Description of Advisory Firm EAG has been a registered investment adviser under the Advisers Act since 2000. EAG is also registered in all 50 states, the District of Columbia, Virgin Islands, Guam, and Puerto Rico. EAG offers investment management and advisory services to plan sponsors of employer-sponsored retirement plans such as 401(a), 401(k), 403(b) and 457 plans, including government entities and their participants, and to all account holders of the Empower Premier IRA (IRA holder or account holder). EAG does not choose the investments offered in employer-sponsored retirement plans or IRAs. EAG-serviced plans receive recordkeeping services through Empower Retirement, LLC (Empower), the recordkeeping entity affiliated with EAG. EAG also offers investment management services to individuals and to retail brokerage account holders. EAG’s sub-advisory relationship with FEA does not currently provide for investment management and advisory services to IRA holders, individuals or retail brokerage account holders. More information about EAG’s services, including an applicable brochure, can be obtained by contacting EAG at the number provided on the cover page of this Brochure or by visiting EAG’s website at: www.empower.com/eag. EAG is a wholly owned subsidiary of Empower Services Holdings US, LLC, (ESH US) a holding company domiciled in the State of Delaware. ESH US is owned by Empower Annuity Insurance Company of America (EAICA). EAICA is a direct, wholly owned subsidiary of Empower Holdings, LLC (EHL), a Delaware holding company. EHL is a direct wholly owned subsidiary of Great-West Lifeco U.S. LLC (Lifeco U.S.) and an indirect wholly owned subsidiary of Great-West Lifeco Inc. (Lifeco), a Canadian holding company. Lifeco is a subsidiary of Power Financial Corporation (Power Financial), a Canadian holding company with substantial interests in the financial services industry. Power Corporation of Canada (Power Corporation), a Canadian holding and management company, has voting control of Power Financial. The Desmarais Family Residuary Trust has voting control of Power Corporation, through a group of private holding companies it controls. Types of Services Discussed in this Brochure: As part of its sub-advisory relationship with FEA, EAG provides non-discretionary investment advisory services through an online service called Online Advice (OA) and discretionary investment advisory services through the Professional Management Program, Professional Management Program with the Income+ feature, and Professional Management Program with Income Beyond Retirement, all of which are referred to as Professional Management Program (PMP or Professional Management) (collectively, the Services). Participants that enroll in one of the advisory service programs are referred to as “Members.” Plan Sponsors or other entities who engage EAG to provide services are referred to as “Clients.” FEA can also advise with respect to collective trusts and insurance products if a plan sponsor includes those products with the investment lineup. There is no guarantee provided by any party that participation in any of the advisory services will result in a profit. Financial Engines Advisors, L.L.C. FEA is a registered investment adviser, wholly owned by Edelman Financial Engines, LLC, and is not affiliated with EAG or any company that is affiliated with EAG. FEA is headquartered in Santa Clara, California. A copy of FEA’s Form ADV Brochure may be obtained at either www.edelmanfinancialengines.com or http://www.adviserinfo.sec.gov. FEA utilizes proprietary software to develop individualized recommendations for allocation of assets within Member accounts. The methodology is designed to provide personalized and diversified investment recommendations for Members. Procedurally, FEA considers a variety of inputs, including desired retention of company stock (up to 20%), risk preference, asset class exposure limitations, assets held outside the plan and desired retirement age. FEA may also take into consideration certain client holdings outside the retirement plan as part of its analysis where Members provide such information. 1. Online Advice OA is a non-discretionary service for Members to get objective advice. Members who choose to receive this service are responsible for implementing OA’s personalized recommendations within their retirement plan accounts and checking back regularly to get updated personalized recommendations. Neither FEA nor EAG places transactions on behalf of the Members or monitors the personalized recommendations OA Members receive. OA includes the following features:
• A forecast of the potential future account value or the potential annual retirement income based on the information provided by a Member;
• A forecast of the likelihood that a Member will achieve their self-reported retirement income or account value goals, taking into consideration the total household investment portfolio as known by the service;
• Recommendations among the investment alternatives available in the employer-sponsored retirement plan (generally mutual funds, other investment company securities, and sometimes, one or more equity securities issued by the plan sponsor); and
• Guidance on savings rate and retirement age. Members may use OA as frequently as they choose to monitor progress toward their retirement goals, receive forecasts and investment recommendations, and access available educational content. OA updates the investment information of most mutual funds and stocks in plan accounts daily. Members are responsible for periodically revisiting OA to:
• Update account information to reflect changes in holdings, including purchases and sales of investments;
• Update personal information (including retirement goals) to reflect changes in personal or financial circumstances; and/or
• Review any updates regarding changes to Member’s account value or forecast. The failure of an OA Member to review and periodically update their personal and financial information can materially affect the value of the investment advisory services provided. For certain Members, some account information may be updated automatically when the Member revisits OA if EAG has an established electronic communications link with the Member’s plan sponsor and/or plan provider or other financial institution. For manually added and linked accounts, EAG relies on Members to provide ongoing and updated data either by logging in to refresh a linked account or by manually updating accounts that were added manually. OA offers Members investment analysis of mutual funds and stocks in the form of Scorecards. The Scorecards for individual equity securities depict the relative risk and historical performance of the individual stock. 2. Professional Management Program (PMP) PMP is a discretionary service, which personalizes each portfolio to fit the Member’s needs and the specific characteristics of the plan by using the program’s methodology and information provided by the Member. PMP simulates thousands of scenarios to find an investment mix designed to optimize the Member’s opportunity for potential future value, including the goal of providing steady income through retirement. PMP may include any of the following features:
• A Retirement Plan or similar document showing how EAG will manage and allocate the account, e.g., the portfolio allocation target, suggestions regarding the Member’s savings and a forecast regarding their likelihood of achieving their self-articulated retirement goals;
• Periodic portfolio monitoring;
• Quarterly Retirement Updates outlining, among other things, how the account is performing against goals;
• Phone access to investment adviser representatives via a toll-free number as well as online account access; and
• Non-discretionary investment advice on retirement accounts outside the plan account. PMP Members authorize EAG to direct the plan provider to execute transactions on a discretionary basis to move toward the account’s allocation target (and to otherwise manage the account) without prior approval of each transaction. PMP is generally made available to plan participants in a defined contribution plan through an agreement between EAG and the plan and/or the sponsoring employer. That agreement will specify

the methods of enrollment into PMP for eligible plan participants, which may include:
• An “opt-in” method of enrollment where a retirement plan participant actively elects to enroll in PMP;
• An “opt-out” method of enrollment where eligible plan participants are automatically enrolled in PMP in accordance with plan or plan sponsor specifications, with the ability to withdraw at any time without penalty. With this type of enrollment, Professional Management may be designated as a qualified default investment alternative (“QDIA”), as permitted under the Employee Retirement Income Security Act (ERISA); or
• Some combination of both methods, as determined by the plan or plan sponsor and as agreed to by EAG. Members who enroll in PMP grant EAG the discretionary authority to determine an allocation target for the plan account based upon a variety of inputs provided to EAG. This discretionary authority allows EAG to allocate the Member’s plan account among the menu of investment alternatives that have been selected by the plan or plan sponsor, typically excluding any brokerage window option (if applicable) or other plan-restricted investments. To allow EAG to provide PMP, the plan provider supplies information about each Member and the plan account. PMP Members may provide additional information to the program concerning a variety of inputs, including desired retention of company stock (up to 20%), risk preference, asset class exposure limitations, assets held outside the plan and desired retirement age. EAG may also take into consideration certain Member holdings outside the retirement plan as part of its analysis where the Member provides such information. The program determines an investment strategy and an allocation target based on a Member’s current age, an assumption about the retirement age, the available investments for the account, any pension plan information provided, an assumption about risk tolerance that is based on the Member’s current age and assumed retirement age, the Member’s current portfolio allocation, and any additional information provided by the Member. Additional information provided by the Member may modify these parameters. During the period following enrollment, the program determines how to transition the account toward the allocation target and directs EAG regarding allocation of the account (which may include transfer or exchange directions). The program provides directions regarding new contributions to the account. Accounts of then-current PMP Members newly eligible for the Income+ or Income Beyond Retirement feature of PMP may also be subject to a similar transition. Certain plan participants, such as plan sponsor “insiders,” as defined under applicable regulations, and non-U.S. participants in plans, may not be eligible for PMP. Income Beyond Retirement and Income+: Members may also, if their plan sponsor has elected to offer this service, access PMP’s Income+ or Income Beyond Retirement features. These services provide certain portfolio management and income payout options to retirees and near retirees from their 401(k) or similar plan account. For those who elect this feature, PMP manages the Member’s portfolio to balance between income and growth, seeking to protect the ability of the account to generate future income. Income Beyond Retirement also seeks to provide additional flexibility for a Member by allowing Members to determine the portion of their account to be managed on a standard “growth” objective and, separately, the portion to be managed on an “income” objective. Income+ and Income Beyond Retirement seek to manage investments and to create payouts that could continue into the Member’s early 90s. Upon request, in addition to managing the investment allocations in such accounts, EAG will work with the plan provider to calculate and facilitate withdrawals from the Member’s plan account post-retirement. Members pay no additional fees for the Income Beyond Retirement or Income+ features, and, if available, they can transition to an Income Beyond Retirement/Income+ portfolio either automatically (upon eligibility) or at their request (as defined, in part, by the agreement between EAG and the relevant plan sponsor). An account balance is maintained for an optional out-of-plan annuity purchase. An in-plan annuity need not be included in a plan’s investment lineup for a plan sponsor to offer Income+ to its participants. While EAG may provide general educational information regarding an out-of-plan annuity, it does not sell or distribute annuities and does not receive any compensation related to out-of-plan annuity purchases. Affiliates of EAG may offer or sell annuities. Income Beyond Retirement and Income+ availability is subject to establishment of certain data connectivity arrangements between EAG and the applicable plan provider and is subject to applicable retirement plan provisions related to plan withdrawals. As part of the suite of advisory services available to participants in employer-sponsored retirement plans described above, EAG may provide plan participants with a “Retirement Evaluation.” The Retirement Evaluation is delivered in printed or electronic format to specified plan participants who have not enrolled in the service, and is designed to communicate some (or all) of the following information:
• A summary of the current value of the plan participant’s plan account;
• A forecast of how much the plan account investments, and other investments that plan participants submit for analysis, might be worth at retirement;
• Whether a change is suggested to the plan participant’s contribution rate, their portfolio’s risk and diversification, unrestricted company stock holdings, target date usage, and/or investment style and allocation;
• Investment proposals; and
• A projection of the plan participant’s annual income at retirement, based on how much the plan account, Social Security, and certain other benefit accounts could provide. Once enrolled in PMP, Members delegate certain account management functions to EAG. As a result of the delegation, the following functions are no longer available to the Member: functionality for fund-to-fund transfers, fund change allocations, and/or the rebalancing tool. Members in PMP retain full-inquiry access to their account and may still request certain services from Empower, including approval for loans and distribution withdrawals. EAG does not manage restricted investments or Member assets held in a brokerage account under the retirement plan. However, the disclosure of any of these types of investments held by the Member may influence the recommendations provided on the managed assets. . Termination of Services: Members may cancel their participation in PMP at any time by calling EAG at the toll-free customer service number. After cancellation of PMP, the Member will have the ability to make allocation and investment option changes to their account, usually within one to two business days following cancellation, subject to applicable investment restrictions. Accordingly, the plan participant’s asset allocation will remain the same as established in PMP at the time of the cancellation, unless and until the plan participant affirmatively and unilaterally changes their asset allocation after cancellation. Information: The use and storage of any information, including, without limitation, an individual’s personal and non- public information, account number, password, identification, portfolio information, and account balances is provided at the individual’s sole risk and responsibility. The individual is responsible for providing and maintaining the communications equipment (including personal computers and modems) and telephone or other services required for accessing and using electronic or automated services. The individual is also responsible for all communications service fees and charges incurred when accessing these services. EAG shall not bear any responsibility for either errors or failures caused by the malfunction of any computer, communication systems, computer viruses, or related problems that may be associated with the use of the services. Assets Under Management: With respect to the services provided by EAG, as of December 31, 2023: Discretionary investment management among all services (including the PMP described herein) in the amount of: $116,502,429,608 Non-discretionary investment advisory services among all services in the amount of: $17,776,730,753 Total discretionary and non-discretionary investment management and advisory services in the amount of: $134,279,160,181