SEC Division of Investment Management staff letter: Fidelity Canada Fund

Fidelity Investment Trust
Fidelity Canada Fund
VIA ELECTRONIC MAIL: imshareholderproposals@sec.gov December 20, 2019 U.S. Securities & Exchange Commission 100 F Street NE Washington, DC 20549 Attn: Office of Disclosure and Review Re: Shareholder Proposals for: Fidelity Canada Fund, series of Fidelity Investment Trust (File No. 811-04008) Ladies and Gentlemen:
As indicated in the table below, letters were received at the principal executive offices of Fidelity Canada Fund (the "Fund"), requesting that a proposal be submitted to shareholders at the next scheduled meeting of the Fund. As detailed in the letters, copies of which are attached, the proposals request that the Boards of Trustees of the Fund implement certain procedures to prevent the Fund from holding investments in companies that, in management's judgment, substantially contribute to genocide or crimes against humanity. Shareholder (each, a "Proponent" and Defect Letter collectively the (the "Defect Letter") Proponents) Proposal Dated Dated Erin O'Brien April 5, 2010 August 30, 2018 and October 9, 2018 Peter J. Barrer July 30, 2010 August 30, 2018 Pursuant to Rule 14a-8(b)(1 ), to be eligible to submit a proposal, a shareholder must have continuously held at least $2,000 in market value, or 1 %, of the company's securities entitled to be voted on the proposal at the meeting for at least one year by the date the proposal is submitted, and must continue to hold those securities through the date of the meeting. Upon initial receipt of the letters, the Fund verified that each Proponent met the eligibility requirements to submit a proposal pursuant to Rule 14a-8(b)(1 ). In preparation for an upcoming shareholder meeting, the Fund attempted to verify that each Proponent continues to satisfy the eligibility requirements of Rule 14a-8(b)(l). The Fund determined that each Proponent was not a record owner of the Fund's shares. On the dates referred to above, we sent each Proponent a Defect Letter, copies of which are attached, requesting that the Proponent provide the information necessary to confirm that he or she continues to meet the requirements of Rule 14a-8(b)(l). To date, the Proponents have not responded to the Fund's requests and have not provided the

December 20, 20 19
Office ofDisclosure and Review information necessary to permit the Fund to confirm that the requirements of Rule 14a-8(b)(l) continue to be satisfied. The next shareholder meeting for the Fund is scheduled to be held on or about May 20, 2020. Because the Fund is unable to confirm based on its records that either Proponent continues to be a shareholder of the Fund and has continuously held the requisite amount of that Fund's shares since the submission of the proposal as required by Rule 14a-8(b)(1 ), and because neither Ms. O'Brien nor Mr. Barrer have responded to requests to provide additional holdings information, we intend to omit this proposal from the proxy statements for the Funds as permitted by Rule 14a-8(f)(l ). If you have questions or comments concerning this matter, please contact Brian Blackbum at (617) 563-7121. Sincerely, Cynt a Lo Bessette Secretary ofthe Trust Enclosures:
Letters to Erin O'Brien
Letter from Erin O'Brien
Letter to Peter J. Barrer
Letter from Peter J. Barrer cc: Erin O'Brien
Peter J. Barrer

FIDELITY INVESTMENT TRUST
Fidelity Canada Fund
FIDELITY HASTINGS STREET TRUST
Fidelity Growth Discovery Fund
FIDELITY MAGELLAN FUND
Fidelity Magellan Fund
VIA CERTIFIED MAIL,
RETURN RECEIPT REQUESTED
August 30, 2018
Erin O'Brien
Dear Ms. O'Brien:
Your previously submitted shareholder proposals, dated April 5, 2010 for the funds (each, a "Fund") and registrants (each, a "Tmst") identified in the table below. Fund Fideli Fideli Investment Trust Fund Hastin s Street T1ust Ma ellan Fund Rule 14a-8(b)(l) provides that in order to be eligible to submit a proposal for inclusion in a proxy statement for a fund, a shareholder must have "continuously held at least $2,000 in market value, or 1%, of the company's secmi ties entitled to be voted on the proposal at the meeting for at least one year by the date [the shareholder] submit[s] the proposal and "must continue to hold those securities through the date ofthe meeting." As required by Rule l 4a-8(b )(2), you have provided a written statement that you "intend to meet Rule l 4a-8 requirements including the continuous ownership ofthe required stock value until after the date ofthe respective shareholder meeting." Based on a review of the Fund's records, we are unable to confirm that you continue to hold the amount of Fund shares required under Rule l 4a-8(b )(I). As provided in Rule l 4a-8(b )(2), we request that you provide us with information about your holdings so that we may verify your continued eligibility to submit a shareholder proposal for the Fund. By this letter we hereby provide you with the oppo1tunity to send us info1mation regarding your holdings with respect to shares of the Fund so that we may verify that you have continuously held the requisite amount ofFund shares and, thus, continue to be eligible to submit a shareholder proposal for the Fund. We request that your response be postmarked, or transmitted electronically, no later than 14 days from the date you receive this notification. Please direct all fmther con espondence with respect to this shareholder proposal to: Fund Shareholder Meetings, 245 Summer Street, Mailzone Vl0B, Boston, MA 02110 or (617) 385-2890 (fax).

Erin O'Brien
August 30, 2018
Page Two
This letter shall not be deemed to waive any right of the Fund to omit any proposal from the proxy materials for the Fund’s next shareholders’ meeting for any other reason. Sincerely, Marc R. Bryant Secretary of the Trust

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FIDELITY INVESTMENT TRUST
Fidelity Canada Fund
FIDELITY HASTINGS STREET TRUST
Fidelity Growth Discovery Fund
FIDELITY MAGELLAN FUND
Fidelity Magellan Fund
VIA CERTIFIED MAU,,
RETURN RECEIPT REQUESTED
October 9, 2018
Dear Ms. O'Brien:
Your previously submitted shareholder proposals, dated April 5, 2010 for the funds (each, a "Fund") and registrants ( each, a "Trust'') identified in the table below. Fund Investment Trust Fideli Fund Hastin°s Street Trust Fideli Ma ellan Fund Rule l 4a-8(b )(1) provides that in order to be eligible to submit a proposal for inclusion in a proxy statement for a fund, a shareholder must have "continuously held at least $2,000 in market value, or 1%, of the company's securities entitled to be voted on the propqsal at the meeting for at least one year by the date [the shareholder] submit[s] the proposal and "must continue to hold those securities through the date ofthe meeting." As required by Rule 14a-8(b)(2), you have provided a written statementthat you "intend to meet Rule l 4a-8 requirements including the continuous ownership ofthe required stock value until after the date of the respective shareholder meeting." Based on a review of the Fund 's records, we are unable to confinn that you continue to hold the amount of Fund shares required under Rule l 4a-8(b )(I). As provided in Rule 14a-8(b )(2), we request that you provide us with information about your holdings so that we may verify your continued eligibility to submit a shareholder proposal for the Fund. By this letter we hereby provide you with the opportunity to send us information regarding your holdings with respect to shares of the Fund so that we may verify that you .have continuously held the requisite amount of Fund shares and, thus, continue to be eligible to submit a shareholder proposal for the Fund. We request that your response be postmarked, or transmitted electronically, no later than 14 days from the date you receive this notification. ln the interest oftime, we have also sent a copy ofthis letter to your address in North Grafton, Massachusetts. The content of that letter is identical and you need only respond to one copy for validation purposes.

Erin O'Brien
October 9, 2018
Page Two
Please direct all further correspondence with respect to this shareholder proposal to: Fund Shareholder Meetings, 245 Summer Street, Mailzone Vl 0B, Boston, MA 02110 or (617) 385-2890 (fax). This letter shall not be deemed to waive any right ofthe Fund to omit any proposal from the proxy materials for the Fund's next shareholders' meeting for any other reason. Sincerely, r) (ifB:L William C.~o~ey Secretary ofthe Trust

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FIDELITY INVESTMENT TRUST
Fidelity Canada Fund
FIDELITY HASTINGS STREET TRUST
Fidelity Growth Discovery Fund
FIDELITY MAGELLAN FUND
Fidelity Magellan Fund
VIA CERTIFIED MAIL,
RETURN RECEIPT REQUESTED
October 9, 2018
Erin O'Brien
Dear Ms. O'Brien:
Your previously submitted shareholder proposals, dated April 5, 20IO for the funds ( each, a "Fund~') and registrants ( each, a "Trust") identified in the table below. Fund Fideli anada Fund Fi ent Trust Fideli h Discove Fund Fid s Street Trust Fideli ellan Fund Fid n Fund Rule l 4a-8(b )( 1) provides that in order to be eligible to submit a proposal for inclusion in a proxy statement for a fund, a shareholder must have "continuously held at least $2,000 in market value, or 1%, of the company's securities entitled to be voted on the proposal at the meeting for at least one year by the date [the shareholder] submit[s) the proposal and "must continue to hold those securities through the date ofthe meeting." As required by Rule l 4a-8(b )(2), you have provided a written statement that you " intend to meet Rule I 4a-8 requirements including the continuous ownership ofthe required stock value until after the date ofthe respective shareholder meeting." Based on a review of the Fund 's records, we are unable to confirm that you continue to hold the amount of Fund shares required under Rule l 4a-8(b )(1 ). As provided in Rule I 4a-8(b )(2), we request that you provide us with infonnation about your holdings so that we may verify your continued eligibility to submit a shareholder proposal for the Fund. By this letter we hereby provide you with the oppo1tunity to send us information regarding your holdings with respect to shares of the Fund so that we may verify that you have continuously held the requisite amount of Fund shares and, thus, continue to be eligible to submit a shareholder proposal for the Fund. We request that your response be postmarked, or transmitted electronically, no later than 14 days from the date you receive this notification. Please direet all further correspondence with respect to this shareholder proposai to: Fund Shareholder Meetings, 245 Summer Stree(, Mailzone V l 0B, Boston, MA 02 l IO or (617) 385-2890 (f~).

Erin O'Brien
October 9, 2018
Page Two
This letter shall not be deemed to waive any right ofthe Fund to omit any proposal from the proxy materials for the Fund's next shareholders' meeting for any other reason.

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I am writing to submit the enclosed shareholder proposals for inclusion in the funds' next proxy statement and for presentation at their next shareholder meeting. Ihope that once they are on the ~ ballot, you will take a favorable, or at least neutral, stance with regard to the proposals. (;)
co I hold 172 shares of the Fidelity Growth Discovery Fund in account- 44.9 shares of the ....
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0 I am also enclosing statements of my account to confirm my ow~~rship of said shares. I have I) continuously held at least $2,000 of each fund for over a year and it is my intention to continue to do m so. 0 _, Please confirm receipt of this cover letter and the proposal. If for any reason you choose to exclude this proposal from your proxy please notify me at the above address. Other shareholders may have submitted this shareholder proposal in support of a campaign initiated by Investors Against Genocide. If another shareholder has already submitted the same proposal, please consider this a joint submission in support of his/her proposal. Thanks for your consideration. Sincerely, I•• .. J ·.. · ... . . I·. . . · Erin O'Brien ·: '. 1 En·c1osures FIMS_RETAIL:509047456 lo uJ (.(I VI N f"-f C:'.) i-1 00 0 ~ G.) LIi N M 0 l"'1 OQ 0 ct 0 I Cf) ..,j QQ C'/J co 0 I 00 ~ e:, N

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Genocide-free Investing
Shareholder Proposal for Fidelity Growth Discovery Fund Fidelity has released no genocide-free investing policy to prevent investments that contribute to genocide. It may at any 0 ....., time increase such holdings or involve new mutual funds. As a result, Individuals, through their mutual funds, may ....., inadvertently invest in companies helping to fund genocide because of investment decisions made by Fidelity . U) We believe that: I..N I 0 1) Investors do not want their pensions and family savings connected to genocide. .f;:. a) Reasonable people may disagree about what constitutes socially responsible investing, but few people want their 0 savings connected to genocide. U) b) In the face of the most extreme human rights crises investment companies share responsibility, along with .... government, to act. 0 c) In KRC Research's 2007 study, 71% of respondents said companies should consider extreme human rights abuses, such as genocide, when making investment decisions. Millions of people voted for similar sharehOlder .... proposals, submitted by supporters of Investors Against Genocide, despite active management opposition. N ..... 2) This problem is particularly important to shareholders because Fidelity:
a) Has, for years, been a large holder of PetroChina, which, through Its closely related parent, China National 0 Petroleum Company, is internationally recognized as the worst offender helping fund the Government of Sudan's .f;:. genocide in Darfur. 0 b) Actively opposed earlier shareholder requests for genocide-free investing. (0 c) Continued to buy shares of problem companies even after becoming aware of the Investment's connection to the f,-1 Darfur genocide. e d) Claimed to have a policy addressing extreme human rights issues, but has taken no action to avoid problem investments. ~ N 3) A policy against investments in genocide must: 0 a) Be clear and transparent. rv m b) Apply today and to any future genocide. c) Prevent purchasing shares of companies known to substantially contribute to genocide. 0 d) Require corrective action for existing problem investments. If the fund holds problem companies and can -I effectively influence their behavior, then time-limited engagement may be approprtate. If not, the problem investments should be sold.
4) There are no sound financial, fiduciary, or legal reasons that prevent the fund from having a policy against
Investments in genocide, as TIAA-CREF demonstrated in 2009. a) Ample competitive investment choices exist, even with index funds. b) Avoiding a small number of problem companies need not have a significant effect on perfonnance, as shown in Gary Brinson's classic asset allocation study. c) Even the most conservative legal concerns can be addressed by a small change to the prospectus. d) Management can easily obtain independent assessments of problem companies and their connection to genocide.
5) Investor pressure can help influence foreign governments, as in South Africa. Simllariy, divestment pressure on 0
rl Talisman Energy helped end the conflict in South Sudan. co 0 RESOLVED: t::J' (;) Shareholders request that the Board institute transparent procedures to prevent holding investments in companies that, in 1 management's judgment, substantially contribute to genocide or crimes against humanity, the most egregious violations of 13, human lights. rl 0:, Cl'J c-:i c:J I OCI q' 0 FIMS_RETAIL:509047456 N

FIDELITY INVESTMENT TRUST
Fidelity Canada Fund
FIDELITY SUMMER STREET TRUST
Fidelity Capital & Income Fund
VIA CERTIFIED MAIL,
RETURN RECEIPT REQUESTED
August 30, 2018
Dear Mr. Bauer:
Your previously submitted shareholder proposals, dated July 30, 2010, for the funds (each, a "Fund") and registrants (each, a "Tmst") identified in the table below. Fund Registrant Fidelity Canada Fund Fidelity Investment Trust Fidelity Capital & Income Fund Fidelity Summer Street Tmst Rule 14a-8(b)(l) provides that in order to be eligible to submit a proposal for inclusion in a proxy statement for a fund, a shareholder must have "continuously held at least $2,000 in market value, or 1%, of the company's secmities entitled to be voted on the proposal at the meeting for at least one year by the date [the shareholder] submit[s] the proposal and "must continue to hold those securities through the date ofthe meeting." As required by Rule l 4a-8(b )(2), you have provided a written statement that you "intend to meet Rule l 4a-8 requirements including the continuous ownership ofthe required stock value until after the date ofthe respective shareholder meeting." Based on a review of the Fund's records, we are unable to confnm that you continue to hold the amount of Fund shares required under Rule l 4a-8(b )(I). As provided in Rule l 4a-8(b )(2), we request that you provide us with information about your holdings so that we may verify your continued eligibility to submit a shareholder proposal for the Fund. By this letter we hereby provide you with the oppo1tunity to send us info1mation regarding your holdings with respect to shares of the Fund so that we may verify that you have continuously held the requisite amount ofFund shares and, thus, continue to be eligible to submit a shareholder proposal for the Fund. We request that your response be postmarked, or transmitted electronically, no later than 14 days from the date you receive this notification. Please direct all fmther conespondence with respect to this shareholder proposal to: Fund Shareholder Meetings, 245 Summer Street, Mailzone Vl0B, Boston, MA 021 10 or (617) 385-2890 (fax).

Peter J. Barrer
August 30, 2018
Page Two
This letter shall not be deemed to waive any right of the Fund to omit any proposal from the proxy materials for the Fund’s next shareholders’ meeting for any other reason. Sincerely, Marc R. Bryant Secretary of the Trust

July 30, 2010
Fidelity Investments
Secretary of the Trust
Attention "Fund Shareholder Meetings"
82 Devonshire Street, Mailzone V1 0A
Boston, Massachusetts 02109
To the Secretary:
I am writing to submit the enclosed shareholder proposals (4) to Fidelity's Canada Fund, International Discovery Fund, Capital and Income Fund and Investment Grade Bond Fund for inclusion in their next proxy statements and for presentation at their next shareholder meetings. I hope that once this is on the ballot, you will take a favorable, or at least neutral, stance with regard to the proposal. I hold 4,187 shares of Canada Fund, 526 shares of International Discovery Fund, 31,684 shares of Capital and Income Fund and 37,557 shares of Investment Grade Bond Fund in Fidelity account number in my name and address as listed above. I am also enclosing a statement of my Fidelity account to confirm my ownership of said shares. I have continuously held at least $2,000 of these four funds for over a year and it is my intention to continue to do so. Please confirm receipt of this cover letter and four shareholder proposals. If for any reason you choose to exclude this proposal from your proxy please notify me at the above address. Other shareholders may have submitted this shareholder proposal in support of a campaign initiated by Investors Against Genocide. If another shareholder has already submitted the same proposal, please consider this a joint submission in support of his/her prof:)osal. · Thank you for your consideration. Sincerely, Peter J. Barrer

Genocide-free Investing
Shareholder Proposal for Fidelity Canada Fund
WHEREAS:
Fidelity has released no genocide-free investing policy to prevent investments in companies that contribute to genocide. It may at any time increase such holdings or involve new mutual funds. As a result, individuals, through their mutual funds, may inadvertently invest in companies helping to fund genocide because of investment decisions made by Fidelity. We believe that:
1) Investors do not want their pensions and family savings connected to genocide.
a) Reasonable people may disagree about what constitutes socially responsible investing, but few people want their savings connected to genocide. b) In the face of the most extreme human rights crises investment companies share responsibility, along with government, to act. c) In KRC Research's 2010 study, 88% of respondents said they would like their mutual funds to be genocide-free. d) Millions of people have voted for shareholder proposals similar to this one, submitted by supporters of Investors Against Genocide, despite active management opposition.
2) This problem is particularly important to shareholders because Fidelity:
a) Has, for years, been a large holder of PetroChina, which, through its closely related parent, China National Petroleum Company, is internationally recognized as the worst offender helping fund the Government of Sudan's genocide in Darfur. b) Actively opposed earlier shareholder requests for genocide-free investing. c) Continued to buy shares of problem companies even after becoming aware of the investment's connection to the Darfur genocide. d) Claimed to have a policy addressing extreme human rights issues, but has taken no action to avoid problem investments.
3) A policy against investments in genocide must:
a) Be clear and transparent. b) Apply today and to any future genocide. c) Prevent purchasing shares of companies known to substantially contribute to genocide. d) Require corrective action for existing problem investments. If the fund holds problem companies and can effectively influence their behavior, then time-limited engagement may be appropriate. If not, the problem investments should be sold. ·
4) There are no sound financial, fiduciary, or legal reasons that prevent the fund from having a policy against
investments in genocide, as TIAA-CREF demonstrated in 2009. a) Ample competitive investment choices exist, even with index funds. b) Avoiding a small number of problem companies need not have a significant effect on performance, as showri in Gary Brinson's classic asset allocation study. c) Even the most conservative legal concerns can be addressed by a small change to the prospectus. d) Management can easily obtain independent assessments of problem companies and their connection to genocide.
5) Investor pressure can help influence foreign governments, as in South Africa. Similarly, divestment pressure on
Talisman Energy helped end the conflict in South Sudan.
RESOLVED:
Shareholders request that the Board institute transparent procedures to prevent holding investments in companies that, in management's judgment, substantially contribute to genocide or crimes against humanity, the most egregious violations of human rights.

Resources

Incoming Letter