Program Fundamentals:
BlackRock ® Diversified Income Portfolio
Strategic Advisers, Inc.
245 Summer Street, V5D
Boston, MA 02210
1-800-544-3455
March 30, 2015
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, Inc. (“Strategic Advisers”), as well as information about one of Fidelity’s
Portfolio Advisory Services offerings, BlackRock® Diversified Income Portfolio.
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.
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 BlackRock® Diversified Income
Portfolio Program Brochure from March 28, 2014, through March 30, 2015. 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.
NEW INFORMATION REGARDING REASONS FOR TERMINATING ACCOUNTS
New information regarding reasons for termination of accounts has been added to the Section
entitled “Account Requirements and Types of Clients.” Please see page 11 for details.
NEW INFORMATION REGARDING REASONS FOR TRADING ACCOUNTS
New information regarding reasons for trading accounts has been added to the Section entitled
“Additional Information About Strategic Advisers’ Investment Practices and Model Provider
Selection Process.” Please see page 14 for details.
UPDATED LANGUAGE REGARDING STRATEGIC ADVISERS’ ERROR CORRECTION POLICY
Additional information regarding Strategic Advisers’ error correction policy has been added to the
Section entitled “Other Information about the Management of Your Account.” Please see pages 18
and 19 for details.
UPDATED ASSETS UNDER MANAGEMENT
Both discretionary and nondiscretionary assets managed by Strategic Advisers were updated
through December 31, 2014. Please see the updates on page 20.
NEW INFORMATION HAS BEEN ADDED TO “DISCIPLINARY INFORMATION AND OTHER
FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS”
An update has been made to “Disciplinary Information and Other Financial Industry Activities
and Affiliations” to include Luminex Trading & Analytics in the Broker-Dealers section. Please see
page 29 for more details.
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TA B L E O F C O N T E N T S
SE R VI C E S, F E E S, A ND CO MPEN S AT I O N
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A C C OU NT R E QU I R E MEN T S A N D T YPES O F CL I EN T S
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P ORTF OL I O M A NA G E R S EL ECT I O N A N D EVA L U AT I O N
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C L I E NT I NF OR M ATI O N PRO V I D ED T O PO RT F O L I O MA N A G ERS
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C L I E NT C ONTA C T W IT H PO RT FO L I O MA N A G ERS
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A D D I TI ONA L I NF OR M AT I O N
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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, Inc. (“Strategic Advisers,” or sometimes referred to as “we” or “us” throughout
this document), is a registered investment adviser and 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”),
trusts, estates, business entities, and charitable organizations. Fidelity’s Portfolio Advisory Services’
offerings include the BlackRock® Diversified Income Portfolio (sometimes referred to herein as the
“Service”). The Service may be used in conjunction with a client’s enrollment in Fidelity Wealth
Management AdvisorySM.
The Service offers you discretionary investment management for accounts of $200,000 or more.
The Service will invest your BlackRock® Diversified Income Portfolio account (“Account”) in a blend
of investments, which may include exchange-traded products and mutual funds. Exchange-traded
products (“ETPs”) can include exchange-traded funds (“ETFs”), exchange-traded notes (“ETNs”),
unit investment trusts, closed-end funds, master limited partnerships, and certain grantor trusts. ETPs
and mutual funds are collectively referred to as “Portfolio Investments” throughout this document.
Strategic Advisers is the investment adviser for the Service, responsible for discretionary
management of accounts enrolled in the Service. Strategic Advisers has retained BlackRock Investment
Management, LLC (“BlackRock”) to provide an investment model to be used by Strategic Advisers
in rendering investment advisory services to accounts enrolled in the Service. BlackRock will provide
Strategic Advisers with a model portfolio, and will provide periodic updates to the model portfolio.
BlackRock may be referred to as the “portfolio strategist” in other collateral. Strategic Advisers provides
oversight of the model portfolio and has discretionary management authority for, and is responsible for
trading within, your Account. Strategic Advisers may select investments for your Account that differ from
BlackRock’s model portfolio, but may also implement BlackRock’s model portfolio without change. The
model portfolio provided by BlackRock to Strategic Advisers will not be based on the circumstances of,
or otherwise tailored to, any individual client, and should not be considered as investment advice to any
client of the Service. Investment advisory services provided to a client of the Service are furnished to
the client solely by Strategic Advisers. 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.
Prior to your enrolling in the Service, Strategic Advisers will determine whether the Service is appropriate
for you based on a review of your investor profile and any other relevant information that you provide
to Strategic Advisers. Certain Fidelity Brokerage Services LLC (“FBS”) employees, including the Wealth
Management Advisers supporting Fidelity Private Wealth Management, serve as investment adviser
representatives of Strategic Advisers (“Fidelity representatives”). To facilitate the collection of such
information, your Fidelity representative will ask that you complete an Investor Profile Questionnaire
(“IPQ”), and we will prepare an investment proposal based on the information you provide (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 in your responses to the Goal Profile Questionnaire (“GPQ”)
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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 mean your GPQ. Your acceptance into the Service is based on the completeness and accuracy of
the information you provide to Strategic Advisers in your IPQ, client Account Application, and other
documentation. Therefore, it is important to respond completely and accurately when completing your
IPQ and other documentation.
If you decide to enroll in the Service, due to the Service’s active, ongoing management, the actual
securities purchased for your Account may differ from the Investment Proposal we prepared
based on your information. Although Strategic Advisers may gather information regarding assets
held outside of your Account as part of the IPQ, Strategic Advisers will not offer investment
management services with respect to those assets. Once your completed and signed application
for the Service has been received, a brokerage account will be opened on your behalf at FBS,
Member NYSE, SIPC. Once the account funding process is complete, Strategic Advisers will begin
to manage your Account on a discretionary basis.
FEES AND COMPENSATION
Advisory Fees — General Information
Your Account will be charged an annual advisory fee that is based on a percentage of the market
value of the assets in the Account. The annual advisory fee covers Strategic Advisers’ ongoing
management of your Account, including Strategic Advisers’ selection and oversight of BlackRock,
any costs incurred by Strategic Advisers in connection with its acquisition of the model portfolio,
trading costs associated with the purchases and sales of individual securities effected through
Fidelity-affiliated broker-dealers, custody services provided by Strategic Advisers’ affiliates, the
communications program associated with your Account, and the personal service you receive from
your Fidelity representative.
The annual advisory fee does not cover charges resulting from trades effected with or through
broker-dealers other than Fidelity affiliates. You should be aware that costs associated with the use
of broker-dealers other than Fidelity affiliates within the Service may be significant, and you should
consider this when evaluating the total cost of participating in the Service.
The annual advisory fee also does not include underlying expenses charged by the individual
Portfolio Investments held in your Account, including the core Fidelity money market fund. These
expenses, which vary by Portfolio Investment, are expenses all ETP and mutual fund owners pay.
Details of these expenses can be found in each Portfolio Investment’s respective prospectus.
These expenses are not separately itemized or billed; rather, the published returns of the Portfolio
Investments are shown net of their expenses. Some of these underlying expenses may be paid
to Strategic Advisers or its affiliates and will be included in the “Credit Amount” described in
the pages that follow. Strategic Advisers’ or its affiliates’ receipt of fees with respect to Portfolio
Investments gives rise to a potential conflict of interest, as it provides an incentive to recommend
such investments. Strategic Advisers seeks to address any such conflict through disclosures
and the Credit Amount. For more information about other forms of compensation received by
Fidelity representatives or Strategic Advisers’ affiliates, please see “Client Referrals and Other
Compensation” below.
Fees accrue daily based on the average daily balance in an account as determined at the close of
business on the last business day of the previous calendar quarter. The advisory fee is calculated
daily and applied in arrears, on a quarterly basis, and is due after the end of each calendar quarter.
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Please see the chart below for the annual advisory fee that may be charged to your Account. Please
note that all fees are subject to change.
ANNUAL ADVISORY FEE SCHEDULE FOR BLACKROCK® DIVERSIFIED INCOME PORTFOLIO
Average Daily Assets*
Annual Advisory Fee
For the first $200,000
1.10%
For the next $100,000 or portion thereof
0.90%
For the next $200,000 or portion thereof
0.85%
For the next $500,000 or portion thereof
0.80%
For the next $1 million or portion thereof
0.70%
For the next $1 million or portion thereof
0.60%
For amounts greater than $3 million
0.55%
*Average daily assets of Fidelity’s Portfolio Advisory Services accounts are determined on the last business day of the
quarter. Clients can fill out a form to aggregate 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 get the form to apply for aggregation.
The annual advisory fee applied to your Account will be reduced by a Credit Amount equaling any
underlying investment management and other fees paid to us or our affiliates in connection with
investments in Fidelity ETFs and mutual funds, including the core Fidelity money market fund, or for
any distribution and shareholder servicing fees or other remuneration, if any, paid to us or our affiliates
with respect to non-Fidelity Portfolio Investments. The compensation that affiliates of Strategic
Advisers receive related to investments in Fidelity funds, such as the core Fidelity money market fund,
may exceed the compensation received from investments in non-Fidelity Portfolio Investments. The
purpose of the Credit Amount is to reduce the annual advisory fee by the amount of compensation, if
any, received by Strategic Advisers or its affiliates with respect to the Portfolio Investments held in the
Account. This Credit Amount is calculated daily and applied quarterly in arrears.
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 the performance of the core Fidelity money market fund.
Performance-Based Fees
The Service does not charge performance-based advisory fees to you, and Strategic Advisers does
not pay a performance-based fee to BlackRock for the provision of the model portfolio. BlackRock
may, however, have customers independent of the Service who are charged performance-based
advisory fees. The side-by-side provision of services by BlackRock for customers, some of which pay
BlackRock performance fees and some of which do not, may lead to a conflict of interest in that
BlackRock may have an incentive to favor those customers from which they receive performancebased fees over those customers from which they do not receive such fees. For more information
regarding performance-based fees that may be received by BlackRock, please consult BlackRock’s
ADV, which is available on the SEC’s website at www.adviserinfo.sec.gov.
Portfolio Investments’ Expenses
Underlying expenses still apply to the Portfolio Investments held in your Account. These are the
standard expenses that all ETP and mutual fund owners pay. Details of these underlying expenses
can be found in each Portfolio Investment’s respective prospectus. These expenses are not
separately itemized or billed; rather, the published returns of ETPs and mutual funds are shown net
of their expenses.
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Sales Loads and Transaction Fees
You generally will not pay any sales loads or transaction fees on the mutual funds purchased in your
Account. A special sales load waiver may enable Strategic Advisers’ investment professionals to
purchase mutual funds for your Account without incurring additional sales loads or transaction fees
on mutual fund sales.
Redemption Fees
In order to protect the interests of long-term owners and/or recoup potential brokerage and other
transaction costs, certain ETPs and mutual funds may impose redemption or other administrative
fees if they are not held for a minimum time period. Strategic Advisers or its affiliates, at their sole
discretion, may choose to pay any such redemption or other administrative fees on your behalf,
but are under no obligation to do so. In addition, you are responsible for any short-term trading
fees and other charges that result from the sale of existing investments (if any) to fund your initial
investment in the Service (whether inside or outside the Account) and any subsequent withdrawals
that you initiate.
Miscellaneous Fees
The annual 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 applicable to your Account.
The respective charges will be reflected on your monthly statements and trade confirmations.
Billing
You will be required to pay advisory fees in connection with an investment in the Service. The
net advisory fee will be deducted from your Account or another Fidelity account in arrears on a
quarterly basis. Certain assets in your Account may be liquidated to pay the fees, which could
in turn lead to further liquidations to adjust the holdings in your Account so that it is invested in
accordance with the model portfolio; these liquidations may generate a taxable gain or loss. Should
either party terminate the investment advisory relationship, Strategic Advisers will prorate the fees
due from the beginning of the quarter to the termination date, which is defined as the date when
Strategic Advisers is no longer actively managing the assets in the Account.
Information about Representative 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.
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However, you are required to complete a questionnaire to assist in determining whether the
Service is appropriate for you. 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.
ADDITIONAL INFORMATION ABOUT FEES
Fee Changes
All fees are subject to change. We will notify you in writing of any changes to the advisory fee
schedule to be paid by you. You will have the ability to object to any changes to the fee schedule
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 certain
accounts in a manner substantially similar to a Service account 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 the Portfolio Investments 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 professional management services offered through the Service and may be subject
to sales loads or transaction and redemption charges that are generally waived as part of the
Service. Participation in the 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. Furthermore, certain Portfolio Investments available through the Service may not be
available for purchase, nor may they be held outside of the Service.
ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
The Service is generally available to individuals, joint account holders, certain retirement plans, IRAs,
trusts and estates.
The minimum initial investment is generally $200,000 per account. In certain limited circumstances,
Strategic Advisers may exempt accounts from the minimum initial investment requirement. Additional
accounts opened by you or other members of your household must meet a $100,000 minimum per
account registration. Note that certain of Fidelity’s Portfolio Advisory Services account balances may
be aggregated with certain other Fidelity’s 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.
Minimums for initial investments may be lowered at the sole discretion of Strategic Advisers,
including those in connection with promotional efforts. 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), have a valid U.S. permanent mailing address,
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and have a valid U.S. taxpayer identification number. We reserve the right to terminate your Account
(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. Strategic Advisers reserves the right to close your
Account if its balance falls below a certain level. Strategic Advisers reserves the right to terminate
its services if it believes the Service is no longer appropriate for you. Strategic Advisers reserves the
right to terminate your Account if your IPQ is incomplete and we have been unable to reach you
for more than three years (two years if you are a Non-prototype Retirement Account (also referred
to as an Investment-Only Retirement Account defined benefit client). Strategic Advisers reserves the
right to terminate, modify, or make exceptions to these policies. If your participation in the Service
terminates, Strategic Advisers reserves the right to redeem any and all Fidelity funds and any other
third-party funds held in your Account that are not eligible to be held outside a managed account
offered by Strategic Advisers, and this redemption may generate a taxable gain or loss.
OPENING AND FUNDING THE ACCOUNT
Once your application and funding have been accepted, an account will be opened at FBS on your
behalf and Strategic Advisers will invest the brokerage account in the Portfolio Investments that make
up the model portfolio, generally within five business days of deposit. You may fund an Account with
cash or by transferring interests in eligible ETPs or mutual funds to your Account. You can generally
fund your Account with ETFs covered by Strategic Advisers’ research team and most mutual funds.
For additional information about which ETPs and mutual funds may be eligible to be accepted
in kind into your Account, please contact a Fidelity representative. 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 receive prior to enrolling.
When funding an account, your interests in any ETPs or mutual funds that are not part of the model
portfolio, or that are part of the model portfolio but do not align with allocations therein, will be
sold in whole or in part, and you acknowledge the transfer of any such interests into your Account
acts as a direction to Strategic Advisers to redeem or sell any such ETPs or mutual funds. You may
be charged a redemption fee, as specified in the prospectus for each ETP or mutual fund, or any
other fees as applicable to the redemption or to the brokerage account from which interests in
such ETPs or mutual funds are being liquidated or transferred. Under certain circumstances, the
Service may voluntarily assume the costs of certain commissions. You may realize a taxable gain
or loss when these interests are sold, and Strategic Advisers does not consider the potential tax
consequences of these sales or current market conditions when following your deemed direction
to sell such securities. In addition, when Strategic Advisers purchases Portfolio Investments on your
behalf, you may receive taxable distributions out of earnings that have accrued with respect to a
Portfolio Investment prior to your purchase (a situation referred to as buying a dividend). Please
consult a tax adviser regarding these matters. Strategic Advisers reserves the right not to accept
otherwise eligible securities, at its sole discretion.
At times, Strategic Advisers may not accept certain ETPs or mutual funds that are used to fund your
Account. These assets 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 or federal), they are no longer eligible.
If you fund an account exclusively with cash, Strategic Advisers’ general policy is to invest that
cash in your core Fidelity money market fund as soon as reasonably practicable, then further invest
portions of these assets in the Portfolio Investments that make up the model portfolio, generally
within five business days of full or substantial funding. If both cash and securities are used, the cash
will be held in your core Fidelity money market fund until the eligible asset transfer is complete.
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ADDITIONAL DEPOSITS
Additional deposits can be made at any time, but please note that Strategic Advisers’ general
policy is to invest cash in your core Fidelity money market fund as soon as reasonably practicable,
then may further invest portions of these assets in the Portfolio Investments that make up the
model portfolio when certain criteria are met, which are determined by Strategic Advisers in its
sole discretion, but generally within five business days of deposit. If there are specific handling
instructions, please contact a Fidelity representative before making the deposit; otherwise, Strategic
Advisers may fully invest the deposit as soon as the next business day following the date of deposit.
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, or
through written instructions by you (on the necessary forms if appropriate) and sent to either a
Fidelity mailing address or delivered to a local Investor Center, or through Fidelity’s Portfolio Advisory
Services’ client website (certain limitations may apply to web transactions and are detailed on the
site). Requests for withdrawals must be received in good order before 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 may be processed on the next business day. If the NYSE closes before 4 p.m. ET, the cutoff time
for withdrawal requests will generally be adjusted earlier in the day to allow sufficient time to process
the transactions; however, it may take an additional day to process the withdrawal. ETP trades
typically settle three business days after a trade is placed, but can take substantially longer, which
could impact the amount of time it takes to complete a withdrawal request. 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.
For withdrawals and account closures, you may request that:
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UÊMoney 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. 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 held in your Account may have policies that restrict excessive trading. In order
to comply, a fund may reject trade orders if the orders are deemed to represent excessive trading.
As a result, in order to comply with a fund’s trading polices, 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 (1) business day to implement, and any trading activity that has been commenced or is in
process within Strategic Advisers’ trading system shall be completed prior to ceasing management
of the Account.
As a feature on your Account, certain clients may elect to have all dividends, interest, and capital
gains on eligible holdings set aside for automatic distribution by completing and submitting to FBS
an Earnings Automatic Withdrawal Plan form. This feature is generally only available to nonretirement
accounts. 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.
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ACCOUNT CLOSURE
At any time, you may request to 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 described below, all trading and
monetary transactions associated with your Account closure must be processed by calling a 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”) on the same business day for requests that are received in good order
before 12 p.m. ET on a business day. Such requests received after 12 p.m. ET may be processed
on the next business day. However, depending on the nature and timing of the request, certain
full closeouts may take longer to fully process. If the NYSE closes before 4 p.m. ET, the cutoff time
for full closeouts will generally be adjusted earlier in the day to allow sufficient time to process the
transactions; however, it may take an additional day to complete an account closure request. ETP
trades typically settle three business days after a trade is placed but can take substantially longer,
which could impact the amount of time it takes to complete an account closure request. 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 will take an additional day or days to close your Account.
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 for investment
by you as a retail investor. If you cease to be a client of the Service, Strategic Advisers reserves the
right to redeem any and all shares of such funds and you may incur a gain or loss as a result. If such
funds 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 you from the Service for withdrawing cash from your Account
that brings your Account balance below the minimum, for failure to maintain a valid email 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. Depending on the reason for the
termination, you may have the opportunity to resolve the issue but if you are unable to do so, your
Account will be closed and assets either liquidated or transferred based on your instructions.
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 is the investment adviser for the Service and is responsible for managing your
Account on a discretionary basis. Strategic Advisers has selected BlackRock as the model provider
for the Service, subject to Strategic Advisers’ oversight and monitoring. Strategic Advisers has
implemented certain oversight processes and controls designed to achieve an appropriate level
of supervision of BlackRock’s activities as model provider to Strategic Advisers. Strategic Advisers
is responsible for portfolio management, trading, and supervision of accounts and the Service.
BlackRock is not acting as an investment adviser or portfolio manager with respect to your Account.
11
GENERAL INVESTMENT STRATEGIES APPLICABLE TO THE OVERALL MANAGEMENT
OF YOUR ACCOUNTS
Strategic Advisers will manage your Account on a discretionary basis by investing in Portfolio
Investments based on a model portfolio provided by BlackRock. In selecting Portfolio Investments
for inclusion in the model portfolio provided to Strategic Advisers, BlackRock will give preference
to Portfolio Investments advised by it (or one of its affiliates), including iShares® ETFs, but may also
include Portfolio Investments advised by third parties, including Strategic Advisers or its affiliates. The
Portfolio Investments included in the model portfolio provided by BlackRock will vary in their exposure
to different asset classes (such as domestic stocks, foreign stocks, fixed-income securities, shortterm assets, real assets and alternative investments), as well as different styles (investing for capital
appreciation or income). Strategic Advisers has designed investment guidelines for the Portfolio
Investments held in Service accounts. These guidelines may change from time to time at Strategic
Advisers’ discretion based on consultation with BlackRock, market conditions or other considerations.
For more information about the underlying Portfolio Investments held in your Account, you should
review the applicable prospectuses. Strategic Advisers may select investments that differ from
BlackRock’s model portfolio, but may also implement BlackRock’s model portfolio without change,
subject to any reasonable investment restrictions you may impose.
The BlackRock® Diversified Income Portfolio seeks to generate risk-adjusted yield while retaining
the potential for capital appreciation by investing the Account in Portfolio Investments that invest
in (or track) four major asset classes: domestic stocks, foreign stocks, bonds and short-term assets.
Under normal market conditions, Strategic Advisers will generally invest accounts in accordance
with BlackRock’s tactical allocation, which seeks to position the model portfolio for risk-adjusted
yield by actively adjusting the asset class weightings in response to prevailing market conditions. In
general, the model portfolio will maintain a risk profile generally consistent with that of a traditional
balanced portfolio that holds 50% equity investments and 50% fixed-income investments (including
short-term assets). However, in constructing the model portfolio, BlackRock has wide flexibility in
the relative weightings given to each asset class and generally may allocate between 20% and 60%
to equity investments and correspondingly between 80% and 40% to fixed-income investments.
The model portfolio seeks to balance yield and risk by controlling volatility over a rolling threeyear period in line with a balanced portfolio (as measured by the annualized standard deviation of
monthly returns).
An account in the Service is not intended to provide a complete investment program. You are
responsible for appropriate diversification of assets outside your Account to help guard against
the risk of loss. Cash flows from dividend distributions or interest payments will be paid to the core
Fidelity money market fund and will be reinvested in the portfolio, unless you elect otherwise. Cash
balances will be held in the core Fidelity money market fund until Strategic Advisers reinvests them
in Portfolio Investments, which may not occur until your balance in the core Fidelity money market
fund exceeds the amount defined by the model portfolio.
ADDITIONAL INFORMATION ABOUT STRATEGIC ADVISERS’ INVESTMENT
PRACTICES AND MODEL PROVIDER SELECTION PROCESS
Prior to selecting BlackRock for the Service, Strategic Advisers performed a review of BlackRock
and its investment style and approach. Strategic Advisers’ review included, among other things,
assessing information about BlackRock and its investment strategies collected from third-party
sources and information received directly from BlackRock. In selecting BlackRock, Strategic Advisers
considered a variety of factors, including but not limited to, investment approach, portfolio
characteristics, and BlackRock’s total assets. Strategic Advisers evaluated information from both
quantitative and qualitative analyses, including but not limited to:
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12
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Strategic Advisers will evaluate BlackRock’s adherence to the investment guidelines no less than
semi-annually based on the factors described above. Strategic Advisers, in its sole discretion, may
replace BlackRock as the Service’s model provider without notice to you if, for example, Strategic
Advisers determines that BlackRock is not adhering to the Service’s investment guidelines.
In constructing the model portfolio, BlackRock will give preference to Portfolio Investments advised
by it (or one of its affiliates), including iShares® ETFs, but may also include Portfolio Investments
advised, distributed and/or issued by third parties, including Strategic Advisers or its affiliates. In
general, the model will be allocated to Portfolio Investments that invest in (or that are linked to the
performance of) four primary 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)
The Service may also invest in Portfolio Investments that invest in (or that are linked to the
performance of) nontraditional asset classes and/or extended asset classes, including, but not
limited to, real estate, commodities or other alternative investments. At times, investments in these
asset classes may make up a substantial portion of your Account. As a result, your exposure to the
primary asset classes may be reduced to gain exposure to these nontraditional and/or extended
asset classes. The allocation of your Account may change over time.
Portfolio Investments 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.
In overseeing the model portfolio, Strategic Advisers may obtain information from various sources.
Strategic Advisers may 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 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 uses this information
in designing the investment guidelines applicable to the model portfolio, and may analyze this
information to assist in its oversight of the model portfolio.
When investing in Fidelity and non-Fidelity mutual 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.
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Additionally, Strategic Advisers may establish internal limits on how much it may invest in any one
Portfolio Investment across the programs it manages. Strategic Advisers will work closely with fund
management to minimize the impact of reallocation activity on acquired funds. In certain situations,
liquidating positions in underlying Portfolio Investments may be accomplished over an extended
period of time as a result of operational considerations, legal considerations, or input from
underlying fund managers.
In managing your Account, Strategic Advisers may decide to adjust positions in Portfolio Investments
for a number of reasons, including:
1. The weighting of a particular security is too high or too low relative to the weighting in the
model portfolio;
2. The deposit or withdrawal of cash or securities into your Account;
3. The composition of the model portfolio has changed.
In general, Strategic Advisers does not attempt to conduct intra-day account evaluations, and
Strategic Advisers does not generally attempt to time intra-day price fluctuations in its decisions to
buy or sell securities. Strategic Advisers does not anticipate that each account will be traded each day.
When Strategic Advisers trades in your Account, you will receive notification that a change has
been made via a transaction confirmation. You will also receive a prospectus for any new Portfolio
Investment not previously held, as applicable, unless you have elected to have Strategic Advisers
act as agent for the receipt of any non-Fidelity prospectuses.
From time to time, Strategic Advisers may be restricted from purchasing or selling securities
on behalf of Strategic Advisers’ clients because of regulatory and legal requirements, as well as
contractual restrictions, applicable to Strategic Advisers and/or its internal policies designed to
comply with, limit the applicability of, or otherwise relate to such requirements.
MATERIAL INVESTMENT RISKS
All investment strategies, including the investment strategy for the Service, pose risks, and many
factors affect each Portfolio Investment’s or 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.
Nondiversified Portfolio Investments and accounts that have exposure to a smaller number of
individual issuers can be more sensitive to these changes. Nearly all Portfolio 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 Portfolio 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 most developed markets.
Additionally, Portfolio Investments or accounts that pursue debt exposure are subject to risks of
prepayment or default, and Portfolio Investments 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 Portfolio Investments or accounts to invest in other Portfolio Investments bear
all the risks inherent in the underlying investments in which they invest, and strategies that pursue
leveraged risk, including investment in derivatives — such as swaps (interest rate, total return, and
14
credit default) and futures contracts — and forward-settling securities, magnify market exposure and
losses. Additionally, Portfolio Investments and accounts may be subject to operational risks, which
can include risk 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, including the investment strategy of the Service, involve risk
of loss. 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 and ETPs. You may lose money by investing in the Service.
Allocation Risk. The Service’s ability to achieve its investment objective depends in part on the
strategic asset class allocation utilized for accounts and the mix of Portfolio Investments selected.
There is a risk that the evaluations and assumptions regarding asset classes or Portfolio Investments
may be incorrect in view of actual market conditions. Asset allocation does not ensure a profit or
guarantee against loss.
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, ETNs, 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. 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. Passively managed ETFs disclose their
portfolio securities each trading day, and because of this transparency the trading prices of passively
managed ETFs tend to closely track the actual NAV of the underlying portfolios. Actively managed
ETFs generally do not have the transparency of passively managed ETFs, and therefore may be
more likely to trade at a discount or premium to actual NAV.
ETNs. An ETN is an unsecured debt security that trades on an exchange and may seek to track an
index, commodity, or a basket of assets. ETNs are issued by a financial institution, and the value of
the ETN can be affected not only by the performance of the index, commodity or basket of assets
the ETN tracks, but also by the creditworthiness of the issuer of the ETN, which at maturity pays the
principal amount of the note as well as any increase in value of the note. Prior to maturity, ETNs may
trade at a premium or discount to their intrinsic economic value. They may also have unique risks
depending on their structure and the index, commodity or basket of assets the ETN tracks.
Money Market Fund Risk. An investment in a money market fund is not insured or guaranteed by
the Federal Deposit Insurance Corporation or any other government agency. Although the fund
seeks to preserve the value of your investment at $1.00 per share, it is possible to lose money by
investing in the fund.
Investing for Volatility Management. Volatility is a statistical measurement of the magnitude of
up and down fluctuations in the value of a financial instrument or index over time. High volatility
may result from rapid and dramatic price swings. When volatility is expected to exceed normal
ranges, the portfolio may increase exposure to short-term assets and away from riskier assets
15
such as equity and high-yield fixed-income securities. When volatility is expected to decrease,
the portfolio may reduce exposure to cash or short-term assets and increase exposure to riskier
assets. There can be no guarantee that the portfolio will be successful in managing the overall level
of volatility. The Service may not realize the anticipated benefits from its volatility management
process or it 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. BlackRock may, as
part of its volatility control process, allocate assets into cash or short-term fixed-income securities.
In doing so, the Service may succeed in avoiding losses but may otherwise fail to achieve its
investment objective. Further, the value of short-term fixed-income securities may be affected by
changing interest rates and by changes in credit ratings of the investments. The use of the volatility
management process may result in high turnover of Portfolio Investments, which can result in
potentially higher capital gains or losses for clients.
Taxable Gains on Account Activity. The Service is not designed to take taxes into account when
managing your Account. 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 advisor.
Investing in Portfolio Investments. Your Account bears all the risks of the investment strategies
employed by the Portfolio Investments held in your Account, including the risk that a Portfolio
Investment will not meet its investment objective. For the specific risks associated with a Portfolio
Investment, please see its prospectus. In selecting the Portfolio Investments for inclusion in the
model, BlackRock will give preference to Portfolio Investments advised by it (or one of its affiliates),
including iShares® ETFs. BlackRock may be subject to potential conflicts of interest in selecting
Portfolio Investments because the fees paid to BlackRock by some Portfolio Investments are higher
than the fees paid by other Portfolio Investments. Certain clients may also be restricted by rules
issued by regulators or self-regulatory organizations, such as short sale limits and trading halts.
In addition, the Portfolio Investments in your Account may be subject to the following risks:
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.
Issuer-Specific Changes. The value of an individual security or particular type of security can be
more volatile than, and can perform differently from, the market as a whole. Lower-quality debt
securities (those of less than investment-grade quality, also referred to as high-yield 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. The value of lower-quality debt securities and certain types
of other securities can be more volatile due to increased sensitivity to adverse issuer, political,
regulatory, market, or economic developments.
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 investments 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.
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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.
Derivatives. Certain Portfolio Investments 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 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 Portfolio Investments to be more volatile, because leverage
tends to exaggerate the effect of any increase or decrease in the value of a Portfolio Investment’s
underlying securities.
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.
17
Real Estate. Real estate is a cyclical industry that is sensitive to interest rates, economic conditions
(both nationally and locally), property tax rates, and other factors. Changes in real estate values or
economic downturns can have a significant negative effect on issuers in the real estate industry.
Alternative Investments. Alternatives are classified as assets whose investment characteristics and/
or performance differ substantially from the major asset classes and therefore offer opportunities
for additional diversification. The Service does not invest in private equity or hedge funds directly;
however, the Service’s underlying Portfolio Investments may invest significantly in these instruments,
and therefore you may have indirect exposure to these types of investments. Alternatives generally
may be illiquid.
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.
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.
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 THE ACCOUNT
You are entitled to impose reasonable investment 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 strategy, or is not fundamentally inconsistent with the nature or operation of the Service.
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. Account restrictions
should be requested through your Fidelity representative.
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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. 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 your loss is less than ten dollars; 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. 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 system
failures, or from external events, such as exchange outages.
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. 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.
The 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 National Financial Services LLC (“NFS”) for your
Account, including investment management (including the costs incurred by Strategic Advisers in
purchasing the model portfolio from BlackRock), brokerage, custody, and other services. Strategic
Advisers retains a portion of the fee for their services as sponsor and investment adviser of the
program, and shares revenue with its affiliates, including FBS and NFS, for the services they provide
to your Account. You are not charged performance-based advisory fees in connection with the
Service. For more information on the fees associated with your Account, and the fees and charges
covered by the advisory fee, please see the section on “Fees and Compensation.”
Strategic Advisers’ investment management services generally include discretionary authority to
determine which securities to purchase or sell, the total amount of such purchases and sales, and
the brokers or dealers through which transactions are effected. Strategic Advisers does not generally
attempt to time intra-day price fluctuations in its decisions to buy or sell securities. As part of your
19
Account application, you will be required to execute a power of attorney that grants Strategic
Advisers discretionary trading authority over your Account, which may include the ability to hire/
fire a third-party money manager. However, Strategic Advisers’ discretionary authority is subject to
certain limits, including the terms of your Agreement, applicable investment guidelines and policies,
any reasonable restrictions imposed by you and accepted by Strategic Advisers, and Strategic
Advisers’ obligation to comply with federal securities law.
PROXY VOTING POLICY AND PROCEDURES
Strategic Advisers does not acquire authority for or exercise proxy voting on your behalf in
connection with your Account. Unless you direct us otherwise pursuant to the paragraph below,
you will receive proxy materials directly from the issuers of the Portfolio Investments held in your
Account, their service providers, or NFS. Strategic Advisers will not advise you on the voting of
proxies. You must exercise any proxy voting directly.
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 semi-annual
reports, and proxy materials, for Portfolio Investments that are not managed by Strategic Advisers or
an affiliate thereof. You may also direct Strategic Advisers to act as your agent to vote proxies on your
behalf for the Portfolio Investments held in your Account. For Fidelity ETFs and mutual funds, you 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 ETPs and mutual funds, 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.
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. You may find more
information about ISS’s proxy voting policies in the ISS’s proxy voting guidelines summary included in
the application materials, or by contacting your Fidelity representative.
You 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 their investment proxies were voted.
ASSETS UNDER MANAGEMENT
Strategic Advisers’ total assets under management as of December 31, 2014, were $418,214,900,000
on a discretionary basis, and $9,414,200,000 on a nondiscretionary basis. Assets under management
in the BlackRock® Diversified Income Portfolio on a discretionary basis as of December 31, 2014,
were $3,210,800,000 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
MANAGERS
Strategic Advisers’ investment management team has access to your relevant Account information,
including 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 financial situation, time horizon, and risk tolerance. If you have any changes
to your personal or financial situation, you should contact your Fidelity representative to ensure that
the Service continues to be appropriate for you. BlackRock is not acting as an investment adviser
or portfolio manager with respect to your Account, and Strategic Advisers will not provide any of
your information to BlackRock in connection with BlackRock’s provision of an investment model to
Strategic Advisers.
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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
In general, you will not be granted access to Strategic Advisers’ investment management team
with respect to your specific questions or requests. You should contact your Fidelity representative
regarding questions associated with your Account, or to provide an update about your Account,
a personal situation that may impact how we manage your Account, or to update your IPQ or
any other information associated with your Account. Your designated representative will act as a
liaison between you and Strategic Advisers’ investment management team, and he or she will be
responsible for communicating your information and questions to 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 management team will also provide you with information
about the management of your Account from time to time, but, absent special circumstances,
Strategic Advisers’ investment management team is focused on managing your account and generally
members of the team do not meet with you or answer your questions directly. BlackRock is not
acting as an investment adviser or portfolio manager with respect to your Account, and clients of the
Service will not be granted access to BlackRock portfolio management staff with respect to specific
questions or requests.
A D D I T I O N A L I N F O R M AT I O N
REVIEW OF ACCOUNTS
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 portfolio
preferences used to manage an Account. Strategic Advisers will rely on this information in making
an initial Investment Proposal and managing your Account.
ANNUAL STRATEGIC REVIEW
The Annual Strategic Review is an important part of the management process that helps ensure
that the Service remains appropriate for you. As a result, at least once a year, Fidelity’s Portfolio
Advisory Services will request information regarding any changes to your IPQ and whether or not
you wish to impose any reasonable restrictions or reasonable modifications of existing restrictions on
the management of your Account, in an effort to ensure that your investment through the Service
remains appropriate. If we fail to hear from you during the Annual Strategic Review process, Strategic
Advisers will determine if the product 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 updated 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 determine you
are no longer suitable for the product and terminate your Account upon notice.
In addition, Strategic Advisers may from time to time modify the information solicited by the IPQ, as well
as the eligibility criteria for the Service. Such modifications may require that you provide new information
to Strategic Advisers. If you do not contact your Fidelity representative with updates to the information
provided in your IPQ, Strategic Advisers will update your age and your goal horizon, as well as consider
the balances of any accounts that were part of your IPQ at your last review, but will otherwise assume that
your IPQ responses have not changed. Strategic Advisers reserves the right to terminate your Account if
your IPQ is incomplete and/or we have been unable to reach you for more than three years. If you are a
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Non-prototype Retirement Account (also referred to as an Investment-Only Retirement Account defined
benefit client) and we have been unable to reach you for more than two years, Strategic Advisers reserves
the right to terminate your Account. If you have a relationship with Fidelity’s Portfolio Advisory Services
through the Fidelity Wealth Management AdvisorySM program, updates to your GPQ will be made at
least annually as part of that service. If there are any changes in your personal circumstances or longterm goals at any time, or we are unable to assess suitability of the product, we may determine that the
Service is no longer appropriate. 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. Strategic Advisers does not monitor activity in your Account to update information in
your IPQ. Any changes in your IPQ must be initiated by you; however, when your IPQ contains out-ofdate 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.
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. Certain investments may generate year-end tax reporting
other than IRS Form 1099. For example, certain investments may generate a Schedule K-1 or a
trust interest holder information statement. These forms of year-end tax reporting typically are more
complex and delivered later in the year than IRS Form 1099. You should consult your tax adviser to
understand the potential tax consequences of investment activity in your Account.
ACCOUNT NOTIFICATIONS
At least quarterly, you will receive a written reminder to notify Strategic Advisers 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 an ongoing liaison
between you and Strategic Advisers’ investment management team, are available to discuss changes
in your Account, and are responsible for conducting reviews at least annually.
You will receive prompt confirmations from NFS of any transactions in your Account. In addition,
you 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 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. 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
upper case and lower case letters as well as special characters and avoid using passwords based on
your date of birth, nickname, or Social Security number.
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CODE OF ETHICS, PARTICIPATION OR INTEREST IN YOUR TRANSACTIONS,
AND PERSONAL TRADING
Strategic Advisers has adopted a Code of Ethics for Personal Trading (the “Code of Ethics”). The
Code of Ethics applies to all officers, directors, 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 Fidelity Brokerage
Services LLC, 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
acknowledgements 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. 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.
From time to time, in connection with their respective businesses, Strategic Advisers and/or
BlackRock may obtain material nonpublic information that is usually not available to other investors
or the general public. In compliance with applicable laws, Strategic Advisers and BlackRock have
each adopted a comprehensive set of policies and procedures that prohibit the use of material
nonpublic information by investment professionals or any other employees, which may in turn limit
the model portfolio recommendations that BlackRock can make to Strategic Advisers, and/or 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, 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, Strategic
Advisers has adopted a Political Contributions and Activity policy that requires all employees to
preclear any political contributions and activity.
Strategic Advisers, its advisory affiliates, or a related person may buy or sell for itself securities that
it also proposes to you. 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.
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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 generally receives a percentage annually of the average daily net assets of
non-Fidelity funds in your Account; however, any such amounts received by FBS or NFS will be
offset against your annual advisory fee by a corresponding Credit Amount equal to the amount
of revenue received. Strategic Advisers and its affiliates will not receive servicing and distribution
fees with respect to funds advised by BlackRock (or its affiliates) that are held in an Account. Each
Fidelity fund pays investment management fees and other fees to Fidelity Management & Research
Company (“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. There is no predetermined allocation
of Fidelity or non-Fidelity funds (except that money market funds will always be Fidelity funds); you
authorize Strategic Advisers to exclude either category. The compensation received by Strategic
Advisers and its affiliates from investments in Fidelity funds will generally exceed, prior to the
application of the Credit Amount (described above), the compensation from investments in nonFidelity funds. See the section entitled “Fees and Compensation” for additional information.
Strategic Advisers seeks to address this potential conflict through the application of the Credit
Amount noted above, and through the application of investment selection criteria and personnel
compensation arrangements that do not differentiate between Fidelity and non-Fidelity Portfolio
Investments. Strategic Advisers’ investment professionals are compensated partially based on
account performance, and are not compensated based on the amount of Fidelity or non-Fidelity
Portfolio Investments used in the Service.
BROKERAGE PRACTICES
Strategic Advisers has discretionary authority to purchase and sell various eligible Portfolio
Investments, as applicable. For the Service, all commissions are waived for individual security
transactions executed through affiliates of Strategic Advisers (see “Fees and Compensation”).
However, the advisory fee charged for the Service does not cover charges resulting from trades
effected with or through broker-dealers other than affiliates of Strategic Advisers or 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 such non-Fidelity-related charge applies
to sales of securities made for all accounts — an industry-wide charge mandated by the SEC
and totaling a few cents per transaction. The respective charges will be reflected on transaction
confirmations and your monthly statement.
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 individual securities 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
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of the execution, Strategic Advisers 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 NFS 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
NFS 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 NFS 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 NFS receives any such consideration in connection with directing the execution of
equity trades for your Account to certain 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 your 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 clients’ 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 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 your 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, 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 their 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.
In connection with trading of individual securities, 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 your Account. With
respect to trade allocation, Strategic Advisers’ policy is to treat each of your Accounts in a fair and
equitable manner when allocating orders for the purchase and sale of securities, including mutual
fund shares. Strategic Advisers has adopted a trade allocation policy designed to achieve fairness
and not to purposefully disadvantage comparable 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.
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Strategic Advisers does not have a soft dollar program.
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 FMRCo and subsidiaries as the
investment adviser for the Fidelity funds; Fidelity Distributors Corporation 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 mutual 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.
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.”
The group of funds eligible for consideration as Portfolio Investments 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, Member NYSE, SIPC. Except with respect to funds
advised by BlackRock (or an affiliate) that are held in an Account, funds participating in Fidelity’s
mutual 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 investment, 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
your investment in Fidelity-managed investments may exceed the compensation received from your
investments in non-Fidelity investment options; however, the Credit Amount calculation is designed
to eliminate this differential. The mutual fund 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 the funds’ shareholders.
Fidelity receives compensation from BlackRock Fund Advisors, an affiliate of BlackRock, in connection
with an exclusive, long-term marketing program that includes promotion of ETFs advised by BlackRock
(or an affiliate) and inclusion of the funds in certain FBS platforms and investment programs. Additional
information about the sources, amounts, and terms of compensation is provided in the ETF’s prospectus
and related documents. Fidelity does not receive additional compensation as a result of an account
holding ETFs advised by BlackRock or an affiliate.
Client referrals are provided by affiliated entities, including FBS to Strategic Advisers, or other
affiliates, pursuant to referring agreements where applicable. Payments may be made to affiliates
for services that facilitate delivery of Strategic Advisers’ services. Additionally, Strategic Advisers
26
may refer clients to other independent investment advisers in connection with a referral program in
which such independent investment advisors participate for a fee. Additional details are available
upon request.
Strategic Advisers receives referrals through its affiliate FBS, pursuant to a referring agreement, for
which compensation is provided to FBS. As noted above in “Fees and Compensation,” some Fidelity
representatives receive economic incentives in addition to their normal compensation for distributing
and supporting BlackRock® Diversified Income Portfolio Accounts.
CUSTODY
In order to participate in the Service, you must authorize Strategic Advisers to establish a brokerage
account on your behalf with FBS, a registered broker-dealer and an affiliate of Strategic Advisers.
NFS, an affiliate of Strategic Advisers and a member of NYSE and SIPC, has custody of your assets
and will perform certain account services, including the implementation of discretionary management
instructions, as well as custodial and related services. Strategic Advisers, FBS, and NFS personnel
may share premises and may have common supervision. You should carefully review all 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 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 has no material disclosable legal or disciplinary events associated with its
management personnel for 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
Pyramis Distributors Corporation LLC, a Strategic Advisers affiliate and registered broker-dealer; however,
such management persons are not involved in the management, operations, or day-to-day oversight of
the programs outlined in this brochure.
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,
529 plans, investment companies, and charitable and other business organizations
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 Strategic Advisers’ affiliates
3. Providing educational materials concerning investment and personal finance
Strategic Advisers’ affiliates provide investment advisory and other services to the Fidelity funds.
When Strategic Advisers invests your assets in Fidelity 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.
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While Strategic Advisers receives no economic benefit from its affiliated or unaffiliated entities in
connection with its 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:
UÊFidelity Management & Research Company (“FMRCo”) as the investment adviser for the
Fidelity funds,
UÊFidelity 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, your 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 Strategic Advisers’ affiliates and in relation to the accounts
over which Strategic Advisers does not have discretionary authority.
From time to time, Strategic Advisers or you may have a material business relationship with the
following affiliated companies:
Investment Companies and Investment Advisers
UÊFidelity 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 adviser or a sub-adviser to registered investment companies. FMRCo
may also provide portfolio management services as an adviser or sub-adviser to you or 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.
UÊFMR 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 subadviser 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.
UÊFidelity 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.
UÊFidelity 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.
Broker-Dealers
UÊFidelity Distributors Corporation (“FDC”), a wholly owned subsidiary of 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 Exchange Act.
UÊNational 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., 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
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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 customers. 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.
UÊFidelity 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, 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.
UÊFidelity Global Brokerage Group, Inc., a wholly owned subsidiary of FMR LLC, wholly owns three
broker-dealers, FBS, NFS, and Fidelity Clearing Canada ULC, 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.
U Pyramis Distributors Corporation LLC (“PDC”), a wholly owned subsidiary of Pyramis Global
Advisors Holding Corp., acts as a placement agent for privately offered investment funds advised
by Pyramis Global Advisors, LLC; Pyramis Global Advisors Trust Company; and their affiliates in
the United States. PDC is a registered broker-dealer under the Exchange Act. Certain employees
of Strategic Advisers may act as registered representatives of PDC.
U 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 intends to charge 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 will serve as the clearing agent for transactions executed in the
LTA ATS.
29
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.
Banking Institutions
Fidelity Management Trust Company (“FMTC”), a trust company organized and operating under
the laws of the Commonwealth of Massachusetts, provides discretionary investment management
and other fiduciary services to IRAs, employee benefit plans, and institutional clients that may
be invested in mutual funds, or to other clients for which FMRCo or its affiliates are the subadviser. 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.
Fidelity Personal Trust Company, FSB (“FPTC”), is a federal savings bank limited to trust powers.
FPTC is an indirect, wholly owned subsidiary of FMR LLC. FPTC provides Trustee or Co-Trustee,
custody, and investment management services to various trust accounts.
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 you 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 customers upon request.
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 annual advisory fee by the amount of revenue received by Strategic Advisers
and its affiliates from such underlying funds. For additional information regarding the Credit
Amount, please see the “Fees and Compensation” section.
30
FOR MORE INFORMATION, PLEASE CALL US TOLL FREE AT
1-800-544-3455
M onda y t hroug h F r i d a y, 8 a . m . t o 7 p . m . Ea s t e r n t i m e
Keep in mind that investing involves risk. The value of your investment will fluctuate over time and you may
gain or lose money.
Strategic Advisers, Inc. and BlackRock Investment Management, LLC are independent entities and are not legally affiliated. Strategic
Advisers, Inc. is the investment manager for client accounts and implements trades for the accounts based on the model portfolio of
investments it receives from BlackRock Investment Management, LLC. Strategic Advisers, Inc. may select investments for an account
that differ from BlackRock Investment Management, LLC’s model.
BlackRock® Diversified Income Portfolio is a service offered through Strategic Advisers, Inc. 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, Inc., 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. Custody and other services are provided by National Financial
Services LLC. Both are Fidelity Investments companies and members of NYSE and SIPC.
For iShares ETFs, Fidelity receives compensation from the ETF sponsor and/or its affiliates in connection with an exclusive, long-term
marketing program that includes promotion of iShares ETFs and inclusion of iShares funds in certain FBS platforms and investment
programs. Additional information about the sources, amounts, and terms of compensation is described in the ETF’s prospectus and
related documents. Fidelity may add or waive commissions on ETFs without prior notice. BlackRock and iShares are registered trademarks of BlackRock, Inc. and its affiliates.
Fidelity Wealth Management Advisory is a service mark, and Fidelity Portfolio Advisory Service, Fidelity, Private Wealth Management,
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
© 2015 FMR LLC. All rights reserved.
662190.4.0
ETF-FUNDMNTL-0315
1.9585352.102
Supplemental Brochures:
Your BlackRock® Diversified Income Portfolio Account
Key Fidelity personnel involved with your account include:
UʈV…>iÊœÕV…iÀÊ
UÊ*iÌiÀÊÀˆ>˜Ê˜Þi>ÀÌ
UÊ,œLiÀÌÊ°Ê>V`œ˜>`
Michael Boucher
Supplemental Brochure:
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3
ˆV…>iÊœÕV…iÀ
EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
ˆV…>iÊœÕV…iÀʈÃÊ>Ê-i˜ˆœÀÊ+Õ>˜ÌˆÌ>̈Ûiʘ>ÞÃÌÊvœÀÊ-ÌÀ>Ìi}ˆVÊ`ۈÃiÀÃ]ʘV°Ê­º-ÌÀ>Ìi}ˆVÊ`ۈÃiÀû®°Ê˜Ê
̅ˆÃÊÀœiʅiʈÃÊÀi뜘ÈLiÊvœÀÊ`iÌiÀ“ˆ˜ˆ˜}Ê̅iʈ˜ÛiÃ̓i˜ÌÊ՘ˆÛiÀÃiÊ܅ˆV…Ê̅iʓœ`iÊ«ÀœÛˆ`iÀÊÕÃiÃÊ̜Ê
Vœ˜ÃÌÀÕVÌÊ̅iʏ>VŽ,œVŽ®ÊˆÛiÀÈvˆi`ʘVœ“iÊ*œÀÌvœˆœ°Ê*ÀˆœÀÊ̜ʍœˆ˜ˆ˜}Ê-ÌÀ>Ìi}ˆVÊ`ۈÃiÀÃʈ˜ÊÓä£Ó]Ê
À°ÊœÕV…iÀʅi`ÊÛ>ÀˆœÕÃÊÀœiÃʈ˜Êˆ`iˆÌÞÊ>˜>}i“i˜ÌÊEÊ,iÃi>ÀV…Ê
œ“«>˜ÞÊ­º,»®]ʈ˜VÕ`ˆ˜}Ê̅>ÌÊ
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ˆ“«i“i˜Ìˆ˜}Ê>«…>ʓœ`iÃÊ>˜`Ê«œÀÌvœˆœÊVœ˜ÃÌÀÕV̈œ˜Ê“i̅œ`œœ}ˆiðÊivœÀiʍœˆ˜ˆ˜}ʈ`iˆÌÞʈ˜Ê£™™{]Ê
À°ÊœÕV…iÀÊܜÀŽi`Ê>ÃÊ>Ê-i˜ˆœÀÊ
œ˜ÃՏ̈˜}ʘ}ˆ˜iiÀʈ˜Ê̅iÊ
>«ˆÌ>Ê>ÀŽiÌÃÊ>˜`Ê>˜Žˆ˜}ʈۈȜ˜Ê>ÌÊ
ˆ}ˆÌ>ÊµÕˆ«“i˜ÌÊ
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vˆ˜>˜ViÊvÀœ“Ê œÀ̅i>ÃÌiÀ˜Ê1˜ˆÛiÀÈÌÞʈ˜ÊÓäää°
DISCIPLINARY INFORMATION
/…iÀiÊ>ÀiʘœÊ“>ÌiÀˆ>Ê`ˆÃVœÃ>Liʏi}>ÊœÀÊ`ˆÃVˆ«ˆ˜>ÀÞÊiÛi˜ÌÃÊ̅>ÌÊ>Àiʓ>ÌiÀˆ>Ê̜ÊޜÕÀÊiÛ>Õ>̈œ˜Ê
œvÊÀ°ÊœÕV…iÀʜÀʅˆÃʈ˜Ìi}ÀˆÌÞ°
OTHER BUSINESS ACTIVITIES
À°ÊœÕV…iÀʈÃʘœÌÊ>V̈ÛiÞÊi˜}>}i`ʈ˜Ê>˜Þʜ̅iÀʈ˜ÛiÃ̓i˜Ì‡Ài>Ìi`ÊLÕȘiÃÃʜÀʜVVÕ«>̈œ˜°
ADDITIONAL COMPENSATION
À°ÊœÕV…iÀÊ`œiÃʘœÌÊÀiViˆÛiÊ>˜ÞÊ>``ˆÌˆœ˜>ÊVœ“«i˜Ã>̈œ˜ÊvœÀÊ«ÀœÛˆ`ˆ˜}Ê>`ۈÜÀÞÊÃiÀۈViÃÊ̜Ê>˜ÞÊ«>ÀÌÞÊ
܅œÊˆÃʘœÌÊ>ÊVˆi˜ÌʜvÊiˆÌ…iÀÊ-ÌÀ>Ìi}ˆVÊ`ۈÃiÀÃ]ʈ˜ÛiÃ̓i˜ÌÊ>`ۈÃiÀÃÊ>vvˆˆ>Ìi`Ê܈̅Ê-ÌÀ>Ìi}ˆVÊ`ۈÃiÀÃ]ʜÀÊ
̅iʏ>VŽ,œVŽ®ÊˆÛiÀÈvˆi`ʘVœ“iÊ*œÀÌvœˆœ°
SUPERVISION
À°ÊœÕV…iÀʈÃÊÃÕ«iÀۈÃi`ÊLÞÊÀˆ>˜Ê˜Þi>ÀÌ]Ê
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ÀiۈiÜÃÊ̅iÊ«ÀœViÃÃÊÕÃi`ÊLÞÊÀ°ÊœÕV…iÀʈ˜Ê`iÌiÀ“ˆ˜ˆ˜}Ê̅iʈ˜ÛiÃÌ>LiÊ՘ˆÛiÀÃiÊvœÀÊ̅iʏ>VŽ,œVŽ®
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`ۈÃiÀýʈ˜ÛiÃ̓i˜ÌÊ«œˆVˆiÃÊ>˜`Ê«ÀœVi`ÕÀið
À°Ê˜Þi>ÀÌʓ>ÞÊLiÊVœ˜Ì>VÌi`Ê>ÌÊȣLJxÈ·ǣää°
REQUIREMENTS FOR STATE-REGISTERED ADVISERS
-ÌÀ>Ìi}ˆVÊ`ۈÃiÀÃ]ʘV°]ʈÃʘœÌÊÀi}ˆÃÌiÀi`Ê܈̅Ê>˜ÞÊÃÌ>ÌiÊÃiVÕÀˆÌˆiÃÊ>Õ̅œÀˆÌÞ°
4
Peter Brian Enyeart
Supplemental Brochure:
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Vœ˜Ãˆ`iÀˆ˜}Ê>ʏ>VŽ,œVŽ ®ÊˆÛiÀÈvˆi`ʘVœ“iÊ*œÀÌvœˆœÊ>VVœÕ˜ÌÊ܈̅ʈ`iˆÌÞ°ÊÌÊ«ÀœÛˆ`iÃʈ˜vœÀ“>̈œ˜Ê
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՘`>“i˜Ì>Ã°Ê*i>ÃiÊVœ˜Ì>VÌÊޜÕÀʈ`iˆÌÞÊÀi«ÀiÃi˜Ì>̈ÛiʈvÊޜÕÊ`ˆ`ʘœÌÊÀiViˆÛiÊ̅iÊ*Àœ}À>“Ê
՘`>“i˜Ì>ÃʜÀʈvÊޜÕʅ>ÛiÊ>˜ÞʵÕiÃ̈œ˜ÃÊ>LœÕÌÊ̅iÊVœ˜Ìi˜ÌÃʜvÊ̅ˆÃÊÃÕ««i“i˜Ì°
"˜ÊLi…>vʜvʈ`iˆÌÞ]ÊÜiÊ̅>˜ŽÊޜÕÊvœÀÊ̅iʜ««œÀÌ՘ˆÌÞÊ̜ʫÀœviÃȜ˜>Þʓ>˜>}iÊޜÕÀÊ«œÀÌvœˆœ°
5
*iÌiÀÊÀˆ>˜Ê˜Þi>ÀÌ
EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
*iÌiÀÊÀˆ>˜Ê˜Þi>ÀÌÊ­ºÀˆ>˜Ê˜Þi>ÀÌ»®ÊˆÃÊ
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ˆÛiÀÈvˆi`ʘVœ“iÊ>VVœÕ˜ÌðÊÀ°Ê˜Þi>ÀÌʈÃÊÀi뜘ÈLiÊvœÀÊVœ˜`ÕV̈˜}Ê>««Àœ«Àˆ>ÌiÊ`ÕiÊ`ˆˆ}i˜ViÊ
ˆ˜Ê̅iÊÃiiV̈œ˜Ê>˜`ʜ˜}œˆ˜}ʜÛiÀÈ}…ÌʜvÊ̅iʓœ`iÊ«ÀœÛˆ`iÀÊi“«œÞi`ʈ˜Ê̅iʓ>˜>}i“i˜ÌʜvÊ̅iÊ
>VŽ,œVŽ®ÊˆÛiÀÈvˆi`ʘVœ“iÊ>VVœÕ˜ÌÃÊ>˜`Ê̅iÊ«œÀÌvœˆœÊ“>˜>}i“i˜ÌÊ`iVˆÃˆœ˜ÃÊ܈̅ˆ˜Ê̅iÊ«œÀÌvœˆœÃ°ÊÊ
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