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Response to sanctions and market liquidity in Russia

Fidelity

Fidelity - Research team

The Board of Directors (‘the Board’) of Fidelity Emerging Markets Limited (“the Company”) and the Investment Manager, FIL Investment Services (UK) Limited (“Fidelity International”) provide the following update to shareholders.

Position Statement

Given the seriousness of events in Ukraine, Fidelity International has made the decision to cease all investment in Russia and Belarus for the foreseeable future. As such, Fidelity International and its associates have implemented a group-wide prohibition on any new or additional purchases of Russian and Belarusian securities, which will apply to the portfolio of the Company. Fidelity International is addressing the Company’s existing exposure and, where it is possible and appropriate, will look at options to reduce it in a thoughtful way which protects the interests of shareholders and mitigates unintended consequences.

The Board and Investment Manager appreciate that this is an extremely uncertain time, with heightened concern about the situation in Ukraine, the humanitarian consequences, and also potential for volatility in financial markets.

Fidelity International’s investment teams, and supporting functions, continue to evaluate the risk environment and are monitoring the situation closely to ensure that, where possible, mitigating actions are put in place to address current and potential impacts on the portfolio. In consultation with key stakeholders, legal and compliance teams, and advisers, Fidelity International will review and comply with any economic sanctions imposed, adjusting the Company’s portfolio if, and where required.

Fair Value Pricing of Russian Securities

In a normal market environment, the prices of assets actively traded are determined with reference to the latest available market price prevailing at the valuation point.

In the current environment, the market for local currency and hard currency Russian securities is very limited. In these circumstances, Fidelity’s Fair Value Pricing process (functionally independent from the Investment Manager) enacts an ‘extraordinary events’ process: a Fair Value Committee (“FVC”) emergency meeting is convened, which will include specialist support from specific areas of the business.

The FVC assesses the impact of an extraordinary event such as the Russian invasion of Ukraine and its potential impact on the price of securities held by the Company. It takes into account the price moves in related securities and the degree of ‘Price Discovery’ that is available in the marketplace. The response would be required to ensure equitable treatment of shareholders and ensure that prices are adjusted to reflect what is likely to be the ‘true’ value of these securities.

Over the course of the last few days, the FVC has significantly marked down the prices of the Russian securities in the Company, as you would expect. This may include, for domestically listed securities that are not currently tradeable and for those where there is no price discovery, adjusting to zero. These adjustments have been and will be reflected in daily published NAVs, and the weights of those securities and the aggregate Russia exposure of the Company moving forward.  The aggregate exposure to all Russian securities (listed domestically and on overseas exchanges) as of 2 March 2022 has reduced accordingly to 0.04% of NAV.

It is worth noting that this approach has not necessarily been taken by index providers where weights of individual securities and aggregate Russian exposure may reflect the ‘screen price’.

Market volatility is an inevitable and inherent part of investing, and Fidelity International has well established processes in place to deal with it. The Board’s and Investment Manager’s current focus is to be mindful and vigilant around volatility in the short term and as always, stay focused on the long-term outlook.

Further detail on the approach and fund level exposures to Russian securities are available on request.