Our Responsible Investment Policy (the “Policy”) provides information on how Fidelity Investments Canada ULC1  undertakes investment stewardship. Environmental, social and/or governance (“ESG”) investing at Fidelity is an approach that incorporates ESG factors into our fundamental research process to assess a company’s risks and opportunities.

Fidelity leverages dedicated sustainable investing resources, which are generally focused on the common key areas identified in the Policy. Engagement is implemented as part of our overall fundamental research process and is generally applied across issuers and will include discussions of ESG and other factors where they have a material impact on either investment risk or return potential. Proxy voting, as further described in the Policy, is carried out across all Fidelity Funds according to each sub-advisor’s proxy voting guidelines, regardless of whether a Fund is ESG-focused or not.

A. Stewardship

Fidelity primarily pursues active investment styles informed by rigorous bottom-up fundamental research. Our primary objective is to deliver long-term investment performance to our clients. Accordingly, we seek a thorough understanding of all aspects of the companies in which we invest.

Fidelity believes that high standards of corporate responsibility generally make good business sense. The investment research process undertaken by our analysts and portfolio managers takes ESG factors into account when, in our view, these have a material impact on either investment risk or return potential. Fidelity believes ESG factors are important inputs into the overall research process and can help identify companies that can drive long-term value creation for investors.

For Fidelity Funds that have an ESG-focused investment objective, please refer to the investment objectives and investment strategies in those funds’ prospectuses, which articulate the ESG parameters used. For non-ESG-focused Fidelity Funds, the applicable Fidelity adviser and portfolio manager(s) have full discretion in determining whether and how relevant and material ESG factors are to a company’s evaluation, consistent with their investment objectives, investment strategies and investable universe. In cases where a non-ESG-focused Fidelity Fund uses one or more ESG strategies (e.g., best-in-class, ESG integration, negative screening, etc.), either as part of its principal investment strategy or investment selection process, we will describe the ESG strategy used in the applicable prospectus of that fund.

For our active investment strategies, regular engagement with company management teams informs our investment decisions and may also serve as a forum to encourage company management to improve procedures and policies. As a general policy, we aim to support the management of the companies in which we invest, but our dialogue with companies is a robust one, and we will form our own views on the strategy and governance of a business. On occasion, our views may differ from those of a company’s management or board. In certain situations, if differences with a company remain unresolved, we may vote against the board in a general meeting. We generally do not intervene on an operational matter; topics that have given rise to disagreements with management in the past include the need for management and/or board change, strategy, capital structure, M&A, protection of shareholder rights and executive compensation. Our specific response will always be determined on a case-by-case basis, and there may be instances when we choose to sell our shares.

B. Investment research process

ESG factors may serve as one of many research inputs in security valuation. Fidelity believes ESG factors are important inputs into the overall research process and can help identify companies that can drive long-term value creation for investors. Fidelity incorporates the use of proprietary and/or third-party ESG/sustainability ratings to inform investment research. For example, the proprietary ESG/sustainability ratings of Fidelity are driven by fundamental inputs and determined by research professionals across the organization using multiple data sources including public disclosures, company management engagements, and third-party data, such as MSCI ESG research data, which is used to supplement our own fundamental research. Companies are evaluated based on the ESG factors that are germane and material to their operations and business over the long term. The proprietary ratings serve as a forward-looking assessment of how a company is incorporating ESG considerations into its business model as well as its ESG performance and trajectory. The monitoring process of ESG risks, factors and opportunities is undertaken as part of the fundamental research process, which includes the assessment of material financial and ESG factors for all companies under coverage, which is updated on a regular basis.

For our active investment strategies, Fidelity’s investment analysts are typically the primary point of contact between Fidelity and companies in which we invest our funds. Analysts undertake extensive quantitative and qualitative analysis of potential investments. Formal meetings involving both portfolio managers and analysts are generally held with investee companies at least twice a year.

Meetings are supplemented by site visits and ad hoc calls, when necessary. Research sources may include customers, suppliers, competitors, external industry experts, sell-side investment analysts and other shareholders, contacted both directly and through intermediary networks.

C. ESG integration

ESG analysis is primarily carried out at the analyst level within our investment teams. Our portfolio managers may also be active in analyzing the potential effects of material ESG factors when making investment decisions.

For our active investment strategies, our investment approach involves bottom-up research. As well as studying financial conditions and results, our portfolio managers and analysts carry out additional qualitative analysis of potential investments. They examine the business, customers and suppliers to develop a view on every company in which we invest.

Examples of ESG factors that our investment teams may consider as part of their fundamental research process

  • corporate governance (e.g., board structure, executive remuneration)
  • shareholder rights (e.g., election of directors, capital amendments)
  • changes to regulation (e.g., greenhouse gas emissions restrictions, governance codes)
  • physical threats (e.g., extreme weather, climate change, water shortages)
  • brand and reputational issues (e.g., poor health and safety record, cyber security breaches)
  • supply chain management (e.g., increase in fatalities, lost time injury rates, labour relations)
  • work practices (e.g., observation of health, safety and human rights provisions)

D. Sub-advised assets

In order to provide our clients access to a wide range of strong investment management talent, Fidelity delegates investment management responsibility for certain assets to various sub-advisors. All of our sub-advisors have a responsible investment policy that outlines how ESG factors are integrated into their investment research process.2  Furthermore, all of our sub-advisors have demonstrated a commitment to furthering the adoption and use of sustainable investment practices by becoming signatories to the United Nations–supported Principles for Responsible Investment.

E. Proxy Voting

Proxy voting is carried out in a consistent manner across all Fidelity Funds according to the applicable portfolio adviser’s proxy voting guidelines, which are publicly available on our designated website, regardless of whether a Fidelity Fund is ESG-focused or not.

Information to inform the voting process is derived from a variety of sources and includes material provided by the company, proxy voting advisory services and internal and external research. Discussions may also be held with investee companies themselves. Fidelity’s approach to and policy regarding the exercise of voting rights are conducted in accordance with applicable laws and regulations, as well as being consistent with the respective investment objectives of the various portfolios.

Proposals not specifically addressed by the applicable portfolio adviser’s proxy voting guidelines will be voted based on an evaluation of a proposal’s likelihood to enhance the long-term economic returns or profitability of the company or to maximize long-term shareholder value. Fidelity will not be influenced by business relationships or outside perspectives that may conflict with the interests of the Fidelity Funds and their securityholders.

We disclose our voting record for the preceding 12-month period ending June 30 on our website, and this information is updated once a year.

Board of Directors

A well-functioning board is critical to the success and long-term sustainability of a company. Fidelity continually assesses the integrity, competence and capacity of individual directors. We believe that adequate independence on a board and its committees is critical in protecting shareholder value.

We strongly support companies assessing and, where relevant, improving the balance of independent representation on the board. The board should also hold individual directors accountable through performance evaluations on an ongoing basis.


Fidelity believes it is in the interest of shareholders that boards should have the ability to attract and retain the highest quality of executive directors. In our view, setting appropriate remuneration levels is primarily the responsibility of the remuneration committee of the board, and this will be a market-based judgement, although all remuneration arrangements should be aligned with the interests of shareholders and be proportionate to the contribution of the individuals concerned. Companies should also seek to achieve an appropriate balance between the rewards to management and the returns to shareholders.

We support the concept of variable remuneration and believe that properly crafted incentive plans play a role in aligning the interests of management and owners. We encourage management ownership of shares, and over time we expect executive directors to build a shareholding in the company that is material in relation to their remuneration.

We strongly support the use of performance-driven vesting criteria and believe that these should incorporate a combination of absolute and relative return targets and a direct linkage to share price performance. In many markets, we also encourage a period of mandatory retention once a share award has vested. Remuneration to independent directors should always be appropriate in nature. Consideration should also be made to ensure that independent directors’ remuneration arrangements do not potentially undermine or compromise their independent oversight role.

Shareholder Proposals

The Fidelity Funds generally consider management’s recommendations and current practices when voting on shareholder proposals concerning environmental and social issues because they believe that management and the board are in the best position to determine how to address these matters. In certain situations, where our views differ from those of a company’s management or board, we may seek to engage with management or the board at an early stage to try to resolve differences. Where this is not successful, we may decide to abstain, or to vote against a company’s recommendation. Our guiding principle is that voting rights should always be exercised in the best interest of our clients.

The Fidelity Funds may support shareholder proposals that request additional disclosure from companies regarding environmental or social issues, including where they believe that the proposed disclosure could provide meaningful information to the investment management process without unduly burdening the company. This means that the Fidelity Funds may support, for example, shareholder proposals calling for reports on sustainability, renewable energy, and environmental impact issues. The Fidelity Funds may also support proposals on issues in other areas, including, but not limited to, equal employment, board diversity and workforce diversity.

F. Climate change

Fidelity recognizes that climate change poses risks to the long-term profitability and sustainability of companies. Investors are exposed to downside risks as a result of climate change, including the direct physical impacts of climate change (e.g., extreme weather events affecting agriculture and food supply, infrastructure, precipitation and water supply) and the impacts of policy measures directed at reducing greenhouse gas emissions from certain economic sectors. While we recognize that individual sectors may be at different stages of development with respect to their awareness of climate change risks and integration of climate change factors into their risk analysis and business planning, we nevertheless expect companies to be directionally aspirational in their efforts to address the potential impact of climate change on their business.


May 2023



1.    Subadvisor responsible investment policies
Additional information about the responsible investment approaches and practices of our subadvisors can be found in their respective responsible investment policies using the links below:

2.    Subadvisor proxy voting policies
Additional information about the proxy voting practices of our subadvisors can be found in their respective proxy voting policies using the links below:


1 The terms “we”, “our”, “us” and “Fidelity” refer to Fidelity Investments Canada ULC.
2 Additional information about the responsible investment approaches and practices of our subadvisors is available in their respective responsible investment policies, which can be found using the links in the appendix.