EX-99.P CODE ETH 119 fidelitycodeofethics2010.htm EX-99.(P)(26) PYRAMIS CODE OF ETHICS DTD 2010 fidelitycodeofethics2010.htm - Generated by SEC Publisher for SEC Filing
2010 
Rules for Employee Investing 
 
Code of Ethics for Personal Investing 
Fidelity Funds Version 



Rules for Employee Investing 
These Rules for Employee Investing contain the Code of Ethics for Personal Investing, 
the Policy on Inside Information, and the Rules for Broker-Dealer Employees. 
 
The Fidelity Funds Version of the Code of Ethics for Personal Investing contains rules 
about owning and trading securities for personal benefit. This version applies to officers, 
directors, and employees of Fidelity companies that are involved in the management and 
operations of Fidelity’s funds, including investment advisors to the funds and the 
principal underwriter of the funds. Keep in mind that if you change jobs within Fidelity, a 
different version of the Code of Ethics may apply to you. 
 
The Policy on Inside Information, which applies to every Fidelity employee, contains 
rules on inside information and how to prevent its unauthorized use or dissemination. 
 
The Rules for Broker-Dealer Employees apply to employees who have a securities 
license or who are employed by or associated with one of Fidelity’s broker-dealers. 
 
Code of Ethics for Personal Investing 4 
This version of the Code of Ethics includes additional rules, which apply to Fund- 
Advisory Employees as well as Traders, Research Analysts, and Portfolio Managers (see 
box, page 3). 
 
Rules for All Employees Subject to This Code of Ethics 
What’s Required 
Acknowledging that you understand the rules 
Complying with federal securities laws 
Reporting violations to the Ethics Office 
Disclosing securities accounts and holdings in covered securities 
Moving covered accounts to Fidelity 
Moving holdings in Fidelity funds to Fidelity 
Disclosing transactions of covered securities 
Disclosing gifts and transfers of ownership of covered securities 
Getting approval before engaging in private securities transactions 
Getting prior approval to serve as a director 
Clearing trades in advance (pre-clearance) 
 
What’s Prohibited 
Trading restricted securities 
Selling short 
Participating in an IPO 
Participating in an investment club 
Investing in a hedge fund 
Excessive trading 
Profiting from knowledge of fund transactions 
Influencing a fund to benefit yourself or others 
Attempting to defraud a client or fund 
Using a derivative to get around a rule 



Additional Rules for Fund-Advisory Employees 
What’s Required 
Surrendering 60-day gains (60-Day Rule) 
What’s Prohibited 
Buying securities of certain broker-dealers 
Trading after a research note 
 
Additional Rules for Traders, Research Analysts, and Portfolio Managers 
All rules listed above for Fund-Advisory Employees, plus the rules in this section 
What’s Required 
Notification of your ownership of securities in a research note 
Disclosing trading opportunities to the funds before personally trading 
What’s Prohibited 
Trading within seven days of a fund you manage 
 
Trust: it works for all of us — and so does good judgment 
The Rules for Employee Investing are fairly comprehensive. They cover most of the personal 
investing situations a Fidelity employee is likely to find. Yet it’s always possible you will 
encounter a situation that isn’t fully addressed by the rules. If that happens, you need to know 
what to do. The easiest way to make sure you are making the right decision is to follow these 
three principles: 
 
1. Know the policy. 
If you think your situation isn’t covered, check again. It never hurts to take a look at the rules. 
2. Seek guidance. 
Asking questions is always appropriate when you are unclear about what the policy says or how it 
applies to your situation. Your manager and the Ethics Office are two good places to start. 
3. Use sound judgment. 
Analyze the situation and weigh the options. Think about how your decision would look to an 
outsider. The trust of our customers is essential to our business, and ethical behavior by all 
employees is essential to maintaining that trust. 
Knowing and following the Code of Ethics is one of the most important ways we show customers 
that we’re serious about the trust they’ve placed in us. 
 
CONTACT INFORMATION 
Ethics Office 
Phone 
(001) 617-563-5566 
(001) 800-580-8780 
Fax (001) 617-385-0939 
E-mail: ethics.office@fmr.com 
Mail zone Z1N 
Web MyCompliance.fmr.com 
Pre-Clearance 
Web 
Internal: preclear.fmr.com 
External: preclear.fi delity.com 
Phone 
(001) 617-563-6109 
(001) 800-771-2707 
To call the phone numbers from outside the United States or Canada, dial “001” before the number. 



Who is subject to This Version of the Code of Ethics? 
All individuals described in each group below are subject to this version of the Code of Ethics. 
You can also be placed in a certain group by designation of the Ethics Office. 
 
Fund-Knowledgeable Employees 
Employees of Fidelity Management Trust Company (FMTC), Fidelity Pricing and Cash 
Management Services (FPCMS), and Fidelity Audit Services; certain employees of Corporate 
Compliance; and employees, including temporary employees, with access to timely fund 
information (including access to systems such as AS400 trading or development machines). 
 
Fund-Advisory Employees 
Employees of Fidelity Management & Research Company (FMR Co.), Fidelity Capital Markets 
(FCM) and the Core Compliance Group; certain employees of Strategic Advisers, Inc.; 
employees of Pyramis Global Advisors; members of the Board of Directors of FMR Co. and 
FMR LLC; elected officers of FMR Co. and FMR LLC; members of the Fidelity Management 
Committee; attorneys acting as counsel in FMR LLC Legal; and employees, including temporary 
employees, with access to fund research notes or investment recommendations for the funds. 
 
Traders, Research Analysts, and Portfolio Managers 
Employees trading for the funds (traders), employees making investment recommendations for 
the funds (research analysts), and employees who manage a fund or a portion of a fund’s assets 
(portfolio managers). 
***** 



Code of Ethics for Personal Investing 
Fidelity Funds Version 
 
 
Following the rules — in letter and in spirit 
This Fidelity Funds Version of the Code of Ethics contains rules about owning and 
trading securities for personal benefit. Certain rules, which are noted, apply both to you 
and to anyone else who is a covered person (see Key Concepts on page 6). 
You have a fiduciary duty to never place your own personal interest ahead of the interests 
of Fidelity’s clients, including shareholders of the Fidelity funds. This means never 
taking unfair advantage of your relationship to the funds or Fidelity in attempting to 
benefit yourself or another party. It also means avoiding any actual or potential conflicts 
of interest with the funds or Fidelity when managing your personal investments. 
Because no set of rules can anticipate every possible situation, it is essential that you 
follow these rules not just in letter, but in spirit as well. Any activity that compromises 
Fidelity’s integrity, even if it does not expressly violate a rule, has the potential to harm 
Fidelity’s reputation and may result in scrutiny or further action from the Ethics Office. 
 
 
WHAT’S REQUIRED 
Acknowledging that you understand the rules 
When you begin working for Fidelity, and again each year, you are required to: 
  acknowledge that you understand and will comply with all rules that apply to you 
  authorize Fidelity to have access to all of your covered accounts (see Key 
  Concepts on page 6) and to obtain and review account and transaction data 
  (including duplicate copies of non-Fidelity account statements) for compliance or 
  employment related purposes 
  acknowledge that you will comply with any new or existing rules that become 
  applicable to you in the future 
 
To Do   
Promptly respond to the e-mail you receive from the Ethics Office each year requiring 
you to acknowledge the Code of Ethics. New employees need to respond within 10 days 
of hire. If you do not have access to e-mail, you may obtain a hard copy of the 
acknowledgment Form at MyCompliance.fmr.com or by contacting the Ethics Office. 
 
Respond to the e-mail that you receive from the Ethics Office to acknowledge your 
understanding of the rules. 
***** 
 
Complying with federal securities laws 
In addition to complying with these rules and other company-wide policies, you need to 
comply with federal securities laws. 



Reporting violations to the Ethics Office 
If you become aware that you or someone else has violated any of these rules, you need 
to promptly report the violation. 
 
To Do 
Call the Ethics Office Service Line at (001) 617-563-5566 or (001) 800-580-8780. 
Call the Chairman’s Line at (001) 800-242-4762 if you would prefer to speak on a non- 
recorded line. 
 
Disclosing securities accounts and holdings in covered securities 
You must disclose all securities accounts — those that hold covered securities (see Key 
Concepts on page 7) and those that do not. You must also disclose all covered securities 
not held in an account. This rule covers not only securities accounts and holdings under 
your own name or control, but also those under the name or control (including trading 
discretion or investment control) of your covered persons (see Key Concepts on page 6). 
It includes accounts held at Fidelity as well as those held at other financial institutions. 
Information regarding these holdings must not be more than 45 days old when you 
submit it. 
 
To Do 
Employees newly subject to this rule 
Within 10 days of hire or of being notified by the Ethics Office that this version of the 
Code of Ethics applies to you, submit an Accounts and Holdings Disclosure (available at 
MyCompliance.fmr.com) showing all of your securities accounts and holdings in covered 
securities not held in an account. Forward the most recent statement for each account 
listed to the Ethics Office. If you do not have any securities accounts or applicable 
holdings, check the appropriate box in the online form confirming that you have nothing 
to disclose. 
 
Current employees 
Each year, you will receive an Annual Accounts and Holdings Report. You will be 
required to confirm that all information previously disclosed is accurate and complete. As 
soon as any new securities account is opened, or a preexisting securities account becomes 
associated with you (such as through marriage or inheritance), complete an Accounts and 
Holdings Disclosure (available at MyCompliance.fmr.com) with the new information and 
submit it promptly to the Ethics Office. 
On your next Quarterly Trade Verification, confirm that the list of disclosed securities 
accounts in the appropriate section of the report is accurate and complete. 
 
Use the online form to disclose all new securities accounts and holdings in covered 
securities not held in an account that become associated with you. 
MyCompliance.fmr.com 
 
KEY CONCEPTS 



Certain terms have a specific meaning within this version of the Code of Ethics. These 
terms are defined as “Key Concepts.” 
Covered person 
Fidelity is concerned not only that you observe the requirements of the Code of Ethics, 
but also that those in whose affairs you are actively involved observe the Code of Ethics. 
This means that the Code of Ethics can apply to persons owning assets over which you 
have control or influence or in which you have an opportunity to directly or indirectly 
profit or share in any profit derived from a securities transaction. This may include: 
• you 
• your spouse or domestic partner who shares your household 
• any other immediate family member who shares your household and: 
a) is under 18, or 
b) is supported financially by you or who financially supports you 
• anyone else the Ethics Office has designated as a covered person 
This is not an exclusive list, and a covered person may include, for example, immediate 
family members who live with you but whom you do not financially support, or whom 
you financially support or who financially support you but who do not live with you. 
If you have any doubt as to whether a person would be considered a “covered person” 
under the Code of Ethics, contact the Ethics Office. 
 
Immediate family member 
Your spouse, or domestic partner who shares your household, and anyone who is related 
to you in any of the following ways, whether by blood, adoption, or marriage: 
• children, stepchildren, and grandchildren 
• parents, stepparents, and grandparents 
• siblings 
• parents-, children-, and siblings-in-law 
 
Covered account 
The term “covered account” encompasses a fairly wide range of accounts. Important 
factors to 
 
Selling short 
Selling a security that is on loan to you from a broker-dealer (rather than owned by you) 
at the time you sell it. 
***** 
 
Moving covered accounts to Fidelity 
You and your covered persons need to maintain all covered accounts (see Key Concepts 
below) at Fidelity Brokerage Services LLC (FBS). 
 
Exceptions 
With prior written approval from the Ethics Office, you or your covered persons can 
maintain a covered account at a broker-dealer other than FBS if any of the following 
applies: 
•  it contains only securities that cannot be transferred 



          it exists solely for products or services that FBS does not provide 
          it exists solely because your covered person’s employer also prohibits external 
  covered accounts 
          it is managed by a third-party registered investment advisor with discretionary 
  authority over the account 
           it is restricted to trading interests in non-Fidelity 529 College Savings Plans only 
          it is associated with an ESOP (employee stock option plan) in which a covered 
  person is a participant through his or her current employer, or was from a 
  previous employer, and for which the employee has options that have not yet 
  vested 
          it is associated with an ESPP (employee stock purchase plan) in which a covered 
  person is a participant through his or her current employer 
          it is required by a direct purchase plan, a dividend reinvestment plan, or an 
  automatic 
          investment plan with a public company (collectively, “automatic investment 
  plans”) 
          in which regularly scheduled purchases are made or planned on a monthly basis 
          it is required by a trust agreement it is associated with an estate of which you or 
  any of your covered persons is the executor, but not a beneficiary, and 
  involvement with the account is temporary 
          transferring the account would be inconsistent with other applicable rules 
 
To Do   
Transfer assets to an FBS account. 
Close all external covered accounts except for those that you have received written 
permission to maintain. 
For permission to maintain an external covered account, submit a completed Exception 
Request Form (available at MyCompliance.fmr.com) to the Ethics Office. Follow the 
specific instructions for each type of account and provide a current statement for each 
account. 
Comply with any Ethics Office request for duplicate reporting. 
 
 
Covered security 
This definition applies to all persons subject to this version of the Code of Ethics. 
Covered securities include securities in which a covered person has the opportunity, 
directly or indirectly, to profit or share in any profit derived from a transaction in such 
securities, and encompasses most types of securities, including, but not limited to: 
• shares of Fidelity mutual funds (except money market funds) 
• shares of another company’s mutual fund if it is advised by Fidelity (check the 
prospectus to see if this is the case) 
• interests in Fidelity 529 College Savings Plans 
• interests in a variable annuity or life insurance product in which any of the underlying 
assets are held in funds advised by Fidelity, such as Fidelity VIP Funds (check the 
prospectus to see if this is the case) 



• interests in Fidelity’s deferred compensation plan reflecting hypothetical investments in 
Fidelity funds 
• interests in Fidelity’s deferred bonus plan (ECI) reflecting hypothetical investments in 
Fidelity funds 
• shares of stock (of both public and private companies) 
• ownership units in a private company or partnership 
• corporate and municipal bonds 
• bonds convertible into stock 
• options on securities (including options on stocks and stock indexes) 
• security futures (futures on covered securities) 
• shares of exchange traded funds (ETFs) 
• shares of closed-end mutual funds 
 
Exceptions 
The following are not considered covered securities (please note that accounts holding 
non covered securities still require disclosure): 
• shares of money market funds (including Fidelity money market funds) 
• shares of non-Fidelity open-end mutual funds 
• interests in non-Fidelity 529 College Savings Plans 
• shares, debentures, or other securities issued by FMR LLC to you as compensation or a 
benefit associated with your employment 
• U.S. Treasury securities 
• obligations of U.S. government agencies with remaining maturities of one year or less 
• money market instruments, such as certificates of deposit, banker’s acceptances, and 
commercial paper 
• currencies 
• commodities (such as agricultural products or metals), and options and futures on 
commodities that are traded on a commodities exchange 
***** 
 
Moving holdings in Fidelity funds to Fidelity 
You and your covered persons need to maintain holdings in shares of Fidelity funds in a 
Fidelity account. 
 
Exceptions — No Approval Required 
You or your covered persons can continue to maintain a preexisting interest in either of 
the following: 
– a Fidelity money market fund 
         a variable annuity or life insurance product whose underlying assets are held in 
            Fidelity advised funds 
         – 
Exceptions — Approval Required 
With prior written approval from the Ethics Office, you or your covered persons can 
maintain holdings in Fidelity funds in an account outside Fidelity if any of the following 
applies: 



           the holdings are in a defined benefit or contribution plan, such as a 401(k), that is 
  administered by a company at which a covered person is currently employed the 
  holdings are in a retirement plan and transferring them would result in a tax 
  penalty 
          the holdings are in an account that is managed by a third-party registered 
  investment advisor with discretionary authority over the account maintaining the 
  holdings in the external account is required by a trust agreement 
          the holdings are associated with an estate of which you or any of your covered 
  persons is the executor, but not a beneficiary, and involvement with the account is 
  temporary 
          you can show that transferring the holdings would create a significant hardship 
 
To Do   
Transfer shares of Fidelity funds to a Fidelity account except for those that you have 
received written permission to maintain. For permission to maintain shares of Fidelity 
funds in an account at another financial institution, complete an Exception Request Form 
(available at MyCompliance.fmr.com). Attach a current statement for each account you 
list on the form. Forward the form and statement(s) to the Ethics Office. 
 
 
Disclosing transactions of covered securities 
You need to disclose transactions in covered securities made by you or your covered 
persons. For accounts held at FBS that you have disclosed, the Ethics Office will receive 
transaction reports automatically. For approved covered accounts held outside FBS, 
comply with any Ethics Office requests for duplicate reporting. For any other transactions 
in covered securities (for example, if you or any of your covered persons purchases 
interests in a Fidelity- advised investment product in a non-broker age account outside 
Fidelity), you need to disclose this transaction information to the Ethics Office. 
 
Exception 
You do not have to report transactions in a covered account if the transactions are being 
made through an approved discretionary account or under an automatic investment plan 
(see Key Concepts on page 6), and the details of the account or plan have been provided 
to the Ethics Office. 
 
To Do   
For transactions in covered securities not made through a covered account, submit a 
completed Securities Transaction Report (available at MyCompliance.fmr.com) to the 
Ethics Office within 30 days following the end of the quarter in which the transaction 
was completed. 
When requested each quarter, promptly confirm or update your transaction history in 
covered securities on the Quarterly Trade Verification. 
Provide the details of any automatic investment plan to the Ethics Office. 
 
Disclosing gifts and transfers of ownership of covered securities 



You need to notify the Ethics Office of any covered securities that you or your covered 
persons give, donate, or transfer to another party, or that you or your covered persons 
receive from another party. This includes, among other things, inheritances of covered 
securities and donations of covered securities to charities. 
To Do 
Complete a Securities Transaction Report (available at MyCompliance.fmr.com) within 
30 days following the end of the quarter during which the gift or transfer was made. 
When requested each quarter, promptly confirm or update your history of giving, 
donating, transferring, or receiving covered securities on the Quarterly Trade 
Verification. 
 
Getting approval before engaging in private securities transactions 
You and your covered persons need prior written approval from the Ethics Office for 
each and every intended investment in a private placement or other private securities 
trans action in covered securities. This includes any add-on, any subsequent investment, 
or any investment whose terms materially differ from any previous approval you may 
have received. 
 
To Do 
Before engaging in any private securities transaction, fill out a Private Transaction 
Request Form (available at MyCompliance.fmr.com). Get the necessary approval from 
your manager, division head, or other authority, as described on the request form. Submit 
the request to the Ethics Office and await approval. 
Report the final transaction within 30 days following the end of the quarter in which it 
was completed using a Securities Transaction Report (available at 
MyCompliance.fmr.com). 
When requested each quarter, promptly confirm or update your transaction history in 
private securities transactions on the Quarterly Trade Verification. 
For private securities transactions offered by a Fidelity company, the Ethics Office will 
typically preapprove such investments for employees who are offered an opportunity to 
invest. In such cases, you will receive notification that the offering has been preapproved 
by the Ethics Office. 
 
Getting prior approval to serve as a director 
You need to get prior approval to serve as a director or trustee of any publicly traded 
company, or of a non-Fidelity privately held company that is likely to issue shares. 
Approval depends on a determination that the activity will not conflict with the best 
interests of the funds and their shareholders. Note that the Policy on Outside Activities 
(available at MyCompliance.fmr.com) requires prior written approval for other activities 
as well, including accepting additional employment outside Fidelity or participating in an 
activity that may create an actual or perceived conflict of interest with Fidelity. 
 
To Do 
Request approval from both your manager and the Ethics Office before participating in 
any activities outside Fidelity by completing an Outside Activity Request Form (available 
at MyCompliance.fmr.com). 



Delegating pre-clearance responsibilities 
In very limited circumstances, you may, with the prior written approval of the Ethics Office, designate 
someone to obtain preclearance approvals for you. In such a case, the agent is responsible for obtaining the 
correct approvals, and you are responsible for maintaining reasonable supervision over that person’s 
activities related to pre-clearance. 
***** 
 
Clearing trades in advance (pre-clearance) 
You and your covered persons must obtain prior approval from the Ethics Office for any 
orders to buy or sell a covered security (see “How to Pre-Clear a Trade” in the sidebar). 
The purpose of this rule is to reduce the possibility of conflicts between personal trades in 
covered securities and trades made by the funds. When you apply for pre-clearance, you 
are not just asking for approval, you are giving your word that you and your covered 
persons: 
do not have any inside information on the security you want to trade (see Policy on Inside 
Information) 
are not using knowledge of actual or potential fund trades to benefit yourself or others 
believe the trade is available to the general investor on the same terms 
will provide any relevant information requested by the Ethics Office 
 
Generally, requests will not be approved if it is determined that your transaction may 
take advantage of trading by the funds or create an actual or perceived conflict of interest 
with fund trades. 
 
The rules of pre-clearance 
You and your covered persons must obtain preclearance approval before placing any 
orders to buy or sell a covered security. It is important to understand the following rules 
before requesting pre-clearance for a trade: 
           Pre-clearance approval is only good during the market session for which you 
  receive it. If you do not trade during the market session for which you were 
  granted approval, it expires. 
          Place day orders only (orders that automatically expire at the end of the trading 
  session). Good-till-cancelled orders (such as orders that stay open indefinitely 
  until a security reaches a specified market price) are not permitted. 
          Check the status of all orders at the end of the market session and cancel any 
  orders that have not been executed. If any covered person leaves an order open 
  and it is executed the next day (or later), it will generate a violation that will be 
  assigned to you. 
          Trade only during the regular market hours, or the after-hours trading session, of 
  the exchange(s) where the security in question is traded. Place requests for pre- 
  clearance after the market has been open for a while, as pre-clearance is not 
  available right at market opening. To find out when pre-clearance for a given 
  market typically becomes available, contact the Ethics Office. 
 
Unless an exception listed below applies or the Ethics Office has instructed you 
otherwise, these pre-clearance rules apply to all your covered accounts — including 



Fidelity accounts and any outside covered accounts that belong to you or any of your 
covered persons. 
 
Exceptions 
You do not need to pre-clear trades or transactions in certain covered securities. These 
include: 
          shares of Fidelity funds 
          options and futures on, or ETFs that track, the following indexes: Dow Jones 
  Industrial Average, NASDAQ 100, Russell 1000, Russell 2000, S&P 100, S&P 
  500, S&P Midcap 400, S&P Europe 350, FTSE 100, FTSE Mid 250, FTSE 350, 
  Hang Seng 100, Deutscher Aktien IndeX (DAX 30), S&P/TSX 60, NSE S&P 
  CNX Nifty (Nifty 50), and Nikkei 225 (note that you do need to pre-clear options, 
  futures, and ETFs on all other indexes) 
          options, futures, and ETFs based on one or more instruments that are not covered 
  securities (i.e., commodities, currencies, and U.S. Treasuries; see Key Concepts 
  on page 7 for an expanded list of non-covered securities) 
          securities being transferred as a gift or a donation 
          automatic dividend reinvestments 
          subscription rights 
          currency warrants 
          the regular exercise of an employee stock option (note that any resulting sale of 
  the underlying stock at current market prices must be pre-cleared) 
 
With the prior written approval of the Ethics Office, there are a few situations where you 
may be permitted to trade without pre-clearing. These situations are: 
trades in a covered account that is managed by a third-party registered investment advisor 
with discretionary authority over the account 
trades made through an automatic investment plan, the details of which have been 
disclosed to the Ethics Office in advance 
when you can show that a repeated rejection of your pre-clearance request is causing a 
significant hardship 
 
To Do   
Before placing any trade in a covered security, pre-clear it using the Fidelity Global Pre- 
Clearance System, available at preclear.fmr.com (internal) and preclear.fidelity.com 
(external). 
Immediately cancel any good-till-cancelled orders in your covered accounts. 
 
 
[Sidebar]   
To avoid errors, use these step-by-step instructions: 
1. Access the Fidelity Global Pre-Clearance System: 
Internal   
preclear.fmr.com 
External   
preclear.fi delity.com 
If you are unable to access the Fidelity Global Pre- Clearance System, call the Pre-Clearance Line at (001) 
617-563-6109 or (001) 800-771-2707. 



Note that pre-clearance for FMR Co. and Pyramis equity traders and their covered persons is not available 
until noon, local market time. 
2. Accurately enter the details of the trade you would like to make. Do not trade unless you receive 
approval. Note the preclearance reference number for your records. 
3. Place your order. Be sure your order is for the same security and direction as your pre-clearance 
approval. Do not place a good-till-cancelled order. 4. Check the status of your 
order at the end of the market session. 
5. Cancel any orders that have not been executed. 
***** 
 
WHAT’S PROHIBITED 
Trading restricted securities 
Neither you nor your covered persons may trade a security that Fidelity has restricted. If 
you have been notified not to trade a particular security, neither you nor your covered 
persons may trade that security until you are notified that the restriction has been 
removed. 
 
Selling short 
The short position in a particular covered security may not exceed the number of shares 
of that security held in the same account. This prohibition includes selling securities short 
(see Key Concepts on page 6), buying puts to open, selling calls to open, straddles, and 
spreads. 
 
Exceptions 
          Options and futures on, or ETFs that track, the following indexes: Dow Jones 
  Industrial Average, NASDAQ 100, Russell 1000, Russell 2000, S&P 100, S&P 
  500, S&P Midcap 400, S&P Europe 350, FTSE 100, FTSE Mid 250, FTSE 350, 
  Hang Seng 100, Deutscher Aktien IndeX (DAX 30), S&P/TSX 60, NSE S&P 
  CNX Nifty (Nifty 50), and Nikkei 225. 
          Options, futures, and ETFs based on one or more instruments that are not covered 
  securities (i.e., commodities, currencies, and U.S. Treasuries; see Key Concepts 
  on page 7 for an expanded list of non-covered securities). 
 
Participating in an IPO 
Neither you nor your covered persons are allowed to participate in an initial public 
offering (IPO) of securities where no public market in a similar security of the issuer 
previously existed. This rule applies to equity securities, corporate debt securities, and 
free stock offers through the Internet. 
 
Exceptions 
          With prior written approval from the Ethics Office, you and your covered persons 
  may participate if: 
          you or your covered persons have been offered shares because you already own 
  equity 



          in the company you or your covered persons have been offered shares because 
  you are a policyholder or depositor of a mutual company that is reorganizing into 
  a stock company 
          you or your covered persons have been offered shares because of employment 
  with the company 
 
To Do   
For written approval to participate in an IPO that may qualify as an exception, submit to 
the Ethics Office a completed Exception Request Form (available at 
MyCompliance.fmr.com). Do not participate in any IPO without prior written approval 
from the Ethics Office. 
 
Participating in an investment club 
Neither you nor your covered persons may participate in an investment club or similar 
entity.   
 
Investing in a hedge fund 
Neither you nor your covered persons may invest in a hedge fund, alternative investment, 
or similar investment product or vehicle. 
Exceptions 
          Investment products or vehicles issued or advised by Fidelity. 
          A hedge fund, alternative investment, or similar investment product or vehicle 
  that you or your covered persons bought before joining Fidelity. You must show 
  that you and your covered persons have no influence over the product’s or 
  vehicle’s investment decisions and that the investment cannot be readily 
  liquidated or that liquidation would cause a significant hardship. The prior written 
  approval of the Ethics Office is required to qualify for this exception. Note that 
  even if your request is approved, neither you nor your covered persons can make 
  any further investments in the product, and the investment must be liquidated at the 
  earliest opportunity. 
 
To Do   
To request an exception to invest in an investment product or vehicle issued or advised 
by Fidelity, submit a completed Private Transaction Request Form (available at 
MyCompliance.fmr.com) to the Ethics Office. To request an exception to maintain a 
preexisting investment, submit a completed Private Transaction Request Form (available 
at MyCompliance.fmr. com) to the Ethics Office. Note that even if your request is 
approved, neither you nor your covered persons can make any further investments in the 
product or vehicle, and the investment must be liquidated at the earliest opportunity. 
 
Excessive trading 
Excessive trading in covered accounts is strongly discouraged. In general, anyone 
trading covered securities more than 60 times (other than Fidelity funds) in a quarter 
across all his or her covered accounts should expect additional scrutiny of his or her 
trades. Note that you and your covered persons also need to comply with the policies in 
any Fidelity fund prospectus concerning excessive trading. The Ethics Office monitors 



trading activity, and may limit the number of trades allowed in your covered accounts 
during a given period. 
 
Exception 
This rule does not apply to transactions in an account that is managed by a third-party 
registered investment advisor with discretionary authority over the account. 
 
Profting from knowledge of fund transactions 
You may not use your knowledge of transactions in funds or other accounts advised by 
FMR Co., Pyramis Global Advisors, or any other Fidelity entity to profit by the market 
effect of these transactions. 
 
Influencing a fund to benefit yourself or others 
The funds and accounts advised by Fidelity are required to act in the best interests of their 
shareholders and clients, respectively. Accordingly, you are prohibited from influencing 
any of these funds or accounts to act for the benefit of any party other than their 
shareholders or clients. For example, you may not influence a fund to buy, sell, or refrain 
from trading a security that would affect that security’s price to advance your own 
interest or the interest of a party that has or seeks to have a business relationship with 
Fidelity. 
 
Attempting to defraud a client or fund 
Attempting to defraud a fund or an account advised by FMR Co., Pyramis Global 
Advisors, or any other Fidelity entity in any way is a violation of Fidelity’s rules and 
federal law. 
 
Using a derivative to get around a rule 
If something is prohibited by these rules, then it is also against these rules to effectively 
accomplish the same thing by using a derivative. This includes futures, options, and other 
types of derivatives. 
 
How we enforce the Code of Ethics 
The Ethics Office regularly reviews the forms and reports it receives. If these reviews 
turn up information that is incomplete, questionable, or potentially in violation of this 
Code of Ethics, the Ethics Office will investigate the matter and may contact you. 
If it is determined that you or any of your covered persons has violated this Code of 
Ethics, the Ethics Office or another appropriate party may take action. Among other 
things, subject to applicable law, potential actions may include: 
• an informational memorandum 
• a written warning 
• a fine, a deduction from wages, disgorgement of profit, or other payment 
• a limitation or ban on personal trading 
• referral of the matter to Human Resources 
• dismissal from employment 
• referral of the matter to civil or criminal authorities 



Fidelity takes all Code of Ethics violations seriously, and, at least once a year, provides 
the funds’ trustees with a summary of actions taken in response to material violations of 
this Code of Ethics. 
You should be aware that other securities laws and regulations not addressed by this 
Code of Ethics may also apply to you, depending upon your role at Fidelity. 
Fidelity and the funds retain the discretion to interpret this Code of Ethics and to decide 
how the rules apply to any given situation. 
 
Exceptions 
In cases where exceptions to this Code of Ethics are noted and you may qualify for them, 
you need to get prior written approval from the Ethics Office. The way to request 
any particular exception is discussed in the text of the relevant rule. If you believe that 
you have a situation that warrants an exception that is not discussed in this Code of 
Ethics, you may submit a written request to the Ethics Office. Your request will be 
considered by the Ethics Office, and you will be notified of the outcome. 
 
Appeals 
If you believe a request of yours has been incorrectly denied or that an action is not 
warranted, you may appeal the decision. To make an appeal, you need to provide the 
Ethics Office a written explanation of your reasons for appeal within 30 days of when 
you were informed of the decision. Be sure to include any extenuating circumstances 
or other factors not previously considered. During the review process, you may, at your 
own expense, engage an attorney to represent you. The Ethics Office may arrange for 
senior management or other parties to be part of the review process. The Ethics Office 
will notify you in writing about the outcome of your appeal. 
 
Additional Rules for Fund-Advisory Employees 
 
WHAT’S REQUIRED 
 
Surrendering 60-day gains (60-Day Rule) 
Any sale of covered securities will be matched against any purchases of that security, or 
its equivalent, in the same account during the previous 60 days (starting with the earliest 
purchase in the 60-day period). Any gain resulting from any matched transactions must 
be surrendered. For specific information about how option transactions are treated under 
this rule, see the sidebar and the examples below. 
Gains are calculated differently under this rule than they would be for tax purposes. 
Neither losses nor potential tax liabilities will be offset against the amount that must be 
surrendered under this rule. 
 
Exceptions 
This rule does not apply: 
                     •   to transactions in shares of Fidelity funds to transactions in options and futures on, 
                   or ETFs that track, the following indexes: Dow Jones Industrial Average, 
                   NASDAQ 100, Russell 1000, Russell 2000, S&P 100, S&P 500, S&P Midcap 
                   400, S&P Europe 350, FTSE 100, FTSE Mid 250, FTSE 350, Hang Seng 100, 



  Deutscher Aktien IndeX (DAX 30), S&P/TSX 60, NSE S&P CNX Nifty (Nifty 
  50), and Nikkei 225 
           to transactions in options, futures, and ETFs based on one or more instruments 
  that are not covered securities (i.e., commodities, currencies, and U.S. Treasuries; 
  see Key Concepts on page 7 for an expanded list of non-covered securities) 
          to transactions made in a covered account that is managed by a third-party 
  registered investment advisor with discretionary authority over the account 
          to transactions under an automatic investment plan (see Key Concepts on page 6) 
          to tax-planning transactions, provided that there is a demonstration of how the 
  proposed transaction relates to the covered person’s tax strategy; this exception is 
  not automatic, is granted on a case-by-case basis, and requires advanced review 
  and written approval of the Ethics Office 
          when the rule would impose a substantial unforeseen personal financial hardship 
  on the employee; this exception is not automatic, is granted on a case-by-case 
  basis, and requires advanced review and written approval of the Ethics Office 
  (note that an employee seeking relief must establish a bona fide financial 
  hardship, such as unforeseen medical expenses, and should be prepared to 
  demonstrate, among other things, that he or she possesses no other assets to meet 
  the financial need) 
 
Option transactions under the 60-Day Rule 
Option transactions can be matched either to a prior purchase of the underlying 
security or to prior option transactions in the opposite direction. When matching an 
option transaction to prior purchases of the underlying security, opening an option 
position by selling a call or buying a put is treated as a sale and will be matched to any 
purchases of the underlying security made during the preceding 60 days. 
When matching an option transaction to prior option transactions, a closing position 
is matched to any like opening positions taken during the preceding 60 days. 
When exercising an option, the initial purchase or sale of an option, not the exercise 
or assignment of the option, is matched to any opposite transactions made during the 
preceding 60 days. The sale of the underlying securities received from the exercise 
of an option will also be matched to any opposite transactions made during the period. 
There is no exception to the 60-Day Rule for the selling of securities upon the automatic 
exercise of an option that is in the money at its expiration date. To avoid surrendering 60- 
day gains that would result from an automatic liquidation, you need to cancel the 
automatic liquidation before it happens. 
 
To Do   
Before trading a covered security in a covered account that might trigger the 60-Day 
Rule, make sure you understand how much may have to be surrendered. The calculation 
may be complicated, especially if options or multiple prior purchases are 
involved. If you have any questions about this provision, call the Ethics Offi ce at (001) 
617-563-5566 or (001) 800-580-8780. 
To request permission for a tax-planning or hardship exception, you must contact the 
Ethics Office before trading. Allow at least two business days for your request to be 
considered. Approvals will be based on fund trading and other pre-clearance tests. 



You are limited to a total of five exceptions per calendar year across all your covered 
accounts. 
 
[Illustration] 
[Table showing examples of the 60-Day Rule] 
EXAMPLES 
Example 1 The March 25 sale is matched to the February 2 purchase (not the January 20 
purchase, which was more than 60 days prior). Surrendered: $500 ($5 x 100 shares). 
JAN 20 Buy 100 shares at $16 each 
FEB 2 Buy 200 shares at $10 each 
MAR 1 Buy 200 shares at $17 each 
MAR 25 Sell 100 shares at $15 each 
Example 2 The March 25 call option sale is matched to the February 2 purchase of the 
underlying security (the call’s execution price and expiration date are immaterial). 
Surrendered: $500 (the premium for selling the option). 
FEB 2 Buy 100 shares at $10 each 
MAR 25 Sell call option to open for 100 shares at $5; receive $500 premium 
Example 3 The March 25 call option purchase is a closing transaction and is matched to 
the February 2 sale (since that opening transaction was made within 60 days). 
Surrendered: $200 (difference between premium received and premium paid). 
FEB 2 Sell one call option to open at $5;receive $500 premium 
MAR 25 Buy an identical call option to close at $3;pay $300 premium 
***************** 
 
WHAT’S PROHIBITED 
Buying securities of certain broker-dealers 
Neither you nor your covered persons are allowed to buy the securities of a broker-dealer 
or its parent company if the Ethics Office has restricted those securities. 
 
Trading after a research note 
Neither you nor your covered persons are allowed to trade a covered security of an issuer 
until two full business days have elapsed (not including the day the note was published) 
since the publication of a research note on that issuer by any Fidelity entity. 
 
WHAT’S REQUIRED 
Notification of your ownership of securities in a research note 
You must check the box on a research note you are publishing to indicate any ownership, 
either by you or your covered persons, of any security of an issuer that is the subject of 
the research note. 
 
Disclosing trading opportunities to the funds before personally trading 
There are three aspects to this rule: 
Disclosing information received from an issuer 
Any time you receive, directly from an issuer, material information about that issuer (that 
is not considered inside information), you must check to see if that information has been 



disclosed to the funds in a research note. If not, you must communicate that information 
to the funds before you or any of your covered persons personally trade any securities of 
that issuer in a covered account. 
To Do 
Confirm whether a Fidelity research note has been published with the relevant 
information. If not, publish a research note or provide the information to the relevant 
head of research. 
If you are a trader, disclose the information to the analyst covering the issuer. 
If you think you may have received inside information, follow the rules in the Policy on 
Inside Information. 
 
Disclosing information about an issuer that is assigned to you 
If you are a research analyst, you must disclose in a research note material information 
you have about an issuer that is assigned to you before you or any of your covered 
persons personally trade a security of that issuer in a covered account. 
 
Exception 
You or any of your covered persons may be permitted to trade the assigned security in a 
covered account without publishing a research note if you have obtained the prior 
approval of both the relevant head of research and the Ethics Office. 
To Do 
Publish a research note with the relevant information and indicate any ownership interest 
in the issuer that you or your covered persons may have before personally trading a 
security you are assigned to cover. Note: You will not be able to obtain pre-clearance 
approval for your personal trade until two full business days have elapsed (not including 
the day the note was published) following the publication of your research note. 
To request an exception to this rule, first contact the relevant head of research and seek 
approval. Then contact the Ethics Office for approval. Do not personally trade the 
security until you have received full approval. 
 
Recommending trading opportunities 
In addition, you must recommend for the funds, and, if you are a portfolio manager, trade 
for the funds, a suitable security before personally trading that security. 
 
 
Additional Rules for Traders, Research Analysts, and Portfolio 
Managers 
Traders, Research Analysts, and Portfolio Managers are subject to the additional rules for 
Fund-Advisory Employees, plus the rules in this section. 
 
WHAT’S PROHIBITED 
Trading within seven days of a fund you manage 
Neither you nor your covered persons are allowed to trade within seven calendar days 
(not including the day of the trade) before or after a trade is executed in any covered 
security of the same issuer by any of the funds you manage. 
Exceptions 



When the rule would work to the disadvantage of a fund You must never let a personal 
trade prevent a fund you manage from subsequently trading a covered security of the 
same issuer, if not making the trade would disadvantage the fund. However, you need 
approval from the Ethics Office before making any trades under this exception. The 
Ethics Office will need to know, among other things, what new information arose since 
the date of the trade in your covered account. 
When the conflicting fund trade results from standing orders A personal trade may 
precede a fund trade in the same covered security when the fund’s trade was generated 
independently by the trading desk because of a standing instruction to trade 
proportionally across the fund’s holdings in response to fund cash flows. 
When the covered account is independently managed. This exception applies only where 
a covered account is managed by a third-party registered investment advisor with 
discretionary authority over the account. To qualify for this exception, you must have 
previously obtained written approval from the Ethics Office to maintain the managed 
account. 
When the conflicting personal trade or fund trade is in options or futures on, or ETFs that 
track, the following indexes: Dow Jones Industrial Average, NASDAQ 100, Russell 
1000, Russell 2000, S&P 100, S&P 500, S&P Midcap 400, S&P Europe 350, FTSE 100, 
FTSE Mid 250, FTSE 350, Hang Seng 100, Deutscher Aktien IndeX (DAX 30), 
S&P/TSX 60, NSE S&P CNX Nifty (Nifty 50), and Nikkei 225. 
When the conflicting personal trade or fund trade is in options, futures, or ETFs based on 
one or more instruments that are not covered securities (i.e., commodities, currencies, and 
U.S. Treasuries; see Key Concepts on page 7 for an expanded list of non-covered 
securities). 
 
To Do 
Before trading personally, consider whether there is any likelihood that you may be 
interested in trading a covered security of the same issuer in your assigned funds within 
seven calendar days following the day of the fund trade. If so, refrain from personally 
trading in a covered account. If a fund you manage has recently traded a security, 
you must delay any covered account trades in any covered security of the same issuer for 
seven calendar days following the day of the most recent fund trade. 
Contact the Ethics Office immediately to discuss any situation where these rules would 
work to the disadvantage of the funds. 
 
Legal Information The Code of Ethics for Personal Investing constitutes the Code of 
Ethics required by Rule 17j-1 under the Investment Company Act of 1940 and by Rule 
204A-1 under the Investment Advisers Act of 1940 for the Fidelity funds, FMR LLC 
subsidiaries that are the funds’ investment advisors or principal underwriters, Fidelity 
Management Trust Company, subsidiaries of Pyramis Global Advisors Holdings Corp., 
and any other entity designated by the Ethics Office. 
Fidelity is required to provide a copy of this Code of Ethics, and any amendments to it, to 
all employees covered under it.