Sustainable, Responsible &/or ESG Policy:

The fund is a high-conviction fund with a focus on long-term sustainable financial and non-financial returns. 

We believe that over the long term, a company’s sustainability performance and financial performance will generally converge. We aim to deploy capital to those companies that enable sustainable development and present attractive potential for risk-adjusted return. We also aim to engage with and influence the companies we invest in, to promote change today for the benefit of future generations. The sustainable transition creates significant economic opportunities across many sectors.

Sustainable investment approach

At Fidelity, we believe that over the long term, a company’s sustainability and financial performance will generally converge. Companies contributing to a more sustainable economy are likely to benefit from a substantial growth opportunity in their end markets, and those with superior ESG characteristics should be at a lower risk from controversies, legal action, brand damage and product recalls.

In line with Fidelity’s SFDR article 9 framework, the fund aims to invest in sustainable investments*. We focus on sustainable 'enablers', those companies that contribute to the UN SDG, align with European Union (EU) Taxonomy, or have robust decarbonisation targets. We use Fidelity’s SDG tool to identify companies whose products and services enable the transition to a sustainable economy. Our SDG framework allows us to access to the most significant structural sustainable investment themes (such as decarbonisation, health and nutrition and financial inclusion) but with more economic diversification relative to a purely thematic approach.

*The fund may (on an ancillary basis and up to 20% of its assets) hold cash, money market instruments, or other investments used for hedging and efficient portfolio management purposes.

In addition, we have been developing a proprietary Climate Rating which utilises our fundamental research capabilities to identify climate risks, net zero investments and targets for transition engagement within the Fidelity investment universe. It assesses which companies are in the best position to transition to net zero, or those that have a positive trajectory towards transition. The Climate Rating is designed to complement our broader ESG Ratings, which already incorporate climate change factors.

The Portfolio Management Team is also active in analysing the effects of business sustainability when making investment decisions, monitoring the ESG profile, contribution to UN SDGs, alignment with EU Taxonomy, decarbonisation targets and carbon footprint of the portfolio, and participating in engagement with companies on ESG issues.

The Portfolio Management Team and fundamental research analysts are also supported by our team of 38* sustainable investing specialists who engage with companies on issues like corporate governance (for example, board structure, executive remuneration), shareholder rights (for example, election of directors, capital amendments), changes to regulation (for example, greenhouse gas emissions restrictions, governance codes), physical threats (for example, extreme weather, climate change, water shortages), and so on. Our sustainable investing specialists engage with senior management of investee companies as well as their Socially Responsible Investment (SRI) / ESG professionals. They access external ESG-themed research as well as the company ratings based on ESG factors that an external vendor produces.

Fidelity also uses a number of external research sources that provide ESG-themed reports and we subscribe to an external ESG research provider and rating agency to supplement our organic analysis. Fidelity receives reports that include company and industry specific research as well as ad hoc thematic research looking at particular topics. Our sources of ESG research are reviewed on a regular basis.

The ESG ratings and associated company reports are included on our centralised research management system, which is an integrated desktop database, so that each analyst has a first-hand view of how each company under their coverage is rated according to ESG factors. In addition, ESG ratings are included in the analyst research notes which are published internally and form part of the investment decision. The external research vendor also provides controversy alerts which include information on companies within our coverage who have been identified to have been involved in a high-risk controversy that may have a material impact on the company’s business or its reputation. 

Process:

The investment process of the fund can be broken down into into six different stages:

• Exclusions and screens
• Sustainable Investment (SI) assessment
• Idea generation
• Research and selection
• Portfolio construction and risk management
• Active ownership

Exclusions and screens

The starting investable universe of the fund consists of approximately 720 companies. It is reduced as we apply sustainability related screens and exclude companies whose activities or failures cause environmental or social harm. The resulting portfolio is invested in 'best-in universe' sustainable leaders with strong ESG credentials and low carbon footprints.

Firm-wide exclusions: Fidelity’s firm-wide exclusion framework screens for issuers with involvement in the various categories of controversial weapons, the use of which is prohibited by international treaties or conventions. These include cluster munitions, landmines, biological weapons, chemical weapons, blinding laser weapons, incendiary weapons and non-detectable fragments. We also screen for nuclear weapons for non-signatories of the Treaty on the Non-Proliferation of Nuclear Weapons, specifically manufacturers of nuclear weapons, warheads, whole nuclear missiles, and /or nuclear fissile materials; manufacturers of components and delivery platforms developed and/or significantly modified for exclusive use in nuclear weapons; and issuers that provide support services related to nuclear weapons.

Fund exclusions: The fund will not invest in issuers who fail the ten Principles of the United Nations Global Compact (UNGC), the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles for Business and Human Rights, Responsible Business Conduct and the International Labour Organization (ILO) Conventions as identified by ISS-Ethix and MSCI and reviewed by Fidelity. This research is complemented by Fidelity’s forward-looking assessment of a company and any changes to its practices.

‘Do No Significant Harm’ (DNSH) activities available in the table above are also excluded from the FF Sustainable Eurozone Equity Fund at the indicated revenue threshold, along with the controversies and principal adverse impacts:

For more details on Fidelity’s Sustainable Investing Framework please see: https://fidelityinternational.com/sustainable-investing-framework/. We will also exclude investment in issuers with an MSCI ESG rating below 'BBB’.

A minimum of 70% of a fund’s net assets are invested in securities deemed to maintain favourable ESG characteristics. Favourable ESG characteristics are defined by reference to a combination of different measurements such as ESG ratings provided by external agencies or Fidelity ESG Ratings. Further details on the methodology applied are set out at https://fidelityinternational.com/sustainable-investing-framework/ and may be updated from time to time.

Companies that meet these criteria are then eligible for further consideration and sustainable investment assessment.

Sustainable Investment assessment

The investible universe is defined using our SI assessment based on below criteria:

• Enabling environmental or social objectives- There are three possible routes to achieve this. The first is to have >50% of revenues aligned to the EU Taxonomy. The second is to have >50% of revenues aligned to UN SDG, as determined by Fidelity’s SDG tool. The third is to have a validated Science Based Target Initiative (SBTi) target consistent with a 1.5 degree or lower scenario.
• Do Not Significant Harm- We have a set of screens that identify issuers assessed to be causing harm. These are based on revenues from certain activities, controversies, and the worst performers on sustainability screens. (See exclusions section above)
• Minimum safeguards and good governance- This is covered by setting a minimum ESG rating threshold, fundamental analysis as well as the measures above.
• Fidelity's Sustainability Team has built a proprietary SDG tool that is used to measure a company's SDG alignment. It works by taking FactSet’s RBICS dataset, which breaks down an issuer's revenues across approximately 1800 different categories, and then maps these different revenue streams to SDGs, looking at the underlying targets and indicators to determine whether a specific business activity is making a contribution or not.

Idea generation 

Ideas are generated via multiple sources, relying on a combination of our research (inputs from 37* analysts covering European equities and 38* dedicated ESG specialists), the Fidelity proprietary SDG tool (to identify companies making a meaningful impact to UN SDGs), company meetings and conferences and third-party research (sector and thematic research, consultants / industry experts meetings), and quantitative screens to help narrow the universe.

Only stocks which meet the sustainability criteria and are consistent with the investment philosophy are considered for further analysis. 

In practical terms, the Portfolio Management Team is also able to reference the investment recommendations of the sustainable investing portfolio managers as well as other European portfolio managers which provides them with an overall perspective and highlights the most promising investment themes and their best stock ideas.
*Source: Fidelity International, as at 31 March 2024.

Research and selection

The Portfolio Management Team uses a bottom-up and fundamentals-driven investment approach that involves both financial and extra-financial analysis. They aim to invest in high-quality and growth stocks that can deliver attractive total shareholder return over the long-term. On ESG, they work in close collaboration with our fundamental and sustainable analysts to understand and analyse a company’s ESG profile and SDG alignment. This involves a thorough assessment of ESG risks and opportunities at the stock (ESG factors) and sector levels to select companies having best practices, sustainable development, high ESG scores and low controversy risks. At a stock level, the focus is on identifying the companies best positioned to drive positive change and also those that are poised to benefit from multi decade megatrends. This is informed by an in-depth assessment of the company’s products and services to assess contribution to the UN SDGs. We also believe investing in businesses contributing to the SDGs is way of accessing several powerful economic themes such as decarbonisation, financial inclusion, and health and wellbeing. These themes (among others) are aligned to sustainable development and provide a rich source of investment opportunity.

This is an iterative process conducted alongside fundamental / financial analysis, with the two aspects informing one another. This approach also serves as a tool to highlight areas for further engagement with companies.

Portfolio construction and risk management

Final selection and position sizing are based on conviction level, ESG credentials, liquidity, concentration risk, market timing and other supportive catalysts and events. The final portfolio is comprised of approximately 35-45 stocks, with highest conviction names making up for larger positions.

The Portfolio Management Team’s risk-management process has multiple lines of defence:

• Absolute risk: Focus on quality companies, balance sheet strength and liquidity.
• Relative risk: Awareness of overall cumulative active positions within the fund and correlations within the portfolio.
• Currency risk: Monitored to ensure understanding of sources of currency risk.
• ESG risk: Assess and monitor ESG-related risk.
• Monitoring by the Portfolio Management Team: Ongoing monitoring of risk exposures and sector weights.

Oversight - The Portfolio Management Team also participates in a Quarterly Fund Review (QFR) chaired by the relevant Head of Equities, which is also attended by a member of the Portfolio Construction and Risk Team. This review covers portfolio construction, liquidity, positions, trading activity, characteristics, style and risk in considerable detail. Our risk oversight process now includes a Quarterly Sustainability Review (QSR) for sustainable funds. This review is supported an approximately 20-page data pack covering a range of ESG data points, including rating profiles and disparities (Fidelity and MSCI), engagement, voting, exclusions, carbon and climate data and Principle Adverse Impacts (PAIs). The QSR discussion is currently led by the Sustainability Team, in active dialogue with our portfolio managers, our Chief Investment Officer, the Investment Director, and data analysts.

The risk management processes described above are further bolstered by independent risk oversight checks and controls. These include daily monitoring of portfolio guidelines and constraints (considering regulatory requirements) by the Compliance function, and monthly Investment Risk Committees’ (IRCs’) evaluations of portfolio risk exposures and their alignment with expectations.

Active ownership

The Portfolio Management Team aims for sustainability focused meetings with all companies held within the fund at least once annually, in order to deliver improved ‘real world’ sustainability outcomes as well as improved long-term outcomes for shareholders. The Portfolio Management Team, along with the fundamental research analyst and relevant sustainable investing analyst will engage with the companies where needed to monitor and encourage improvement in a company’s ESG performance (including any shortcomings identified during the research process). These interactions also help us to identify best practices that can inform other engagements and our investment process. As part of our active ownership, we communicate our voting practices and discuss areas of divergence with our holding. The failed engagements on material issues will also result in divestment.

Resources, Affiliations & Corporate Strategies:

At Fidelity, we are dedicated to achieving the best possible risk-adjusted returns for our investors. We believe that high standards of corporate responsibility generally make good business sense and have the potential to protect and enhance investment returns. Consequently, we integrate Environmental, Social and Governance (ESG) issues into our research and investment decision-making process; we believe it has the potential to affect the long-term value of the investment.

Our integrated ESG approach is relevant across all asset classes, sectors and markets in which we invest.

ESG integration is carried out at the fundamental research analyst level within our investment teams, primarily through the implementation of Fidelity's proprietary ESG Rating. This rating leverages our internal research capabilities and our engagement with companies to inform our view on a company’s sustainability credentials.

The cornerstone of our investment approach is bottom-up research. As well as studying financial results, our portfolio managers and analysts are dedicated to carrying out additional qualitative analysis of potential investments. They visit companies in person, examining everything that could influence its business, from the shop floor to the boardroom. Customers and suppliers also come in for scrutiny. In this way we can develop a 360-degree view of every company in which we invest and ESG factors are regularly considered in this research process.

Our approach to integrating ESG aspects into our investment processes is detailed in the following policies:

Sustainable Investing Principles (Published 2013, Updated 12/2022)

Our Sustainable Investing Principles sets out the guiding principles and minimum requirements for Fidelity’s sustainable investing activities across all asset classes and geographies.

Engagement Policy (Published 02/2021)

Our Engagement Policy sets out how we undertake stewardship and shareholder engagement across our listed equity and fixed income holdings.

Exclusion Framework (Published 12/2021)

Our Exclusion Framework forms part of our Sustainable Investment Policy and defines the main requirements for an effective exclusion framework applicable throughout the organisation.

Voting Principles and Guidelines (Published 07/2021, updated 03/2023)

Our Sustainable investing voting principles and guidelines provides information on how we exercise ownership rights through voting to improve sustainable business behaviour and client returns.

Climate Investing Policy (Published 10/2021)

Our Climate Investing Policy details how we plan to work with stakeholders to reduce climate risk across all investment strategies in a way that aligns with our foundation in active, bottom-up research.

Nature Roadmap  (Published 11/2023)

Our Nature Roadmap details how we are enhancing the integration of nature into our investment platform to help create a world where both people and the planet can thrive.

Deforestation Framework (Published 12/2022)

Our Deforestation Framework outlines how we engage with stakeholders to address agricultural commodity-driven deforestation risks across our investment strategies, aligned to our active, bottom-up investment approach.

All our sustainable investing related policies and reports are available on our website:

https://professionals.fidelity.co.uk/sustainable-investing/our-policies-and-reports

We use a combination of internal and external resources.

Internal

The bulk of the engagement and analysis is carried out by our research analysts who strive to go beyond studying just financial results and aim to integrate ESG and other factors into a comprehensive perspective. They are supported by our team of 34* sustainable investing specialists who engage with companies on various issues including:

• Corporate governance (for example, board structure, executive remuneration);
• Shareholder rights (for example, election of directors, capital amendments);
• Changes to regulation (for example, greenhouse gas emissions restrictions, governance codes); and 
• Physical threats (for example, extreme weather, climate change, water shortages).

Our sustainable investing specialists engage with senior management of investee companies as well as their Socially Responsible Investment/ESG professionals. 

Proprietary ratings and tools sit at the heart of Fidelity’s sustainable investing approach, facilitating the integration of sustainability in our fundamental research and ensuring a consistent approach. Our suite of proprietary tools include:

• ESG ratings: An assessment designed to generate a forward-looking and holistic assessment of ESG risks and opportunities. Analysts qualify the direction of change of companies’ ESG performance (positive, neutral or negative trajectory).
• Climate ratings: An assessment that utilises our fundamental research capabilities to identify climate risks, net zero investments and targets for transition engagement within the Fidelity investment universe. It assesses which companies are in the best position to transition to net zero or have a positive trajectory towards transition. The Climate Rating is designed to complement our broader ESG Ratings, which already incorporate climate change factors.
• SDG tool: An assessment which provides the percentage of an entities or portfolio’s alignment with each SDG, and where relevant the underlying targets and indicators. This provides a quantitative, transparent, and consistent approach to measuring the alignment of portfolios against the underlying targets and indicators behind the SDGs.

External

Fidelity is a signatory to many industry initiatives such as the Principles for Responsible Investing, UK Stewardship Code and the Japanese Stewardship Code. We are also active members of the Asian Corporate Governance Association, Assogestioni, the UK Sustainable Investment and Finance Association, the UK Investor Forum and many other trade and industry bodies around the world.

Fidelity uses a number of external research sources that provide ESG-themed reports, research, ratings and data on themes such as corporate involvement in verified or alleged failures to respect international norms, for example the Ten Principles of the United Nations Global Compact as well as on carbon emission, fossil fuel and power generation. The coverage of companies varies by provider and the providers currently cover more than 10,000 companies globally.

We also subscribe to a number of corporate governance and voting advisory services, including products supported by Institutional Shareholder Services (ISS), Glass Lewis and ZD Proxy Shareholder Services. In addition to these, we leverage information from these providers:

• MSCI: ESG data and indicators, exclusions, non-carbon PAIs, ratings, controversies.
• FactSet: RBICS/GeoRev in portfolio analysis.
• Moody's: EU Taxonomy Data.
• ICE Data Services: avoided emissions.

We constantly explore new data sets and approaches that can provide enhanced insights into companies.

*Source: Fidelity International, as at 30 September 2024. Excludes China AMC resources. 

Sustainability Team

Fidelity's Sustainability Team, part of Fidelity’s broader investment team, comprises sustainability and stewardship professionals with expertise in various subject areas. Consisting of 34* professionals, based in locations across Europe and the Asia Pacific region, the team’s scope now encompasses a wide range of activities related to ESG integration, engagement, policy, product development, sales and marketing, proxy voting as well as corporate sustainability.

The Sustainability Team functions across Fidelity in several ways:

• Collaborates closely with the broader investment team, supporting analysts in producing ESG research and conducting company-specific engagements, driving thematic engagement outcomes with sector analysts' input, and assisting portfolio managers in integrating ESG into their investment processes through proprietary tools, training, and frameworks.
• Works in tandem with the product team to develop sustainable investing frameworks and strategies in compliance with ESG regulations and tailored to diverse investor needs.
• Assists client-facing teams and clients with sustainable investing requirements and needs, including client communications, questionnaires, reporting, and training.

*Source: Fidelity International, as at 30 September 2024. Excludes China AMC resources. 

Oversight of ESG at Fidelity

The following individuals and teams are responsible for maintaining and integrating Fidelity’s ESG policies:

• The board members of FIL Limited (the ultimate holding company of the group known as Fidelity International) are responsible for overseeing and being accountable for sustainable investing. The Sustainability Team provides regular reports to the board on its activities, at least once a year. Any changes or amendments to our Sustainable Investing Principles, including our voting guidelines, are approved by the board.
• In 2017, the company established a Sustainable Investing Operating Committee (SIOC) with the aim of providing thorough oversight of all ESG matters across the company's various jurisdictions and business areas. The committee consists of senior management team members representing all asset classes and convenes monthly to review ESG company policy changes, industry developments, client requirements, new product innovations, and regulatory updates. It also ensures the alignment of all active ESG initiatives across the company. Additionally, ad-hoc meetings may be called to address urgent issues that arise before the next scheduled meeting.
• Andrew Wells - Interim Co-Chief Investment Officer, Fixed Income, Multi Asset and Private Assets and Head of Canada and Niamh Brodie-Machura - Co-Chief Investment Officer, Equities (both members of our Global Operating Committee) have oversight and accountability for our sustainable investing strategy and activities globally.
• Jenn-Hui Tan, our Chief Sustainability Officer, oversees Fidelity’s strategy and policies on engagement, voting and ESG integration across our active product range. He manages our dedicated Sustainability Team that is comprised of 34* sustainable investing specialists, based in London, Singapore, Hong Kong, Shanghai, Melbourne, Sydney and Tokyo, who work closely with the investment management teams globally across all asset classes. They are responsible for consolidating our approach to ESG integration, engagement and voting.
• Our directors of research are directly involved in the implementation of sustainable investing principles and procedures in the company. 
• Fidelity’s research analysts have overall responsibility for analysing and rating the ESG performance of the companies and buildings in which we invest. Our portfolio managers are also active in analysing the potential effects of these factors when making investment decisions, ensuring that each stock in the final portfolio adheres to the strategy’s and clients’ ESG requirements.
• The Compliance Monitoring Team monitors the portfolios with screening criteria systematically through hard-coded restrictions in the investment guidelines.

*Source: Fidelity International, as at 30 September 2024. Excludes China AMC resources. 

Industry collaboration

Fidelity recognises the importance of networks and information platforms to share tools, pool resources, and make use of investor reporting as a source of learning. Fidelity is a member or signatory to the following:

Gender Diversity:

• 30% Club Australia (2021)
• 30% Club Hong Kong (2022)
• 30% Club Japan (2019)
• 30% Club Investors Group (2019)
• 40:40 Vision (2020)
• Bright Network Women in Leadership
• Lord Mayor's Appeal - We Can Be
• Women in Finance Charter (2017)
• Women on Boards (2018)

Social Inclusion and Diversity:

• #10000 Black Interns (2020)
• BBBA Talent Accelerator (2020)
• Black North Initiative
• Black Young Professionals
• Catalyst After School Programme
• Disability:IN (2022)
• Diversity Project
• LGBT Great (2019)
• Lord Mayor's Appeal (2019)
• Minority Supplier Development UK (2020)
• OutBritain (2022)
• President’s Challenge Enabling Employment Pledge and Enabling Mark (2023)
• Race at Work Charter
• Social Enterprise UK (2021)
• Social Mobility Foundation (2021)
• Stonewall (2016)
• Trans in the City (2021)
• Valuable 500 (2019)
• Veteran Owned UK (2021)
• WeConnect International (2021)

Climate Change:

• Asia Investor Group on Climate Change (2020)
• CDP - formerly Carbon Disclosure Project (2019)
• Climate Bonds Initiative (2019)
• Climate Investment Summit (2022)
• Coalition for Climate Resilient Investment
• Global Standard on Responsible Corporate Climate Lobbying (2022)
• Green Finance Industry Taskforce Singapore (2020)
• Glasgow Financial Alliance for Net Zero (2021)
• Institutional Investors Group on Climate Change (2020)
• Investor Agenda (2021)
• Investor Group on Climate Change (2021)
• Net Zero Asset Managers Initiative (2020)
• One Planet Asset Manager Initiative (2021)
• Partnership for Carbon Accounting Financials (2022)
• Point Zero Carbon Programme (2022)
• Powering Past Coal Alliance (2021)
• Transition Pathway Initiative (2021)
• UN Climate Change Conference (2021)

Responsible Investment and Finance:

• Asia Securities Industry and Financial Markets Association (2015)
• Asia Research & Engagement (2023)
• European Sustainable Investment Forum (2017)
• European Public Real Estate Association (2023)
• Hong Kong Green Finance Association (2020)
• International Regulatory Strategy Group
• Investment Association (2010)
• Investor Forum - UK (2014)
• Principles for Responsible Investing (2012)
• The Purposeful Company Task Force
• Responsible Investment Association Australasia (2020)
• Sustainable Trading (2005)
• UK Sustainable Investment and Finance Association (2010)
• World Benchmarking Alliance (2020)

Governance and Corporate Accountability:

• Asian Corporate Governance Association (2004)
• Assogestioni (2007)
• Corporate Governance Forum (2009)
• Hong Kong Principles of Responsible Ownership (2017)
• International Corporate Governance Network (2005)
• Japanese Stewardship Code (2014)
• Taiwan Stock Exchange’s Stewardship Principles for Institutional Investors (2016)
• UK Stewardship Code (2010)

Biodiversity:

• Finance for Biodiversity (2021)
• Finance for Biodiversity Pledge (2021)
• Green Praxis Biodiversity (2022)
• Natural Capital Investment Alliance (2021)
• Taskforce on Nature-related Financial Disclosures Forum (2021)
• The Finance Sector Deforestation Action Initiative (2023)

Other Initiatives and Collaborations:

• Council for Sustainable Business
• Edinburgh Airport Sustainability Pledge
• Environment management system standard ISO 14001 (2023)
• Farm Animal Investment Risk and Return (2020)
• Inspiring More Sustainability (2019)
• Investors Against Slavery and Trafficking Asia-Pacific (2020)
• Maastricht University & GRESB (2021)
• Mental Health First Aid Training (2017)
• WEF Stakeholder Capitalism Metrics (2019)
• WorkWell Leaders (2023)

Dialshifter

Our organisation is helping to support the Paris Climate Agreement and the Race to Net Zero by…

We take a pro-active approach to minimising our own environmental footprint. We are committed to achieving net zero emissions by 2030 for Fidelity International’s operational emissions (including all Scope 1, 2 and 3 emissions we have direct control over). Our focus will be on the reduction of emissions through operational changes and investment in operational efficiencies, on-site renewals and purchasing of renewable energy whilst offsetting those we are unable to eradicate.

The goal at Fidelity is to conduct current and future business operations in a sustainable manner which helps create a better future for the environment. Fidelity ensures Environmental Sustainability is managed as any other critical business activity in an integrated, systematic way. The framework is designed to ensure Pollution Prevention, Carbon Reduction, Waste minimisation, responsible use of resources and compliance with legislation through good practice and continuous improvement.

Fidelity’s Commitment: 

• Manage Environmental Sustainability requirements in a systematic way aligned to the environmental management system standard ISO 14001;
• Develop carbon, Natural Resources and Waste data systems to effectively monitor and analyse performance; 
• Continuous improvement through setting realistic objectives to ensure sustainability management is improved in line with resources;
• Complying with legal and other mandatory requirements in relation to sustainability issues;
• Providing adequate control of environmental risks arising from our work activities and operations, including Pollution Prevention;
• Develop an environmentally sustainable culture where every employee can contribute towards Fidelity International goal to create a better future for the environment;
• Ensure effective communication and consultation on Environmental Sustainability with employees keeping them informed, motivated, and suitably trained;
• Ensure that business strategies, via the Environmental Sustainability Group, integrate Environmental Sustainability requirements;
• Reduce our consumption of resources (energy, water, materials, packaging), where feasible;
• Minimise Waste through a commitment to the Waste hierarchy to reduce, re-use, recover or recycle Waste, where feasible;
• To pursue Energy Efficiency in the design, maintenance, management and operation of our owned/operated buildings;
• Seek to use products that have the least possible environmental impact; and
• Reviewing and revising this policy, as necessary, at regular intervals.

Reports on environmental performance are produced covering a range of areas including energy management, carbon footprint, waste reduction, water usage and recycling. This data is collated on a monthly basis and communicated to Senior Management on a regular basis.

Our environmental management policy is based around our ability to obtain regular, accurate information on our environmental performance, not only in energy use and waste management, but also areas such as monitoring our carbon emissions in (for instance) air travel.

We receive regular reports from our incumbent service providers, and collate these for review. We then hold regular meetings with them to investigate areas for improvement. Where the meetings produce ideas which may help reduce the environmental impact of our operations, they are implemented and monitored. Where successful, they are incorporated into our procedures.

Fidelity’s corporate sustainability team have initiated carbon footprinting for a number of offices in recent years and are consolidating that in 2020 to produce global carbon emissions for Fidelity’s activities.

SDR Labelling:

Not eligible to use label