deflation.

21

Legislative and Regulatory Risk. Investments in your Account may 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, individual issuers of securities, and Strategic Advisers’ determinations with respect to the expected rate of return, value, or creditworthiness of a particular security. The impact of these changes may not be fully known for some time.

Taxable Gains on Account Activity. The Service is not designed to take taxes into account when managing the model portfolios. As a result, you may have taxable gains or losses as a result of investment decisions made in your Account. In addition, Strategic Advisers may make structural changes to the Service that may result in taxable gains to your Account. To understand the potential tax consequences of the trading activity in your Account, please consult your tax adviser.

Funds with Multiple Managers. Separate investment decisions and the resulting purchase and sale activities of a fund’s Sub-Advisers might adversely affect a fund’s performance or lead to disadvantageous tax consequences.

Defensive Investing. The ability of the Defensive Strategy Preference to mitigate the extreme volatility of the markets depends on Strategic Advisers’ ability to estimate correctly the volatility of the investments it chooses relative to the broader market. Volatility may be higher than anticipated, and the specific investments used in Defensive Strategy Preference Accounts may not be as correlated or uncorrelated with the broader market as Strategic Advisers expects. It is reasonable to expect that Defensive Strategy Preference Accounts may underperform when markets rise, but there can be no assurance that Strategic Advisers will be able to mitigate losses when markets fall.

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, and market volatility or the quantitative model’s assumption about market behavior.

Exchange-Traded Products (“ETPs”). An ETP is a security that trades on an exchange and may seek to track an index, commodity or a basket of assets. ETPs can include ETFs, exchange-traded notes, unit investment trusts, closed-end funds, master limited partnerships and certain grantor trusts. ETPs can be actively or passively managed. The performance of a passively managed ETP may not correlate to 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 their underlying securities. ETPs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Share trading may be halted or the security may cease to trade on an exchange. Trading volume and liquidity may vary and may affect the ability to buy or sell shares or cause the market price of shares to experience significant premiums or discounts relative to 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 may vary significantly.

ETFs. An ETF is a security that trades on an exchange and may seek to track an index, commodity, or a basket of assets like an index fund. However, some ETFs are actively managed and do not seek to track a certain index or basket of assets. Passive ETFs seek to replicate the performance of relevant market indices. ETFs may trade at a premium or discount to their net asset value (“NAV”) and may also be affected by the market fluctuations of their underlying investments. They may also have unique risks depending on their structure and underlying investments.

Derivatives. Certain funds used by Strategic Advisers may 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 may subject these funds to risks different from, and possibly

22

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 be easily 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 may be more difficult to value. Derivatives may involve leverage because they can provide investment exposure in an amount exceeding the initial investment. As a result, the use of derivatives may 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.

Alternative Investments. Alternatives are classified as assets whose investment characteristics and/or performance differ substantially from the major asset classes and therefore offer opportunities for additional diversification. They may be illiquid. Examples include private equity and hedge funds. Strategic Advisers does not invest in private equity or hedge funds directly in Fidelity Portfolio Advisory Service® Accounts; however, Strategic Advisers may invest in mutual funds that invest significantly in these instruments, and therefore clients may have indirect exposure to these sorts of investments.

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.

Cybersecurity Risk. With the increased use of technologies such as the Internet to conduct business, Strategic Advisers and its affiliates are susceptible to operational, information security, and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events and may arise from external or internal sources. Cyber attacks 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; or causing operational disruption. Cyber attacks may 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 and its affiliates, or any of their other service providers (including, but not limited to, accountants, custodians, transfer agents, and financial intermediaries used by a fund or account) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, interference with the ability to calculate 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 a fund or account invests, counterparties with which a fund or 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.

OTHER INFORMATION ABOUT THE MANAGEMENT OF YOUR ACCOUNT

You are entitled to impose reasonable restrictions on Strategic Advisers’ management of your Account. Any management restriction you may wish to impose is subject to the review and approval of Strategic Advisers. Such a restriction may include prohibitions with respect to the purchase of a particular fund or sub–asset class, provided such restriction is not inconsistent with the investment management team’s stated investment strategy or philosophy, or is not fundamentally inconsistent with the nature or operation of the Service.

23

If a restriction is accepted, assets will be invested in a manner that is appropriate given your restriction. Accounts with imposed management restrictions may experience different performance from accounts without restrictions, possibly producing lower overall results. You can request an Account restriction through your Fidelity representative.

Strategic Advisers maintains policies and procedures that address the identification and correction of errors, consistent with applicable standards of care, to ensure that you are treated fairly when an error has been detected. In the event that an incident or event occurs that interrupts normal investment related activities, the determination of whether an incident constitutes an error is made by Strategic Advisers or its affiliates, in their sole discretion. Incidents involving aggregate holding compliance violations may or may not be deemed by Strategic Advisers to be errors, depending on the facts and circumstances. To the extent that client Accounts hold securities that directly or indirectly contribute to certain aggregate ownership thresholds being exceeded, Strategic Advisers may sell securities held in such Accounts in order to bring account-level and/or aggregate ownership below the relevant threshold. If any such sales result in losses for clients’ Accounts, those clients’ Accounts may bear such losses depending on the particular circumstances. Strategic Advisers or its affiliates will review the relevant facts and circumstances of each incident and if deemed to be an error, will resolve the error in a timely manner.

In the event that Strategic Advisers or its affiliates make an error that has a financial impact on your Account, Strategic Advisers or its affiliates will generally return your Account to the position it would have held had no error occurred. Strategic Advisers will evaluate each situation independently. This corrective action may result in financial or other restitution to your Account, or inadvertent gains being reversed out of the Account. Any corrective action may result in a corresponding loss or gain to Strategic Advisers or its affiliates. Other measures to correct an error may be facilitated through a fee credit or a deposit to your Account, which may result in a taxable gain. Unless prohibited by applicable regulation or a specific agreement with you, Strategic Advisers will net your gains and losses from the error or a series of errors with the same root cause and compensate you for the net loss. In general, compensation is expected to be limited to direct monetary losses and will not include any amounts that Strategic Advisers deems to be speculative or uncertain. Strategic Advisers and its affiliates have established error accounts for the resolution of errors, which may be used depending on the facts and circumstances. Strategic Advisers is not obligated to follow any single method of resolving errors. We may not reimburse for certain errors where a client’s loss is less than ten dollars per account; in such cases, we have instituted procedures designed to prevent Strategic Advisers from receiving economic benefits from limiting the correction of such errors.

Additionally, funds and Accounts may be subject to operational risks, which can include risks 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. These incidents as well as incidents resulting from the mistakes of third parties may not be compensable by Strategic Advisers to you.

In certain instances, a “do-not-trade” order may be placed on your Account for reasons including, but not limited to, processing a trade correction, your request or to comply with a court order or applicable law, rule, or regulation. For the period when a do-not-trade order is on your Account, Strategic Advisers will suspend management of your Account and will not monitor your Account for potential buys and sells of securities. Additionally, any deposits to your Account during a do-not-trade period will not be invested. Strategic Advisers is not held responsible for any market loss experienced as a result of a do-not-trade order.

24

Fidelity Portfolio Advisory Service® is a “wrap fee” program, which means that you will pay a single advisory fee for all the services provided by Strategic Advisers, FBS, and NFS for your Account, including investment management, brokerage, custody, and other services. Strategic Advisers retains a portion of the wrap fee for its services as sponsor and investment manager of the Fidelity Portfolio Advisory Service® program, and shares revenue with its affiliates, FBS and NFS, for the services they provide to your Account. For more information on the fees associated with your Account, and the fees and charges covered by your advisory fee, please see the “Fees and Compensation” section above. Fidelity Portfolio Advisory Service® does not charge performance-based advisory fees for its services.

Strategic Advisers’ investment management services generally include discretionary authority to determine which funds to purchase or sell, the total amount of such purchases and sales, and the brokers or dealers through which transactions are effected. As part of your Account application, you will be required to execute a power of attorney that grants Strategic Advisers discretionary trading authority over your Account. However, Strategic Advisers’ discretionary authority is subject to certain limits, including the applicable investment objectives, policies, and restrictions. These limitations may be based on a variety of factors such as regulatory constraints, as well as those imposed by you and agreed on by Strategic Advisers in accordance with applicable laws.

PROXY VOTING POLICY AND PROCEDURES

Strategic Advisers does not generally acquire authority for or exercise proxy voting on your behalf in connection with Fidelity Portfolio Advisory Service® Accounts. Unless you direct us otherwise pursuant to the paragraph below, you will receive proxy materials directly from the funds, their service providers, or NFS. Strategic Advisers will not advise you on the voting of proxies. You must exercise any proxy voting directly. Once you establish your Account, you may request information from your Fidelity representative as to how specific proxies were voted with respect to holdings of the Strategic Advisers Funds in your Account.

Notwithstanding the information above, you may request that Strategic Advisers act as your agent for receipt of certain legally required communications, including prospectuses, annual and semiannual reports, and proxy materials, for Non-Fidelity Funds and ETFs. You may also direct Strategic Advisers to act as your agent to vote proxies on your behalf for the funds held in your Account. For Fidelity Funds and ETFs, including the Strategic Advisers Funds, you may instruct Strategic Advisers to vote proxies of a Fidelity Fund or ETF in the same proportion as the vote of all other holders of such Fidelity Fund or ETF. For Non-Fidelity Funds and ETFs, you may 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 client 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, clients may contact a Fidelity representative to transfer the security out of the client’s Account.

In connection with this election, you acknowledge that Strategic Advisers is acting solely at your direction, and does not exercise discretion with respect to the voting of any proxy. For more information about ISS’s proxy voting policies, please see the ISS proxy voting guidelines summary included in your application materials, or contact your Fidelity representative. You may request a copy of Strategic Advisers’ proxy voting guidelines by contacting your Fidelity representative.

25

ASSETS UNDER MANAGEMENT

Strategic Advisers’ total assets under management as of December 29, 2017, were $324,851,600,000 on a discretionary basis, and $15,556,800,000 on a nondiscretionary basis. Assets under management in Fidelity Portfolio Advisory Service® on a discretionary basis as of December 29, 2017, were $214,591,700,000 and are included in the total assets listed above.

C L I E N T I N F O R M AT 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’ investment managers have access to all your relevant Account information, as well as any reasonable restrictions you have placed on your Account, on a daily ongoing basis. However, Strategic Advisers’ investment management is based on the completeness and accuracy of the information you have provided to Strategic Advisers, including, but not limited to, information about your goals, financial situation, time horizon, and risk tolerance. If you have any changes to your personal or financial situation, please contact your Fidelity representative to ensure that Strategic Advisers is managing your Account based on the most accurate information available.

C L I E N T C O N TA C T W I T H P O R T F O L I O M A N A G E R S

It is important that you contact your Fidelity representative regarding questions associated with your Account, or to provide an update about your personal situation that may impact how we manage your Account or any of the other information associated with your Account. Your service representative will act as liaison between you and the Strategic Advisers investment management team, and he or she will be responsible for communicating any changes to your personal or financial situation to the Strategic Advisers investment management team to ensure appropriate management of your Account. Strategic Advisers’ investment management team is responsible for all the investment management services provided for your Account. Strategic Advisers’ investment managers may also provide you with information about the management of your Account from time to time, but, absent special circumstances, Strategic Advisers’ investment managers generally do not meet with clients or answer client questions directly.

A D D I T I O N A L I N F O R M AT I O N

REVIEW OF ACCOUNTS

After reviewing the information provided in your IPQ, Strategic Advisers will initially propose an investment strategy and a corresponding model portfolio of funds. Your investment strategy seeks to yield adequate long-term risk-adjusted returns and manage volatility within the boundaries associated with your stated financial goals and risk tolerance. Your investment strategy will remain unchanged through various market conditions unless there is a material change to the responses in your IPQ or other material changes to your situation, or unless you determine to select a different investment strategy that you believe is most appropriate. Your ability to select a different investment strategy is subject to constraints defined by Strategic Advisers. As your investment strategy is designed to be a long-term asset allocation, please note that if you change your direction as to asset allocation frequently, Strategic Advisers may require that you terminate your participation in the Service.

26

Strategic Advisers’ investment management team will make decisions regarding reallocations within the model portfolio upon which your 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. However, the Strategic Advisers Funds are reviewed daily and assets within the Strategic Advisers Funds are reallocated based on the discretion of the Strategic Advisers portfolio managers. As a result, reallocation activity applicable to your Account’s assets invested in the Strategic Advisers Funds may take place at the fund level, rather than directly in your Account.

Strategic Advisers seeks to maintain accurate information concerning your financial situation and investment objectives, including any reasonable restrictions or reasonable modifications of existing restrictions you may wish to impose regarding the management of your Account. You are responsible for the accuracy and completeness of your IPQ information and other investment preferences used to select the model portfolio upon which your Account is invested. Strategic Advisers will rely on this information in making an initial investment proposal and managing your Account.

Strategic Advisers may provide substantially similar model portfolio proposals to different clients with similar investment objectives; however, your proposal will be based on an analysis of your individual situation as defined by your responses to the IPQ. Strategic Advisers may (and often will) provide identical model portfolio proposals to clients with similar investment objectives. Therefore, Accounts managed using the same model portfolio are expected to be invested in the same portfolio of investments and in similar weightings; however, the composition of Accounts managed using the same model portfolio may differ for a variety of reasons including, but not limited to, the timing of client investments or withdrawals and any client-imposed investment restrictions.

ANNUAL STRATEGIC REVIEW

The Annual Strategic Review is an important part of the management process that helps ensure that your investment strategy remains appropriate for you. As a result, at least once a year, Fidelity’s Portfolio Advisory Services will request information on your ongoing investment objectives, risk tolerance, planned investment time horizon, and financial goals. Additionally, you will be prompted to notify Strategic Advisers whether or not you wish to impose any reasonable restrictions on the management of your Account. Please note, if your Account is associated with Fidelity Wealth Management AdvisorySM, your profile will be updated at least annually in conjunction with that service. During your Annual Strategic Review, if you provide a change to any of your IPQ responses, this may result in a change to your investment strategy that could be either more aggressive or more conservative than your current strategy. If we fail to hear from you during the Annual Strategic Review process, Strategic Advisers will determine if the long-term asset allocation continues to be suitable for you by updating your age, your goal horizon, and all date-relative elements of the effective investment horizon. Strategic Advisers will also consider updated balances of your Fidelity-recordkept accounts as well as balances of certain outside accounts and additional accounts you may have otherwise provided to Fidelity, but will otherwise assume that your IPQ responses have not changed. In some cases, the change in your age, goal horizon, and/or account balances may be sufficient for Strategic Advisers to assign a new investment strategy even when we fail to hear from you during the Annual Strategic Review process. Strategic Advisers may monitor certain activity in your Account and contact you to confirm responses in your IPQ; however, you continue to be responsible for contacting your Fidelity representative with any changes to the IPQ information and your personal situation. However, when your IPQ contains out-of-date data which is no longer relevant, such as an expired goal, a Fidelity representative may proactively remove the data to help ensure the accuracy of your IPQ, which may have an impact in determining whether a change in your investment strategy is warranted or not. If

27

your IPQ is incomplete and/or we have been unable to reach you for an extended period of time after multiple attempts, Strategic Advisers may terminate your participation in the Service upon notice. Moreover, Strategic Advisers reserves the right to terminate your participation in the Service at any time upon notice; provided, however, that in order to comply with applicable law, rule, or regulation, there may be situations when notice will not be provided. If you are a client with a relationship with Fidelity’s Portfolio Advisory Services through the Fidelity Wealth Management AdvisorySM program, updates to your asset allocation and investment strategy will be made as part of that service. If you have multiple advisory relationships with Strategic Advisers, you will need to update your personal, financial, and other important information independently for each respective service.

From time to time, we may modify the IPQ as well as the investment or scoring methodologies that are used to generate your investment strategy. These changes may require you to provide new information to Strategic Advisers upon request or upon your next Annual Strategic Review, which may result in a new investment strategy being proposed. In these cases, if you fail to respond, Strategic Advisers will assume that none of your IPQ information has changed, other than your age, goal, and timeline, and will consider the balance of any accounts or other accounts at Fidelity that were part of your IPQ at your last review.

Note that if you have provided consent and selected an investment strategy that you believe is most appropriate for your situation, Strategic Advisers will inform you of its proposed investment strategy but will not change your strategy unless you provide instructions to terminate the consent you have previously provided. There may be instances where the investment strategy you have selected is no longer available to you because it falls outside the constraints defined by Strategic Advisers. In these instances, Strategic Advisers may terminate the consent agreement and you will receive notification of the proposed investment strategy and Strategic Advisers will invest your assets in the proposed strategy unless you provide updated profile information or you select an investment strategy that does fall within the constraints defined by Strategic Advisers. Additionally, as noted previously, Strategic Advisers will not affirmatively suggest your participation in another preference. However, you are free to change your preference.

After completing your review, if Strategic Advisers believes that a change in investment strategy is necessary, it will adjust the holdings in your Account and send a prospectus for any new fund not previously held, unless you have elected to have Strategic Advisers act as your agent for the receipt of Non-Fidelity Fund or ETF prospectuses. Any change in your personal circumstances or long-term goals at any time might also warrant a change in your investment strategy. If you have multiple advisory relationships with Strategic Advisers, you will need to update your personal, financial, and other important information independently for each respective service.

TAX INFORMATION

Fidelity is required to report certain taxable gain/loss and holding-period information on “covered securities” to the Internal Revenue Service (“IRS”) on Form 1099-B (which you will receive as part of your year-end consolidated tax-reporting statement). In addition, the Service provides estimated tax basis, corresponding realized and unrealized gain and loss, and holding-period information as a courtesy. Regardless of whether the information is reported to the IRS or only as a courtesy, information reported by Fidelity may not reflect all adjustments required for tax-reporting purposes. For example, transactions occurring in other accounts may require you to make adjustments not captured by your 1099-B or the Service.

28

ACCOUNT NOTIFICATIONS

At least quarterly, you will receive a reminder to notify Fidelity Portfolio Advisory Service® of any change in your financial situation or investment needs. At any time that your personal or financial situation changes, you should contact your Fidelity representative to initiate a review of your IPQ. Changes to your IPQ information may not currently be processed through Fidelity.com and may only be made by contacting your Fidelity representative. Your Fidelity representative serves as the ongoing liaison between you and the investment management team, and is available to discuss changes in your mutual fund allocations and is responsible for conducting reviews at least annually.

You will receive prompt confirmations from NFS for any transactions in your Account; provided, however, with respect to automatic investments, automatic withdrawals, dividend reinvestments, and transactions that involve your core Fidelity money market fund, your account statement will serve in lieu of a confirmation. You will receive monthly statements from NFS that will detail all holdings and transaction information, including trades, additions, withdrawals, shifts in investment allocations, and estimated gain/loss and tax basis information. Monthly statements and confirmations are also available online at Fidelity.com and by enrolling in the electronic delivery program. Upon signing up for this service, you will be notified by email of the availability of documents and sent a link or Internet address where the documents can be accessed. You will not pay a different fee based on your decision to receive electronic monthly statements or trade confirmations. You will also receive quarterly reviews that detail your Account’s performance and summarize the market activity during the quarter. You will also receive advisory fee information in your monthly statements during the month in which the advisory fee is paid, as well as at year-end. Industry standards are applied when calculating Account performance information. Strategic Advisers may also make available Account performance information, on a dedicated, password-protected website. We recommend that you create strong passwords containing both uppercase and lowercase letters as well as special characters, and avoid using passwords based on your date of birth, nickname, or Social Security number.

CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING

CODE OF ETHICS

Strategic Advisers has adopted a Code of Ethics for Personal Trading (the “Code of Ethics”). The Code of Ethics applies to all officers, directors, and employees of Strategic Advisers, and requires that they place the interests of Strategic Advisers’ clients above their own. The Code of Ethics establishes securities transactions requirements for all covered employees and their covered persons, including their spouses. More specifically, the Code of Ethics contains provisions requiring:

(i) Standards of general business conduct reflecting the 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 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 of securities in initial public offerings unless an exception has been approved

(vi) Reporting of Code of Ethics violations

(vii) Distribution of the Code of Ethics to all supervised persons, documented through acknowledgments of receipt

29

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, including: (i) pre-clearing of transactions in covered securities; (ii) prohibiting investments in limited offerings without prior approval; (iii) reporting of transactions in covered securities on a quarterly basis; (iv) reporting of accounts and holdings of covered securities on an annual basis; and (v) disgorgement of profits from short-term transactions unless an exception has been approved. Violation of the Code of Ethics requirements may 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 upon request.

Strategic Advisers, its advisory affiliates, or a related person may buy or sell for itself securities that it also recommends to clients. The potential conflicts of interest involved in such transactions are governed by the Code of Ethics, which establishes sanctions if its requirements are violated and requires that Strategic Advisers, its advisory affiliates, or a related person place the interests of Strategic Advisers’ clients above their own. For information about our practice with respect to conflicts regarding trading with affiliates, please refer to the “Brokerage Practices” section within this document.

From time to time, in connection with its business, Strategic Advisers may 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 nonpublic information by investment professionals or any other employees and limit the transactions that Strategic Advisers can implement for your Account.

In addition, Strategic Advisers has implemented a policy on Business Entertainment and Workplace Gifts intended to set standards for business entertainment and gifts and help employees make sound decisions with respect to these activities and ensure that the interests of Strategic Advisers’ clients come first. Similarly, to ensure compliance with applicable “pay to play” laws, Strategic Advisers has adopted a Political Contributions and Activity policy that requires all employees to pre-clear any political contributions and activities.

If you elected to invest in the All Fidelity Preference, Strategic Advisers will select only Fidelity Funds for your Account, including Strategic Advisers Funds. If you elected to invest in the Blended Preference, the Index-Focused Preference or the Defensive Strategy Preference, currently Strategic Advisers will consider only funds available through the Fidelity Investments fund supermarkets. Certain of these funds pay servicing and distribution fees to FBS or NFS. This compensation is paid by the fund and/or its affiliate.

The servicing and distribution fees that FBS or NFS receives from a fund and/or its affiliate are in addition to the advisory fees that you pay Strategic Advisers. With respect to certain of these funds, FBS or NFS may receive a percentage of the average daily net assets of Non-Fidelity Funds or ETFs in your Account; however, any such amounts received by FBS or NFS will be offset against your Gross Advisory Fee by a corresponding Credit Amount equal to the amount of revenue received as a result of your investments in these funds. See the section entitled “Fees and Compensation” above for additional information. The servicing and distribution fees that FBS receives are taken into consideration when determining your net advisory fee for your Account. Each Fidelity Fund or ETF, including the Strategic Advisers Funds, pays investment management fees and other fees to FMRCo, Strategic Advisers, or their affiliates. In addition, affiliates of Strategic Advisers are compensated for providing distribution, transfer agency, shareholder servicing, and custodial and other services to

certain funds. For Blended Preference, Index-Focused Preference and Defensive Strategy Preference portfolios, there is no predetermined allocation of Fidelity or Non-Fidelity Funds or ETFs (except that money market funds will always be Fidelity Funds). The compensation received by Strategic Advisers and its affiliates from investments in Fidelity Funds and ETFs included in a Blended Preference, Index-Focused Preference or Defensive Strategy Preference portfolio will generally exceed, prior to the application of the Credit Amount (described above), the compensation from investments in Non-Fidelity Funds and ETFs. However, the Credit Amount is intended to offset this differential.

Strategic Advisers seeks to address this potential conflict through the application of the Credit Amount noted above, and through the application of fund selection criteria and personnel compensation arrangements that do not differentiate between Fidelity and Non-Fidelity Funds and ETFs. Strategic Advisers’ investment professionals are compensated partially based on account performance and are not compensated based on the amount of Fidelity or Non-Fidelity Funds and ETFs used in the Service. Depending on market conditions and other events, certain factors in the fund selection process at times may result in a significant portion of the model portfolio being invested in Fidelity Funds or ETFs. Such an outcome is not the result of an intentional bias toward Fidelity Funds or ETFs.

BROKERAGE PRACTICES

With respect to Service Accounts, Strategic Advisers has discretionary authority to purchase and sell various eligible funds. For the Service, all commissions are waived for transactions executed through affiliates of Strategic Advisers (see “Fees and Compensation”). However, the advisory fee charged for the Service does not cover the charges resulting from trades effected with or through broker-dealers other than affiliates of Strategic Advisers or cover mark-ups or mark-downs by broker-dealers, transfer taxes, exchange fees, regulatory fees, odd-lot differentials, handling charges, electronic fund and wire transfer fees, and any other charges imposed by law or otherwise agreed to with regard to your Account. One non–Fidelity-related charge applies to sales of securities made for Accounts — an industry-wide charge mandated by the SEC and totaling a few cents per $1,000 of securities sold. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to Fidelity, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, Fidelity may retain the excess. These charges will be reflected on transaction confirmations and/or monthly statements.

Trading through Affiliates

Strategic Advisers and its delegates are authorized to place portfolio transactions with affiliated registered broker-dealers or transfer agents. Strategic Advisers will arrange for the execution of transactions through affiliated broker-dealers if Strategic Advisers reasonably believes that the quality of the execution of the transaction is comparable to what could be obtained through other qualified broker-dealers. In determining the ability of a broker-dealer to obtain best execution, Strategic Advisers will consider a number of factors, including the broker-dealer’s execution capabilities, reputation, and access to the markets for the securities being traded.

In general, Strategic Advisers or its delegate will place trades with Fidelity Capital Markets (“FCM”), a division of NFS, with respect to the execution of trades for ETFs in your Account. Strategic Advisers may allocate up to 100% of your order to FCM, subject to Strategic Advisers’ obligation to obtain best execution. Strategic Advisers reasonably believes that the quality of the execution of transactions is comparable to or more favorable than what could be obtained through other qualified broker-dealer firms. To that effect and in order to continuously assure the quality of the execution, Strategic Advisers

30

31

receives Institutional Equity Quality reporting from FCM, monitoring the quality of the execution of transactions allocated to FCM.

You will not be charged commissions on transactions executed through FCM. NFS transmits orders received for execution through FCM to various exchanges or market centers based on a number of factors. These include the following: size of the order, trading characteristics of the security, favorable execution prices (including the opportunity for price improvement), access to reliable market data, availability of efficient automated transaction processing, and execution costs. Some market centers or broker-dealers may execute orders at prices superior to the publicly quoted market prices. Strategic Advisers believes that FCM’s order-routing policies, taking into consideration all the factors listed above, are designed to result in transaction processing that is favorable to its customers. Where Strategic Advisers directs the market center to which an order is routed, FBS or FCM will route the order to such market center in accordance with Strategic Advisers’ instructions without regard to its general order-routing practices. FBS and/or FCM receives remuneration, compensation, or other consideration for directing some customers’ orders for equity securities to certain market centers for execution. Such consideration may take the form of financial credits, monetary payments, rebates, volume discounts, or reciprocal business; provided, however, that neither FBS nor FCM receives any consideration in connection with directing the execution of equity trades for your Account to market centers. The details of any credit, payment, rebate, or other form of compensation received in connection with the routing of a particular order 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 may provide aggregated trade execution data to customers and prospective customers.

Strategic Advisers and its affiliates may execute trading through an affiliated broker-dealer where the affiliated broker-dealer crosses Strategic Advisers client’s trades with those of affiliated broker-dealer clients (agency cross transactions). Such transactions will be executed in accordance with Section 206(3) of the Investment Advisers Act of 1940, as amended (“Advisers Act”), requiring written consent, confirmations of transactions, annual reporting, and compliance procedures. In addition, to the extent permitted by law and applicable policies and procedures, Strategic Advisers may effect cross trades involving Accounts in which a security is purchased in or sold from one account advised by us or our affiliate and sold or purchased from another account advised by us or our affiliate through a book-entry transfer, when Strategic Advisers believes such trades are in the best interest of all clients involved. Cross trades will be done through a book-entry transfer, either directly or through a broker-dealer (including FBS or NFS), based on one or more third-party pricing services and/or actual market bids. In general, to comply with applicable law, Strategic Advisers will not conduct any brokerage transactions on a principal basis with any affiliate or affiliated broker-dealer. However, a broker-dealer affiliated with Strategic Advisers, including NFS, may act as principal with respect to a client’s transactions in other accounts maintained with Fidelity over which Strategic Advisers has no discretionary management authority to the extent permitted by law and subject to applicable restrictions.

With respect to investments made by Fidelity Funds and ETFs, Strategic Advisers and its affiliates may allocate brokerage transactions to brokers who are not affiliates of Strategic Advisers and 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 may be paid to Strategic Advisers or its affiliates. Not all brokers with whom Strategic Advisers trades have agreed to participate in brokerage commission recapture. Strategic Advisers expects that brokers from whom Strategic Advisers or its affiliates purchase research products and services with “hard dollars” are unlikely to participate in commission recapture.

32

In connection with trading of ETFs, Strategic Advisers may aggregate the purchase and sale of securities in an effort to provide better execution. Generally, Strategic Advisers reviews and adjusts account holdings, as needed, based on the investment strategy for the client’s Account. With respect to trade allocation, Strategic Advisers’ policy is to treat each of its client’s Accounts in a fair and equitable manner when allocating orders for the purchase and sale of securities, including fund shares. Strategic Advisers has adopted a trade allocation policy designed to achieve fairness and not to purposefully disadvantage comparable client Accounts over time when allocating purchases and sales. All allocations among your Account and/or funds of funds managed by Strategic Advisers will be made in a manner consistent with Strategic Advisers’ fiduciary duties, taking into account all relevant factors.

Strategic Advisers does not have a soft dollar program. Some sub-advisers to the Strategic Advisers Funds may use soft dollar or other commission-sharing arrangements in connection with transactions effected for the Strategic Advisers Funds.

During your participation in the Service, your Account will not be available for brokerage activities outside of activities directed by Strategic Advisers including, but not limited to, margin trading or trading of securities by you or any of your designated agents. Further, FBS’s responsibilities for the Service shall be limited solely to brokerage services relating to your participation in the Service. The activities for your Account will not apply or be related to any other activities or accounts that you may maintain with Fidelity.

CLIENT REFERRALS AND OTHER COMPENSATION

FMRCo and its affiliates and subsidiaries are compensated for providing services to one or more of the funds in which Strategic Advisers’ clients may invest. These include Fidelity SelectCo, LLC, FMRCo and subsidiaries as the investment adviser for the Fidelity Funds and ETFs; Fidelity Distributors Corporation as the underwriter of the Fidelity Funds and ETFs; Fidelity Investments Institutional Operations Company, Inc., as transfer agent for the Fidelity Funds, servicing agent for Non-Fidelity Funds and ETFs, and as recordkeeper of certain workplace savings plans. In addition, one or more broker-dealer affiliates of the Fidelity Funds or ETFs may execute portfolio transactions for the funds. FMRCo or its affiliates may obtain brokerage or research services, consistent with Section 28(e) of the Securities Exchange Act of 1934 (the “Exchange Act”), from broker-dealers in connection with the execution of the Fidelity funds’ portfolio security transactions.

The group of mutual funds eligible for consideration in Fidelity Portfolio Advisory Service® model portfolios is currently limited to funds available through Fidelity’s mutual fund supermarket, FundsNetwork®. FundsNetwork is a registered service mark of FMR LLC and a service of FBS. Funds participating in Fidelity’s fund supermarket that Strategic Advisers may purchase for its clients pay remuneration to affiliates of Strategic Advisers for providing shareholder services; however, any such revenue received by affiliates of Strategic Advisers is subject to the Credit Amount mechanism described above in the section entitled “Fees and Compensation.”

In connection with your investments, certain personnel of Strategic Advisers receive other economic incentives in addition to their normal compensation. In addition, our affiliates are compensated for providing distribution, transfer agency, servicing, and custodial services to certain funds (certain of these fees are also used to calculate the Credit Amount, where applicable). The compensation that Strategic Advisers and its affiliates receive as a result of your investment in Fidelity Funds and ETFs may exceed the compensation received from your investments in Non-Fidelity Funds and ETFs; however, the Credit Amount calculation is designed to eliminate this differential. The fund fees and expenses for the various services that Strategic Advisers or its affiliates provide to the funds are

33

disclosed in each Fidelity Fund or ETF prospectus. These fees and expenses are paid by the Fidelity Funds and ETFs and are ultimately borne by the funds’ shareholders.

Client referrals are provided by affiliated entities, including FBS, or other affiliates, pursuant to referral agreements where applicable. Payments may be made to affiliates for services that facilitate delivery of Strategic Advisers’ services. Additionally, Strategic Advisers may refer clients to other independent investment advisers in connection with a referral program in which such independent investment advisers participate for a fee. Additional details are available upon request.

Strategic Advisers receives referrals through its affiliate FBS, pursuant to a referral agreement, for which compensation is provided to FBS. As noted above, Fidelity representatives receive economic incentives in addition to their normal compensation for distributing and servicing Fidelity Portfolio Advisory Service® Accounts.

CUSTODY

In order to participate in the Service, you must establish a brokerage account with FBS, a registered broker-dealer and an affiliate of Strategic Advisers. NFS, another affiliate of Strategic Advisers 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 other related services. Strategic Advisers, FBS, and NFS personnel may share premises and may have common supervision. You should carefully review statements and other communications received from FBS and NFS.

DISCIPLINARY INFORMATION AND 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 may have material business relationships with any of the subsidiaries and affiliates of FMR LLC. In addition, the principal officers of Strategic Advisers may serve as officers and/or employees of affiliated companies that are engaged in various aspects of the financial services industry.

Strategic Advisers has no material disclosable legal or disciplinary events for its management personnel associated with its advisory services.

Strategic Advisers is not registered as a broker-dealer, nor does it have an application pending to register as a broker-dealer. Certain management persons of Strategic Advisers are registered representatives of FBS and/or Fidelity Investments Institutional Services Company, Inc., Strategic Advisers affiliates and registered broker-dealers. Though Strategic Advisers may advise the mutual funds and other institutional accounts it manages regarding futures contracts, options, and swaps, Strategic Advisers currently operates pursuant to an exemption from registration with the U.S. Commodity Futures Trading Commission as a commodity trading advisor and/or a commodity pool operator.

Strategic Advisers is generally engaged in three areas of business:

1. Providing discretionary investment advisory services to individuals, trusts, retirement plans, investment companies, and charitable and other business organizations

34

2. Providing nondiscretionary advisory products and services to individuals and financial intermediaries, and developing and maintaining asset allocation and portfolio modeling methodologies for use by our affiliates

3. Providing educational materials concerning investment and personal finance

Strategic Advisers’ affiliates provide investment advisory and other services to the Fidelity mutual funds and Fidelity ETFs, and may also provide sub-advisory services to mutual funds that are managed by us (for example, Strategic Advisers Funds). When Strategic Advisers invests your assets in Fidelity mutual funds or funds that are sub-advised by an affiliate, those affiliates may receive investment management and other fees from the funds based on the amount of your invested assets.

While Strategic Advisers receives no economic benefit from our affiliated or unaffiliated entities in connection with our investment decisions, including fund selections made for your Account, FMRCo and various affiliates of FMRCo are compensated for providing services to the funds; for example:

• Fidelity Management & Research Company (“FMRCo”) as the investment adviser for the Fidelity funds;

• Fidelity Distributors Corporation (“FDC”) as the underwriter of the Fidelity funds.

One or more broker-dealer affiliates of the Fidelity funds may execute portfolio transactions for the funds. The funds’ investment advisers may obtain brokerage or research services, consistent with Section 28(e) of the Exchange Act, from broker-dealers in connection with the execution of the funds’ portfolio security transactions.

Under special, limited circumstances, clients’ assets held in Fidelity’s Portfolio Advisory Services nonretirement accounts may be counted toward certain retail brokerage account benefits/promotions in connection with offers sponsored by the affiliates of Strategic Advisers and in relation to the accounts over which Strategic Advisers does not have discretionary authority.

From time to time, Strategic Advisers or its clients may have a material business relationship with the following affiliated companies:

Investment Companies and Other Investment Advisers

• Fidelity Management & Research Company (“FMRCo”), a wholly owned subsidiary of FMR LLC, is a registered investment adviser under the Advisers Act. FMRCo principally provides portfolio management services as an adviser or a sub-adviser to registered investment companies. FMRCo may also provide portfolio management services as an adviser or sub-adviser to clients of other affiliated and unaffiliated advisers. Strategic Advisers pays FMRCo an administrative fee for handling the business affairs of the investment companies Strategic Advisers advises. In addition, it is expected that we may share employees from time to time with FMRCo.

• FIAM LLC (“FIAM”) is a wholly owned subsidiary of FIAM Holdings Corp., which in turn is wholly owned by FMR LLC and provides investment management services, including sub-advisory services to FMRCo or its affiliates. FIAM is a registered investment adviser under the Advisers Act. FIAM is also registered with the Central Bank of Ireland. In addition, it is expected that Strategic Advisers may share employees from time to time with FIAM.

• Fidelity Investments Money Management, Inc. (“FIMM”) is a wholly owned subsidiary of FMR LLC and a registered investment adviser under the Advisers Act. FIMM provides portfolio management services as a sub-adviser to certain of our clients, including investment companies in the Fidelity group of funds or as an adviser. We have sub-advisory agreements with FIMM for certain of our funds. In addition, it is expected that we may share employees from time to time with FIMM.

35

• FMR Co., Inc. (“FMRC”) is a wholly owned subsidiary of FMRCo and is a registered investment adviser under the Advisers Act. FMRC may provide portfolio management services as a sub-adviser to certain of Strategic Advisers’ clients. FMRC may also provide portfolio management services as an adviser or a sub-adviser to clients of other affiliated and unaffiliated advisers. In addition, it is expected that we may share employees from time to time with FMRC.

• Fidelity SelectCo, LLC (“SelectCo”) is a wholly owned subsidiary of FMR LLC and a registered investment adviser under the Advisers Act. SelectCo may serve as an adviser to investments in your Account.

• Fidelity Management & Research (Hong Kong) Limited (“FMR (Hong Kong)”) is a wholly owned subsidiary of FMRCo, a registered investment adviser under the Advisers Act, and has been authorized by the Hong Kong Securities & Futures Commission to advise on securities and to provide asset management services. FMR (Hong Kong) may provide investment advisory or portfolio management services as a sub-adviser with respect to certain clients of our clients, including investment companies in the Fidelity group of funds, and for clients of other affiliated and unaffiliated advisers. We have sub-advisory agreements with FMR (Hong Kong) for certain of our funds.

• Fidelity Management & Research (Japan) Inc. (“FMR (Japan)”), a direct, 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 services and discretionary investment management services. FMR (Japan) may supply investment research and investment advisory information, and may provide discretionary investment management services to certain clients of Strategic Advisers, including investment companies in the Fidelity group of funds, and to clients of other affiliated and unaffiliated advisers. We have sub-advisory agreements with FMR (Japan) for certain of our funds.

• FMR Investment Management (UK) Limited (“FMRIM(UK)”), an indirect, wholly owned subsidiary of FMRCo, is registered as an investment adviser under the Advisers Act and is authorized by the U.K. Financial Conduct Authority to provide investment advisory and asset management services. FMRIM(UK) provides investment advisory and portfolio management services as a sub-adviser to certain of Strategic Advisers’ clients, including investment companies in the Fidelity group of funds. FMRIM(UK) may provide portfolio management services as an adviser or sub-adviser to clients of other affiliated and unaffiliated advisers. FMRIM(UK) is also registered with the Central Bank of Ireland. We have sub-advisory agreements with FMRIM(UK) for certain of our funds.

• Fidelity Personal and Workplace Advisors LLC (“FPWA”) is an indirect, wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is wholly owned by FMR LLC, and a registered investment adviser under the Advisers Act. FPWA provides non-discretionary investment management services and, effective July 16, 2018, will serve as the sponsor to investment advisory programs, including the Service.

Broker-Dealers

• Fidelity Distributors Corporation (“FDC”), a wholly-owned subsidiary of Fidelity Global Brokerage Group, Inc., acts as principal underwriter and general distribution agent of the registered investment companies advised by FMRCo. FDC is a registered broker-dealer under the Exchange Act.

• National Financial Services LLC (“NFS”) is engaged in the institutional brokerage business and provides clearing and execution services for other brokers. NFS is a wholly owned subsidiary of

36

Fidelity Global Brokerage Group, Inc., a holding company that provides administrative services to NFS. Fidelity Capital Markets (“FCM”), a division of NFS, may execute transactions for our investment companies and other clients. Additionally, FCM operates CrossStream®, an alternative trading system that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. FCM charges a commission to both sides of each trade executed in CrossStream. Using CrossStream, FCM crosses client accounts, and it charges a commission on its trades to both of its brokerage customers. CrossStream may be used to execute transactions for our investment companies and other clients. NFS is a registered broker-dealer under the Exchange Act, and NFS is also registered as an investment adviser under the Advisers Act. NFS may serve as a clearing agent for client transactions that we place with certain broker-dealers. NFS may provide transfer agent or subtransfer agent services to certain of our or our affiliates’ clients. NFS provides transaction processing services in conjunction with the implementation of our discretionary investment management instructions. NFS also provides custodial, recordkeeping, and reporting services to clients. We compensate NFS for these services to the Service.

In all cases, transactions executed by affiliated brokers on behalf of investment company clients are effected in accordance with Rule 17e-1 under the 1940 Act, and procedures approved by the Board of Trustees of the funds. The Board of Trustees of each fund in the Fidelity group of funds has approved FCM effecting fund portfolio transactions and retaining compensation in connection with such transactions pursuant to Section 11(a) of the Exchange Act.

• Fidelity Brokerage Services LLC (“FBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., is a registered broker-dealer under the Exchange Act and provides brokerage products and services, including the sale of shares of investment companies advised by FMRCo to individuals and institutions, including retirement plans administered by affiliates. Pursuant to referral agreements and for compensation, representatives of FBS may refer customers to various services offered by FBS’s related persons, including Strategic Advisers. In addition, FBS is the distributor of insurance products, including variable annuities, that are issued by FMRCo’s related persons, Fidelity Investments Life Insurance Company (“FILI”) and Empire Fidelity Investments Life Insurance Company® (“EFILI”). FBS may provide shareholder services to certain of FMRCo’s or FMRCo’s affiliates’ clients.

• Fidelity Investments Institutional Services Company, Inc. (“FIISC”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, primarily markets Fidelity mutual funds and other products advised by FMRCo or an affiliate thereof to third-party financial intermediaries and certain institutional investors. FIISC is a registered broker-dealer under the Exchange Act.

• Fidelity Global Brokerage Group, Inc., a wholly-owned subsidiary of FMR LLC, wholly-owns four broker-dealers: FBS, NFS, FIISC and FDC, and also has an equity interest in eBX LLC (“eBX”), a holding company and a registered broker-dealer under the Exchange Act, which was formed for the purpose of developing, owning and operating an alternative trading system, the “Level ATS.” Transactions for Strategic Advisers’ customers or other entities for which Strategic Advisers serves as adviser or sub-adviser or provides discretionary trading services, as well as for customers of Strategic Advisers’ affiliates may be executed through the Level ATS. Strategic Advisers disclaims that it is a related person of eBX.

37

• Fidelity Clearing Canada ULC (“FCC”) is engaged in the institutional brokerage business and provides clearing and execution services for other brokers. FCC is a wholly-owned subsidiary of 483 Bay Street Holdings LP, which is a joint venture between Fidelity Canada Investors LLC and FIL Limited.

• Luminex Trading & Analytics LLC (“LTA”), a registered broker-dealer and alternative trading system, was formed for the purpose of establishing and operating an electronic execution utility (the “LTA ATS”) that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. FMR LLC is the majority owner of LTA. LTA charges a commission to both sides of each trade executed in the LTA ATS. The LTA ATS may be used to execute transactions for Strategic Advisers or Strategic Advisers’ affiliates’ investment company and other advisory clients. NFS serves as the clearing agent for transactions executed in the LTA ATS.

Banking Institutions

• Fidelity Management Trust Company (“FMTC”), a trust company organized and operating under the laws of the Commonwealth of Massachusetts, provides non-discretionary trustee and custodial services to employee benefit plans and IRAs through which individuals may invest in mutual funds managed by FMRCo or its affiliates, and discretionary investment management services to institutional clients. FMTC is a wholly owned subsidiary of FMR LLC. FMRCo or its affiliates provide certain administrative services to FMTC, including, but not limited to, securities execution, investment compliance, and proxy voting.

Limited Partnerships and Limited Liability Company Investments

Strategic Advisers may provide 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 intend to engage in borrowing, lending, purchasing securities on margin, short selling, or trading in commodities.

Participating Affiliates

Fidelity Business Services India Private Limited (“FBS India”), with its registered office in Bangalore, is incorporated under the laws of India and is ultimately owned by FMR LLC through certain of its direct or indirect subsidiaries. Certain employees of FBS India (“FBS India Associated Employees”) may from time to time provide certain research services for Strategic Advisers, which Strategic Advisers may use for its customers.

FBS India 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 FBS India and each of the FBS India Associated Employees as “associated persons” of Strategic Advisers within the meaning of Section 202(a)(17) of the Advisers Act. FBS India Associated Employees and FBS India, through such employees, may contribute to Strategic Advisers’ research process and may have access to information concerning securities that are being selected for the client prior to the effective implementation of such selections.

FIAM and Strategic Advisers each maintain a list of FBS India Associated Employees whom it has deemed “associated persons,” which Strategic Advisers will make available to current U.S. clients upon request.

38

As noted above, Strategic Advisers and certain of its affiliates receive compensation as a result of sales or servicing of funds used in Fidelity’s Portfolio Advisory Services program. However, conflicts associated with the receipt of any such fees are mitigated by the use of a Credit Amount that reduces the Service’s Gross Advisory Fee by the amount of revenue received by Strategic Advisers and its affiliates from such underlying funds or their affiliates as a result of investments by an Account. For additional information regarding the Credit Amount, please see the “Fees and Compensation” section.

39

Keep in mind that investing involves risk. The value of your investment will fluctuate over time and you may gain or lose money.Fidelity Portfolio Advisory Service® is a service of Strategic Advisers LLC, a registered investment adviser and a Fidelity Investments company. This service provides discretionary money management for a fee.

Fidelity Wealth Management AdvisorySM is a service of Strategic Advisers LLC, a registered investment adviser and a Fidelity Investments company. This advisory service is provided for a fee. Brokerage services are provided by Fidelity Brokerage Services LLC, 900 Salem Street, Smithfield, RI 02917, a Fidelity Investments company and a member of NYSE and SIPC. Custody and other services are provided by National Financial Services LLC, a Fidelity Investments company and a member of NYSE and SIPC.Fidelity Wealth Management Advisory is a service mark, and Fidelity, Fidelity Private Wealth Management, and Fidelity Investments are registered service marks, of FMR LLC.Dow Jones U.S. Total Stock Market Index: A float-adjusted market capitalization–weighted index of all equity securities of U.S.-headquartered companies with readily available price data.Russell 3000® Index: A market capitalization–weighted index designed to measure the performance of the 3,000 largest companies in the U.S. equity market.S&P 500® Index: A registered service mark of The McGraw-Hill Companies, Inc., the index has been licensed for use by Fidelity Distributors Corporation and its affiliates. It 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. Stock markets are volatile and can fluctuate significantly in response to company, industry, political, regulatory, market, or economic developments. Investing in stock involves risks, including the loss of principal.Indexes are unmanaged. It is not possible to invest directly in an index.Fidelity Brokerage Services LLC, Member NYSE and SIPC, 900 Salem Street, Smithfield, RI 02917© 2018 FMR LLC. All rights reserved.

418882.21.0 PAS-FNDMNTL-0318 1.862818.117

FOR MORE INFORMATION, PLEASE CALL US TOLL FREE AT

1 - 8 0 0 - 5 4 4 - 3 4 5 5

Monday through Fr iday, 8 a.m. to 7 p.m. Eastern t ime

Supplemental Brochures:

Your Fidelity Portfolio Advisory Service® Account

Key Fidelity personnel involved with your account include:

• Wilfred Chilangwa

• George A. Fischer

• Robert L. Macdonald

• Gregory Pappas

• Lawrence Rakers

• John A. Stone

Additional information about the persons listed above is available on the SEC’s website at adviserinfo.sec.gov.

3

Wilfred Chilangwa

Supplemental Brochure:

FIDELITY PORTFOLIO ADVISORY SERVICE®

Strategic Advisers, Inc. 245 Summer Street, V5D Boston, MA 02210 617-563-7100

August 31, 2015

This supplemental brochure is designed for clients and/or anyone interested in a professionally managed account from Fidelity. This separate section is devoted to information about Wilfred Chilangwa, a member of the Strategic Advisers, Inc., Investment Management Team, and should be viewed as additional information to the Fidelity Portfolio Advisory Service brochure (the “Program Fundamentals”). You should have already received a copy of the Program Fundamentals. Please contact your Fidelity representative if you did not receive the Program Fundamentals or if you have any questions about the contents of this new information.

On behalf of Fidelity, we thank you for the opportunity to help you reach your investing goals through a professionally managed account from Fidelity.

4

Wilfred Chilangwa

EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCEWilfred Chilangwa, an international equity Portfolio Manager for Strategic Advisers, Inc. (“Strategic” or “Strategic Advisers”), is a lead member of the team that manages the Fidelity Portfolio Advisory Service (the “Service”) program. Prior to joining Strategic Advisers in February 1997, Mr. Chilangwa was with State Street in Boston, where he worked as a Senior Research Analyst on emerging markets and as Assistant Vice President focusing on new product development for global investment and asset administration. Born in 1969, Mr. Chilangwa’s education includes a BA in physics and economics from Brandeis University, an MA in international finance and economics from the Brandeis International Business School, and an International Baccalaureate from St. Clare’s, Oxford, United Kingdom. Mr. Chilangwa is a Chartered Financial Analyst (CFA®) charterholder.1

DISCIPLINARY INFORMATIONThere are no material disclosable legal or disciplinary events that are material to your evaluation of Mr. Chilangwa or his integrity.

OTHER BUSINESS ACTIVITIESMr. Chilangwa is not actively engaged in any other investment-related business or occupation.

ADDITIONAL COMPENSATIONMr. Chilangwa does not receive any economic benefit or compensation for providing advisory services to any party who is not a client of Strategic Advisers.

SUPERVISIONMr. Chilangwa reports to Brian Enyeart, the Chief Investment Officer (“CIO”), who is responsible for the oversight of Portfolio Management for Fidelity Portfolio Advisory Service®, and has supervisory authority for the team that manages the Service. The CIO is responsible for ensuring that the Portfolio Management Team manages all portfolios in the Service within the parameters that have been established for each investment strategy and in adherence with Strategic Advisers’ investment policies and procedures. This includes risk management and exposures, and performance management and attribution.

Mr. Enyeart may be contacted at 617-563-5200.

REQUIREMENTS FOR STATE-REGISTERED ADVISERSStrategic Advisers, Inc., is not registered with any state securities authority.

1 The CFA designation is offered by the CFA Institute. To obtain the CFA charter, candidates must pass three exams demonstrating their competence, integrity and extensive knowledge in accounting, ethical and professional standards, economics, portfolio man-agement, and security analysis, and must also have at least three years of qualifying work experience, among other requirements.

5

George A. Fischer

Supplemental Brochure:

FIDELITY PORTFOLIO ADVISORY SERVICE®

Strategic Advisers, Inc. 245 Summer Street, V5D Boston, MA 02210 617-563-7100

March 9, 2018

This supplemental brochure is designed for clients and/or anyone interested in a professionally managed account from Fidelity. This separate section is devoted to information about George A. Fischer, a member of the Strategic Advisers, Inc., Investment Management Team, and should be viewed as additional information to the Fidelity Portfolio Advisory Service brochure (the “Program Fundamentals”). You should have already received a copy of the Program Fundamentals. Please contact your Fidelity representative if you did not receive the Program Fundamentals or if you have any questions about the contents of this new information.

On behalf of Fidelity, we thank you for the opportunity to help you reach your investing goals through a professionally managed account from Fidelity.

6

George A. Fischer

EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCEGeorge Fischer, a Portfolio Manager for Strategic Advisers, Inc. (“Strategic” or “Strategic Advisers”), is a lead member of the team that manages the Fidelity Portfolio Advisory Service (the “Service”) program. Prior to assuming his current position in January 2018, Mr. Fischer served as senior advisor in Fidelity’s Fixed Income Division. Previous to that, he was managing director of research for macroeconomic and structured securities within Fidelity’s Fixed Income division. Before that, he managed a variety of retail mutual funds and separate accounts as a portfolio manager at FMR Co., and was a member of both the Municipal Bond portfolio management team and the Taxable Bond portfolio management group. He joined Fidelity as a municipal research analyst in 1989. Born in 1961, Mr. Fischer earned his bachelor of arts degree in psychology from Boston College and his master of business administration degree in finance from The Wharton School of the University of Pennsylvania.

DISCIPLINARY INFORMATIONThere are no material disclosable legal or disciplinary events that are material to your evaluation of Mr. Fischer or his integrity.

OTHER BUSINESS ACTIVITIESMr. Fischer is not actively engaged in any other investment-related business or occupation.

ADDITIONAL COMPENSATIONMr. Fischer does not receive any economic benefit or compensation for providing advisory services to any party who is not a client of Strategic Advisers.

SUPERVISIONMr. Fischer reports to Brian Enyeart, the Chief Investment Officer (“CIO”), who is responsible for the oversight of Portfolio Management for Fidelity Portfolio Advisory Service®, and has supervisory authority for the team that manages the Service. The CIO is responsible for ensuring that the Portfolio Management Team manages all portfolios in the Service within the parameters that have been established for each investment strategy and in adherence with Strategic Advisers’ investment policies and procedures. This includes risk management and exposures, and performance management and attribution.

Mr. Enyeart may be contacted at 617-563-5200.

REQUIREMENTS FOR STATE-REGISTERED ADVISERSStrategic Advisers, Inc., is not registered with any state securities authority.

7

Robert L. Macdonald

Supplemental Brochure:

FIDELITY PORTFOLIO ADVISORY SERVICE®

Strategic Advisers, Inc. 245 Summer Street, V5D Boston, MA 02210 617-563-7100

August 31, 2015

This supplemental brochure is designed for clients and/or anyone interested in a professionally managed account from Fidelity. This separate section is devoted to information about Robert L. Macdonald, a member of the Strategic Advisers, Inc., Investment Management Team, and should be viewed as additional information to the Fidelity Portfolio Advisory Service brochure (the “Program Fundamentals”). You should have already received a copy of the Program Fundamentals. Please contact your Fidelity representative if you did not receive the Program Fundamentals or if you have any questions about the contents of this new information.

On behalf of Fidelity, we thank you for the opportunity to help you reach your investing goals through a professionally managed account from Fidelity.

8

Robert L. Macdonald

EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCERobert L. Macdonald is a Senior Vice President and Director of Financial Solutions for Strategic Advisers, Inc. (“Strategic” or “Strategic Advisers”). Mr. Macdonald oversees the investment profiling methodol-ogy used by Portfolio Advisory Service to provide suitable asset allocation proposals to clients. Mr. Macdonald joined Fidelity in 1985 as a quantitative analyst with Fidelity Management Trust Company (“FMTC”). In 1987, he was promoted to Vice President and Portfolio Manager with FMTC’s Structured Investment group. Born in 1955, Mr. Macdonald received a BA in finance from the University of South Florida in 1979 and an MBA in finance from Boston University in 1985. Mr. Macdonald is a Chartered Financial Analyst (CFA®) charterholder.1

DISCIPLINARY INFORMATIONThere are no material disclosable legal or disciplinary events that are material to your evaluation of Mr. Macdonald or his integrity.

OTHER BUSINESS ACTIVITIESMr. Macdonald is not actively engaged in any other investment-related business or occupation.

ADDITIONAL COMPENSATIONMr. Macdonald does not receive any economic benefit or compensation for providing advisory services to any party who is not a client of Strategic Advisers.

SUPERVISIONMr. Macdonald reports to Bruce T. Herring, President of Strategic Advisers, who is responsible for overseeing multi-asset-class and managed account investment management capabilities, including the profiling methodology developed by Mr. Macdonald, which is used to determine the asset allocation proposals provided to clients. Mr. Herring holds regular meetings with Mr. Macdonald in which the profiling methodology is reviewed and approved.

Mr. Herring may be contacted at 617-563-7966.

REQUIREMENTS FOR STATE-REGISTERED ADVISERSStrategic Advisers, Inc., is not registered with any state securities authority.

1 The CFA designation is offered by the CFA Institute. To obtain the CFA charter, candidates must pass three exams demonstrating their competence, integrity and extensive knowledge in accounting, ethical and professional standards, economics, portfolio man-agement, and security analysis, and must also have at least three years of qualifying work experience, among other requirements.

9

Gregory Pappas

Supplemental Brochure:

FIDELITY PORTFOLIO ADVISORY SERVICE®

Strategic Advisers, Inc. 245 Summer Street, V5D Boston, MA 02210 617-563-7100

August 31, 2015

This supplemental brochure is designed for clients and/or anyone interested in a professionally managed account from Fidelity. This separate section is devoted to information about Gregory Pappas, a member of the Strategic Advisers, Inc., Investment Management Team, and should be viewed as additional information to the Fidelity Portfolio Advisory Service brochure (the “Program Fundamentals”). You should have already received a copy of the Program Fundamentals. Please contact your Fidelity representative if you did not receive the Program Fundamentals or if you have any questions about the contents of this new information.

On behalf of Fidelity, we thank you for the opportunity to help you reach your investing goals through a professionally managed account from Fidelity.

10

Gregory Pappas

EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCEGregory Pappas, a fixed income Portfolio Manager for Strategic Advisers, Inc. (“Strategic” or “Strategic Advisers”), is a lead member of the team that manages the Fidelity Portfolio Advisory Service pro-gram. Prior to joining Strategic Advisers in 1996, Mr. Pappas was with Fidelity’s National Financial Correspondent Services group, where he was a Vice President focusing on fixed income product and business development. Before he joined Fidelity in 1990, Mr. Pappas was with the Bank of New England, where he was a Senior Portfolio Manager working on the bank’s investment portfolio. Born in 1955, Mr. Pappas received a BA, cum laude, in economics, from St. Lawrence University. Mr. Pappas is a Chartered Financial Analyst (CFA®) charterholder.1

DISCIPLINARY INFORMATIONThere are no material disclosable legal or disciplinary events that are material to your evaluation of Mr. Pappas or his integrity.

OTHER BUSINESS ACTIVITIESMr. Pappas is not actively engaged in any other investment-related business or occupation.

ADDITIONAL COMPENSATIONMr. Pappas does not receive any economic benefit or compensation for providing advisory services to any party who is not a client of Strategic Advisers.

SUPERVISIONMr. Pappas reports to Brian Enyeart, the Chief Investment Officer (“CIO”), who is responsible for the oversight of Portfolio Management for Fidelity Portfolio Advisory Service®, and has supervisory authority for the team that manages the Service. The CIO is responsible for ensuring that the Portfolio Management Team manages all portfolios in the Service within the parameters that have been established for each investment strategy and in adherence with Strategic Advisers’ investment policies and procedures. This includes risk management and exposures, and performance management and attribution.

Mr. Enyeart may be contacted at 617-563-5200.

REQUIREMENTS FOR STATE-REGISTERED ADVISERSStrategic Advisers, Inc., is not registered with any state securities authority.

1 The CFA designation is offered by the CFA Institute. To obtain the CFA charter, candidates must pass three exams demonstrating their competence, integrity and extensive knowledge in accounting, ethical and professional standards, economics, portfolio man-agement, and security analysis, and must also have at least three years of qualifying work experience, among other requirements.

11

Lawrence Rakers

Supplemental Brochure:

FIDELITY PORTFOLIO ADVISORY SERVICE®

Strategic Advisers, Inc. 245 Summer Street, V5D Boston, MA 02210 617-563-7100

August 31, 2015

This supplemental brochure is designed for clients and/or anyone interested in a professionally managed account from Fidelity. This separate section is devoted to information about Lawrence (“Larry”) Rakers, a member of the Strategic Advisers, Inc., Investment Management Team, and should be viewed as additional information to the Fidelity Portfolio Advisory Service brochure (the “Program Fundamentals”). You should have already received a copy of the Program Fundamentals. Please contact your Fidelity representative if you did not receive the Program Fundamentals or if you have any questions about the contents of this new information.

On behalf of Fidelity, we thank you for the opportunity to help you reach your investing goals through a professionally managed account from Fidelity.

12

Lawrence Rakers

EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCELarry Rakers is a Portfolio Manager for Strategic Advisers, Inc. (“Strategic” or “Strategic Advisers”). In his role as lead asset allocation Portfolio Manager, Mr. Rakers has responsibility for the asset allocation process within Fidelity Portfolio Advisory Service®, working closely with the Investment Management and Research Teams to make asset allocation decisions. Mr. Rakers joined Fidelity in 1993 as an analyst at Fidelity Management & Research Company (FMRCo), covering various industries, and managed multiple funds from 1993 to 2008. In 2008, he became Portfolio Manager for a number of Fidelity mutual funds, including Fidelity® Dividend Growth Fund. Born in 1963, Mr. Rakers received BS and MS degrees from the University of Illinois and an MBA from Northeastern University.

DISCIPLINARY INFORMATIONThere are no material disclosable legal or disciplinary events that are material to your evaluation of Mr. Rakers or his integrity.

OTHER BUSINESS ACTIVITIESMr. Rakers is not actively engaged in any other investment-related business or occupation.

ADDITIONAL COMPENSATIONMr. Rakers does not receive any economic benefit or compensation for providing advisory services to any party who is not a client of Strategic Advisers.

SUPERVISIONMr. Rakers reports to Brian Enyeart, the Chief Investment Officer (“CIO”), who is responsible for the oversight of Portfolio Management for Fidelity Portfolio Advisory Service®, and has supervisory authority for the team that manages the Service. The CIO is responsible for ensuring that the Portfolio Management Team manages all portfolios in the Service within the parameters that have been established for each investment strategy and in adherence with Strategic Advisers’ investment policies and procedures. This includes risk management and exposures, and performance management and attribution.

Mr. Enyeart may be contacted at 617-563-5200.

REQUIREMENTS FOR STATE-REGISTERED ADVISERSStrategic Advisers, Inc., is not registered with any state securities authority.

13

John A. Stone

Supplemental Brochure:

FIDELITY PORTFOLIO ADVISORY SERVICE®

Strategic Advisers, Inc. 245 Summer Street, V5D Boston, MA 02210 617-563-7100

August 31, 2015

This supplemental brochure is designed for clients and/or anyone interested in a professionally managed account from Fidelity. This separate section is devoted to information about John A. Stone, a member of the Strategic Advisers, Inc., Investment Management Team, and should be viewed as additional information to the Fidelity Portfolio Advisory Service brochure (the “Program Fundamentals”). You should have already received a copy of the Program Fundamentals. Please contact your Fidelity representative if you did not receive the Program Fundamentals or if you have any questions about the contents of this new information.

On behalf of Fidelity, we thank you for the opportunity to help you reach your investing goals through a professionally managed account from Fidelity.

14

John A. Stone

EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCEJohn A. Stone, a domestic equity Portfolio Manager for Strategic Advisers, Inc. (“Strategic” or “Strategic Advisers”), is a lead member of the team that manages the Fidelity Portfolio Advisory Service program. Mr. Stone joined Strategic Advisers in 2008. Prior to joining Strategic Advisers, Mr. Stone was a Portfolio Manager and a Principal at Mercer Global Investments. Prior to joining Mercer in 2006, Mr. Stone was with Fidelity Investments for 12 years, most recently as Vice President, Senior Investment Analyst. Born in 1970, Mr. Stone earned a BS in quantitative economics from Tufts University (in 1992) and an MBA from The Johnson Graduate School of Management at Cornell University (in 1998). Mr. Stone is a Chartered Financial Analyst (CFA®) charterholder.1

DISCIPLINARY INFORMATIONThere are no material disclosable legal or disciplinary events that are material to your evaluation of Mr. Stone or his integrity.

OTHER BUSINESS ACTIVITIESMr. Stone is not actively engaged in any other investment-related business or occupation.

ADDITIONAL COMPENSATIONMr. Stone does not receive any economic benefit or compensation for providing advisory services to any party who is not a client of Strategic Advisers.

SUPERVISIONMr. Stone reports to Brian Enyeart, the Chief Investment Officer (“CIO”), who is responsible for the oversight of Portfolio Management for Fidelity Portfolio Advisory Service®, and has supervisory authority for the team that manages the Service. The CIO is responsible for ensuring that the Portfolio Management Team manages all portfolios in the Service within the parameters that have been established for each investment strategy and in adherence with Strategic Advisers’ investment policies and procedures. This includes risk management and exposures, and performance management and attribution.

Mr. Enyeart may be contacted at 617-563-5200.

REQUIREMENTS FOR STATE-REGISTERED ADVISERSStrategic Advisers, Inc., is not registered with any state securities authority.

1 The CFA designation is offered by the CFA Institute. To obtain the CFA charter, candidates must pass three exams demonstrating their competence, integrity and extensive knowledge in accounting, ethical and professional standards, economics, portfolio man-agement, and security analysis, and must also have at least three years of qualifying work experience, among other requirements.

Fidelity Portfolio Advisory Service® is a service of Strategic Advisers, Inc., a registered investment adviser and a Fidelity Investments company. This service provides discretionary money management for a fee.

Brokerage services are provided by Fidelity Brokerage Services LLC. Custody and other services are provided by National Financial Services LLC. Both are Fidelity Investments companies and members of NYSE and SIPC.

Fidelity Brokerage Services LLC, Member NYSE and SIPC, 900 Salem Street, Smithfield, RI 02917

© 2018 FMR LLC. All rights reserved.

584768.8.0 PAS-FNDMNTL-PART B-0318 1.930374.107

Fidelity® Wealth Services

Program Fundamentals

Fidelity Personal and Workplace Advisors LLC

245 Summer Street, V2A

Boston, MA 02210

(617) 563-7000

March 29, 2018 (with an effective date of July 16, 2018)

This wrap fee program brochure provides information about the qualifications and business practices of Fidelity Personal and Workplace Advisors LLC (“FPWA”), a Fidelity Investments company, as well as information about Fidelity® Wealth Services.

Throughout this brochure and related materials, FPWA may refer to itself as a “registered investment adviser” or “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 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 FPWA is available on the SEC’s website at www.adviserinfo.sec.gov.

2

TA B L E O F C O N T E N T S

SERVICES, FEES AND COMPENSATION 3

ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS 12

PORTFOLIO MANAGER SELECTION AND EVALUATION 15

CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS 15

CLIENT CONTACT WITH PORTFOLIO MANAGERS 15

ADDITIONAL INFORMATION 16

3

S E R V I C E S , F E E S A N D C O M P E N S AT I O N

Fidelity Personal and Workplace Advisors LLC (“FPWA”) is a registered investment adviser and an indirect, wholly owned subsidiary of FMR LLC (collectively with FPWA and its affiliates, “Fidelity Investments,” “Fidelity,” “us,” or “we”). FPWA was formed in 2017 and, as of July 2018, will offer Fidelity® Wealth Services (the “Program”). In addition, as of July 16, 2018, FPWA will succeed its affiliate, Strategic Advisers LLC (“Strategic Advisers”), as the sponsor offering certain other Fidelity investment advisory programs (see “Predecessor Services” below) and, simultaneously, clients in the Predecessor Services will be transitioned to this Program.

As described below, the Program services include discretionary investment management, access to assistance from one or more Fidelity representatives, and access to financial planning (altogether, the “Program Services”). Discretionary investment management is provided through one or more Portfolio Advisory Services accounts (each a “Program Account”). Program Accounts can include tax-advantaged accounts (e.g., Traditional, Roth, SEP, and SIMPLE Individual Retirement Accounts, collectively “Retirement Program Accounts”) and taxable accounts (each a “Taxable Program Account”). A client (“client” or “you”) must invest and maintain a minimum of $50,000 in at least one Program Account to be eligible for the Program. Program Services may be provided in person, via telephone or digitally.

FPWA has retained the services of its affiliate, Strategic Advisers, to provide the discretionary portfolio management services described in this document. Strategic Advisers has access to a wide range of research and analytics that support its management of Program Accounts. Important information regarding Strategic Advisers, including details regarding its research and portfolio management capabilities, can be found in Strategic Advisers’ Fidelity® Wealth Services Program Fundamentals (“Strategic Advisers’ Program Brochure”).

Discretionary Investment Management Services

As a first step in the delivery of Program Services, we will help you to identify your investment goals and objectives, risk tolerance, planned investment time horizon, other assets, and other information we deem necessary to understand your situation (“Profile Information”). Based on your Profile Information, we will propose a long-term asset allocation for each of your Program Accounts, as appropriate. Each asset allocation is composed of a combination of stocks, bonds, and short-term investments and is designed to correspond to a level of risk ranging from conservative (lower risk/lower return potential) to aggressive (higher risk/higher return potential).

Each Program Account will typically be invested on a discretionary basis to align with the asset allocation (“Account Asset Allocation”) and/or investment preferences and strategies you select, and will be subject to ongoing management and rebalancing, as appropriate, to maintain such alignment. As described in greater detail below, investments can include mutual funds, exchange-traded products (“ETPs”) and, for eligible Taxable Program Accounts of certain asset levels, individual securities. ETPs may include exchange-traded funds (“ETFs”), exchange-traded notes, unit investment trusts, closed-end funds, master limited partnerships, and certain grantor trusts. Mutual funds and ETPs may be managed by Fidelity, including Strategic Advisers, and/or third-party investment managers. Mutual funds and ETPs selected for Program Accounts will typically invest in a combination of 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 may also hold shares of mutual funds and ETPs that invest in nontraditional asset classes and/or extended asset classes, including, but not limited to, real estate, inflation-protected debt securities, commodities, or other alternative investments. BlackRock® Diversified Income Portfolio (“BDIP”) Program Accounts have specific investment parameters that are discussed below, and information regarding Program investment preferences and options is not applicable to BDIP Program Accounts. In addition, clients who participate in Fidelity Private Wealth Management may be eligible to receive enhanced Program Services, including tailored portfolio management solutions, as discussed below.

4

Retirement Program Accounts are generally invested in a model-based portfolio composed of mutual funds and, depending on a client’s preference, ETPs. The composition of Program Accounts managed using the same model portfolio may differ for a variety of reasons, including, but not limited to, the timing of client investments and withdrawals, and any client-imposed investment restrictions. Taxable Program Accounts, other than BDIP Program Accounts, are invested in a portfolio of mutual funds and/or ETPs, and, if a client is willing to invest at least $200,000 in such Taxable Program Account, may also be invested in individual securities through separately managed accounts (“SMAs”) discussed below (each, a “Tax-Sensitive Program Account”). Tax-Sensitive Program Accounts will be managed using tax-sensitive investment strategies that seek to enhance after-tax returns, including, without limitation, harvesting tax losses, analyzing tax lots, and managing exposure to mutual fund distributions. The specific tax-sensitive strategies utilized will depend on the size of the account and the Account Asset Allocation selected.

Clients may select from the following investment preferences for their Program Accounts (other than Tax-Sensitive Program Accounts):

• The Blended Preference uses both Fidelity and non-Fidelity mutual funds and, for Tax-Sensitive Program Accounts, ETPs, and seeks to enhance risk-adjusted returns through broad diversification across asset classes;

• The Fidelity Focused Preference primarily uses Fidelity mutual funds and/or ETPs, and seeks to enhance risk-adjusted returns through broad diversification across asset classes;

• The Index-Focused Preference uses both Fidelity and non-Fidelity mutual funds and/or ETPs, and seeks to enhance risk-adjusted returns through broad diversification across asset classes. Generally, there is a preference for passively managed mutual funds or ETPs, but this strategy may also invest in actively managed mutual funds or ETPs when deemed appropriate; and

• The Defensive Strategy Preference uses both Fidelity and non-Fidelity mutual funds and/or ETPs, and seeks to temper downside risk by investing in “defensive” strategies across asset classes.

For their Tax-Sensitive Program Accounts, clients may select the Blended Preference, and it is anticipated that the other investment preferences identified above will be made available to Tax-Sensitive Program Accounts in the near future. Additional investment preferences may be made available to Retirement and/or Tax-Sensitive Program Accounts from time to time.

With respect to Tax-Sensitive Program Accounts, a portion of an account may be invested in one or more SMAs, depending on the amount invested, Profile Information and Account Asset Allocation. SMAs consist of investment “sleeves,” each of which is managed using investment models provided by Fidelity or third-party investment advisers (“Model Providers”) which are then individually tailored based on a client’s existing holdings and unique financial situation, as well as the tax attributes of the holdings in the Tax-Sensitive Program Account. We may propose one or more of the following SMAs for a client’s consideration:

• Fidelity Strategic Advisers U.S. Large Cap Equity SMA seeks to outperform the S&P 500® Index;

• Strategic Advisers Tax-Managed U.S. Large Cap SMA seeks to approximate the pre-tax risk and return characteristics of the S&P 500® Index;

• Strategic Advisers Equity Growth SMA seeks to outperform the Russell 1000® Growth Index; and

• Strategic Advisers Equity Value SMA seeks to outperform the Russell 1000® Value Index.

Additional SMAs may be made available to Program clients from time to time. Note that there is an additional fee for SMAs where a Model Provider that is unaffiliated with FPWA (“Unaffiliated Model Provider”) is used (see “Fees for SMAs” below). See Strategic Advisers’ Program Brochure for additional information regarding its tax-sensitive investing process and the SMA models.

5

A client may elect to participate in the Increased International Option, which will modify the Account Asset Allocation of a Tax-Sensitive Program Account by increasing the exposure to international equity securities from approximately 30% of the overall equity allocation to approximately 50% of the overall equity allocation. Performance may differ, at times significantly, from the performance of a Tax-Sensitive Program Account without increased international exposure.

A client may request that monies be invested in a “Short-Term Position” sleeve of a Tax-Sensitive Program Account, whereby such amounts will be invested in the client’s core Fidelity money market fund to be used for short-term and liquidity purposes. Assets held in the Short-Term Position sleeve are not managed on a discretionary basis and are not assessed an annual Gross Advisory Fee (see “Fees and Compensation” below).

Over time, transactions will be made in a Tax-Sensitive Program Account that could trigger taxable gains. For example, trading activity will likely trigger taxable gains in a Tax-Sensitive Program Account if (1) many or all of the securities in the account have experienced investment gains since last being traded, or (2) if the account is reallocated to align with a change in a client’s Account Asset Allocation. In addition, in a given year, a client may receive varying levels of taxable fund distributions within a Tax-Sensitive Program Account. Tax-Sensitive Program Accounts are actively managed for federal income taxes, but are not managed in consideration of state or local taxes, foreign taxes on non-U.S. investments, or estate, gift, or generation-skipping transfer taxes.

Further, clients willing to invest at least $200,000 in a Program Account may also choose to hold Retirement and Taxable Program Account assets in a BDIP Program Account, with respect to which BlackRock Investment Management, LLC (“BlackRock”) serves as the Model Provider. 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. In selecting investments, BlackRock will primarily select mutual funds and ETPs advised by it (or one of its affiliates) and which may pay fees and other compensation to BlackRock (or one of its affiliates), including iShares® ETFs (collectively, “BlackRock Affiliated Funds”). BlackRock may also include mutual funds and ETPs advised by third parties, including Fidelity if BlackRock determines, in its sole discretion, that a BlackRock Affiliated Fund may not achieve the investment objective. BlackRock’s model typically identifies an asset allocation that is between 20–60% stocks and 40–80% investment-grade fixed-income (including short-term investments). BlackRock may provide a similar model portfolio to, or manage accounts using a similar investment strategy for, its other clients and may provide the model to such accounts or clients prior to providing to Strategic Advisers. All Program Accounts, including BDIP Program Accounts, will be managed on a discretionary basis by Strategic Advisers; BlackRock does not have any discretionary investment authority over any Program Accounts. Strategic Advisers may select investments for your BDIP Program Account that differ from BlackRock’s model portfolio, but may also implement BlackRock’s model portfolio without change. BDIP Program Accounts are not managed based on an Account Asset Allocation, or the investment preferences and tax-sensitive strategies described above. In addition, although model-based, the composition of BDIP Program Accounts may differ for a variety of reasons, including, but not limited to, the timing of client investments and withdrawals and any client-imposed investment restrictions.

Investment Restrictions

A client is entitled to impose reasonable restrictions on the management of a Program Account. Any proposed restriction is subject to our review and approval. Such a restriction may include prohibitions such as with respect to the purchase of a particular fund, individual security or sub–asset class (e.g., international equity securities). If a restriction is accepted, assets will be invested in a manner that is appropriate given the restriction. Program Accounts with imposed management restrictions may experience different performance from Program Accounts without restrictions, possibly producing lower overall results. Program Account restrictions should be requested through a Fidelity representative.

6

Access to a Fidelity Representative

Clients have access to assistance provided by a dedicated representative or a team of representatives. Fidelity assigns representatives based on a variety of factors, including Program Account investment levels and complexity of financial situation.

Access to Financial Planning Services

At your request, we can provide financial planning services to help you evaluate your ability to meet identified goals. Typically we begin by understanding your needs and goals related to Program Account(s), as well as any “Other Assets” you have also identified (i.e., assets held in other Fidelity programs or accounts, or at a third party, that are aligned to the same goal as your Program Account). If requested, we may also discuss goals unrelated to your Program Account(s). We then work with you to obtain information regarding your financial situation. We may complete this step when working with you to gather information in connection with opening your Program Account. Next, we will review your information and prepare an analysis. Our financial planning services typically include asset allocation modeling, which evaluates your ability to meet your identified goal based on your current asset allocation and may also provide suggestions for changes to your asset allocation.

Depending on the complexity of your financial situation and/or assets held in a Fidelity program or accounts, we may also provide an analysis of your net worth and identify general strategies to help you evaluate financial needs such as retirement planning, college savings, wealth protection, employee benefits planning (e.g., equity compensation arrangements), tax planning, or estate planning. We use various financial planning analytics and applications to provide financial planning services; the specific analysis provided to you will be based on the assets allocated to a goal and the complexity of your financial situation. Our financial planning services do not include initial or ongoing advice regarding specific securities or other investments, any financial analysis provided outside this Program, or any “what-if” or other changes you may model on your own in any financial planning tool that is made available to you online. In addition, we are not obligated to update any analysis provided or monitor your progress toward an investment goal.

Other than with respect to your Program Accounts, which are managed on a discretionary basis through the Program, the implementation of the asset allocation or 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. 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. Please see the “Guide to Brokerage and Investment Advisory Services at Fidelity Investments” included with your Program enrollment materials, or speak to a Fidelity representative for more information.

There can be significant differences between the asset allocation modeling results shown and the performance a client may actually experience. 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. In addition, our methodologies and algorithms used in this process may be adjusted from time to time and impact 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 results, and is not a guarantee of future investment outcomes. The modeling results shown may vary with each use and over time.

7

Limitations on Tax and Estate Planning Suggestions. Although Fidelity may consider the potential effect of certain estate or tax strategies, any information presented to you in conjunction with the Program, including in providing the financial planning services, about tax considerations affecting financial transactions or estate arrangements is not intended as tax or legal advice, and should not be relied upon for the purpose of avoiding any tax penalties. Fidelity does not provide tax, accounting, or legal advice. You should review any planned financial transactions or arrangements that may have tax, accounting, or legal implications with your personal professional advisors. The Program does not prepare or file personal tax returns. You should consult your legal advisor regarding your particular circumstances related to rendering and/or preparation of all legal advice, legal opinions, legal determinations, and legal documents; similarly, you should consult your tax advisor to evaluate the tax or accounting considerations for any proposals presented in conjunction with the Program, including in conjunction with the provision of financial planning services, as well as any work performed in the implementation of any aspect of a financial plan or any tax-sensitive investment strategies suggested therein or otherwise in conjunction with the Program.

Private Wealth Management

To be eligible for enhanced discretionary investment management and/or financial planning (“PWM Program Services”), Fidelity Private Wealth Management clients are subject to a qualification and acceptance process, and must typically invest at least $2,000,000, in the aggregate, in Program Accounts and have investable assets of at least $10,000,000. Depending on the eligible client’s situation, PWM Program Services can include either or both of the following:

• With respect to discretionary investment management, a dedicated investment manager will be assigned to discuss, implement and review tailored portfolio management solutions across Program Accounts, including personalized tax-sensitive investment strategies (“PWM tax management services”). These services can include strategically positioning assets among the client’s Tax-Sensitive and Retirement Program Accounts in order to help enhance marginal after-tax returns (e.g., more tax-efficient investments to be held in a Tax-Sensitive Program Account and less tax-efficient investments to be held in a Retirement Program Account).

• With respect to financial planning, eligible clients will receive in-depth analyses and customized financial planning solutions, as well as access to a Wealth Strategist. These analyses may include information about clients’ employee benefits plans to help them understand components of the benefits offered, and the opportunities that participating in those benefits plans may provide.

Predecessor Services

As of July 16, 2018, Strategic Advisers will assign the contracts for certain Fidelity investment management programs, including Fidelity Private Client Group AdvisorySM, Fidelity Portfolio Advisory Service® (“PAS”), Fidelity® Personalized Portfolios, Fidelity® Personalized Portfolios for Trusts (“FPP-T”), Fidelity Wealth Management AdvisorySM, and BlackRock® Diversified Income Portfolio (collectively, the “Predecessor Services”) to its affiliate, FPWA and, simultaneously, clients enrolled in the Predecessor Services as of that date (“Legacy Clients”) will be transitioned to this Program. The discretionary investment management services provided to clients through the Predecessor Services will continue to be provided in this Program, and Legacy Clients’ annual Gross Advisory Fee (as defined below under “Fees and Compensation”) per transitioned account will be evaluated during the quarterly billing cycle following the account’s transition to the Program and adjusted as applicable in accordance with the following:

• On a one-time basis per transitioned account, the Gross Advisory Fee (net of any applicable discount) then paid by each Legacy Client for the Predecessor Service(s) (the “Predecessor Fee”) will be compared to the Program’s applicable Gross Advisory Fee (the “Program Fee”) for that account, taking into consideration investment preference and account balance.

• If a Legacy Client’s Predecessor Fee applicable to the transitioned account is equal to or greater than the Program Fee, then the Program Fee will apply to the transitioned account.

8

• If a Legacy Client’s Predecessor Fee is less than the Program Fee that would be applicable to the transitioned account, the percentage difference between the fees will be calculated (the “Percentage Difference”) and the client’s Gross Advisory Fee applicable to the transitioned account will equal the Program Fee less the Percentage Difference. The Percentage Difference will remain constant throughout the life of the transitioned account, irrespective of any changes to investment preference or account balance, and will supersede any discount previously applied in calculating the Predecessor Fee.

Program Accounts opened by Legacy Clients following the transition will not be considered for the Percentage Difference, and any change in the account number associated with a Legacy Client’s transitioned account could result in a fee change; please speak with a Fidelity representative at any time regarding the fees associated with your Program Account(s). While the preferences and strategies available through the Predecessor Services are also available through the Program, Legacy Clients’ Taxable Program Accounts previously invested through PAS will generally not be managed using the same tax-sensitive investment strategies used to manage the Tax-Sensitive Program Accounts as described above, will not have access to the SMAs, will not have the option of electing the Increased International Option, and will not be able to allocate amounts to a Short-Term Position sleeve. Legacy Clients may elect to convert their legacy PAS taxable accounts to Tax-Sensitive Program Accounts; however, such conversion will result in securities transactions that may have tax consequences for these Legacy Clients. For Legacy Clients enrolled in FPP-T in which Fidelity Personal Trust Company, FSB (“FPTC”) acts as investment manager and may provide certain trust services as trustee or co-trustee, FPWA will act as sub-advisor to FPTC in providing the Program Services, and Strategic Advisers will continue to provide the discretionary portfolio management. As of December 6, 2015, FPP-T was only available to client accounts in which FPTC would be acting as trustee or co-trustee.

Trust Accounts Where Fidelity Personal Trust Company, FSB Serves as Trustee or Co-Trustee

For trust accounts where FPTC serves as trustee or co-trustee (“Program Trust Accounts”), FPWA acts as sub-advisor to FPTC in providing the Program Services. Strategic Advisers will provide discretionary portfolio management for all Program Accounts, including these Program Trust Accounts. FPTC, in its capacity as trustee or co-trustee may provide additional services, including management of certain assets not included in a Program Trust Account. All Program Trust Accounts, including those of Legacy Clients, will be subject to a trust administration fee that is separate from, and in addition to, the Gross Advisory Fee. Please see FPTC’s separate fee schedule for a complete listing of its fees. The Program Services provided for the benefit of FPTC’s clients are subject to ongoing supervisory oversight performed by FPTC. Program Trust Accounts will not directly participate in the financial planning services described herein. If Program Services are provided for the benefit of Program Trust Accounts, references to “client” throughout this document assume FPTC is trustee or co-trustee of the applicable trust.

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 that may affect the Program Services, including, if appropriate, to adjust an Account Asset Allocation, to modify tax-sensitive investment strategies, or to update or revise any analyses generated in providing the financial planning services. If you have multiple relationships with Fidelity, you should ensure that your personal, financial, and other important information is updated for each respective service or account.

FEES AND COMPENSATION

Advisory Fees — Gross and Net of Fee Credit

The Program charges an annual Gross Advisory Fee that includes access to assistance from one or more Fidelity representatives, access to financial planning services, and the ongoing discretionary management of Program Account(s), as well as the brokerage, clearing and custody services provided by FPWA’s affiliates.

9

The Gross Advisory Fee does not include (i) any fees associated with investment through an SMA (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 trades effected with or through broker-dealers other than affiliates of FPWA, mark-ups or mark-downs by broker-dealers, 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 (iv) any additional expenses, including trading fees and management expenses, a client may incur with respect any non-Program account. 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 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 FPWA or its affiliates and will be included in a Credit Amount as described below.

The annual Gross Advisory Fee applied to a Program Account is reduced by a Credit Amount in an effort to address the potential conflicts of interest that arise in selecting investments that generate income for Fidelity. The purpose of the Credit Amount is to reduce the Gross Advisory Fee by the amount of compensation, if any, FPWA or its affiliates receive from the underlying mutual funds or ETPs (or their affiliates) as a result of investments by a Program Account, as detailed below. This Credit Amount is applied quarterly in arrears.

To the extent applicable, a Credit Amount will be calculated for each mutual fund or ETP held in 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 FPWA or its affiliates receive from these funds and ETPs, as a result of investments by the Program Account.

• For non-Fidelity funds and ETPs, the Credit Amount will equal the distribution fees, shareholder servicing fees, and any other fees or compensation FPWA or its affiliates receive from these funds and ETPs or their affiliates, as a result of investments by the Program Account.

These are added together to arrive at a total Credit Amount.

Please note that (i) individual securities held in a Program Account do not affect the calculation of the Credit Amount, and (ii) amounts held in a Short-Term Position sleeve of a Tax-Sensitive Program Account qualify for the breakpoints described below, but are not assessed an annual Gross Advisory Fee, and are not subject to the Credit Amount calculation.

Net Advisory Fee = Gross Advisory Fee – Credit Amount

Please see the chart below for the Gross Advisory Fees charged to Program Accounts. Please note that all fees are subject to change.

ANNUAL ADVISORY FEE SCHEDULE FOR PROGRAM ACCOUNTS

Average Daily Assets*Annual Gross Advisory Fee

If Average Daily Assets total $500,000 or less, then:

For Average Daily Assets between $0 and $500,000

1.50% (up to a maximum of

$6,250)

Less Credit Amount†

Equals Net Advisory Fee

If Average Daily Assets total more than $500,000, then:

For the first $500,000 in Average Daily Assets1.25%

For the next $500,000 or portion thereof in Average Daily Assets 1.10%

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. Aggregation of Average Daily Assets of multiple Program Accounts may be permitted. Contact a Fidelity representative for details. †The Gross Advisory Fee is reduced by a Credit Amount (as defined above).

10

Cash balances in a Program Account will be invested in the core Fidelity money market fund, the cash sweep vehicle for a Program Account. Any such cash or cash investments in a Program Account will result in a negative yield to the extent the quarterly advisory fee exceeds the rates of return for the core Fidelity money market fund. Please ask a Fidelity representative about current performance of the core Fidelity money market fund.

Fees for SMAs

Where an affiliate of FPWA provides an investment model for an SMA sleeve, no additional SMA Fee is charged, and a client will be charged only the Net Advisory Fee. Where an Unaffiliated Model Provider has provided an investment model, an additional fee is charged to cover the costs associated with obtaining and implementing the model (“SMA Fee”). The Credit Amount identified above is applicable to the SMA Fee only to the extent that the SMA holds mutual funds or ETPs for which FPWA or an affiliate receives compensation. Please see the chart below for the SMA fees.

ANNUAL MANAGER FEE FOR ASSETS HELD IN SMAsFidelity Strategic Advisers U.S. Large Cap Equity SMA None

Strategic Advisers Tax-Managed U.S. Large Cap SMA None

Strategic Advisers Equity Growth SMA Not to exceed 0.35%

Strategic Advisers Equity Value SMA Not to exceed 0.35%

The fees shown for the Strategic Advisers Equity Growth SMA and the Strategic Advisers Equity Value SMA are an approximation of the blended rate of the fees charged by the Unaffiliated Model Providers who provide investment recommendations for those SMAs. The applicable blended rate may change on a quarterly basis as a result of (1) changes in the number of Unaffiliated Model Providers used for these SMAs, or (2) changes in the asset levels assigned to a Model Provider to a given SMA. The SMA Fee for each of these SMAs will be equal to the blended rate for the relevant calendar quarter. While the fee level may vary among Model Providers, the total fee for such SMA will not exceed 0.35%. Please note that Strategic Advisers may use its discretion with respect to the amount of your assets that may be invested in SMAs.

Fund Sales Loads and Transaction Fees

Generally, clients will not pay any sales loads or transaction fees on the funds purchased in a Program Account.

Fund Redemption Fees

In order to protect the interests of long-term shareholders, certain funds may impose redemption or other administrative fees if shares are not held for a minimum time period. Fidelity may, at its sole discretion, choose to pay any such redemption fees on behalf of Program clients, but are under no obligation to do so. In addition, clients are responsible for any short-term trading fees or other charges that result from the sale of existing investments (if any) to fund a client’s initial investment in a Program Account (whether such sale is inside or outside a Program Account) and any subsequent withdrawals that the client initiates.

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 Fee (in the aggregate, the “Program Fee”), a fee may be assessed for financial planning services. This fee will be negotiated with the client.

Billing

The Net Advisory Fee and, if applicable, any trust administration or SMA Fees, will be deducted, pro rata, from a client’s Program Account(s) or another Fidelity account identified by a client for this purpose, in arrears on a quarterly basis. Certain assets in a Program Account may be liquidated to pay the fees; this liquidation may generate a taxable gain or loss.

11

Availability of Separate or Similar Services

Clients should understand the brokerage and investment advisory services offered by Fidelity to determine which services are appropriate for them. The tools and analytics used to support the financial planning services provided through the Program may also be used in connection with other services available to Fidelity customers or prospects, electronically or otherwise, including tools and analytics provided in support of Fidelity brokerage services. In addition, a client may be able to invest directly in the securities available through the Program through a Fidelity brokerage account or a brokerage account at another firm, without incurring the advisory fee charged by the Program. Also, the investment strategies available through the Program’s SMAs, while designed by Fidelity for the Program, may be similar to a mutual fund or other products offered and/or managed by Fidelity or unaffiliated entities, and the operating expenses of such a mutual fund or product may be lower or higher than the Program’s fees. Clients may also be able to obtain similar discretionary investment management and financial planning services from Fidelity or other firms for the same or lower fees. However, clients may not receive the same combination of Program Services; purchasing the services separately may cost more or less than the Program Fee; certain investment products used by the Program may not be available for purchase outside of the Program; and investments may be subject to sales loads or transaction and redemption charges that are generally waived as part of the Program.

Factors that bear upon the cost of the Program in relation to the cost of the same or similar services purchased separately include, among other things, the type and size of the Program Account, the historical and expected size or number of trades for the Program Account, the amount of brokerage trades effected through Fidelity affiliated broker-dealers (the charges for which are included in the Gross Advisory Fee) as compared with the brokerage trades effected through other broker-dealers (the charges for which are not included in the annual advisory 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.

Clients may be eligible for certain benefits offered by FPWA’s affiliates based, in whole or in part, on the amount a client invests in Program Accounts; however, such benefits are offered outside the Program and do not constitute Program Services.

Additional Fee Information

All fees are subject to change. In rare circumstances, FPWA may agree to negotiate the advisory fee for certain accounts. FPWA may also agree to waive fees, in whole or in part, in its sole discretion, including, but not limited to (i) for certain Program Accounts, including with respect to Predecessor Services’ accounts that migrate to the Program; (ii) in connection with promotional efforts and other programs, including but not limited to situations designed to facilitate transitions between advisory programs; or (iii) for certain current and former employees of Fidelity. This will result in certain clients paying less than the standard fee.

The Program Fee is inclusive of fees paid to Strategic Advisers for the discretionary portfolio management services provided to Program Accounts. The Program Fee does not cover costs associated with implementing any suggestions provided as part of our financial planning services, other than the discretionary services provided through the Program. The advisory fee also does not cover a charge that applies to sales of securities made for Program Accounts — an industry-wide assessment mandated by the U.S. Securities and Exchange Commission (“SEC”) totaling a few cents per $1,000 of securities sold. Please note that the amount of this regulatory fee may vary over time, and because variations may not be immediately known to Fidelity, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, Fidelity may retain the excess. These charges will be reflected on your monthly statements and/or trade confirmations.

12

Information about Representative Compensation

Fidelity representatives who support the Program are associated with FPWA and Fidelity Brokerage Services LLC (“FBS”). Separate and apart from the Program, these Fidelity representatives, or other Fidelity representatives, may provide you with investment education, financial analysis, research, and guidance offered by FBS. When providing services for FBS, these Fidelity representatives are acting solely as representatives of FBS, and Program fees are not related to those additional services provided through FBS.

Fidelity representatives receive a percentage of their total annual compensation as base pay — a predetermined and fixed annual salary. Base pay varies between Fidelity representatives based on experience, position, and seniority. In addition to base pay, Fidelity representatives are also eligible to receive variable compensation. Fidelity representatives may participate in sales contests and may earn additional rewards based on sales criteria, including, but not limited to, the number of solicitations for advisory services they make, gross sales of Program Accounts, or retention of assets in the Program and similar programs.

Depending on the specific situation, the compensation received by Fidelity representatives in connection with the Program could be greater than the compensation received by Fidelity representatives if a client participated in another Fidelity advisory program or maintained a brokerage account. In such cases, Fidelity representatives would have a financial incentive to recommend the Program over other programs or services. Fidelity addresses these conflicts of interest by disclosing them to you and by supervising our representatives. It is important to note that in determining a Fidelity representative’s compensation, Fidelity considers whether the Fidelity representative provides guidance about appropriate products and services based upon customer needs. Fidelity takes this approach to client relationships very seriously, and reviews representative interactions in order to help ensure that this standard is met.

For information about how Fidelity compensates its representatives in connection with the sale of the Program and other products, please see the “Introduction to Representatives’ Compensation” disclosure document (available at Fidelity.com and included with your Program enrollment materials), or contact a Fidelity representative.

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. In order to participate in the Program, a client must be a U.S. person (including a U.S. resident alien), reside in the U.S., have a valid U.S. permanent mailing address, and have a valid U.S. taxpayer identification number. The Program is not available to non-U.S. trusts, foreign investors, and persons who are not U.S. residents. FPWA may, in its sole discretion, decline to permit participation in the Program for any reason. Please contact a Fidelity representative for additional information about the limitations of the Program.

Clients must maintain a minimum of $50,000 invested in at least one Program Account to be eligible for the Program (“Program Minimum”). In addition, clients must generally maintain at least $50,000 per Program Account, except that Tax-Sensitive Program Accounts and BDIP Program Accounts are subject to a $200,000 per account minimum. Access to SMAs is only available for Tax-Sensitive Program Accounts and is limited based on investment balance and Account Asset Allocation. In addition, as discussed above, there are minimums to qualify for the PWM Program Services. FPWA may, in its sole discretion, elect to change or waive the Program Minimum or other identified Program Account minimums at any time, and it is anticipated that the minimum investment amount required for Tax-Sensitive and BDIP Program Accounts will be lowered in the near future. Program Accounts that fall below required minimums may be removed from the Program. Clients who became enrolled in the Program Services as a result of enrollment in the Predecessor Services may have lower minimums for their Program Accounts.

With respect to Retirement Program Accounts, Program fees are solely attributable to Program services associated with such Program Accounts. In addition, certain limitations apply to the management of a Retirement Program Account holding defined benefit plan assets. Generally, only single participant defined

13

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 his or her 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 FPWA to provide the Program Services. As part of the Program Client Agreement, clients will delegate discretionary authority to FPWA, and acknowledge that FPWA has retained its affiliate, Strategic Advisers, to provide discretionary portfolio management for the clients’ Program Account(s), 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 effected in Program Accounts, subject to certain Program and regulatory limitations and Strategic Advisers’ internal policies and procedures. The Program Client Agreement also directs that the client establish a brokerage account with FBS, a registered broker-dealer, affiliate of FPWA, and member of NYSE and SIPC. During a client’s participation in the Program, the client’s Program Account(s) will not be available for brokerage activities including, but not limited to, margin trading or trading of securities. Another affiliate of FPWA, 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. FPWA, FBS, NFS, and Strategic Advisers personnel may share premises and may have common supervision.

Once the client has agreed to the terms of the Program Client Agreement, the client will have 90 days to reach the Program Minimum in order to receive Program Services. If the client has not reached the Program Minimum within 90 days, Fidelity may elect, in its sole discretion, to terminate the client’s participation in the Program. In general, Program fees will begin to accrue once a Program Account is fully funded and has been deemed in good order for management purposes.

Opening and Funding a Program Account

Clients may fund Program Accounts with cash and/or securities acceptable to us. 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 available to fund a Program Account. These securities must be held free and clear of any liens, pledges, or other legal or contractual restrictions. At times, Fidelity may not accept individual securities that may generally be used to fund a Program Account due to internal guidelines or regulations (state or federal). If a client elects to transfer non-eligible 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 does not consider the potential tax consequences of these sales when following a client’s deemed direction to sell such securities. Fidelity also reserves the right to transfer a non-eligible security back to the Client’s source account based on certain circumstances.

Sales of eligible and non-eligible transferred securities will be subject to redemption and other applicable fees, including commissions on sales of securities; however, under certain circumstances, the Program may voluntarily assume the costs of certain commissions. A client may realize a taxable gain or loss when these shares are sold. In addition, when securities are purchased in Program Accounts, the client may receive taxable distributions out of the earnings that have accrued prior to such purchases (a situation referred to as buying a dividend).

Once the account funding process is complete, discretionary portfolio management will begin. Investment typically occurs within 10 business days of full funding. Clients investing at least $200,000 in a Tax-Sensitive Program Account may elect to have their Tax-Sensitive Program Account invested over time, in order to manage potential tax consequences associated with the sale of eligible securities (maximum of 12 months), as long as 100% of the assets intended for account funding are deposited into the Tax-Sensitive Program Account, and to have concentrated positions in such accounts sold off

14

over time (maximum of three years), to help defer the realization of associated taxable gains. For initial funding or subsequent deposits to a Tax-Sensitive 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-Sensitive 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 (“IRS”), Fidelity will not otherwise verify (and is not otherwise responsible for) the accuracy of the tax basis information provided.

If a client transfers assets from another Fidelity managed account program into a Program Account, a “do-not-trade” order will be placed on the account from which the client is transferring assets during the processing of the asset transfer. For the period when a do-not-trade order is on such an account, management of the source account will be suspended, and the investment manager for such other program will not monitor the source account for potential buys and sells of securities, and any deposits during the do-not-trade period will not be invested.

Additional deposits of cash or securities can be made at any time. Discretionary management of additional deposits will occur as soon as reasonably practicable but may be delayed for various reasons, including time needed to liquidate securities or special handling instructions. 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.

Please see Strategic Advisers’ Program Brochure for additional information regarding its discretionary portfolio investment process, or contact a Fidelity representative for details.

Withdrawals and Program Termination/Account Closure

At any time, a client can request a withdrawal from a Program Account, elect to close a Program Account, or elect to terminate participation in the Program and close a Program Account. All closure and termination instructions must be processed through a Fidelity representative. FPWA 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(s) falls below the minimum investment level required for the Program; 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 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.

Clients will be required to provide instructions regarding which of the following methods should be used in event of withdrawals or Program Account closing:

• Assets liquidated and a check sent with the proceeds;

• Assets transferred in kind into another account; or

• Assets liquidated and proceeds wired or transferred via electronic funds transfer to a bank account or other account.

Generally, partial and full withdrawals may take up to 10 business days to process. If instructions are not provided within 30 days of a partial withdrawal request, Fidelity will reinvest the cash or securities into the client’s discretionarily managed Program Account. Note that liquidation of assets in taxable accounts may have adverse tax consequences. Program Account(s) may hold certain mutual funds that clients would not be able to purchase directly or that may only be held as part of an advisory program. In general, if an investor ceases to be a client of the Program, shares of such funds will be redeemed and the client may incur a gain or loss as a result, subject to the terms and conditions specified in that fund’s prospectus.

With respect to nonretirement Program Accounts, a client may elect to have all dividends, interest, and capital gains on eligible holdings set aside for automatic distribution by completing and submitting an

15

Earnings Automatic Withdrawal Plan form. Please note that upon providing these instructions to Fidelity, the amounts awaiting distribution will not be subject to Fidelity’s discretionary authority.

For Program Trust Accounts, liquidation processes and time periods may vary from those identified above.

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 VA L U AT I O N

FPWA has retained the services of its affiliate, Strategic Advisers, to provide the discretionary portfolio management services described in this document based on Strategic Advisers’ qualifications in managing assets. Accordingly, FPWA will not provide portfolio construction, investment selection and portfolio management (including execution of transactions for Program Accounts); rather, these services will be provided by Strategic Advisers. In selecting Strategic Advisers, FPWA reviewed a variety of factors, including, but not limited to, Strategic Advisers’ investment approach, total assets under management, experience, and trading and operational capabilities. FPWA has implemented oversight processes and controls to review Strategic Advisers’ performance of portfolio management services for Program Accounts.

Clients will be provided with information about the performance of their Program Accounts on both a pre-tax and after-tax basis, as appropriate depending on the tax status of the Program Account. In addition, clients will typically receive performance information comparing their Program Accounts with the performance of relevant industry standard indexes. Pre-tax Program Account performance is calculated based on industry standards. After-tax Program Account performance is based on the pre-tax performance of the Program Account and other tax-related factors. Detailed information about the calculations and assumptions 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 FPWA and Strategic Advisers, performance information is not reviewed or approved by a third party.

C L I E N T I N F O R M AT 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

Through FPWA, Strategic Advisers has access to the relevant Program Account information, including Profile Information and, for Tax-Sensitive Program Accounts, information on record with FPWA regarding the client’s tax situation and tax characteristics of the securities in a client’s Tax-Sensitive Account(s). 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. FPWA does not provide client information to any of the Model Providers.

C L I E N T C O N TA 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 situations or any other information that may affect how clients’ Program Accounts are managed. A Fidelity representative will act as a liaison between a client and Strategic Advisers (the discretionary portfolio manager), and will help ensure appropriate management of the client’s Program Account(s). While Strategic Advisers may provide clients with information about the management of Program Accounts from time to time, typically Strategic Advisers does not meet or communicate directly with Program clients. The Model Providers do not meet with clients.

16

A D D I T I O N A L I N F O R M AT I O N

MATERIAL RISKS

Risks Associated with Financial Planning. The financial planning analyses provided through the Program are based on the information provided by clients and, in certain cases, on static assumptions — e.g., fixed return rates, fixed life expectancies, fixed rates of income or cash flow, etc. In reality, these variables will not be static — market fluctuation will affect overall asset performance, and uncertain life expectancy may cause clients to outlive their resources or fail to accumulate necessary resources. In addition, financial planning analysis may include probabilistic modeling, whereby the probability of success varies based on differing assumptions and on changing circumstances and market information. The methodologies and algorithms used in the process may be adjusted from time to time. Results may reflect one point in time only and are only one factor that clients should consider as they determine how to best plan for their future.

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 results, and are not guarantees of future investment outcomes. Such projections will vary over time and each time a financial planning analysis is updated. 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 may deviate significantly from the projections provided as a component of our financial planning services.

The Goal Asset Allocation may differ from the Account Asset Allocation identified for discretionary management services provided to a Program Account. The financial planning analysis assumes that the asset allocation of all of the accounts associated with a goal, when aggregated, will generally reflect the Goal Asset Allocation. 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 may have a significant impact on the outcome of our financial planning analysis.

As part of the financial planning services, we may suggest that a client consider 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 his or her goals. In addition, the legal and tax treatment of these types of accounts may 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 details that are more specific about the risks and limitations associated with that analysis.

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 a deposit of a bank and are not insured or guaranteed by the Federal Deposit Insurance Corporation (FDIC) or any other government agency. A client may lose money by investing in mutual funds, ETPs, SMAs, and/or individual securities. A client may lose money by investing in the Program.

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

17

counterparties. 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 may be less liquid than other investments, and therefore may be 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, SMAs, and accounts that invest in a smaller number of individual issuers can be more sensitive to these changes, and funds, SMAs, 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 international or emerging markets funds’ exposure to a particular country or region) may be significantly impacted by events affecting those industries or markets.

For Tax-Sensitive Program Accounts, Fidelity relies on information provided by clients in an effort to provide tax-sensitive investment management and does not offer tax advice. Fidelity cannot guarantee the effectiveness of the tax-sensitive investment management techniques used in managing Tax-Sensitive Program Accounts to reduce or minimize clients’ overall tax liability or the tax results of a given transaction. Fidelity believes appropriate asset allocation is of primary importance, and changes may be made to a Tax-Sensitive Program Account’s asset allocation even if such changes may trigger significant tax consequences.

It is important to understand that a Program Account’s actual asset allocation may deviate from the identified Account Asset Allocation 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. In addition, if a client has selected an Account Asset Allocation that differs from the allocation proposed, the performance of the Program Account may differ from the performance of an account managed according to the Account Asset Allocation originally proposed.

For more details about the risks associated with the particular investment strategies employed by Strategic Advisers as portfolio manager to the Program Accounts, including the risks and limitations with the Program’s tax-sensitive investment management approach, please see Strategic Advisers’ Program Brochure included in your Program materials.

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.

Money Market Funds. 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 insured or guaranteed by the FDIC or any other government agency. Fidelity, the sponsor of Fidelity’s money market funds, has no legal obligation to provide financial support to a Fidelity money market fund, and a client should not expect that Fidelity will provide financial support to a Fidelity money market fund at any time. Fidelity’s government and U.S. Treasury money market funds will not impose a fee upon the sale of shares, nor temporarily suspend an investor’s ability to sell shares, if a fund’s weekly liquid assets fall below 30% of its total assets because of market conditions or other factors.

18

ETPs. An ETP is a security that trades on an exchange and may seek to track an index, a commodity, or a basket of assets. ETPs can include exchange-traded funds, exchange-traded notes, unit investment trusts, closed-end funds, master limited partnerships, and certain grantor trusts. ETPs can be actively or passively managed. The performance of a passively managed ETP may not correlate to 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 their underlying securities. ETPs that use derivatives, leverage, or complex investment strategies are subject to additional risks.

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 may not ever realize their full value.

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 may also be exempt from state and local income taxes. Income exempt from regular federal income tax (including distributions from tax-exempt, municipal, and money market funds) may be subject to state, local, or federal alternative minimum tax. 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 may be removed or phased out for investors at certain income levels.

Legislative and Regulatory Risk. Investments in a Program Account may 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, individual issuers of securities, and the Investment Team’s determinations with respect to the expected rate of return, value, or creditworthiness of a particular security. The impact of these changes may not be fully known for some time.

Cybersecurity Risks. With the increased use of technologies such as the Internet to conduct business, FPWA and its affiliates are susceptible to operational, information security, and related risks. Cyber attacks 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; or causing operational disruption. Cyber attacks may 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 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.

Operational Risks. Operational risks can include risks 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 FPWA suggests an appropriate Account Asset Allocation that corresponds to a level of risk consistent with a client’s initial or updated 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 may also utilize algorithms in support of its discretionary portfolio management process. There is a risk that the algorithms

19

and data input into the algorithms could have errors, omissions, imperfections and malfunctions. Any decisions made in reliance upon incorrect data expose Program Accounts to potential risks. Issues in the algorithm are often extremely difficult to detect and may go undetected for long periods of time; some may never be detected. These risks are mitigated by testing and human oversight of the algorithms and their output. We believe that the oversight, testing and monitoring performed on our algorithms and their output will enable us to identify and address issues that a prudent person managing a similar service would identify and address. 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.

Incidents arising from operational failures, including those resulting from the mistakes of third parties, may not be compensable by FPWA to you. FPWA maintains policies and procedures that address the identification and correction of errors, consistent with applicable standard of care, to ensure that clients are treated fairly when an error has been detected. The determination of whether an incident constitutes an error is made by FPWA or its affiliates, in their sole discretion. In the event that FPWA or its affiliates make an error that has a financial impact on a Program Account, FPWA or its affiliates will generally return the Program Account to the position it would have held had no error occurred. FPWA will evaluate each situation independently. This corrective action may result in financial or other restitution to the Program Account, or inadvertent gains being reversed out of the Program Account. Under certain circumstances, clients will not be reimbursed for errors where the loss is less than $10 per Program Account; in such cases, we have instituted procedures designed to prevent Fidelity from receiving economic benefits from limiting the correction of such errors.

DISCIPLINARY INFORMATION

FPWA has no material disclosable legal or disciplinary events associated with its management personnel for its advisory services.

OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS

FPWA is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is wholly owned by 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, FPWA and its customers may have material business relationships with any of the subsidiaries and affiliates of FMR LLC. In addition, the principal officers of FPWA serve as officers and/or employees of affiliated companies that are engaged in various aspects of the financial services industry.

FPWA is not registered as a broker-dealer, futures commission merchant, commodity pool operator, or commodity trading advisor, nor does it have an application pending to register as such. Certain management persons of FPWA are registered representatives and management persons of FBS, an FPWA affiliate and a registered broker-dealer. In addition, FPWA has entered into an intercompany agreement with FBS, pursuant to which FBS provides to FPWA various operational, administrative, analytical and technical services, and the personnel necessary for the performance of such services.

From time to time, FPWA or its clients may have a material relationship with the following affiliated companies:

Investment Companies and Investment Advisers

• Strategic Advisers is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is wholly owned by FMR LLC, and is a registered investment adviser under the Investment Advisers Act of 1940 (the “Advisers Act”). Strategic Advisers provides discretionary and non-discretionary advisory services and acts as the investment manager to registered investment companies (the “Strategic Advisers Funds”) that invest in affiliated and unaffiliated funds and as sub-advisor to various retail accounts, including separately

20

managed accounts. Strategic Advisers acts as sub-advisor to FPWA in providing discretionary portfolio management of Program Accounts, and assists FPWA in evaluating other sub-advisors.

• Fidelity Management & Research Company (“FMRCo”) is a wholly owned subsidiary of FMR LLC, and is a registered investment adviser under the Advisers Act. FMRCo principally provides portfolio management services as an investment adviser or a sub-advisor to registered investment companies. FMRCo provides portfolio management services as investment adviser or sub-advisor to clients of other affiliated and unaffiliated advisers.

• Fidelity Investments Money Management, Inc. (“FIMM”) is a wholly owned subsidiary of FMR LLC and a registered investment adviser under the Advisers Act. FIMM provides sub-advisory services and/or model portfolio recommendations to FPWA and its affiliates, and provides portfolio management services as a sub-advisor to certain Fidelity clients, including investment companies in the Fidelity Group of funds, or as an investment adviser.

• FMR Co., Inc. (“FMRC”) is a wholly owned subsidiary of FMRCo, which in turn is wholly owned by FMR LLC, and is a registered investment adviser under the Advisers Act. FMRC may provide portfolio management services as a sub-advisor to certain affiliated investment companies. FMRC provides sub-advisory services and/or model portfolio recommendations to FPWA’s affiliates, and may also provide portfolio management services as an investment adviser or a sub-advisor to customers of other affiliated and unaffiliated advisors.

• FIAM LLC (“FIAM”) is a wholly owned subsidiary of FIAM Holdings Corp., which in turn is wholly owned by FMR LLC, and provides investment management services, including sub-advisory services to Strategic Advisers, or its affiliates. FIAM is a registered investment adviser under the Advisers Act. FIAM is also registered with the Central Bank of Ireland.

• Fidelity SelectCo, LLC (“SelectCo”) is a wholly owned subsidiary of FMR LLC and a registered investment adviser under the Advisers Act. SelectCo may provide portfolio management services as an adviser to certain affiliated investment companies.

• FMR Investment Management (UK) Limited (“FMRIM(UK)”), an indirect, wholly owned subsidiary of FMRCo, which in turn is wholly owned by FMR LLC, is registered as an investment adviser under the Advisers Act and is authorized by the U.K. Financial Conduct Authority to provide investment advisory and asset management services. FMRIM(UK) provides investment advisory and portfolio management services as a sub-advisor to certain of Strategic Advisers’ clients, including investment companies in the Fidelity group of funds. FMRIM(UK) may provide portfolio management services as an adviser or sub-advisor to clients of other affiliated and unaffiliated advisers. FMRIM(UK) is also registered with the Central Bank of Ireland. Strategic Advisers has sub-advisory agreements with FMRIM(UK) for certain of the Strategic Advisers Funds.

• Fidelity Management & Research (Japan) Limited (“FMR (Japan)”) is a wholly owned subsidiary of FMRCo, which in turn is wholly owned by FMR LLC, 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) may supply investment research and investment advisory information and may provide discretionary investment management services to certain clients of Strategic Advisers, including investment companies in the Fidelity group of funds, and to clients of other affiliated and unaffiliated advisers. Strategic Advisers has sub-advisory agreements with FMR (Japan) for certain of the Strategic Advisers Funds.

21

• Fidelity Management & Research (Hong Kong) Limited (“FMR (Hong Kong)”) is a wholly owned subsidiary of FMRCo, which in turn is wholly owned by FMR LLC, a registered investment adviser under the Advisers Act, and has been authorized by the Hong Kong Securities & Futures Commission to advise on securities and to provide asset management services. FMR (Hong Kong) may provide investment advisory or portfolio management services as a sub-advisor to certain of Strategic Advisers’ clients, including investment companies in the Fidelity group of funds, and for clients of other affiliated and unaffiliated advisers. Strategic Advisers has sub-advisory agreements with FMR (Hong Kong) for certain of the Strategic Advisers Funds.

Broker-Dealers

• Fidelity Distributors Corporation (“FDC”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, acts as principal underwriter and general distribution agent of the registered investment companies advised by FMRCo. FDC is a registered broker-dealer under the Securities Exchange Act of 1934 (the “Exchange Act”).

• National Financial Services LLC (“NFS”) is engaged in the institutional brokerage business and provides clearing and execution services for other brokers. NFS is a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC. Fidelity Global Brokerage Group, Inc. is a holding company that provides administrative services to NFS. Fidelity Capital Markets (“FCM”), a division of NFS, may execute transactions for investment company and other Fidelity clients. Additionally, FCM operates CrossStream®, an alternative trading system that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. FCM charges a commission to both sides of each trade executed in CrossStream. Using CrossStream, FCM crosses trades for client accounts, and it charges a commission on its trades to both of its brokerage customers. CrossStream may be used to execute transactions for investment company and other Fidelity clients. NFS is a registered broker-dealer under the Exchange Act, and NFS is also registered as an investment adviser under the Advisers Act. NFS may serve as a clearing agent for client transactions that are placed with certain broker-dealers. NFS may provide transfer agent or subtransfer agent services to certain clients. NFS provides transaction processing services in conjunction with the implementation of Strategic Advisers’ discretionary portfolio management instructions. NFS also provides custodial, recordkeeping, and reporting services to clients.

In all cases, transactions executed by affiliated brokers on behalf of investment company clients are effected in accordance with Rule 17e-1 under the Investment Company Act of 1940, and procedures approved by the Boards of Trustees of the funds. The Board of Trustees of each fund in the Fidelity group of funds has approved FCM effecting fund portfolio transactions and retaining compensation in connection with such transactions pursuant to Section 11(a) of the Exchange Act.

• Luminex Trading & Analytics LLC (“LTA”), a registered broker-dealer and alternative trading system, operates an electronic execution utility (the “LTA ATS”) that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. FMR LLC is the majority owner of LTA. LTA charges a commission to both sides of each trade executed in the LTA ATS. The LTA ATS may be used to execute transactions for FPWA’s or FPWA’s affiliates’ investment company and other advisory clients. NFS serves as the clearing agent for transactions executed in the LTA ATS.

• 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 investment companies advised by FMRCo to individuals and institutions, including retirement plans administered by affiliates. Pursuant to referral agreements and for compensation, representatives of FBS may refer customers to various services offered by FBS’s related persons, including FPWA. In addition, along with Fidelity Insurance Agency, Inc. (“FIA”), FBS distributes insurance products, including variable annuities, which are issued by FMRCo’s related persons, Fidelity Investments Life Insurance Company (“FILI”) and Empire Fidelity Investments Life Insurance Company®

22

(“EFILI”). FBS may provide shareholder services to certain of FMRCo’s or FMRCo’s affiliates’ clients. FBS is the introducing broker for Program Accounts and places trades for execution with its clearing broker, NFS.

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 may offer shares of investment companies managed by FPWA’s affiliates.

• EFILI is a wholly owned subsidiary of FILI, which in turn is wholly owned by FMR LLC, and is engaged in the distribution and issuance of life insurance and annuity products that may offer shares of investment companies managed by FPWA’s 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 trust company organized and operating under the laws of the Commonwealth of Massachusetts, provides non-discretionary trustee and custodial services to employee benefit plans and individual retirement accounts through which individuals may invest in mutual funds managed by FMRCo or its affiliates, and discretionary investment management services to institutional clients. FMTC is a wholly owned subsidiary of FMR LLC.

• FPTC, a federally chartered savings bank that offers fiduciary services to its customers, including trustee or co-trustee services, custody, income and principal accounting, investment management services, and recordkeeping and administration. FPTC is a wholly owned subsidiary of Fidelity Thrift Holding Company, Inc., which in turn is wholly owned by FMR LLC.

CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING

FPWA 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 FPWA, and requires that they place the interests of FPWA’s 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:

(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 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 of securities in initial public offerings unless an exception has been approved

(vi) Reporting of Code of Ethics violations

(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, including (i) preclearing of transactions in covered securities; (ii) prohibiting investments in limited offerings without prior approval; (iii) reporting of transactions in covered securities on a quarterly basis; (iv) reporting of accounts and holdings of covered securities on an annual basis; and (v) disgorgement of profits from short-term transactions unless an exception has been approved. Violation of the Code of Ethics requirements may also result in the imposition of remedial action. The Code of

23

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 FPWA. A copy of the Code of Ethics will be provided upon request.

FPWA’s related persons may buy or sell for themselves securities that they also recommend to clients. The potential 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 ensure that Fidelity personnel 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, supervised persons may obtain material nonpublic information that is usually not available to other investors or the general public. In compliance with applicable laws, FPWA has adopted a comprehensive set of policies and procedures that prohibit the use of material nonpublic information by investment professionals or any other employees, and that limit the transactions that FPWA can implement for Program Accounts.

In addition, Fidelity has implemented a policy on Business Entertainment and Workplace Gifts intended to set standards for business entertainment and gifts, to help employees make sound decisions with respect to these activities, and to ensure that the interests of FPWA’s clients come first. Similarly, to ensure compliance with applicable “pay to play” laws, Fidelity has adopted a Political Contributions and Activity policy that requires all employees to preclear any political contributions and activities.

The servicing and distribution fees that FBS or NFS receives from a fund or ETP and/or its affiliates are in addition to the advisory fees the client pays FPWA. With respect to certain of these funds or ETPs, FBS or NFS generally receives a percentage annually of the average daily net assets of non-Fidelity funds or ETPs in a client’s Program Account(s); however, any such amounts received by FBS or NFS will be offset against a client’s Gross Advisory Fee by a corresponding Credit Amount equal to the amount of revenue received as a result of the client’s investments in these funds or ETPs. The servicing and distribution fees that FBS receives are taken into consideration when determining the Net Advisory Fee applied to the client’s Program Account(s). Each Fidelity fund pays investment management fees and other fees to FMRCo, Strategic Advisers, or their affiliates. In addition, affiliates of FPWA are compensated for providing distribution, transfer agency, shareholder servicing, and custodial and other services to certain Fidelity and non-Fidelity funds or ETPs. The compensation received by FPWA and its affiliates from investments in Fidelity funds or ETPs will generally exceed, prior to the application of the Credit Amount (described above), the compensation from investments in non-Fidelity funds or ETPs. See the section entitled “Fees and Compensation” for additional information.

FPWA seeks to address this potential conflict through the application of the Credit Amount noted above, and through the application of selection criteria and personnel compensation arrangements that do not differentiate between Fidelity and non-Fidelity funds or ETPs. FPWA’s investment professionals are compensated partially based on account performance, and are not compensated based on the amount of Fidelity or non-Fidelity funds or ETPs, or the amount of SMAs, used in the Program. Depending on market conditions and other events, certain factors in the selection process at times may result in a significant portion of the portfolio being invested in Fidelity funds or ETPs. A client may be assessed an additional SMA Fee if the client’s Tax-Sensitive Program Account(s) is invested in any SMA in the Program. However, unlike the mutual funds and ETPs held in a client’s Program Account(s), there are no underlying fund-level expenses attributable to the individual securities held in an SMA. Accordingly, amounts invested in an SMA will be subject to a Credit Amount only to the extent that the SMA holds securities that pay compensation to FPWA’s affiliates.

REVIEW OF ACCOUNTS

We will contact Program clients at least annually to evaluate whether there have been any changes to their personal financial situation that may affect the client’s Profile Information or the Program Services. If we fail to hear from a client during this process, we will update each such client’s age, goal horizon, and all other

24

date-relative elements of the client’s Profile Information. We may also consider updated account balances of the client’s Program Accounts and other Fidelity accounts, as well as updated balances of certain outside accounts a client may have provided, but will otherwise assume that the client’s Profile Information has not changed. In some cases, the changes to the date-relative elements of a client’s Profile Information and/or account balances may cause us to update a client’s Goal or Account Asset Allocation. In these instances, we will notify the client of the resulting change to their Goal or Account Asset Allocation. Strategic Advisers will use the updated asset allocation information in connection with the discretionary portfolio management services it provides, which can result in material changes to a client’s Program Account. A client’s continued acceptance of Program services subsequent to notification of a change to a Goal or Account Asset Allocation will be deemed consent to any modification in the discretionary investment management services provided. At our discretion, updates to a client’s Profile Information may also be used to provide additional financial planning analyses.

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 monthly 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. Monthly statements and confirmations may also be available online at Fidelity.com and by enrolling in the electronic delivery program. Clients will not pay a different fee based on their decision to receive electronic monthly statements or trade confirmations. You should carefully review all statements and other communications received from FBS and NFS.

Clients may also receive quarterly reviews or similar reports that detail the performance of a client’s Program Account(s) and summarize the market activity during the quarter. Industry standards are applied when calculating performance information. FPWA also makes available account performance information on a password-protected website.

CLIENT REFERRALS AND OTHER COMPENSATION

Certain affiliates of FPWA are compensated for providing distribution, transfer agency, servicing, and custodial services to certain Fidelity and non-Fidelity investment options (certain of these fees are also used to calculate the Credit Amount described above in the section entitled “Fees and Compensation”). These affiliates include Strategic Advisers as the investment adviser for the Strategic Advisers Funds; FMRCo and subsidiaries as the investment adviser for the Fidelity funds; FDC as the underwriter of the Fidelity funds; and Fidelity Investments Institutional Operations Company, Inc., as transfer agent for the Fidelity funds, servicing agent for non-Fidelity funds, and recordkeeper of certain workplace savings plans. In addition, one or more broker-dealer affiliates of the Fidelity funds may execute portfolio transactions for the funds. FMRCo may obtain brokerage or research services, consistent with Section 28(e) of the Securities Exchange Act of 1934 (the “Exchange Act”), from broker-dealers in connection with the execution of the Fidelity mutual funds’ portfolio security transactions.

For Program Accounts, the group of mutual funds and ETPs eligible for consideration in proposed portfolios is currently limited to funds available through Fidelity’s mutual fund supermarket, FundsNetwork®. FundsNetwork is a registered service mark of FMR LLC and a service of FBS. Mutual funds participating in Fidelity’s mutual fund supermarket that FPWA may invest its clients’ Program Accounts in pay remuneration to affiliates of FPWA for providing shareholder services; however, any such revenue received by affiliates of FPWA is subject to the Credit Amount mechanism described above.

The compensation that FPWA and its affiliates receive as a result of a client’s investment in Fidelity-managed investments may exceed the compensation received from a client’s investments in non-Fidelity investment options; although the Credit Amount calculation may reduce this disparity, the Credit Amount does not eliminate this differential in all cases. The fees and expenses for the various services that

25

FPWA or its affiliates provide to the funds are disclosed in each Fidelity fund prospectus. These fees and expenses are paid by the Fidelity funds and are ultimately borne by the funds’ shareholders.

Client referrals are provided by affiliated entities, including FBS, or other affiliates, pursuant to referral agreements where applicable. Payments may be made to affiliates for services that facilitate delivery of FPWA’s services. As noted above in “Information about Representative Compensation,” some Fidelity representatives receive economic incentives in addition to their normal compensation for distributing and supporting Program Accounts. Additionally, FPWA may refer clients to other independent investment advisors in connection with a referral program in which such independent investment advisors participate for a fee payable to FPWA.

FINANCIAL INFORMATION

FPWA does not solicit prepayment of client fees.

FPWA is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients.

26

This page intentionally left blank.

27

This page intentionally left blank.

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® Wealth Services provides non-discretionary financial planning and discretionary investment management through one or more Portfolio Advisory Services accounts for a fee. Advisory services offered by Fidelity Personal and Workplace Advisors LLC (FPWA), a regis-tered investment adviser, and Fidelity Personal Trust Company, FSB (FPTC), a federal savings bank. Nondeposit investment products and trust services offered through FPTC and its affiliates are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency, are not obligations of any bank, and are subject to risk, including possible loss of principal. Discretionary portfo-lio management services provided by Strategic Advisers LLC (Strategic Advisers), a registered investment adviser. Brokerage services pro-vided by Fidelity Brokerage Services LLC (FBS), and custodial and related services provided by National Financial Services LLC (NFS), each a member NYSE and SIPC. FPWA, Strategic Advisers, FPTC, FBS, and NFS are Fidelity Investments companies.BlackRock Investment Management, LLC (BlackRock) is an independent entity which 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 may select investments for an account that differ from BlackRock’s model.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.Dow Jones U.S. Total Stock Market Index: A float-adjusted market capitalization–weighted index of all equity securities of U.S.-headquartered companies with readily available price data.Russell 1000® Growth Index: An unmanaged market capitalization–weighted index of those stocks of the 1,000 largest U.S.-domiciled com-panies that exhibit growth-oriented characteristics.Russell 1000® Value Index: An unmanaged market capitalization–weighted index of those stocks of the 1,000 largest U.S.-domiciled com-panies that exhibit value-oriented characteristics. Russell 3000® Index: A market capitalization–weighted index designed to measure the performance of the 3,000 largest companies in the U.S. equity market. S&P 500® Index: A market capitalization–weighted index of 500 common stocks chosen for market size, liquidity, and industry group repre-sentation to represent U.S. equity performance.S&P ADR Index: A market capitalization–weighted index of those companies from the S&P Global 1200 that offer Level II or Level III American Depository Receipts, or global or ordinary shares that trade on a major U.S. exchange.Indexes are unmanaged. It is not possible to invest directly in an index.Fidelity, Fidelity Investments, the Fidelity Investments and pyramid design logo, FundsNetwork, and CrossStream are registered service marks of FMR LLC.Fidelity Brokerage Services LLC, Member NYSE and SIPC, 900 Salem Street, Smithfield, RI 02917© 2018 FMR LLC. All rights reserved.833180.1.0 1.9887733.100

FOR MORE INFORMATION, PLEASE CALL US TOLL FREE AT

8 0 0 - 5 4 4 - 3 4 5 5

Monday through Fr iday, 8 a.m. to 7 p.m. Eastern t ime

Fidelity® Wealth Services

Program Fundamentals

Strategic Advisers LLC

245 Summer Street, V5D

Boston, MA 02210

617-563-7000

March 29, 2018 (with an effective date of July 16, 2018)

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® Wealth Services.

Throughout this brochure and related materials, Strategic Advisers may refer to itself as a “registered investment adviser” or “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 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 www.adviserinfo.sec.gov.

2

TA B L E O F C O N T E N T S

ADVISORY BUSINESS 3

FEES AND COMPENSATION 3

PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT 4

TYPES OF CLIENTS 4

METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 4

DISCIPLINARY INFORMATION 17

OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 17

CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT

TRANSACTIONS AND PERSONAL TRADING 21

BROKERAGE PRACTICES 22

REVIEW OF ACCOUNTS 25

CLIENT REFERRALS AND OTHER COMPENSATION 26

CUSTODY 26

INVESTMENT DISCRETION 27

VOTING CLIENT SECURITIES 27

FINANCIAL INFORMATION 27

3

A D V I S O R Y B U S I N E S S

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” or “we”). Strategic Advisers was formed in 1977 and, as of July 2018, will serve as sub-advisor to its affiliate, Fidelity Personal and Workplace Advisors LLC (“FPWA”), in connection with various investment advisory programs offered by FPWA, including Fidelity® Wealth Services (the “Program”). As such, Strategic Advisers will make the day-to-day trading decisions with respect to all Program accounts and will receive a portion of the fees clients pay to FPWA in connection with the Program. Important information regarding FPWA and the Program can be found in FPWA’s Fidelity Wealth Services Program Fundamentals (“FPWA Program Fundamentals”).

Strategic Advisers provides a variety of investment management services including providing discretionary portfolio management services to retail and institutional clients and providing non-discretionary advisory services, including developing and maintaining asset allocation and portfolio modeling methodologies for use by its affiliates. This brochure provides information only about Strategic Advisers’ role with respect to the Program. For additional services that Strategic Advisers provides, please see Strategic Advisers’ relevant Form ADV Part 2A brochures.

As described in the FPWA Program Fundamentals, the Program includes discretionary investment management, access to assistance from one or more Fidelity representatives, and access to financial planning. Strategic Advisers provides day-to-day discretionary portfolio management of one or more Portfolio Advisory Services accounts (each a “Program Account”). Program Accounts can include tax-advantaged accounts (“Retirement Program Accounts”) and taxable accounts (“Taxable Program Accounts”). For clients willing to invest at least $200,000 in a Taxable Program Account (other than BlackRock® Diversified Income Portfolio (“BDIP”) Program Accounts discussed below), such Taxable Program Account may be invested in individual securities through separately managed account (“SMA”) sleeves discussed below, and will be managed using a tax-sensitive investment strategy that seeks enhanced after-tax returns (each, a “Tax-Sensitive Program Account”). A client is entitled to impose reasonable restrictions on the management of a Program Account. Any proposed restriction is subject to our review and approval. Such a restriction may include prohibitions with respect to the purchase of a particular fund, individual security or sub–asset class (e.g., international equity securities). If a restriction is accepted, assets will be invested in a manner that is appropriate given the restriction. Program Accounts with imposed management restrictions may experience different performance from Program Accounts without restrictions, possibly producing lower overall results. Program Account restrictions should be requested through a Fidelity representative.

As of December 29, 2017, Strategic Advisers’ total assets under management were $324,851,600,000 on a discretionary basis, and $15,556,800,000 on a non-discretionary basis.

F E E S A N D C O M P E N S AT I O N

Clients of the Program do not pay Strategic Advisers for the services it provides under the Program. Instead, as compensation for its discretionary portfolio management services provided to Program Accounts, Strategic Advisers receives a portion of the advisory fee paid to FPWA by Program clients. Strategic Advisers and its affiliates may receive compensation with respect to the mutual funds and exchange-traded products (“ETPs”) that may be held in a client’s Program Account. However, the Program’s gross advisory fee is reduced by a credit amount equal to the amount of compensation, if any, Strategic Advisers and its affiliates receive with respect to these mutual funds and ETPs as a result of investments by a client’s Program Account. Please see the FPWA Program Fundamentals for information about Program fees and the application of the credit amount.

4

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 currently charge performance-based management fees for any of its advisory services and, therefore, does not engage in side-by-side management.

T Y P E S O F C L I E N T S

Strategic Advisers provides discretionary portfolio management services for clients’ Program Accounts. Please see the FPWA Program Fundamentals for information about the types of clients eligible for the Program.

M E T H O D S O F A N A LY S I S , I N V E S T M E N T S T R AT E G I E S A N D R I S K O F L O S S

This section contains information about how Strategic Advisers provides discretionary portfolio management services to Program Accounts.

FPWA will propose for each Program Account an appropriate long-term asset allocation (an “Account Asset Allocation”) that corresponds to a level of risk consistent with a client’s financial situation, investment goals and objectives, risk tolerance, planned investment time horizon, and other information the client provides (the “Profile Information”). Each Account Asset Allocation is designed to correspond to a level of risk ranging from conservative (lower risk/lower return potential) to aggressive (higher risk/higher return potential). If a client has selected an Account Asset Allocation that differs from the allocation proposed by FPWA, the performance of the Program Account may differ from the performance of an account managed according to the Account Asset Allocation originally proposed, and such clients understand and acknowledge directing Strategic Advisers to manage the Program Account according to such Account Asset Allocation. Subject to the imposition of reasonable restrictions, Strategic Advisers will apply its proprietary methodology to manage a client’s Program Account to align with the identified Account Asset Allocation.

Program Accounts can include allocations to combinations of 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), short-term assets (short-duration investments), and/or other asset classes and will be managed either (i) using individualized, federal tax-sensitive investment management that seeks to enhance after-tax returns, in the case of Tax-Sensitive Program Accounts, or (ii) without regard to a client’s individual tax situation, in the case of all other Program Accounts. Program Accounts may also have allocations to nontraditional asset classes 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 may 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, may be reduced to gain exposure to these nontraditional and/or extended asset classes.

Program Accounts, other than Tax-Sensitive Program Accounts, are generally invested in a model-based portfolio composed of mutual funds and, depending on a client’s investment preference (discussed below), ETPs. The composition of Program Accounts managed using the same model portfolio may differ for a variety of reasons, including, but not limited to, the timing of client investments and withdrawals, and any client-imposed investment restrictions. Tax-Sensitive Program Accounts may be composed of several different “sleeves” in which different types of investments may be held. For most investment strategies, the majority of positions will be held in the “Central Investment Positions” sleeve which holds interests in mutual funds and ETPs based on the Tax-Sensitive Program Account’s Account Asset Allocation. If a Tax-Sensitive Program Account qualifies, the account may have SMA sleeves that hold individual securities within a given asset class to provide an additional layer of tax-sensitive investment management. The

5

Fidelity Strategic Advisers U.S. Large Cap Equity, the Strategic Advisers Equity Growth and the Strategic Advisers Equity Value SMAs are implemented within Tax-Sensitive Program Accounts and are based on investment models provided to Strategic Advisers by affiliated and/or unaffiliated investment advisers (“Model Providers”).

In addition, a client may request that monies be invested in a “Short-Term Position” sleeve of a Tax-Sensitive Program Account, whereby such amount will be invested in a client’s core Fidelity money market fund to be used for short-term and liquidity purposes. This option may not be available to certain taxable accounts in Fidelity Portfolio Advisory Service® that will be transitioned to Program Accounts. Please note that Strategic Advisers does not provide portfolio management services over assets held in the Short-Term Position sleeve; however, Strategic Advisers may take into consideration assets designated for the Short-Term Position sleeve when making investment decisions and will manage short-term investment flows into and out of the Short-Term Position sleeve into other sleeves per the client’s direction.

Strategic Advisers will manage eligible securities that a client uses to fund a Tax-Sensitive Program Account. Please see the FPWA Program Fundamentals for information about eligible securities. Please note that as Strategic Advisers believes appropriate asset allocation is of primary importance, eligible securities that may not be part of Strategic Advisers’ expected portfolio may be sold, even if such changes may trigger significant tax consequences. Please note that taxable accounts in Fidelity Portfolio Advisory Service that will be transitioned to Program Accounts generally will not be able to use SMAs or Short-Term Position sleeves and will not receive the same tax-sensitive investment strategies described for Tax-Sensitive Program Accounts below. Please contact a Fidelity representative for more information.

The mutual funds and ETPs used in Program Accounts may be managed by Fidelity and/or non-Fidelity advisers. These mutual funds and ETPs are selected based on a variety of objective and subjective factors, including, but not limited to, performance, expense ratios, quality and history of portfolio management, understanding of style consistency, portfolio asset size, fund availability, current public information on the portfolio and its management, and overall fit within Program Accounts. Mutual funds in a Program Account may include mutual funds managed by Strategic Advisers that have been developed specifically for use in Program Accounts (the “Strategic Advisers Funds”) and/or other funds that are available to only clients of the Program. The Strategic Advisers Funds may 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 mutual funds and ETPs used in Program Accounts, whether managed by Strategic Advisers, by its affiliates or by non-Fidelity advisers, may pay compensation to Fidelity. The Program’s annual gross advisory fee will be reduced by the amount of compensation, if any, Strategic Advisers or its affiliates receive from these mutual funds or ETPs (or their affiliates) as a result of investments by a Program Account. Please see the FPWA Program Fundamentals for more information about the Program’s advisory fee and crediting mechanism.

Strategic Advisers generally uses both fundamental and quantitative investment strategies to manage Program Accounts. Strategic Advisers uses sophisticated research tools to gauge when certain asset 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 factors, including, but not limited to, proprietary fundamental and quantitative fund research, fund performance, a manager’s experience and investment style, fund company infrastructure, and fund characteristics such as expense ratio, asset size, and portfolio turnover. 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 and ETPs. Sources of information used include publicly available information and performance data on mutual funds and ETPs, 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 fund companies and managers) and secondary sources (reports prepared by fund companies and other sources that provide data on specific fund investment strategies, portfolio

6

management teams, fund positioning, portfolio risk characteristics, performance attribution, and historical fund returns) as inputs into its investment process.

About the Program Account Preferences

The Program offers the following four investment preferences for the management of Program Accounts, other than BDIP Program Accounts, to accommodate investor preferences: the Blended Preference, the Fidelity Focused Preference, the Index Focused Preference, and the Defensive Strategy Preference. Tax-Sensitive Program Accounts are invested using the Blended Preference, but it is anticipated that the other preferences identified above will be made available for Tax-Sensitive Program Accounts in the near future. Additional investment preferences may be made available from time to time.

Blended Preference and Fidelity Focused Preference Program Accounts seek to enhance risk-adjusted returns through broad diversification across asset classes. Blended Preference Program Accounts use both Fidelity and non-Fidelity mutual funds and, for Tax-Sensitive Program Accounts, ETPs. Fidelity Focused Preference Program Accounts primarily use Fidelity mutual funds and, for Tax-Sensitive Program Accounts, ETPs. Blended Preference and Fidelity Focused Preference Program Accounts will generally invest in actively managed mutual funds and ETPs. Blended Preference and Fidelity Focused Preference Program Accounts may also invest in passively managed mutual funds and ETPs that seek to replicate the performance of their applicable market indexes, based on market conditions, risk management and trading considerations, and the availability of actively and passively managed mutual funds or ETPs to be used to gain exposure to a particular asset or sub–asset class, in each case in the judgment of Strategic Advisers. Please note that taxable accounts in Fidelity Portfolio Advisory Service managed using the Blended or Fidelity Focused Preferences that will be converted to Program Accounts will invest only in mutual funds.

Index Focused Preference Program Accounts also seek to enhance risk-adjusted returns through broad diversification across asset classes, but will have a preference for passively managed mutual funds and ETPs. Index Focused Preference Program Accounts may also invest in actively managed mutual funds and ETPs when deemed appropriate by the investment team, based on market conditions and the availability of actively and passively managed mutual funds or ETPs to be 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 Preference Program Accounts, the investment management team expects to use actively managed mutual funds and ETPs to gain exposure to certain fixed income asset classes, including municipal bond, high yield, short-term bond and money market, though this may change in the future depending on the availability and appropriateness of passively managed mutual funds or ETPs with exposure to certain asset or sub–asset classes. Accordingly, Index Focused Preference Program Accounts that are taxable or that have a more conservative asset allocation will typically hold a higher percentage of actively managed mutual funds and ETPs than other accounts with the same asset allocation or preference, respectively.

Defensive Strategy Preference Program Accounts seek to temper downside risk by investing in “defensive” strategies across asset classes. Defensive Strategy Preference Program Accounts will have increased sub–asset class exposures to defensive investments that, in the judgment of Strategic Advisers, may cause the account to have lower sensitivity to broader market price movements. These defensive investments may include conservative equity (those with stable earnings growth, low financial leverage and a high return on equity, or those that are expected to rise and fall in price less or more slowly than the market generally), which may be combined with increased exposure to longer-term high quality bonds. Strategic Advisers believes these conservative equity investments may have lower variability in returns than the equity market as a whole, and that the longer-term high quality bonds may help reduce some of the equity and credit risk associated with the other investments used in Defensive Strategy Preference Program Accounts. Based on the judgment of Strategic Advisers, the Defensive Strategy Preference Program Accounts will invest in both actively and passively managed mutual funds and ETPs based on market conditions.

A client may also elect to participate in the Increased International Option, which will modify the asset allocation of a Program Account, other than a BDIP Program Account, by increasing the exposure to

7

international equity securities from approximately 30% of the overall equity allocation to approximately 50% of the overall equity allocation. This increase in international exposure may be accomplished by increasing the percentage of assets invested in international mutual fund or ETP holdings or by adding new mutual fund or ETP holdings to a client’s Program Account. For new Program Accounts, the ability to manage potential tax consequences from funding a client’s Tax-Sensitive Program Account will depend on the assets used to fund the account. For existing Program Accounts, Strategic Advisers will generally sell U.S. equity assets (mutual funds, ETPs and, as applicable, SMA equities) and purchase international mutual funds and ETPs. The performance of a Program Account managed using the Increased International Option may differ, at times significantly, from the performance of a Program Account without increased international equity exposure.

About Tax-Sensitive Investment Management Strategies

Strategic Advisers believes appropriate asset allocation is of primary importance. If, based on information the client provides, Strategic Advisers determines that the client’s Tax-Sensitive Program Account requires modification to its Account Asset Allocation, it will generally make such changes as soon as reasonably possible, even if such changes may 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-Sensitive Program Accounts. Please note that Strategic Advisers does not take direction from a client on when to take gains or losses from the client’s Tax-Sensitive Program Account. Clients who participate in Fidelity Private Wealth Management (“PWM”) may 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-Sensitive Program Accounts. Please see the FPWA Program Fundamentals for information about the types of clients eligible for PWM. Taxable accounts in Fidelity Portfolio Advisory Service that will be transitioned to Program Accounts generally will not receive the same tax-sensitive investment strategies described for Tax-Sensitive Program Accounts below. Strategic Advisers cannot guarantee the effectiveness of its tax-sensitive investment management techniques in serving to reduce or minimize a client’s overall tax liability or the tax results of a given transaction. The specific tax-sensitive strategies used will depend on the size of the account and the investment strategy selected. Prior to making trading decisions to buy, hold, or sell mutual funds, ETPs, or other types of securities for a client’s Tax-Sensitive Program Account, the following is considered:

Purchase of municipal bond and money market funds, based on factors including tax bracket and estimated tax-equivalent yields. When appropriate, Program Accounts may be invested in state-specific municipal bond and money market funds (as alternatives to comparable taxable bond funds) to seek to generate income generally exempt from federal (and state, if a resident of the issuer’s state or another exemption applies) income taxes. When consistent with overall portfolio objectives, Program Accounts may also invest in non-state-specific (i.e., national) municipal bond and money market funds to seek to generate income generally exempt from federal income taxes.

Ability to harvest tax losses. Individual mutual fund, ETP, stock, or bond positions may 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-Sensitive Program Account). In such instances, losses may be realized in the client’s Tax-Sensitive 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 similar investments in order to maintain consistent market exposure. In harvesting tax losses, Strategic Advisers does not attempt to harvest every tax loss that occurs in the client’s Tax-Sensitive Program Account.

Opportunity to avoid and/or postpone capital gain realizations. As applicable, each specific lot of securities in a client’s Tax-Sensitive Program Account — a block of shares bought at a particular time at a particular price — is 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 it decides to sell an eligible security,

8

Strategic Advisers 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.

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 account. It is important to understand that in a given year, due to investment decisions or market conditions, a client may receive varying levels of taxable fund distributions within a client’s Tax-Sensitive 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.

Asset location services. In addition, for PWM clients with both Tax-Sensitive and Retirement Program Accounts, Strategic Advisers may use asset location strategies to seek to strategically position assets within the type of account (taxable, tax-deferred, or tax-exempt) that may help enhance marginal after-tax returns. Generally, this means locating more tax-efficient investments in a Tax-Sensitive Program Account and less tax-efficient investments in a Retirement Program Account. Please see the FPWA Program Fundamentals for information about the types of clients eligible for PWM and the use of asset location services.

About the SMAs for Tax-Sensitive Program Accounts

If a client’s Tax-Sensitive Program Account qualifies, a portion of the account may be invested in the SMAs offered by Strategic Advisers. Please note that taxable accounts in Fidelity Portfolio Advisory Service that will be converted to Program Accounts generally will not be able to use SMAs. These SMAs provide an additional layer of tax-sensitive investment management within a Tax-Sensitive Program Account.

The Strategic Advisers Tax-Managed U.S. Large Cap SMA will initially consist of a diversified portfolio of approximately 200–300 securities selected from the universe of 500 securities that compose the S&P 500® Index. The number of securities used by Strategic Advisers within the Strategic Advisers Tax-Managed U.S. Large Cap SMA will vary over time and may be materially higher or lower than Strategic Advisers’ initial estimate. The Strategic Advisers Tax-Managed U.S. Large Cap SMA is intended to act as a diversified, risk-adjusted portfolio that attempts to closely align with the return (before taxes) and overall risk profile of the S&P 500® Index. Strategic Advisers will attempt to trade holdings in the Strategic Advisers Tax-Managed U.S. Large Cap SMA actively within the universe of securities that compose the S&P 500® Index in an attempt to enhance after-tax returns through methods such as proactive tax-loss harvesting and deferring the realization of capital gains. Note that this trading may result in a “drift” from the S&P 500® Index and/or wash sales from trading activity in non-Program accounts.

The Fidelity Strategic Advisers U.S. Large Cap Equity SMA is actively managed to seek additional opportunities for return and tax-sensitive investment management within Tax-Sensitive Accounts managed using the Fidelity Focused preference. The Fidelity Strategic Advisers U.S. Large Cap Equity SMA will invest in recommended portfolios of stocks that are designed to complement the Strategic Advisers Tax-Managed U.S. Large Cap SMA, which provides core market exposure. The Fidelity Strategic Advisers U.S. Large Cap Equity SMA will initially consist of approximately 150–250 securities, selected by Strategic Advisers based on the portfolio recommendations of the affiliated Model Provider that provides investment models to Strategic Advisers. The number of securities used by Strategic Advisers within the Fidelity Strategic Advisers U.S. Large Cap Equity SMA will vary over time and may be materially higher or lower than Strategic Advisers’ initial estimate. The Model Provider provides multiple investment models to Strategic Advisers, which then blends those stock portfolio recommendations. If the models provided by the Model Provider include securities that cannot be purchased for client accounts, Strategic Advisers may in its discretion substitute other equity securities or ETPs for those securities.

The Strategic Advisers Equity Growth and Strategic Advisers Equity Value SMAs are actively managed to seek additional opportunities for return and tax-sensitive investment management. The Strategic Advisers Equity Growth and Strategic Advisers Equity Value SMAs will invest in recommended portfolios of stocks that are designed to complement the Strategic Advisers Tax-Managed U.S. Large Cap SMA,

9

which provides core market exposure. Both the Strategic Advisers Equity Growth and Strategic Advisers Equity Value SMAs will initially consist of approximately 70–150 securities in each SMA, selected by Strategic Advisers based on the portfolio recommendations of multiple Model Providers that provide investment models to Strategic Advisers. The number of securities used by Strategic Advisers within the Strategic Advisers Equity Growth and Strategic Advisers Equity Value SMAs will vary over time and may be materially higher or lower than Strategic Advisers’ initial estimate. The Model Providers are selected by Strategic Advisers to have complementary investment styles and may be affiliated or unaffiliated with Strategic Advisers. Strategic Advisers then blends those stock portfolio recommendations for each of the Strategic Advisers Equity Growth and Strategic Advisers Equity Value SMAs. If the models provided by the Model Providers include securities that cannot be purchased for client accounts, Strategic Advisers may, in its discretion, substitute other equity securities or ETPs for those securities.

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, may change the weight allocated to a particular Model Provider’s stock portfolio recommendations within client accounts. In addition, Strategic Advisers may, in its discretion, replace the Model Providers from which it receives stock portfolio recommendations, or may contract with additional Model Providers to provide stock portfolio recommendations. There is expected to be an overlap among the securities held in each of the SMAs. Each of the securities purchased in the SMAs will appear on the monthly account statement. Securities selected for the SMAs 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-Sensitive Program Account. A client can expect that the securities that comprise the SMAs may vary, perhaps significantly, from the securities purchased for other clients in the Program.

When determining the appropriateness of implementing SMAs, Strategic Advisers considers the trade-offs inherent in managing a client’s Tax-Sensitive Program Account toward the appropriate risk and return while monitoring the potential tax consequences. This may mean that the implementation of the SMAs may not happen on the first set of trades, and indeed may happen in small amounts over the course of months or even years from the start date. In some circumstances, a client’s account may 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 SMAs. In the future, Strategic Advisers may offer additional SMAs. These SMAs may be managed by Strategic Advisers or by affiliated or unaffiliated third-party registered investment advisers retained by Strategic Advisers. If such additional SMAs become available, Strategic Advisers will consider whether these SMAs are appropriate for a client’s Tax-Sensitive Program Account and may offer these additional SMAs to a client.

About the Strategic Advisers Funds

Strategic Advisers Funds enable Strategic Advisers to choose from an expanded group of Fidelity and non-Fidelity mutual funds and ETPs and Fund Sub-advisors. All Strategic Advisers Funds are considered to be Fidelity funds; however, most are a blend of both affiliated and unaffiliated mutual funds, ETPs and Fund Sub-advisors. 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. For more information on the investment strategies employed by the Strategic Advisers Funds, please see the prospectuses for those funds.

Strategic Advisers 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-Sensitive and BDIP Program Accounts, may be invested in the Strategic Advisers Funds. If an investor ceases to be a client of the Program, in general, Strategic Advisers will redeem any and all Strategic Advisers Fund shares and shares of other funds either made available only to clients

10

of the Program or due to other account restrictions, such as minimum balance requirements, held in a Program Account, and a client may incur gains or losses as a result of such redemptions.

About Strategic Advisers’ Model Provider Selection Process

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 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.

About Program Accounts Selecting BDIP

Clients may select the BDIP strategy, which seeks an attractive level of investment income for an appropriate level of risk by investing mutual funds and ETPs that invest in (or track) the following major asset classes: domestic stocks, foreign stocks, investment grade and high yield bonds, and short-term investments. Strategic Advisers has retained BlackRock Investment Management, LLC (“BlackRock”) as Model Provider for this strategy. Strategic Advisers may select investments for a BDIP Program Account that differ from BlackRock’s model portfolio, but may 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 selected 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 of 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 mutual funds and ETPs advised by it (or one of its affiliates) and which may pay fees and other compensation to BlackRock (or one of its affiliates), including iShares® ETPs (collectively, “BlackRock Affiliated Funds”). BlackRock may 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 Affiliated Fund may not achieve the investment objective. The mutual funds and ETPs included in the model portfolio provided by BlackRock will vary in their exposure to different asset classes, as well as different styles (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 may change from time to time.

BlackRock seeks to maintain a risk profile for the model portfolio that is generally consistent with 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 may allocate from 20% to 60% to equity investments and correspondingly from 40% to 80% to fixed income investments. BlackRock seeks to balance income and risk in the model portfolio by limiting volatility over a rolling three-year period in line with a balanced portfolio (as measured by the annualized standard deviation of monthly returns).

11

Investment Restrictions

A client is entitled to impose reasonable restrictions on the management of a Program Account. Any proposed restriction is subject to our review and approval. Such a restriction may include prohibitions such as with respect to the purchase of a particular fund or sub–asset class, provided such restriction is not inconsistent with the Program’s stated investment strategy or philosophy, or is not fundamentally inconsistent with the nature or operation of the Program. If a restriction is accepted, assets will be invested in a manner that is appropriate given the restriction. Program Accounts with imposed management restrictions may experience different performance from Program Accounts without restrictions, possibly producing lower overall results. Program Account restrictions should be requested through a Fidelity representative.

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 the proprietary or material nonpublic information of the investment advisers to the Fidelity mutual funds or ETPs.

When investing in Fidelity and non-Fidelity funds, Strategic Advisers may from time to time consult the fund 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 Strategic Advisers on behalf of all its clients. Funds are not required to accept investments and may limit how much Strategic Advisers can purchase. One way that Strategic Advisers deals with potential capacity issues is to the use the Strategic Advisers Funds instead of third-party funds. Additionally, Strategic Advisers may establish internal limits on how much it may invest in any one fund across the programs for which it provides management services. Regulatory restrictions also may limit the amount that one fund can invest in another, which means that Strategic Advisers or the Strategic Advisers Funds may be limited in the amount they can invest in any particular fund. Strategic Advisers will work closely with fund management to minimize the impact of its reallocation activity on acquired funds. In certain situations, liquidating positions in underlying funds may be accomplished over an extended period of time as a result of operational considerations, legal considerations, or input from underlying fund managers. 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 may be sold 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 may bear such losses depending on the particular circumstances.

From time to time, Strategic Advisers and/or its affiliates may determine that, as a result of regulatory requirements that may 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 may be impractical or undesirable. The foregoing limits and thresholds may 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 may be owned by all such accounts. In such instances, the adviser may limit or exclude a client’s investment in a particular issuer, which may include investment in related derivative instruments, and investment flexibility may be restricted.

12

Additionally, the mutual funds Strategic Advisers invests in may have policies that restrict excessive trading. As a result, a fund may reject trade orders if they are deemed to represent excessive trading. In general, a fund may 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, in order to comply with a fund’s trading policies, Strategic Advisers may 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 may take up to one (1) business day to implement, and may stop any trading activity that is occurring in a Program Account.

Material Investment Risks

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 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 higher exposure to fixed income will have greater exposure to the risks associated with those products, such as credit risk and bond investment risk.

Risk of Loss. The discretionary investment management strategies implemented by Strategic Advisers for clients in the Program, including conservative investments, involve risk of loss. Investments in a Program Account are not a deposit of a bank and are not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. A client may lose money by investing in mutual funds, ETPs, and individual securities. A client may lose money by investing in the Program.

Many factors affect each investment’s or Program Account’s performance. Strategies that pursue investments in equities will be subject to stock market volatility, and strategies that pursue fixed income investments (such as bond or money market funds) will see values fluctuate in response to changes in interest rates. All strategies are ultimately 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. Non-diversified funds, SMAs, 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, 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. Additionally, investments or accounts that pursue debt exposure are subject to risks of prepayment or default, and funds, SMAs, 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 international or emerging markets funds’ exposure to a particular country or region) may be significantly impacted by events affecting those industries or markets. Strategies that lead funds, SMAs, 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. Additionally, investments and accounts may be subject to operational risks, which can include risks of loss arising from failures in internal processes, people, or systems, such as routine processing errors or major systems failures, or from external events, such as exchange outages.

In addition, investments in the mutual funds, ETPs, and individual securities in a Program Account may be subject to the following risks:

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.

13

ETPs. An ETP is a security that trades on an exchange and may seek to track an index, a commodity, or a basket of assets. ETPs can include exchange-traded funds, exchange-traded notes, unit investment trusts, closed-end funds, master limited partnerships, and certain grantor trusts. ETPs can be actively or passively managed. The performance of a passively managed ETP may not correlate to 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 their underlying securities. ETPs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Share trading may be halted or the security may cease to trade on an exchange. Trading volume and liquidity may vary and may affect the ability to buy or sell shares, or may cause the market price of shares to experience significant premiums or discounts relative to 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 may vary significantly. ETPs may also have unique risks depending on their structure and underlying investments.

Money Market Funds. 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 insured or guaranteed by the FDIC or any other government agency. Fidelity, the sponsor of Fidelity’s money market funds, has no legal obligation to provide financial support to a Fidelity money market fund, and a client should not expect that Fidelity will provide financial support to a Fidelity money market fund at any time. Fidelity’s government and U.S. Treasury money market funds will not impose a fee upon the sale of shares, nor temporarily suspend an investor’s ability to sell shares, if a fund’s weekly liquid assets fall below 30% of its total assets because of market conditions or other factors.

Funds with Multiple Managers. Separate investment decisions and the resulting purchase and sale activities of a fund’s sub-advisors might adversely affect a fund’s performance or lead to disadvantageous tax consequences.

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 may be subject to the risks described below under the heading, “Operational Risks.”

Investing for Volatility Management. The ability of Defensive Strategy Preference 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 in providing the model portfolio to Strategic Advisers) to estimate correctly the volatility of the investments it chooses relative to the broader market. Volatility may be higher than anticipated, and the specific investments used to manage volatility may 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 may not realize the anticipated benefits from the volatility management process or may 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 may also result in less favorable performance than if such processes had not been used. The volatility management strategies used in managing these accounts may cause them to underperform when markets rise, and there can be no assurance that these strategies will help mitigate losses when markets fall.

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 may be subject to risk related to market capitalization as well as company-specific risk.

14

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.) The ability of an issuer of a bond to repay principal prior to a security’s maturity can cause greater price volatility if interest rates change, and, if a bond is prepaid, a bond fund may have to invest the proceeds in securities with lower yields. Fixed income securities also carry inflation risk and 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 may be less liquid than other investments, and therefore may be 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 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 may also be exempt from state and local income taxes. Income exempt from regular federal income tax (including distributions from tax-exempt, municipal, and money market funds) may 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 may 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, may 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 may 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 may be relying for funding may 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 may directly impact the liquidity and valuation of municipal bonds.

Foreign Exposure. Foreign securities are subject to interest rate, currency exchange rate, economic, regulatory, and political risks, all of which may be greater in emerging markets. These risks are particularly significant for funds that focus on a single country or region or emerging markets, or for clients who elect the Increased International Option. Foreign markets may 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.

Derivatives. Certain funds and ETPs used by Strategic Advisers may 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 may 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

15

derivatives (such as swap agreements), on the other hand, tend to be more specialized or complex, and may be more difficult to value. Derivatives may involve leverage because they can provide investment exposure in an amount exceeding the initial investment. As a result, the use of derivatives may 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.

Alternative Investments. Alternatives are classified as assets whose investment characteristics and/or performance differ substantially from the major asset classes and therefore offer opportunities for additional diversification. Strategic Advisers does not invest in private equity, hedge funds, or similar investments directly in Program Accounts; however, Strategic Advisers may invest in mutual funds that invest significantly in these instruments, and therefore clients may have indirect exposure to these types of investments. Generally, alternatives may be illiquid.

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 may be more volatile and less liquid than the underlying commodity, instruments, or measures and their value may be affected by the performance of the overall commodities markets, as well as by weather, political, tax, and other regulatory and market developments.

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.

Risks and Limitations Associated with Tax-Sensitive Investment Management Techniques. Strategic Advisers applies tax-sensitive investment management techniques on a limited basis, at its discretion. Strategic Advisers actively manages for federal income taxes, but does not manage in consideration of state or local taxes; foreign taxes on non-U.S. investments; or estate, gift, or generation-skipping transfer taxes. In harvesting tax losses, Strategic Advisers does not attempt to harvest every tax loss that occurs in a Tax-Sensitive Program Account. It is important to understand that in a given year, due to investment decisions or market conditions, a client may receive varying levels of taxable distributions within a Tax-Sensitive 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. Strategic Advisers relies on information a client provides in an effort to provide tax-sensitive investment management and does not offer tax advice. Strategic Advisers cannot guarantee the effectiveness of its tax-sensitive investment management techniques in serving to reduce or minimize a client’s overall tax liability or the tax results of a given transaction. Strategic Advisers believes appropriate asset allocation is of primary importance, and will make changes to a Tax-Sensitive Program Account’s asset allocation even if such changes may trigger significant tax consequences.

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 may not ever realize their full value.

Risks Associated with the Strategic Advisers Tax-Managed U.S. Large Cap SMA. The Strategic Advisers Tax-Managed U.S. Large Cap SMA relies on a quantitative model that is designed to replicate the overall risk and return characteristics of the S&P 500® Index. To the extent that the quantitative model fails to

16

adequately match the risk and return profile of the index, the SMA may perform differently from the S&P 500® Index on a pretax basis. In addition, to the extent that the components of the index perform in a highly correlated fashion, the strategy may be less effective at harvesting the tax losses on which the strategy relies. In addition, the Strategic Advisers Tax-Managed U.S. Large Cap SMA relies on algorithmic processes, and therefore may be subject to the risks described below under the heading, “Operational Risks.”

Model Overlay Risks. There are risks associated with BDIP Program Accounts and the Fidelity Strategic Advisers U.S. Large Cap Equity, Strategic Advisers Equity Growth and Strategic Advisers Equity Value SMAs. Each relies on Strategic Advisers’ ability to purchase the investments in the Model Providers’ portfolio recommendations. This may not be possible due to liquidity constraints or aggregate holdings limitations, among other reasons. BDIP Program Accounts and the Fidelity Strategic Advisers U.S. Large Cap Equity, Strategic Advisers Equity Growth and Strategic Advisers Equity Value SMAs may perform differently from the Model Providers’ portfolio recommendations.

Legislative and Regulatory Risk. Investments in a Program Account may 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, individual issuers of securities, and Strategic Advisers’ determinations with respect to the expected rate of return, value, tax treatment, or creditworthiness of a particular security. The impact of these changes may not be fully known for some time.

Cybersecurity Risks. With the increased use of technologies such as the internet to conduct business, Strategic Advisers and its affiliates are susceptible to operational, information security, and related risks. Cyber attacks 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; or causing operational disruption. Cyber attacks may 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 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 a fund or account invests, counterparties with which a fund or 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 risks 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. Algorithms may be used by Strategic Advisers in support of its discretionary portfolio management process and contribute to operational risks. There is a risk that the algorithms and data input into the algorithms could have errors, omissions, imperfections and malfunctions. Any decisions made in reliance upon incorrect data expose Program Accounts to potential risks. Issues in the algorithm are often extremely difficult to detect and may go undetected for long periods of time; some may never be detected. These risks are mitigated by testing and human oversight of the algorithms and their output. We believe that the oversight, testing and monitoring performed on our algorithms and their output will enable us to identify and address issues that a prudent person managing a similar service would identify and address. 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.

Incidents arising from operational failures, including those resulting from the mistakes of third parties, may not be compensable by Strategic Advisers to a client. Strategic Advisers maintains policies and procedures that address the identification and correction of errors, consistent with applicable standard of care, to ensure that clients are treated fairly when an error has been detected. The determination of whether

17

an incident constitutes an error is made by Strategic Advisers or its affiliates, in their sole discretion. In the event that Strategic Advisers or its affiliates make an error that has a financial impact on a Program Account, Strategic Advisers or its affiliates will generally return the Program Account to the position it would have held had no error occurred. Strategic Advisers will evaluate each situation independently. This corrective action may result in financial or other restitution to a Program Account, or inadvertent gains being reversed out of a Program Account. Under certain circumstances, clients will not be reimbursed for errors where the loss is less than $10 per Program Account; in such cases, we have instituted procedures designed to prevent Fidelity from receiving economic benefits from limiting the correction of such errors.

D I S C I P L I N A R Y I N F O R M AT I O N

Strategic Advisers has no material disclosable legal or disciplinary events associated with its management personnel for its advisory services.

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 AT I O N S

Strategic Advisers is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is wholly owned by 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 customers may have material business relationships with any of the subsidiaries and affiliates of FMR LLC. In addition, the principal officers of Strategic Advisers may 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, commodity pool operator, or commodity trading advisor, nor does it have an application pending to register as such. Certain management persons of Strategic Advisers are registered representatives of Fidelity Brokerage Services LLC (“FBS”) and/or Fidelity Investments Institutional Services Company, Inc. (“FIISC”), Strategic Advisers affiliates and registered broker-dealers.

From time to time, Strategic Advisers or its clients may have a material relationship with the following affiliated companies:

Investment Companies and Investment Advisers

• FPWA is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is wholly owned by FMR LLC, and a registered investment adviser under the Investment Advisers Act of 1940 (“Advisers Act”). FPWA provides non-discretionary investment management services and serves as the sponsor to investment advisory programs, including the Program. Strategic Advisers acts as sub-advisor to FPWA in providing discretionary portfolio management of Program Accounts, and assists FPWA in evaluating other sub-advisors.

• Fidelity Management & Research Company (“FMRCo”) is a wholly owned subsidiary of FMR LLC and a registered investment adviser under the Advisers Act. FMRCo principally provides portfolio management services as an adviser or a sub-advisor to registered investment companies. FMRCo provides portfolio management services as investment adviser or sub-advisor to clients of other affiliated and unaffiliated advisers. Strategic Advisers pays FMRCo an administrative fee for handling the business affairs of the investment companies Strategic Advisers advises. In addition, it is expected that Strategic Advisers may share employees from time to time with FMRCo.

18

• Fidelity Investments Money Management, Inc. (“FIMM”) is a wholly owned subsidiary of FMR LLC and a registered investment adviser under the Advisers Act. FIMM provides portfolio management services as a sub-advisor to certain of our clients, including investment companies in the Fidelity group of funds, or as an adviser. In addition, it is expected that Strategic Advisers may share employees from time to time with FIMM.

• FMR Co., Inc. (“FMRC”) is a wholly owned subsidiary of FMRCo, which in turn is wholly owned by FMR LLC, and a registered investment adviser under the Advisers Act. FMRC may provide portfolio management services as a sub-advisor to certain affiliated investment companies. FMRC provides sub-advisory services and/or model portfolio recommendations for Strategic Advisers clients, and may also provide portfolio management services as an adviser or a sub-advisor to customers of other affiliated and unaffiliated advisers. In addition, it is expected that Strategic Advisers may share employees from time to time with FMRC.

• FIAM LLC (“FIAM”) is a wholly owned subsidiary of FIAM Holdings Corp., which in turn is wholly owned by FMR LLC, and a registered investment adviser under the Advisers Act. FIAM provides investment management services, including sub-advisory services, to Strategic Advisers or its affiliates. FIAM is also registered with the Central Bank of Ireland. In addition, it is expected that Strategic Advisers may share employees from time to time with FIAM.

• Fidelity SelectCo, LLC (“SelectCo”) is a wholly owned subsidiary of FMR LLC and a registered investment adviser under the Advisers Act. SelectCo may provide portfolio management services as an adviser or sub-advisor to certain affiliated investment companies.

• FMR Investment Management (UK) Limited (“FMRIM(UK)”), an indirect, wholly owned subsidiary of FMRCo, which in turn is wholly owned by FMR LLC, is registered as an investment adviser under the Advisers Act and is authorized by the U.K. Financial Conduct Authority to provide investment advisory and asset management services. FMRIM(UK) provides investment advisory and portfolio management services as a sub-advisor to certain of Strategic Advisers’ clients, including investment companies in the Fidelity group of funds. FMRIM(UK) may provide portfolio management services as an adviser or sub-advisor to clients of other affiliated and unaffiliated advisers. FMRIM(UK) is also registered with the Central Bank of Ireland. Strategic Advisers has sub-advisory agreements with FMRIM(UK) for certain of Strategic Advisers’ funds.

• Fidelity Management & Research (Japan) Limited (“FMR (Japan)”), a wholly owned subsidiary of FMRCo, which in turn is wholly owned by FMR LLC, 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) may supply investment research and investment advisory information and may provide discretionary investment management services to certain clients of Strategic Advisers, including investment companies in the Fidelity group of funds, and to clients of other affiliated and unaffiliated advisers. Strategic Advisers has sub-advisory agreements with FMR (Japan) for certain of Strategic Advisers’ funds.

• Fidelity Management & Research (Hong Kong) Limited (“FMR (Hong Kong)”) , a wholly owned subsidiary of FMRCo, which in turn is wholly owned by FMR LLC, is a registered investment adviser under the Advisers Act, and has been authorized by the Hong Kong Securities & Futures Commission to advise on securities and to provide asset management services. FMR (Hong Kong) may provide investment advisory or portfolio management services as a sub-advisor with respect to certain clients of Strategic Advisers’ clients, including investment companies in the Fidelity group of funds, and for clients of other affiliated and unaffiliated advisers. Strategic Advisers has sub-advisory agreements with FMR (Hong Kong) for certain of Strategic Advisers’ funds.

19

Broker-Dealers

• Fidelity Distributors Corporation (“FDC”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, acts as principal underwriter and general distribution agent of the registered investment companies advised by FMRCo. FDC is a registered broker-dealer under the Securities Exchange Act of 1934 (“Exchange Act”).

• National Financial Services LLC (“NFS”) is engaged in the institutional brokerage business and provides clearing and execution services for other brokers. NFS is a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC. Fidelity Global Brokerage Group, Inc. is a holding company that provides administrative services to NFS. Fidelity Capital Markets (“FCM”), a division of NFS, may execute transactions for Strategic Advisers’ investment company and other clients. Additionally, FCM operates CrossStream®, an alternative trading system that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. FCM charges a commission to both sides of each trade executed in CrossStream. Using CrossStream, FCM crosses trades for client accounts, and it charges a commission on its trades to both of its brokerage customers. CrossStream may be used to execute transactions for investment company and other Fidelity clients. NFS is a registered broker-dealer under the Exchange Act, a member of NYSE and SIPC, and a registered investment adviser under the Advisers Act. NFS may serve as a clearing agent for client transactions that we place with certain broker-dealers. NFS may provide transfer agent or subtransfer agent services to certain of our or our affiliates’ clients. NFS provides transaction processing services in conjunction with the implementation of our discretionary portfolio management instructions. NFS also provides custodial, recordkeeping, and reporting services to clients.

In all cases, transactions executed by affiliated brokers on behalf of investment company clients are effected in accordance with Rule 17e-1 under the Investment Company Act of 1940 and procedures approved by the Boards of Trustees of the funds. The Board of Trustees of each fund in the Fidelity group of funds has approved FCM effecting fund portfolio transactions and retaining compensation in connection with such transactions pursuant to Section 11(a) of the Exchange Act.

• Luminex Trading & Analytics LLC (“LTA”), a registered broker-dealer and alternative trading system, operates an electronic execution utility (the “LTA ATS”) that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. FMR LLC is the majority owner of LTA. LTA charges a commission to both sides of each trade executed in the LTA ATS. The LTA ATS may be used to execute transactions for Strategic Advisers’ or Strategic Advisers’ affiliates’ investment company and other advisory clients. NFS serves as the clearing agent for transactions executed in the LTA ATS.

• 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 investment companies advised by FMRCo, to individuals and institutions, including retirement plans administered by affiliates. Pursuant to referral agreements and for compensation, representatives of FBS may refer customers to various services offered by FBS’s related persons, including Strategic Advisers. In addition, along with Fidelity Insurance Agency, Inc. (“FIA”), FBS distributes insurance products, including variable annuities, which are issued by FMRCo’s related persons, Fidelity Investments Life Insurance Company (“FILI”) and Empire Fidelity Investments Life Insurance Company® (“EFILI”). FBS may provide shareholder services to certain of FMRCo’s or FMRCo’s affiliates’ clients. FBS is the introducing broker for Program Accounts and places trades for execution with its clearing broker, NFS.

• FIISC, a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, primarily markets Fidelity mutual funds and other products advised by FMRCo or an affiliate thereof to third-party financial intermediaries and certain institutional investors. FIISC is a registered broker-dealer under the Exchange Act.

20

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 may offer shares of investment companies managed by Strategic Advisers or its affiliates.

• EFILI is a wholly owned subsidiary of FILI, which in turn is wholly owned by FMR LLC, and is engaged in the distribution and issuance of life insurance and annuity products that may offer shares of investment companies managed by Strategic Advisers or its 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 trust company organized and operating under the laws of the Commonwealth of Massachusetts, provides non-discretionary trustee and custodial services to employee benefit plans and individual retirement accounts through which individuals may invest in mutual funds managed by FMRCo or its affiliates, and discretionary investment management services to institutional clients. FMTC is a wholly owned subsidiary of FMR LLC.

• Fidelity Personal Trust Company, FSB (“FPTC”), a federally chartered savings bank, offers fiduciary services to its customers that include trustee or co-trustee services, custody, income and principal accounting, investment management services, and recordkeeping and administration. FPTC is a wholly owned subsidiary of Fidelity Thrift Holding Company, Inc., which in turn is wholly owned by FMR LLC.

Limited Partnerships and Limited Liability Company Investments

Strategic Advisers may provide 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 intend to engage in borrowing, lending, purchasing securities on margin, short selling, or trading in commodities.

Participating Affiliates

Fidelity Business Services India Private Limited (“FBS India”), with its registered office in Bangalore, is incorporated under the laws of India and is ultimately owned by FMR LLC through certain of its direct or indirect subsidiaries. Certain employees of FBS India (“FBS India Associated Employees”) may from time to time provide certain research services for Strategic Advisers, which Strategic Advisers may use for its customers.

FBS India 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 U.S. Securities and Exchange Commission’s (“SEC”) 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 FBS India and each of the FBS India Associated Employees as “associated persons” of Strategic Advisers within the meaning of Section 202(a)(17) of the Advisers Act. FBS India Associated Employees and FBS India, through such employees, may contribute to Strategic Advisers’ research process and may 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, FBS India 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’ customers.

Strategic Advisers maintains a list of FBS India Associated Employees whom FBS India has deemed “associated persons,” which Strategic Advisers will make available to its current U.S. clients upon request.

21

C O D E O F E T H I C S , PA R T I C I PAT 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:

(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 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 of securities in initial public offerings unless an exception has been approved

(vi) Reporting of Code of Ethics violations

(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, including (i) preclearing of transactions in covered securities; (ii) prohibiting investments in limited offerings without prior approval; (iii) reporting of transactions in covered securities on a quarterly basis; (iv) reporting of accounts and holdings of covered securities on an annual basis; and (v) disgorgement of profits from short-term transactions unless an exception has been approved. Violation of the Code of Ethics requirements may 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 upon request.

Strategic Advisers and its related persons may buy or sell for themselves securities that they also recommend to clients. The potential 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 ensure that Fidelity personnel 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, supervised persons may 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 nonpublic information by investment professionals or any other employees and that limit the transactions that Strategic Advisers can implement for Program Accounts.

In addition, Fidelity has implemented a policy on Business Entertainment and Workplace Gifts intended to set standards for business entertainment and 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 ensure compliance with applicable “pay to play” laws, Fidelity has adopted a Political Contributions and Activity policy that requires all employees to preclear any political contributions and activities.

If a client elects to invest in the Fidelity Focused Preference, Strategic Advisers will have a preference for Fidelity Funds, including the Strategic Advisers Funds. If a client elects to invest in the Blended Preference, the Index Focused Preference or the Defensive Strategy Preference, currently Strategic Advisers will

22

consider only funds available through the Fidelity fund supermarket. Certain of these funds pay servicing and distribution fees to FBS or NFS. This compensation is paid by the fund and/or its affiliate.

The servicing and distribution fees that FBS or NFS receives from a mutual fund or ETP and/or its affiliate are in addition to the advisory fees the client pays FPWA. With respect to certain of these mutual funds or ETPs, FBS or NFS generally receives a percentage annually of the average daily net assets of non-Fidelity mutual funds or ETPs in a client’s Program Account(s); however, any such amounts received by FBS or NFS will be offset against a client’s gross advisory fee by a corresponding credit amount equal to the amount of revenue received as a result of the client’s investments in these mutual funds or ETPs. The servicing and distribution fees that FBS receives are taken into consideration when determining the net advisory fee applied to the client’s Program Account(s). Each Fidelity mutual fund and ETP pays investment management fees and other fees to FMRCo, Strategic Advisers, or their affiliates. In addition, affiliates of Strategic Advisers are compensated for providing distribution, transfer agency, shareholder servicing, and custodial and other services to certain Fidelity and non-Fidelity funds or ETPs. The compensation received by Strategic Advisers and its affiliates from investments in Fidelity funds or ETPs will generally exceed, prior to the application of the credit amount (described above), the compensation from investments in non-Fidelity funds or ETPs. Please see the FPWA Program Fundamentals for additional information about advisory fees and related credit amounts.

This potential conflict is addressed through the application of selection criteria and personnel compensation arrangements that do not differentiate between Fidelity and non-Fidelity mutual funds or ETPs. Strategic Advisers’ investment professionals are compensated partially based on account performance, and are not compensated based on the amount of Fidelity or non-Fidelity mutual funds or ETPs, or the amount of SMAs, used in the Program. Depending on market conditions and other events, certain factors in the selection process at times may result in a significant portion of the portfolio being invested in Fidelity mutual funds or ETPs. A client may be assessed an additional SMA fee if the client’s Tax-Sensitive Program Account is invested in any SMA in the Program. However, unlike the mutual funds and ETPs held in a client’s Program Accounts, there are no underlying fund-level expenses attributable to the individual securities held in an SMA. Accordingly, amounts invested in an SMA will be subject to a credit amount only to the extent that the SMA holds securities that pay compensation to Strategic Advisers’ affiliates.

B R O K E R A G E P R A C T I C E S

Transactions in Program Accounts

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 notification that a change has been made via a transaction confirmation. 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.

Clients will receive prompt confirmations from NFS for any transactions in their Program Account; 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 will receive monthly statements from NFS that will detail all holdings and transaction information, including trades, additions, withdrawals, shifts in investment allocations, advisory fees, and estimated gain/loss and tax basis information. Monthly statements and confirmations may also be 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.

For the Program, all commissions are waived for transactions executed through affiliates of Strategic Advisers. However, the advisory fee charged for the Program does not cover the charges resulting from trades effected with or through broker-dealers other than affiliates of Strategic Advisers or cover mark-ups

23

or mark-downs by broker-dealers, 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. One non-Fidelity-related charge applies to sales of securities made for Program Accounts — an industry-wide charge mandated by the SEC and totaling a few cents per $1,000 of securities sold. The amount of this regulatory fee may vary over time, and because variations might not be immediately known to Fidelity, the amount may be estimated and assessed in advance. To the extent that such estimated amount differs from the actual amount of the regulatory fee, Fidelity may retain the excess. These charges will be reflected on transaction confirmations and/or monthly statements.

Trading through Affiliates

Strategic Advisers is authorized to place portfolio transactions with affiliated registered broker-dealers or transfer agents. Strategic Advisers will arrange for the execution of transactions through affiliated broker-dealers if Strategic Advisers reasonably believes that the quality of the execution of the transaction is comparable to what could be obtained through other qualified broker-dealers. In determining the ability of a broker-dealer to obtain best execution, Strategic Advisers will consider a number of factors, including the broker-dealer’s execution capabilities, reputation, and access to the markets for the securities being traded.

In general, Strategic Advisers or its delegate will place trades with NFS through FCM with respect to the execution of trades for ETPs and individual securities in a Program Account. Strategic Advisers may allocate up to 100% of a client’s order to FCM, subject to Strategic Advisers’ obligation to strive for best execution. Strategic Advisers reasonably believes that the quality of the execution of transactions is comparable to or more favorable than what could be obtained through other qualified broker-dealer firms. To that effect and in order to continuously ensure the quality of the execution, Strategic Advisers receives equity quality reporting from FCM, monitoring the quality of the execution of transactions allocated to FCM.

Clients will not be charged commissions on transactions executed through FCM. NFS transmits orders received for execution through FCM to various exchanges or market centers based on a number of factors. These include the following: size of the order, trading characteristics of the security, favorable execution prices (including the opportunity for price improvement), access to reliable market data, availability of efficient automated transaction processing, and execution costs. Some market centers or broker-dealers may execute orders at prices superior to the publicly quoted market prices.

Strategic Advisers believes that FCM’s order-routing policies, taking into consideration all the factors listed above, are designed to result in transaction processing that is favorable to its customers. Where Strategic Advisers directs the market center to which an order is routed, FBS or FCM will route the order to such market center in accordance with Strategic Advisers’ instructions without regard to its general order-routing practices. FBS and/or FCM receives remuneration, compensation, or other consideration for directing some customers’ orders for equity securities to certain market centers for execution. Such consideration may take the form of financial credits, monetary payments, rebates, volume discounts, or reciprocal business; provided, however, that neither FBS nor FCM receives any consideration in connection with directing equity trades for Program Accounts to market centers for execution. The details of any credit, payment, rebate, or other form of compensation received in connection with the routing of a particular order 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 may provide aggregated trade execution data to customers and prospective customers.

In general, to comply with applicable law, Strategic Advisers will not conduct any brokerage transactions on a principal basis with any affiliate or affiliated broker-dealer. However, a broker-dealer affiliated with Strategic Advisers, including NFS, may act as principal with respect to a client’s transactions in other accounts maintained with Fidelity over which Strategic Advisers has no discretionary management authority to the extent permitted by law and subject to applicable restrictions.

24

With respect to investments made by Fidelity mutual funds and ETPs, Strategic Advisers and its affiliates may allocate brokerage transactions to brokers who are not affiliates of Strategic Advisers and 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 may be paid to Strategic Advisers or its affiliates. Not all brokers with whom Strategic Advisers trades have agreed to participate in brokerage commission recapture. Strategic Advisers expects that brokers from whom Strategic Advisers or its affiliates purchase research products and services with “hard dollars” are unlikely to participate in commission recapture.

Trade Aggregation and Allocation

When effecting trades of individual securities for Program Accounts, Strategic Advisers may aggregate these trades with trades for other clients when, in Strategic Advisers’ judgment, as applicable, aggregation is in the best interest of all clients involved. Orders are aggregated 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. The transactions are averaged as to price and allocated as to amount according to the purchase and sale orders actually placed for each client account.

With respect to trade allocation, Strategic Advisers’ policy is to treat each of its clients’ accounts in a fair and equitable manner when allocating orders for the purchase and sale of securities. Strategic Advisers has adopted a trade allocation policy designed to achieve fairness and not to purposefully disadvantage comparable client accounts over time when allocating purchases and sales. All allocations among a client’s Program Account and/or funds of funds managed by Strategic Advisers will be made in a manner consistent with Strategic Advisers’ fiduciary duties, taking into account all relevant factors.

Cross Trades

Strategic Advisers may effect agency “cross trades” (that is, trades in which Strategic Advisers, or any person controlling, controlled by, or under common control with Strategic Advisers, acts as investment adviser to a client, and as broker for that client and for the party or parties on the other side of the trade) for Program Accounts to the extent permitted by law. Such transactions will be executed in accordance with Section 206(3) of the Advisers Act, requiring written consent, confirmations of transactions, annual reporting, and compliance procedures. In addition, to the extent permitted by law and applicable policies and procedures, Strategic Advisers may effect cross trades involving Program Accounts, in which a security is purchased in or sold from one account advised by us (or our affiliate), and sold or purchased from another account advised by us (or our affiliate) through a book-entry transfer, when Strategic Advisers believes such trades are in the best interest of all clients involved. Cross trades will be done either directly or through a broker-dealer (including FBS or NFS), based on one or more third-party pricing services and/or actual market bids.

Soft Dollars

Strategic Advisers does not have a soft dollar program. Some sub-advisors to the Strategic Advisers Funds may use soft dollars or other commission sharing arrangements in connection with transactions effected for the Strategic Advisers Funds.

Client-Directed Brokerage Activities

During a client’s participation in the Program, Program Accounts will not be 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 its designated agents. The activities for Program Accounts will not apply or be related to any other activities or accounts that a client may maintain with Fidelity.

25

R E V I E W O F A C C O U N T S

Ongoing Review and Adjustments of Program Accounts

Periodically, market conditions and/or an upturn or downturn in a particular security may cause a “drift” in a client’s investment portfolio away from the appropriate long-term risk level associated with the client’s Program Account. Strategic Advisers may choose to rebalance a client’s Program Account to bring it back in line with the Account 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 may also modify the funds held in a Program Account to accommodate new fund allocations and fund closures.

In managing Program Accounts, Strategic Advisers may decide to 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 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/withdrawal of cash or securities into a Program Account;

• Accommodating mutual fund or ETP closures or limitations; or

• For Tax-Sensitive Program Accounts, certain changes in the client’s tax situation or in the tax treatment of the investments in the Tax-Sensitive Program Account.

For Program Accounts, other than Tax-Sensitive and BDIP Program Accounts, Strategic Advisers’ investment management team will make decisions regarding reallocations within the model portfolio upon 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 may request. The Strategic Advisers Funds are reviewed daily and assets within the Strategic Advisers Funds are reallocated based on the discretion of the Strategic Advisers portfolio managers. As a result, reallocation activity applicable to such a Program Account’s assets invested in the Strategic Advisers Funds may take place at the fund level, rather than directly in a client’s Program Account.

Generally, Strategic Advisers reviews and adjusts account holdings in Tax-Sensitive 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-Sensitive Program Account with respect to a variety of factors to determine whether the Tax-Sensitive Program Account may benefit from trading that day. Strategic Advisers does not anticipate that each Tax-Sensitive Program Account will be traded each day. Rather, Strategic Advisers’ proprietary account evaluation system monitors each Tax-Sensitive Program Account periodically to identify those accounts that may benefit from trading, and Strategic Advisers then evaluates those Tax-Sensitive 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 night’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.

In certain instances, a “do-not-trade” order may 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 order is on a Program Account, Strategic Advisers will suspend management

26

of the Program Account and will not monitor the Program Account for potential buys and sells of securities. Additionally, any deposits to a Program Account during a do-not-trade period will not be invested. Strategic Advisers is not held responsible for any market loss experienced as a result of a do-not-trade order.

Clients may receive periodic performance summaries or similar reports that detail the performance of a client’s Program Account(s) and summarize the market activity during the quarter. Industry standards are applied when calculating performance information. FPWA also makes available account performance information on a password-protected website.

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 AT I O N

FMRCo and its affiliates and subsidiaries are compensated for providing services to one or more of the funds in which Strategic Advisers’ clients may invest. These include FMRCo and subsidiaries as the investment adviser for the Fidelity funds; FDC as the underwriter of the Fidelity funds; and FIISC as transfer agent for the Fidelity funds, servicing agent for non-Fidelity funds, and recordkeeper of certain workplace savings plans. In addition, one or more broker-dealer affiliates of the Fidelity funds may execute portfolio transactions for the funds. FMRCo may 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 mutual funds’ portfolio security transactions.

As noted above, Strategic Advisers is authorized to place portfolio transactions with affiliated registered broker-dealers or transfer agents. For additional information on these practices, please see the section entitled “Brokerage Practices.”

For Program Accounts, the group of mutual funds and ETPs eligible for consideration in proposed portfolios is currently limited to funds available through Fidelity’s mutual fund supermarket, FundsNetwork®. FundsNetwork is a registered service mark of FMR LLC and a service of FBS. Mutual funds participating in Fidelity’s mutual fund supermarket that Strategic Advisers may invest its clients’ accounts in pay remuneration to affiliates of Strategic Advisers for providing shareholder services; however, any such revenue received by affiliates of Strategic Advisers is subject to the credit amount mechanism. Please see the FPWA Program Fundamentals for additional information about advisory fees and related credit amounts.

In connection with clients’ investments, certain personnel of Strategic Advisers may receive other economic incentives in addition to their normal compensation. In addition, our affiliates are compensated for providing distribution, transfer agency, servicing, and custodial services to certain Fidelity and non-Fidelity investment options (certain of these fees are also used to calculate the credit amount, where applicable). The compensation that Strategic Advisers and its affiliates receive as a result of a client’s investment in Fidelity-managed investments may exceed the compensation received from a client’s investments in non-Fidelity investment options; although the credit amount calculation may reduce this disparity, the credit amount does not eliminate this differential in all cases. The fees and expenses for the various services that Strategic Advisers or its affiliates provide to the funds are disclosed in each Fidelity fund prospectus. These fees and expenses are paid by the Fidelity funds and are ultimately borne by each fund’s shareholders.

Client referrals are provided by affiliated entities, including FBS, or other affiliates, pursuant to referral agreements where applicable. Payments may be made to affiliates for services that facilitate delivery of Strategic Advisers’ services.

C U S T O D Y

Strategic Advisers does not maintain custody for Program clients’ assets in connection with the discretionary portfolio management services it provides to Program Accounts. In order to participate in the Program, clients must establish and maintain a brokerage account with FBS, a registered broker-dealer and an affiliate of FPWA and Strategic Advisers. NFS, an affiliate of FBS, FPWA, and Strategic Advisers, has

27

custody of client assets and will perform certain account services, including the implementation of trading instructions, as well as custodial and related services. FPWA, Strategic Advisers, FBS, and NFS personnel may share premises and may have common supervision. Clients should carefully review all statements and other communications received from FBS and NFS.

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 effected 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 may 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 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, a client may 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. A client may also 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 may 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, clients may 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, 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 may contact us to transfer the security out of the client’s Program Account.

In connection with this election, clients 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 may see more information about ISS’s proxy voting policies in the summary of ISS’s proxy voting guidelines included in the application materials, or by contacting a Fidelity representative. Clients may contact Strategic Advisers directly to obtain a copy of its proxy voting guidelines, a copy of ISS’s summary proxy voting guidelines, and information on how investment proxies were voted.

F I N A N C I A L I N F O R M AT I O N

Clients of the Program do not pay Strategic Advisers for the services it provides under the Program. 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.

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® Wealth Services provides non-discretionary financial planning and discretionary investment management through one or more Portfolio Advisory Services accounts for a fee. Advisory services offered by Fidelity Personal and Workplace Advisors LLC (FPWA), a registered investment adviser, and Fidelity Personal Trust Company, FSB (FPTC), a federal savings bank. Nondeposit investment products and trust services offered through FPTC and its affiliates are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency, are not obligations of any bank, and are subject to risk, including possible loss of principal. Discretionary portfolio management services provided by Strategic Advisers LLC (Strategic Advisers), a registered investment adviser. Brokerage services provided by Fidelity Brokerage Services LLC (FBS), and custodial and related services provided by National Financial Services LLC (NFS), each a member NYSE and SIPC. FPWA, Strategic Advisers, FPTC, FBS, and NFS are Fidelity Investments companies.BlackRock Investment Management, LLC (BlackRock) is an independent entity which 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 may select investments for an account that differ from BlackRock’s model.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.S&P 500® Index: A market capitalization–weighted index of 500 common stocks chosen for market size, liquidity, and industry group repre-sentation to represent U.S. equity performance.Indexes are unmanaged. It is not possible to invest directly in an index.Fidelity, Fidelity Investments, the Fidelity Investments and pyramid design logo, FundsNetwork, and CrossStream are registered service marks of FMR LLC.Fidelity Brokerage Services LLC, Member NYSE and SIPC, 900 Salem Street, Smithfield, RI 02917© 2018 FMR LLC. All rights reserved.833404.1.0 1.9887736.100

FOR MORE INFORMATION, PLEASE CALL US TOLL FREE AT

8 0 0 - 5 4 4 - 3 4 5 5

Monday through Fr iday, 8 a.m. to 7 p.m. Eastern t ime