SEC Division of Investment Management staff letter: Fidelity Growth Discovery Fund

Fidelity Hastings Street Trust
Fidelity Growth Discovery 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 Growth Discovery Fund, series of Fidelity Hastings Street Trust; File No. 811-00215 Ladies and Gentlemen:
As indicated in the table below, letters were received at the principal executive offices of Fidelity Growth Discovery 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 October 9, 2018 Ian Andrew Dunn July 24, 2009 August 30, 2018 October 9, 2018 Pursuant to Rule 14a-8(b)(l), 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)(l). 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 l 4a-8(b )(1 ). To date, the Proponents have not responded to the Fund's requests and have not provided the

December 20, 2019
Office of Disclosure and Review information necessary to permit the Fund to confirm that the requirements of Rule l 4a-8(b )( 1) 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 l 4a-8(b )( 1 ), and because neither Ms. O'Brien nor Mr. Dunn 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 l 4a8(f)( 1 ). If you have questions or comments concerning this matter, please contact Brian Blackburn at (617) 563-7121. Cynthi Lo Bessette Secretary of the Trust Enclosures:
Letters to Erin O'Brien
Letter from Erin O'Brien
Letters to Ian Andrew Dunn
Letter from Ian Andrew Dunn cc: Erin O'Brien
Ian Andrew Dunn

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
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 "Trust'') identified in the table below. Fund Investment Trust Fund Hastin°s Street Trust Ma ellan Fund Fideli Fideli 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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(Page 3 of 10)
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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. I hope that once they are on the 0 ballot, you will take a favorable, or at least neutral, stance with regard to the proposals. ~ 0 tO I hold 172 shares of the Fidelity Growth Discovery Fund in account- 44.9 shares of the 1-- Fidelity Canada Fund in account•••■ and 32 shares of the Fidelity Magellan Fund in account 0
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N I am also enclosing statements of my account to confirm rny own~~ship of said shares. I have 0 UJ I) (.!) continuously held at least $2,000 of each fund for over a year and it is my intention to continue to do m Ill c:, so. (\J ...., r-f Please confirm receipt of this cover letter and the proposal. If for any reason you choose to exclude c:.) this proposal from your proxy please notify me at the above address. i-1 ¢0 0 Other shareholders may have submitted this shareholder proposal in support of a campaign initiated ~ by G.) Investors Against Genocide. If another shareholder has already submitted the same proposal, please consider this a joint submission in support of his/her proposal. L/1 (\J Thanks for your consideration. ri Sincerely, 0 M 00 0 t:1 0 I••• I ·.. · .. ' I

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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 HASTINGS STREET TRUST
Fidelity Growth Discovery Fund
VIA CERTIFIED MAIL,
RETURN RECEIPT REQUESTED
August 30, 2018
Ian Andrew Dunn
Dear Mr. Dunn:
Your shareholder proposal, dated July 24, 2009, was previously received in the principal executive offices ofFidelity Growth Discovery Fund (the "Fund"), a series ofFidelity Hastings Street Trust (the "Trust"). 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 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 of the meeting." As required by Rule l 4a-8(b)(2), you have provided a written statement that you "intend to meet Rule 14a-8 requirements including the continuous ownership of the 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 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 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). 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, Marc R. Bryant Secretary of the Trust

FIDELITY HASTINGS STREET TRUST
Fidelity Growth Discovery Fund
VIA CERTIFIED MAIL,
RETURN RECEIPT REQUESTED
October 9, 2018
Ian Andrew Dunn
Dear Mr. Dunn:
Your shareholder proposal, dated July 24, 2009, was previously received in the principal executive offices of Fidelity Growth Discovery Fund (the "Fund"), a series ofFidelity Hastings Street Trust (the "Trust"). Rule l4a-8(b )( I) 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 14a-8(b)(2), you have provided a written statement that you "intend to meet Rule 14a-8 requirements including the continuous ownership ofthe required stock value until after the date ofthe respective shareholder meeting." Based on a review ofthe Fund's records, we are unable to confirm that you continue to hold the amount of Fund shares required under Rule 14a-8(b)(l). 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 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 electroniGally, no later than 14 days from the date you receive this notification. In the interest oftime, we have also sent a copy ofthis letter to your address in Dayton, Ohio. The content ofthat letter is identical and you need only respond to one copy for validation purposes. Please direct all further correspondence with respect to this shareholder proposal to: Fund Shareholder Meetings, 245 Summer Street, Mailzone VIOB, 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 ~ - · William C. C~ Secretary ofthe Trust

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v, I am writing to submit the enclosed shareholder proposal for inclusion in the fund's next proxy 0 statement and for presentation at the next shareholder meeting. I hope that once it is on the ballot, you will take a favorable (or at least neutral) stance with regard to the proposal. 0 ;:: I hold 246.148 shares of Fidelity Growth Discovery Fund In my Account (0 e I am also enclosing a statement of my account confirming my ownership of said shares. I have l "' continuously held at least $2,000 of Fidelity Diversified Growth Discovery Fund for over a year and it o UJ is my intention to continue to do so. t,.a co U'1 Q N Please confirm receipt of this letter. If for any reason you choose to exclude this proposal from your !""I ..., o proxy please notify me at the above address. m c Other shareholders may have submitted this shareholder proposal in support of a campaign initiated (I) _. by Investors Against Genocide. If another shareholder has already submitted the same proposal, 0 (11 please consider this a joint submission in support of his / her proposal. N Thank you for your consideration. "' 0 ,.,...

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AUG-11-2009 01:34P FROM: T0:92920088
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Genocide-Free Investing 1:1
~ 'Shareholder Proposal for Fidelity Growth Discovery Fund (FDSVX) I 0
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I Fidelity portfolio managers make investment decisions based on financial and legal considerations while seeming to Ignore other issues. Even in the face of the most egregious violations of human rights, such as genocide, Fidelity has (;J released no policy to prevent investments that help fund or support such human rights violations. N" a:) Ordinary individuals, through their investments in Fidelity, may inadvertently invest in companies funding genocide ~ because of investment decisions made on their behalf by Fidelity. With no policy to prevent these problem investments, (0 Fidelity may at any time increase its holdings or involve new funds in such problem investments. 0 We believe that this problem is not merely theoretical, since Fidelity was one of the largest holders of PetroChina, which, U'1 through its closely related parent, China National Petroleum company, Is providing funding that the Government of 1-1 Sudan uses to conduct genocide in Darfur. 0 We believe that in the face of the most extreme human rights crises investors share responsibility to act, Individually and '"'"' collectively, in addition to the role and responsibility of governments. I) (.() We believe that investors do not want their pensions and family savings connected to genocide. In KRC Research's ,... (;) 2007 study, 71% of respondents said companies should take extreme cases of human rights abuses, such as genocide, f/j 0 Into account rather than base investment decisions solely on economic criteria. Further, over 150,000 people have objected to financial firms about such problem investments. Reasonable people may disagree about what constitutes w ,-.i 00 socially responsible investing, but few people want their savings to be complicit in genocide. l11 en N rl We believe that negative publicity resulting from the many national press reports and widespread consumer protests can (!) rl m damage the company's reputation, hurt employee morale, increase its cost to acquire customers, and reduce the C, shareholder base for distributing expenses, all of which can negatively impact Fidelity shareholders.

-I We see no compelling reason to invest in companies that fund genocide. We believe there are ample competitive
alternatives and flexibility of investment choices, even with index funds. As noted by Gary Brinson's classic study, investment returns are affected much more by asset allocation than individual security selections, so avoiding a small number of problem companies need not result in any significant effect on performance. Investor pressure has proven effective in influencing foreign governments. The campaign against Talisman Energy contributed to the January 2005 Comprehensive Peace Agreement between Khartoum and South Sudan. RESOLVED:
Shareholders request that the Board institute procedures to prevent holding investments in companies that, in the judgment of the Board, substantially contribute to genocide or crimes against humanity, the most egregious violations of human rights. DISCUSSION:
In addition to preventing future investments in problem companies, the proposal calls for corrective action to address existing investments in problem companies. If the fund can effectively influence the problem company's management, then this may be an appropriate action. If not, the security should be sold.
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