SEC Division of Investment Management staff letter: Fidelity Mid-Cap Stock Fund

Fidelity Concord Street Trust
Fidelity Mid-Cap Stock 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 Mid-Cap Stock Fund, series of Fidelity Concord Street Trust File No. 811-05251 Ladies and Gentlemen:
As indicated in the table below, letters were received at the principal executive offices of Fidelity Mid-Cap Stock Fund (the "Fund"), requesting that a proposal be submitted to shareholders at the next scheduled meeting ofthe 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"} proponent)s proposaIDaet d Dtdae Jerome E. Meyer April 18, 2010 August 30, 2018 Mary Haskell* September 17, 2007 and July 24, 2010 August 30, 2018 October 9, 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 l %, 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 ofthe 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 eligibi !ity requirements or Rule I4a-8(b )( I). 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

Ms. Haskell actively confinned redemption of her shares on September 20, 2018.

December 20, 2019
Office of Disclosure and Review
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)(I). To date, one Proponent confinned their redemption of Fund shares and the remaining Proponent has not responded to the Fund's requests and has not provided the information necessary to permit the Fund to confirm that the requirements ofRule 14a-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 any Proponent continues to be a shareholder of the Fund and have continuously held the requisite amount of that Fund's shares since the submission ofthe proposal as required by Rule 14a-8(b)(l), and because Mr. Meyer did not respond to a request to provide additional holdings information, we intend to omit this proposal from the proxy statements for the Funds as permitted by Rule I 4a-8(f)( I). If you have questions or comments concerning this matter, please contact Brian Blackbum at (617) 563-7121. essette Secretary of the Trust Enclosures:
Letter to Jerome E. Meyer
Letter from Jerome E. Meyer cc: Jerome E. Meyer

FIDELITY CONCORD STREET TRUST
Fidelity Mid-Cap Stock Fund
VIA CERTIFIED MAIL,
RETURN RECEIPT REQUESTED
August 30, 2018
Jerome E. Me er
Dear Mr. Meyer:
Your shareholder proposal, dated April 18, 2010, was previously received in the principal executive offices ofFidelity Mid-Cap Stock Fund (the "Fund"), a series of Fidelity Concord Street Tmst (the "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 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 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 ve1ify your continued eligibility to submit a shareholder proposal for the Fund. By this letter we hereby provide you with the oppo1tunity to send us inf01mation 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. B1yant Secretaiy of the Tmst

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April 18, 2010
Fidelity Investments
Secretary ofthe Trust
Attention "Fund Shareholder Meetings"
82 Devonshire Street, Mail Zone VlOA
Boston, Massachusetts 02109
To the Secretary:
I am writing to submit the enclosed shareholder proposals to four Fidelity funds for inclusion in their next proxy statements and for presentation at their next shareholder meetings. I hope that once they are on the ballot, you will take a favorable, or at least neutral, stance with regard to the proposal. The funds and the number ofshares I own ofeach are
1) Fidelity Contrafund (FCNKX) ;;2. '-/.>, f'" 7 7 shares
2) Fidelity Inflation-Protected Bond Fund (FINPX) r-3 ~ , et IS-- shares
3) Fidelity Low-Priced Stock Fund (FLPKX) 3 I l/, 7 Cf O shares
4) Fidelity Mid-Cap Stock Fund (FKMCX) 'f6 ?, :)..

9 .Sshares
I am also enclosing a statement ofmy Fidelity Benefits account# which confirms my ownership ofsaid shares. I have continuously held at least $2,000 of each ofthe four funds for over a year and it is my intention to continue to do so. Please confirm receipt ofthis 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 ofa campaign initiated by Investors Against Genocide. If another shareholder has already submitted the same proposal, please consider this a joint submission in support ofhis/her proposal. Thanks for your consideration. Sincerely, Jerome E. Meyer

Genocide-free Investing
Shareholder Proposal for Fidelity Low-Priced Stock 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 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. 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.

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