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"Fidelity International does not tolerate modern slavery or human trafficking within its business operations and takes a risk-based approach regarding its supply chain. Given the professional and regulated nature of our business, and the fact that we do not have intricate supply chains or obtain material services from external businesses located in high risk countries, we have a low-risk of modern slavery or human trafficking within our business operations and supply chain.

Our procurement process includes performing a full risk assessment on every new supplier to determine the inherent risk the supplier and its service brings to Fidelity. In addition to a full risk assessment, all suppliers which are not classed as low-risk, undergo enhanced due diligence screening activities which range from financial crime, information security, and data protection assessments along with more standard financial stability checking.

Our template supplier agreements require new material suppliers to comply with all applicable anti-slavery and human trafficking laws and to agree not to engage in any activity anywhere in the world that would be an offence under the Modern Slavery Act 2015 if the activity were undertaken in the UK. All new suppliers and any existing suppliers which are due for renewal are required to accept the Fidelity supplier code of conduct which sets out the standards and behaviours we expect from our suppliers, including adherence to employment standards, nondiscrimination and human rights legislation. Effective from 2020, a new supplier management tool has been rolled out within the organisation which requires an annual attestation from all suppliers (other than low-risk) of their acceptance of the Fidelity supplier code of conduct along with a comprehensive set of requirements on monitoring the suppliers performance against its contractual obligations. In 2021, we will be making a sustainability assessment mandatory for our material and critical suppliers. The sustainability assessment covers seven management indicators, across 21 sustainability criteria, in four themes: environment, labour & human rights, ethics and sustainable procurement. It is based on leading standards such as GRI, UNGC and ISO 26000. Performance is rated by assessing a supplier’s policy, actions and results, as well as inputs from third-party professionals and external stakeholders."