Compensation Program Overview Thrivent Investment Management Inc. (“Thrivent” or “we” or “us”) is an investment adviser and broker- dealer registered with the Securities and Exchange Commission. The words “you” and “your” refer to the person(s) who signs the Thrivent Investment Management Inc. AdvisorFlex Managed Variable Annuity Client Agreement (the “Agreement”) whether one or more individuals or entities. Thrivent sponsors the Thrivent AdvisorFlex Managed Variable Annuity™ program (“AdvisorFlex Program”) a non-discretionary investment advisory and managed accounts program that is described in this Brochure and is a part of Thrivent’s overall Managed Accounts Program (“Program”). The Program also includes a number of other investment advisory, managed account programs sponsored by Thrivent with the objective of managing a portfolio of assets on both a discretionary and nondiscretionary basis. These programs include:
• Thrivent Advisor (“Advisor”)
• Thrivent Advisor Guided (“Advisor Guided”)
• Thrivent Advantage Managed PortfoliosTM (“Advantage”) (closed to new investors)
• Thrivent SELECT Managed PortfoliosTM (“SELECT”)
• Thrivent Income-Focused Managed PortfoliosTM (“Income-Focused”)
• Thrivent Genesis Managed PortfoliosTM (“Genesis”)
• Thrivent Shepherd Managed Portfolios® (“Shepherd”)
• Thrivent Impact Managed PortfoliosTM (“Impact”)
• Thrivent Shield Managed PortfolioTM (“Shield”)
• Thrivent Separately Managed Account (“SMA”)
• Thrivent Unified Managed Account 2.0 (“UMA”) If you are interested in learning more about these other programs, ask your financial advisor (“Financial Advisor”) for a copy of the Thrivent Investment Management Inc. Managed Accounts Program Brochure (“Managed Accounts Program Brochure”). The AdvisorFlex Program enables you to receive ongoing investment advice and related services, including performance, custody and transaction reporting in connection with your Thrivent AdvisorFlex Variable Annuity™—for an asset-based fee (“Program Fee”). Participation in the AdvisorFlex Program may cost you more or less than purchasing these services separately. Envestnet Asset Management, Inc. (“Platform Manager”), an unaffiliated registered investment adviser provides services for the AdvisorFlex Program. Investment advisory services for the AdvisorFlex Program will be provided to you by Thrivent and your Financial Advisor. To participate in the AdvisorFlex Program, you will sign an AdvisorFlex Variable Annuity Application to establish an annuity contract (“Contract”) with Thrivent Financial for Lutherans, an affiliated fraternal benefit society. Thrivent Financial for Lutherans is also the issuer of the Contract and will serve as the custodian for the assets in the Contract. Generally, you will pay a Program Fee based on the accumulated value of the Contract assets. The Contract is the only investment in the AdvisorFlex Program. No other securities may be purchased or otherwise held within the AdvisorFlex Program. Review the AdvisorFlex Program chart below and the Thrivent Investment Management Inc. AdvisorFlex Managed Variable Annuity Client Agreement (“Client Agreement”) for more information about the Contract assets. The investment options available in your Contract are referred to as subaccounts (“Subaccounts”). You also have the option of investing a portion of your Contract assets in a fixed account (“Fixed Account”). Portfolios of the Thrivent Series Fund, Inc. are among the Subaccount options (“Thrivent Financial for Lutherans Subaccounts”) available for purchase within the Contract. Thrivent Financial for Lutherans, the issuer of the Contract, also serves as the investment manager for the Thrivent Series Fund, Inc. portfolios and receives a management fee for its services. Thrivent Financial for Lutherans may also earn administrative service fees or revenue-sharing fees from the use of certain non- proprietary portfolio Subaccount options available for purchase in the Contract. Page 5 of 17 – Only valid with all pages. As a shareholder of portfolio(s) invested in a Subaccount, you will pay your proportionate share of the portfolio’s underlying expenses, which may include advisory fees and other operating expenses. Thrivent Financial for Lutherans, the issuer of the Contract, may also charge you a fund facilitation fee to make certain non-proprietary portfolios available as investment options in a Subaccount. These fees are in addition to the Program Fee you pay. Not all portfolios have fund facilitation fees. Generally, it is more profitable for us if you purchase investment products that are underwritten, distributed or advised by Thrivent and/or its affiliates, such as portfolios of the Thrivent Series Fund, Inc. Carefully review the sections titled “Fees and Compensation—Other Charges, Fees and Expenses”and “Item 9—Additional Information— Third-Party and Thrivent-Based Financial Incentives” for further information related to this conflict of interest. The managed account programs and investment- related advice and services your Financial Advisor is able to provide depend on the securities licenses and registrations they hold and the programs to which Thrivent has granted them access. In order to offer managed account programs, your Financial Advisor is required to be registered with Thrivent as an investment advisor representative (i.e., they must hold a Series 65 or 66 license). Your Financial Advisor will recommend an appropriate managed account program for you based upon your investment objectives, financial situation and needs. The decision to select the AdvisorFlex Program and to establish a Contract is solely yours. Review the chart below for an at-a-glance view of the AdvisorFlex Program, including the investment selection process and the Program Fee Schedule.
AdvisorFlex Guided Program Overview Investment Advisory Structure Non-discretionary Asset Allocation Strategy Financial Advisor recommends; client approves or rejects recommendation Eligible Program Assets AdvisorFlex Variable Annuity Subaccount and Fixed Account/Investment Selection Financial Advisor recommends; client approves or rejects recommendation Minimum Initial Investment1 $25,000 Rebalancing and Reallocation Financial Advisor recommends; client approves or rejects recommendation The AdvisorFlex Program Fee Schedule is outlined in “Item 4—Services, Fees and Compensation” below. Financial Advisors may work with you either individually, as a team or in partnership with other Financial Advisors and/or support staff. If your Financial Advisor works with other Financial Advisors or support staff, these individuals may have access to your Contract and other information and may be responsible for certain aspects of servicing your participation in the AdvisorFlex Program. For example, these other Financial Advisors may enter trades at your request, participate in the preparation of the portfolio reviews, perform investment research, and be available to answer general questions you may have related to the AdvisorFlex Program. Investing involves risks, including the potential for loss of principal invested. Strategies and recommendations provided may have tax or legal consequences that you should consider. Thrivent and its Financial Advisors do not provide tax or legal advice. Consult your tax professional and attorney for such advice. The “Services” section below describes the AdvisorFlex Program in greater detail.
1You may be eligible to participate in the AdvisorFlex Program below the initial minimum investment listed in the chart. Review the Contract prospectus and “Item 5—Account Requirements and Types of Clients” for additional information. Page 6 of 17 – Only valid with all pages. Services The AdvisorFlex Program is a non-discretionary investment advisory program that gives you access to a Thrivent AdvisorFlex Variable Annuity Contract. Your Financial Advisor will help you develop an asset allocation strategy, select from the Subaccounts available in your Contract, and determine how much of your premium (payments you make) to allocate into each of the Subaccount(s) and/or the Fixed Account within the Contract. Your Financial Advisor may use a variety of methods and resources to develop a recommended asset allocation strategy. Due to changing market conditions, the asset allocation among the Subaccounts within your Contract may change or deviate from its original allocation. In light of this, your Financial Advisor may recommend that you participate in the automatic asset rebalancing program, which is an option available in the Contract. If you do not choose to participate in the asset rebalancing program, your Financial Advisor will recommend that you rebalance or reallocate the Subaccounts and the Fixed Account assets. It is solely your decision to implement any rebalancing or reallocation recommendations provided by your Financial Advisor. You may also contact your Financial Advisor to rebalance or reallocate the Subaccounts and the Fixed Account assets. Where permitted by applicable law and business need, Thrivent Financial for Lutherans reserves the right to make certain changes to the structure and operation of the Contract. These changes include, among others, the right to:
• Remove, combine or add new Subaccounts in its sole discretion.
• Substitute shares of one portfolio for another, which may have differences including different fees, expenses, objectives and risks.
• Restrict or prohibit additional allocations, and/or payments to Subaccounts. Review the AdvisorFlex Variable Annuity prospectus (“Prospectus”) for more information about these changes. Thrivent Financial for Lutherans aggregates multiple client transaction orders to seek the most favorable price and/or lower execution costs at the time of execution. All aggregated client transaction orders receive the same price. Cash Management There are no cash management features in the AdvisorFlex Program. All cash must be invested in a Subaccount and/or the Fixed Account within the Contract. Refer to the Client Agreement for information about additional payments and surrenders. Program Account Reviews and Reports Performance reporting, custodial statements and trade confirmations are features available in the AdvisorFlex Program. You should review these documents upon receipt and promptly notify Thrivent of any discrepancies. Performance Reporting You and your Financial Advisor will receive quarterly performance reports detailing the following: • Portfolio Subaccount and Fixed Account appraisal—Reports your portfolio’s holdings, current market value of all positions, and unrealized gains/losses.
• Quarterly performance—Summarizes the current quarterly performance of the portfolio.
• Performance history—Summarizes the performance of the Subaccount(s) and compares it to various market indexes.
• Cost basis—Provides cost basis information in year-end summary statements. Consolidated quarterly performance reports may be available if you or members of your household have the AdvisorFlex Program and multiple accounts in the Program with the same taxpayer identification number and/or household mailing address.

Custodial Statements Thrivent Financial for Lutherans will send you statements at least quarterly. These statements contain information including, but not limited to, the accumulated value of your Contract, the current market value of each Subaccount invested in, the amount of the Fixed Account and transaction activity for the previous quarter period. In certain instances, Thrivent will also send you a quarterly statement describing certain activity during the previous quarter. We encourage you to carefully review and compare the Contract statements that you receive from Thrivent Financial for Lutherans with those you receive, if any, from Thrivent. Page 7 of 17—Only valid with all pages. Trade Confirmations Thrivent Financial for Lutherans will also send you confirmations of each purchase or surrender transaction effected in your Contract and/or any other transaction for which it is obligated to send you a confirmation. Fees and Compensation You will be charged a quarterly Program Fee for each AdvisorFlex Program not to exceed the fee rate from the fee schedule(s) provided below. AdvisorFlex Program Fee Schedule Accumulated Value of Household*Contract(s) Maximum Program Fee (annual as a % of assets) Up to $100,000 2.00% $100,000–$249,999 1.85% $250,000–$499,999 1.70% $500,000–$999,999 1.55% $1,000,000–$2,999,999 1.45% $3,000,000–$4,999,999 1.25% $5,000,000–$9,999,999 1.00% $10,000,000 and above 0.90% Fee for funds in the Fixed Account. For funds held in the Fixed Account, the Maximum Program Fee is 0.50%. *Household includes all of your Contracts and/or managed accounts within the Program with the same SSN/TIN or mailing address. The Program Fee will vary among clients and may be negotiable under certain circumstances. Factors typically considered to determine your Program Fee include:
• The managed account program(s) you have selected.
• The amount of assets in your Contract.
• Your personal financial needs, objectives and complexity of your financial situation.
• The level of anticipated or actual trading within the Subaccounts.
• The experience level and credentials of your Financial Advisor.
• The amount of household assets you have within the Program, where Contracts and/or managed accounts have the same taxpayer identification number and/or home mailing address. Thrivent and your Financial Advisor may receive a financial benefit by you not paying a reduced fee should you qualify for, but opt out of, householding. However, your negotiated fee for individual Contracts may be lower than the fee you qualify for with householding. To address this conflict, in addition to the information described in “Item 9—Additional Information— Review of Accounts” below, Thrivent trains its Financial Advisors to review householding with clients when appropriate. Calculation of Program Fees The Program Fee is based on the accumulated value of your Contract assets as of the last business day of the end of the quarter and in accordance with the Client Agreement. Thrivent, in its sole discretion, determines which assets are billable and included in the calculation of the Program Fee. Thrivent Financial for Lutherans will deduct your Program Fee from either a bank account that you designate or this Contract. If your Program Fee is deducted from your Contract, it will reduce the value of your Contract. National Financial Services LLC (“NFS”) will deduct your Program Fee if you select a Thrivent brokerage or managed account as the billing account for the AdvisorFlex Program. Review “Item 9—Additional Information—Other Financial Industry Activities and Affiliations” for more information about NFS. Thrivent is not affiliated with NFS. Allocation of the Program Fee A portion of your Program Fee is paid to Thrivent, your Financial Advisor and the Platform Manager for their services. The amount of the fees paid to your Financial Advisor and/or Thrivent depends upon the Program Fee that you negotiate with your Financial Advisor and the amount of the fee payable to your Financial Advisor pursuant to Thrivent’s compensation policies. Page 8 of 17 – Only valid with all pages. Other Charges, Fees and Expenses to Consider If you invest in Thrivent Series Funds, Inc. and certain non-proprietary portfolios, you will receive an offset credit in the amount by which the total of certain fees received by Thrivent exceed 0.45% annually of your Contract’s accumulated value. If these fees received by Thrivent do not exceed 0.45%, you will not receive a credit. The types of fees included in the offset if received by Thrivent are provided below. Thrivent Series Fund, Inc.:
• Investment advisory fees charged by the investment manager of the funds.
• The offset does not include administrative fees, transfer agent fees, sub-transfer agent fees or networking fees. Non-proprietary portfolios:
• Reimbursement payments.
• Administrative fees.
• Transfer agent fees or other servicing and account maintenance fees paid to us or our affiliate related to this program. The credit will be applied to the same source you authorized Thrivent Financial for Lutherans to deduct your Program Fee. Fees and charges that are not included in the Program Fee, but may be incurred in addition to the Program Fee, include:
• Surrender charges.
• Transfer charges.
• Mortality and expense charges.
• Charge for a maximum anniversary death benefit rider.
• Operating expenses of the Subaccount(s) that you select.
• Fund facilitation fees for certain Subaccounts.
• Electronic fund, banking and wire transfer fees.
• Other miscellaneous or service charges. Additional Compensation and Charges Applicable to Your Financial Advisor and Thrivent Your Financial Advisor recommending and providing advice with respect to the Program receives additional compensation as a result of your participation in the AdvisorFlex Program. The amount of this compensation may be more or less than what your Financial Advisor would receive if you received other Thrivent services or paid separately for investment advice, brokerage and other services (e.g., the cost of the services if provided separately and the trading activity in the client’s Contract or account(s)). Therefore, your Financial Advisor may have a financial incentive to recommend one of Thrivent’s managed account programs over other programs or services. In addition, your Financial Advisor may get paid a higher percentage of the Program Fee, depending upon the program(s) you select and Thrivent’s compensation payout criteria. This creates a conflict of interest on the part of your Financial Advisor, which Thrivent manages through its new account or best-interest review process, surveillance and by training Financial Advisors regarding the Program and related services. Linking Programs/Accounts If you have an AdvisorFlex Program and other accounts within the Program with the same taxpayer identification number and/or home mailing address, you may link those Programs/Accounts for purposes of billing by selecting a primary account (“Primary Account”) from which to pay the Program Fees on behalf of the other linked Programs/Accounts on a quarterly basis. The accounts do not need to be within the same managed account program. This linking is only available if you elect to have the AdvisorFlex Program Fee deducted from a non-qualified brokerage or managed account. The Primary Account may not be a retirement account. A retirement account, as used in this Brochure, is a plan subject to the provisions of Title I, Part 4 of the Employee Retirement Income Security Act of 1974 (ERISA), a tax- qualified plan of self-employed persons, or an individual retirement account or other plan within the meaning of section 4975(e) of the Internal Revenue Code of 1986, as amended. Factors to Consider in Assessing AdvisorFlex Program Costs There are a number of factors to consider when assessing the costs of the AdvisorFlex Program. These factors include:
• The combination of investment advisory, custodial and related services and the Contract available through the AdvisorFlex Program may not be available separately. Page 9 of 17—Only valid with all pages.
• The source of investible assets and the time period for which you have held the assets or any surrender charges paid to sell those assets could affect whether the assets are included in the Program Fee calculation.
• Whether you have previously paid a sales load to Thrivent or its affiliates within a 24-month period prior to enrollment in the AdvisorFlex Program.
• Whether you have paid a surrender charge to Thrivent or its affiliates immediately prior to enrolling in the AdvisorFlex Program. Is the Program Appropriate for You? Your Financial Advisor and/or Thrivent may recommend to you one or more programs. The decision to select one or more managed account programs is solely yours. Discuss, among other things, the following with your Financial Advisor to determine if the recommended program is appropriate for you:
• Whether it is more advantageous for you to enroll in the AdvisorFlex Program or to pay separately for other products or services that may not offer the combination of investment advisory, custodial and brokerage services and advisory services, as part of the Program.
• The cost, potential benefits and potential risks of the AdvisorFlex Program.
• Your investment objectives and the complexity of your investment strategy.
• The types of and number of investments you hold and intend to make, including the percentage of the overall portfolio that you intend to hold in the Fixed Account.
• Your desire for diversification across Subaccount(s).
• The frequency with which you expect to trade in your Subaccount(s).
• Your anticipated use of other services and features specific to AdvisorFlex.
• The payment preference of an asset-based fee for ongoing investment advice and other related services compared to a commissioned-based variable annuity. At any time, a Contract can vary greatly in the size, number and diversity of the Subaccounts held, due to, among other things, market conditions and your current investment needs and objectives. Generally, it is recommended that you diversify your holdings in an effort to help reduce your portfolio’s overall market risk. Investment diversification does not ensure a profit or guarantee against loss. If you intend to hold a concentrated portfolio, including a concentrated position in the Fixed Account, for an extended period of time, you should consider other Contract options (i.e., investing in a commissioned-based variable annuity) that may be more economically advantageous for you. Your Financial Advisor receives training related to offering and servicing Contracts in the AdvisorFlex Program. Training includes understanding factors relative to client needs and the suitability of product and service recommendations, expected trading or transaction frequency, fee preference (e.g., asset-based fee or a commission-based fee arrangement), and desire for ongoing investment advice.