Fidelity, through an affiliate, provides recordkeeping services to companies (plan sponsors) for their equity compensation plans through stock plan services (SPS) accounts for the companies’ domestic and international employees (plan participants). From December 2012 to October 2020, the firm’s supervisory system, including its written supervisory procedures, was not reasonably designed to supervise associated persons’ access to SPS account data or the transmittal of funds from international SPS accounts.