EMPOWER ADVISORY GROUP, LLC

Item 1 – Cover Page EMPOWER ADVISORY GROUP, LLC Disclosure Brochure Personal Strategy Wrap Fee Program 8515 East Orchard Road, 4T2 Greenwood Village, CO 80111 Telephone: 855-855-8005 www.empower.com November 25, 2025 This Wrap Fee Program Brochure (Brochure) provides information about the qualifications and business practices of Empower Advisory Group, LLC (EAG). Specifically, this Brochure provides information on the qualifications and business practices for the advisory services provided by EAG for the Personal Strategy and Personal Strategy+ advisory services. If you have any questions about the contents of this Brochure, please contact us at 855-855-8005. The information in this Brochure has not been approved or verified by the Securities and Exchange Commission (SEC) or by any state securities authority. EAG is a federally registered investment adviser under the Investment Advisers Act of 1940 (Advisers Act). Registration of EAG does not imply any level of skill or training. Additional information about EAG is available on the SEC website at https://adviserinfo.sec.gov or at EAG’s website at https://empower.com/EAG. The SEC’s web site also provides information about any person affiliated with EAG who is registered, or is required to be registered, as an investment adviser representative with EAG. Item 2 — Material Changes This section of the Brochure highlights and discusses any changes that were made since the Adviser’s last update on March 31, 2025. A material change was made to Item 9 to provide information about a disciplinary event that EAG recently settled with the SEC. 1  Item 3 — Table of Contents Item 1 – Cover Page ....................................................................................................................................................... 1 Item 2 — Material Changes ........................................................................................................................................... 1 Item 3 — Table of Contents ........................................................................................................................................... 2 Item 4 — Advisory Business .......................................................................................................................................... 3 Item 5 — Fees and Compensation ................................................................................................................................. 5 Item 6 – Performance Based Fees and Side by Side Management ............................................................................... 7 Item 7 – Types of Clients ............................................................................................................................................... 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................... 8 Item 9 — Disciplinary Information ............................................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations ..................................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................... 15 Item 12 – Brokerage Practices ..................................................................................................................................... 15 Item 13 – Review of Accounts ..................................................................................................................................... 16 Item 14 – Client Referrals and Other Compensation ................................................................................................... 16 Item 15 — Custody ...................................................................................................................................................... 18 Item 16 – Investment Discretion ................................................................................................................................. 18 Item 17 — Voting Client Securities .............................................................................................................................. 18 Item 18 — Financial Information ................................................................................................................................. 18 2  Item 4 — Advisory Business 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 also offers investment management services to individuals and to 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. Empower Annuity Insurance Company of America (EAICA) owns ESH US. 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: TM EAG provides a range of advisory services directly to Personal Strategy® and Personal Strategy+ clients (the Services). The Services include the Personal Strategy core managed account advisory services (Advisory Services or Managed Accounts) and Personal Strategy+ advisory and investment management services for enrolled active or former employer-sponsored retirement accounts (Personal Strategy+ Services). Our Services combine technology with objective financial advice from Investment Advisor Representatives (Advisor(s)) who act as fiduciaries to our clients. EAG charges an all-inclusive fee for its Advisory Services and Personal Strategy+ Services described in this Brochure. Our Services are comprised of the services described below. Availability of some of the Advisory Services depends on the level of investment by a client. The web, mobile, tablet, and personal financial management aggregation service (Dashboard) provided to clients is delivered through Empower Personal Wealth, LLC (Empower Personal Wealth). Personal Strategy Core Managed Account Advisory Services (Advisory Services or Managed Accounts): Clients are required to establish brokerage accounts at a qualified custodian (Broker or Brokers) identified by EAG. All identified Brokers are member firms of the Financial Industry Regulatory Authority, Inc. and the Securities Investor Protection Corporation. The currently identified Broker is: Pershing Advisor Solutions LLC One Pershing Plaza, 4th Floor, Jersey City, NJ 07399, www.pershing.com/who-we-serve/registered-investment-advisors. All Managed Account client assets described herein are held in custody at the above-listed Broker except as noted otherwise herein. Pershing is not affiliated with EAG. Advisory Services: Periodic rebalancing Tax optimization and tax loss harvesting, as applicable In some instances, collaboration with CPA and estate planning professionals Portfolio personalization, as applicable • Ongoing discretionary investment management • • • • 3  Financial planning education Securities transaction costs included at no additional charge • • U.S. equity portfolio Smart Weighting ™, as applicable • Custody services included at no additional charge • • Assignment of a personal financial Advisor or team • Unaffiliated, qualified custodian • Minimum relationship size is generally $100,000 • Access to a Socially Responsible Personal Strategy that systematically screens U.S.-based companies based on their actions in three key areas: environmental, social, and governance • Access to an unaffiliated Private Equity Offering for qualifying clients, which provides the opportunity to invest in funds of private equity funds. Private Equity Offerings are subject to additional fees, which include significantly higher fees and additional layers of expenses relative to other investment options within Personal Strategy. • Access to Personal Strategy+ Services as described below., Personal Strategy+ Services In addition to the Advisory Services listed above, EAG also provides Personal Strategy+ Services to clients also enrolled in Personal Strategy+. Our Personal Strategy+ Services are for active or former retirement accounts like 401k, 403b and 457s. Personal Strategy+ is not available to Empower plan accounts. Pershing holds in custody the taxable Managed Account from which the fees for Personal Strategy+ Services are deducted (unless the client elects the credit card payment method); However, the employer-sponsored retirement accounts to which EAG provides Personal Strategy+ Services are held away at the respective plan’s financial institution and are not held at Pershing. Socially Responsible Investing In addition to the Core Personal Strategy offering, EAG offers investment portfolios with a socially responsible lens. EAG defines Socially Responsible Investing (SRI) as the application of value-based investment filters coupled with the integration of ESG factors. EAG partners with Sustainalytics, a provider of ESG and Corporate Governance research, for ESG scoring data. “ESG” stands for Environmental, Social, and Governance, which represent three categories of corporate risks and opportunities. Building Socially Responsible portfolios begins with the same underlying methodology and investment philosophies as the Core Personal Strategy, but for the U.S. equity component of the portfolio the investment team considers Sustainalytics’ ESG rating before adding each individual security. Sustainalytics provides an ESG Rating for each individual equity security that evaluates ESG factors that it deems financially material. Sustainalytics evaluates 20 “material ESG issues” (MEIs) across all sub-industries and assesses each MEI for how material it is to each sub-industry and subsequent company. If an ESG issue is considered material at the sub-industry level but is not relevant for the specific company, it can be removed from that company’s rating. Due to limited scoring data, in the SRI accounts small-cap stocks are represented by a mix of non-ESG exchange-traded funds (ETFs,) and foreign equities use a set of diversified ESG-optimized ETFs on the foreign developed and emerging market sectors. SRI accounts also hold non-ESG ETFs in international small-cap equities due to a lack of desirable investment options. Any utilization of EAG’s optional SRI strategy feature, which integrates ESG factors into the Personal Strategy methodology, is pursuant to the client’s affirmative election only. Unless the client affirmatively elects the optional SRI strategy, EAG’s default investment portfolio strategy does not consider ESG factors. The performance of EAG’s Core Managed Accounts will differ from the performance of SRI accounts due to differences in holdings and investments. Advisors are available during normal business hours and are accessible via telephone, email, or by video conference. Advice is based on each client’s financial situation typically evidenced by accounts that clients have linked through the Dashboard, as well as detailed information about personal circumstances such as age, investment time horizon, risk tolerance, expectations, goals, and investment restrictions. 4  There is no guarantee provided by any party that participation in any of the Services will result in a profit. Termination of Services: Clients may cancel their participation in Services at any time by calling EAG at the toll-free customer service number. 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. For clients who elect to participate in our Personal Strategy+ offering, EAG’s Portfolio Management staff will have access to employer-sponsored retirement account information, including personally identifying information and financial information (Personal Information), as well as general information about a client’s retirement plan, such as the investment options, plan management fees and other data (Plan Data). Assets Under Management: With respect to the services provided by EAG, as of December 31, 2024: Discretionary investment management among all services (including the PMP described herein) in the amount of: $136,437,797,6460 Non-discretionary investment advisory services among all services in the amount of: $22,682,532,844 Total discretionary and non-discretionary investment management and advisory services in the amount of: $159,120,330,490 Item 5 — Fees and Compensation EAG charges a single fee for Advisory Services and a single fee for Personal Strategy+ Services, both of which are based on the value of the client’s respective assets under management (AUM). The single fee includes portfolio management, trading commissions, and except with respect to Personal Strategy+ Services, custody services. Advisory Services Fees and Compensation: The fee for Advisory Services commences upon the first date that the Broker receives a client’s assets, including cash and securities, in a Managed Account. EAG charges a fee for all client assets it manages as part of the Advisory Services, which includes uninvested cash. Fees and rates are calculated daily and deducted on a monthly basis in arrears. EAG reserves the right to negotiate separate fee and billing arrangements at its sole discretion. The client authorizes EAG to debit Advisory Services fees directly from the client’s Managed Accounts held with the Broker. If insufficient cash is available to pay such fees, securities will be liquidated to pay the unpaid balance. On an annualized basis, EAG bases its Advisory Services fee on the following schedule calculated as a percentage of the total AUM: 0.89% Investment Services Clients ($100,000 - $249,999 total AUM) Wealth Management Clients ($250,000 - $999,999 total AUM) 0.89% Private Clients ($1 million or more total AUM) tiered structure 5  $3MM or less AUM On only the next $2MM AUM On only the next $5MM AUM On only the AUM over $10MM 0.79% 0.69% 0.59% 0.49% For example, here is how your annual Advisory Services fee would be calculated if you are a Private Client with $7.5 million AUM: • • • The fee for the first $3 million of your total AUM would be calculated at 0.79% annually, The fee for the next $2 million portion of your AUM ($3,000,001 to $5 million) would be calculated at 0.69% annually, and The fee for the last $2.5 million portion of your AUM ($5,000,001 to $7.5 million) would be calculated at 0.59% annually. Personal Strategy+ Advisory Fees and Compensation: Fees for Personal Strategy+ Services are charged monthly in arrears and calculated based on month-end assets (or last asset value available during the month). The annualized fee rate for Personal Strategy+ Services is 0.49%. Personal Strategy+ Services fees commence upon successful aggregation of the employer-sponsored retirement account assets and either the confirmation or establishment of an eligible Managed Account or the enrollment in a credit card payment method. If the client does not already have a fee account designated and does not elect credit card payment as described below, the client authorizes EAG to deduct advisory fees for Personal Strategy+ Services from the client’s largest taxable Managed Account held with the Broker. Payment of Fees: Personal Strategy+ clients have the option to select credit card payment of advisory fees for Personal Strategy+ Services. For clients who authorize EAG to charge their credit card for Personal Strategy+ Services fees, EAG engages a third- party vendor to provide the credit card billing option to Personal Strategy+ Services clients. Credit card information is processed by the vendor through Dashboard integration and complete account credentials are not stored or accessible by EAG or EAG’s employees. By electing to pay fees for Personal Strategy+ Services with a credit card, the client agrees to be held to the specific terms and conditions of their credit card agreement directly with the applicable card-issuing financial institution. While EAG accepts credit card payment for Personal Strategy+ Services, such acceptance is not a recommendation to pay advisory fees by credit card. Selecting this payment method may or may not be the best option, depending on the client’s financial circumstance. While paying advisory fees via credit card could provide more opportunity for assets to grow (as a result of fees not being paid directly from assets), these payments will be subject to the interest rate of the applicable credit card sponsor in the event that the balance of the credit card is not paid off each month. This interest rate is typically much higher than any advisory fees paid for investment services, and the interest rate applicable to credit card borrowing may exceed the performance return of the account. Clients should carefully consider whether paying for Services with a credit card is appropriate for their specific circumstances, given the benefits and drawbacks. EAG does not assess any surcharge to clients who elect to pay for Personal Strategy+ Services with a credit card. EAG’s Personal Strategy+ Services are limited to providing investment advice and management of the assets in a client’s employer-sponsored retirement account(s) and the plan administrator continues to act as the qualified custodian for these accounts. Any transaction or performance information provided by EAG is for informational purposes only, as the plan administrator for the employer-sponsored retirement account(s) is the official custodian and recordkeeper for all performance and transaction information. EAG reserves the right to reduce its advisory fee rate at its discretion, including for promotional events that may result in complimentary or reduced advisory fee rates for new clients, for current clients for referrals, or for early adoption of new services. The fee rate also has been reduced for personnel (including employees and consultants) of EAG and its affiliates. These reductions apply to clients of the same households. Fee errors are corrected promptly upon discovery. 6  In determining whether to establish an account, a client should be aware that the overall cost to the client of Advisory Services will be higher or lower than the client would incur by purchasing separately the types of securities available through the Advisory Services. In comparing the cost of the Advisory Services with unbundled services, the client should consider the turnover rate in EAG’s investment strategies, trading activity in the account, standard advisory fees, and brokerage commissions that would be charged at other broker-dealers and investment advisers. We have compensation arrangements with our sales and service Advisors that include a component of variable compensation subject to the achievement of certain measures, including pertaining to new account AUM, retained account AUM, as well as performance-related scores applicable to servicing of client accounts. Although this variable compensation is only a component of the Advisor’s compensation, this creates a conflict of interest because EAG and our individual Advisors earn more revenue, or greater individual compensation, if a client chooses to hold, retain and add investable assets with us. Compensation paid to Advisors does not increase the fees paid by account holders. Additional Fees and Expenses: All fees paid to EAG for Advisory Services are separate and distinct from the fees and expenses charged by underlying pooled investment vehicles (e.g., ETFs, mutual funds, closed-end investment companies or other managed investments). The specific fees and expenses are described in each vehicle’s prospectus or other offering document. Additional investment management fees are paid to Empower Capital Management, LLC (ECM) if Empower Funds are included among the available investment options within a client’s plan. The fees paid to ECM are for management of the Empower Funds; these management fees are included in the fund share price. In addition, there are other third-party costs assessed that are not included in the Advisory Services fees, such as costs associated with exchanging currencies, wire transfer fees, Personal Strategy+ plan administration fees charged by the plan administrator, Personal Strategy+ plan transaction fees, or other fees required by law, as applicable. If a client elects to pay for Personal Strategy+ Services by credit card, there may be other fees associated with the specific terms and conditions of that credit card. Clients who participate in a Private Equity fund through an arrangement with Institutional Capital Network (iCapital) will pay additional fees charged by iCapital or the underlying funds, which include significantly higher fees and additional layers of expenses relative to other investment options within Personal Strategy. Item 6 – Performance Based Fees and Side by Side Management EAG does not charge any performance–based or side-by-side management fees. Clients considering an investment in an iCapital Private Equity fund should be aware that, although EAG does not charge performance fees, iCapital’s underlying fund managers may do so, and these additional fees include significantly higher fees and additional layers of expenses relative to other investment options within Personal Strategy. Item 7 – Types of Clients EAG generally provides Services to: Individuals, • • High-net worth individuals, • Corporations and other business entities, and • Charitable Organizations. Our Advisory Services are offered to clients who sign up with a minimum of $100,000 of AUM with us. Clients who elect to enroll in our Personal Strategy+ program are also required to have a Managed Account with a minimum of $25,000 in assets. The minimum AUM requirements may be reduced or waived at EAG’s discretion. Clients who invest below $250,000 using the Services (Investment Services Client(s)) fall under our Investment Services tier. In addition to access to the free Dashboard, Investment Services Clients have access to a team of Advisors who assist in planning their investment goals. Investment Service Clients normally have portfolios consisting of ETFs with goals of diversification and tax efficiency. 7  Clients who invest between $250,000 and less than $1 million using the Services (Wealth Management Client(s)) fall under our Wealth Management tier. Wealth Management Clients are provided with a comprehensive financial plan to help address retirement, college planning and tax optimization needs. They are offered a dedicated financial Advisor and a customized portfolio of individual securities and ETFs designed to meet their financial goals. Clients who invest at least $1 million using the Services (Private Client(s)) fall under EAG’s Private Client tier, which is designed for high-net worth investors who want a robust financial plan along with personalized service and portfolio management. Private Clients have access to financial Advisors and financial planning specialists, private banking services, legacy and estate planning specialists, and family-tiered billing with reduced fees for assets over a certain level. Private Client portfolios offer a blend of individual securities and bonds, as well as ETFs. Private Clients are also eligible to participate in the Private Equity fund. The Private Equity fund is made available to Private Clients through an arrangement with iCapital. Private Clients who invest in this program have the opportunity to invest in the iDirect Private Markets Fund (Fund), a registered closed end fund product advised by iCapital, which is responsible for Fund investment selection and portfolio management in private equity investments. Clients who participate in the Private Equity Fund will incur additional fees charged by the Fund, which include significantly higher fees and additional layers of expenses relative to other investment options within Personal Strategy. Though no longer offered to new clients, existing clients utilizing the Vintage iCapital Private Equity (Vintage) Offering will remain invested in the Vintage product. These eligible Vintage investors were Private Clients who had been with EAG for at least six months and who had at least $5 million invested with Personal Strategy. The Vintage Offering was made through an arrangement with iCapital. Private Clients who invested in this program had the opportunity to invest in an access fund sponsored by iCapital, which in turn invested in one or more underlying private equity funds. Clients who participated in the Vintage Offering through this arrangement with iCapital will continue to pay additional fees charged by iCapital or the underlying funds. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss EAG’s investment analysis emphasizes asset allocation research and portfolio diversification techniques over individual security analysis. EAG’s methods and techniques include: • • • Sampling and screening relevant baskets of securities, or indices, in order to select the desired security attributes. Correlation analysis – evaluating the historical relationship of two securities or market segments movement in relation to each other. Fundamental analysis – evaluating securities based upon historical and projected financial performance. Within US equities, Managed Accounts employs an approach termed Smart WeightingTM. The starting universe is generally ETFs and US stocks traded on an exchange with a market capitalization over $250 million and sufficient liquidity. The objective of the approach is to maintain relatively even weighting in company size, style and economic sector. Securities are selected largely to complete this factor exposure in conjunction with other existing holdings. In other asset classes we employ a mix of low-cost ETFs in an attempt to generate an efficient exposure to the asset class. The most important areas for consideration in ETF selection are underlying exposure, liquidity, and cost. All investments involve risk. EAG does not guarantee the results of the advice given. Significant losses can occur by investing in any security, or by following any strategy, including those recommended or applied by EAG. EAG offers its clients an array of investment strategies (Personal Strategy). A client’s assets are managed within a given Personal Strategy based upon the client’s overall investment objectives and suitability parameters. A Personal Strategy is a comprehensive investment portfolio. It is focused on achieving the client’s financial goals and is designed to grow with the client over time. Portfolios in a Personal Strategy can be customized for a client’s needs or wants; however, EAG maintains ultimate investment discretion. Clients should be aware that to the extent a personalized trading restriction limits full strategy implementation, it may impact their account performance relative to other non-restricted peers in the same strategy. Personal Strategy asset allocations go beyond basic stock and bond portfolios. The Personal Strategy service invests globally, primarily utilizing individual equities and ETFs. EAG’s 8  unique Smart Weighting approach adds further diversification and potential return by providing exposure to all areas of the U.S. stock market while avoiding being overweight to high-risk segments. EAG believes that asset allocation is an important investment decision. The goal-based nature of a Personal Strategy means the client’s asset allocation is linked to their evolving situation, thereby maximizing the likelihood of long-term success. EAG has a Market Cap Weighted strategy as an additional investment strategy option for Advisory Services clients who prefer a traditional approach that is more closely aligned with U.S. market benchmarks. EAG will utilize its Smart Weighting methodology for the allocation of U.S. equities in a client’s Managed Account(s) unless the client directs EAG to utilize the Market Cap Weighted strategy’s market-weighting methodology. EAG’s Smart Weighting methodology weights economic sector, style, and size more equally than a market-weighted methodology. A market-weighted methodology utilizes a market capitalization weighted approach to U.S. equities, approximately weighting each position based on its free-float market capitalization value within the broader U.S. total stock market. Target allocations for Personal Strategy+ accounts will be built in an attempt to align with the fundamental asset allocation of the client’s Personal Strategy. In alignment with this general approach to investing, preference will generally go to selecting low-cost passive index funds over actively managed mutual funds for otherwise similar plan options. Funds are selected within the context of their overall fit in the portfolio allocation and how well they represent a particular asset class that the Personal Strategy is aiming to replicate. The investment selection process involves a cost/benefit analysis that takes into consideration cost, diversification benefits, risk, return, our preference for unaffiliated products, and plan constraints. There will be allocation and performance differences between a client’s Personal Strategy+ employer-sponsored retirement account(s) and the client’s Core Personal Strategy Managed Account(s). General Risks of Investing: Investing in securities involves risk of loss that clients should be prepared to bear. Neither EAG nor its affiliates guarantee that the recommendations will result in achieving the retirement income goal. Neither EAG nor its affiliates can guarantee that you can or will avoid negative returns in any of the recommendations. An investment’s future performance may differ substantially from its historical performance and may incur a loss. Past performance is no guarantee of future results. Additionally, the plan provider may make changes from time to time with respect to the investment options available in the plan. While a diversified investment portfolio, including a portfolio of investment products representing different asset categories, can mitigate some risks, it does not and cannot prevent all losses. Ultimately, the investor bears such risks. Below are some of the common factors that can produce a loss in a client’s account and/or in a specific investment product or asset category: Market Risk: Stock and bond markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market or economic developments in the U.S. and in other countries. Market risk may affect a single company, a sector of the economy, a country or geopolitical region, or the market as a whole. Market risk may impact stock and/or bond markets in unanticipated and different ways. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. • Capitalization Risk: Limited resources or less diverse products or services may hinder small-cap and mid-cap companies, and such companies’ stocks have historically been more volatile than the stocks of larger, more established companies. • Category or Style Risk: During various periods of time, one category or style may underperform or outperform other categories and styles. • Credit Risk: The risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may 9  affect a security’s value and impact on the performance of the issue along with any mutual fund or ETF that holds it. • Interest Rate Risk: Interest rate changes significantly affect a debt security’s market value. When interest rates rise, the debt security’s market value declines. When interest rates decline, market values rise. The longer bond maturity results in the greater risk and the higher yield. Conversely, the shorter bond maturity results in the lower risk and the lower yield. Inflation Risk: When any type of inflation is present, purchasing power may erode at the rate of inflation. • • Reinvestment Risk: The risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This relates primarily to fixed income securities. • Exchange-traded funds: ETFs present market and liquidity risks because they are listed on a public securities exchange and are purchased and sold via the exchange at the listed price. The price will vary based on current market conditions and may deviate from the net asset value of the ETF’s underlying portfolio. There may also be an inactive market for certain funds, and/or losses from trading in secondary markets. • Target Date Funds: Generally, the asset allocation of each target date fund will change on an annual basis with the asset allocation becoming more conservative as the fund nears the target retirement date. The target date is the approximate date when investors plan to start withdrawing their money. The principal value of the fund(s) in a plan’s lineup is not guaranteed at any time, including at the time of target date and/or withdrawal. • An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation (FDIC) or any other government agency. Although some money market funds such as U.S. Government money market funds strive to preserve the value of the investment at $1.00 per share, it is possible to lose money by investing in a money market fund. Additionally, other money market funds may operate under new rules and regulations permitting them to have a “floating” value per share. A floating value may be more or less than $1.00 per share (depending on market conditions) and impose liquidity/redemption fees for large or frequent withdrawals. Additionally, participating in the Private Equity fund and investing in the Fund involves significant risks including, but not limited to, liquidity risk, market risk, concentration risk, and potentially highly volatile performance. The Fund is considered a speculative investment and involves a high degree of risk relative to other investment options within Personal Strategy. The Fund is uniquely illiquid in that a client may be unable to liquidate or redeem any or a substantial portion of their investment in the Fund because the Fund in its sole discretion may, but is not required to, provide the client with an offer to redeem a limited portion of their shares. The inability to sell Fund shares could result in the need to sell some or all of a client’s more liquid assets (including to pay EAG’s fees) at a time when it is not optimal to do so, which could result in the client’s account holding a greater concentration of less liquid assets. In-House Portfolio Management: EAG does not utilize outside portfolio managers for Advisory Services except as noted below. All Personal Strategy accounts are managed by EAG’s in-house professionals. EAG’s Personal Strategy Investment Committee acts as the Portfolio Management Team for this wrap fee program. Note that certain portfolio decisions for both Managed Accounts and Personal Strategy+ involve investing in or recommending an investment in securities issued by pooled investment vehicles, e.g., mutual funds, ETFs, and private funds. Outside portfolio managers make investment management decisions for such pooled investment vehicles. Empower Personal Strategy Investment Committee: Our Empower Personal Strategy Investment Committee is dedicated to constructing and maintaining strategic investment portfolios. This includes security selection, portfolio monitoring, and trade oversight. The Committee combines expertise and decades of experience to build a wide range of portfolios designed to help clients meet their financial goals. 10  Craig Birk CFP®, Chief Investment Officer As CIO for Empower Personal Wealth, Craig leads the Empower Personal Strategy Investment Committee, focused on translating improvements in technology into better financial lives. Previously, Craig was CIO of Personal Capital. Jonathan Kreider CFA, EVP and Head of Empower Investments Jonathan leads Empower’s proprietary funds business and is responsible for fund development and management, investment sales and service, and the investment research functions. He has been the Head of Empower Investments since January 2020; prior to that, he was the VP of Investment Products from August 2016. Lacey Cobb CFA, CFP®, Senior Director of Advice Solutions Lacey is Director of Advice Solutions. She has extensive investment industry experience, with a career beginning in 2008 and encompassing roles in advice solutions at Personal Capital and trading at Polaris Greystone. Lacey focuses on personalized strategy selection and contributes to security selection and client education. Brendan Erne CFA, CSRIC, Senior Director of Portfolio Management Brendan leads our research and trading team with a focus on portfolio construction and socially responsible investing. Prior to joining EAG, he was the director of portfolio management at Personal Capital for over 11 years. Marta Norton CFA, Chief Investment Strategist, Empower Marta is Empower’s Chief Investment Strategist and is responsible for developing Empower’s economic and market outlook. She shares her commentary across the enterprise, with both Workplace and Wealth clients. A regular speaker at industry conferences, Marta also appears frequently in financial media. She joined Empower in 2024. Previously she was the Chief Investment Officer for the Americas at Morningstar Wealth. Roger Hobby, EVP Personal Wealth Distribution and Advisory Roger joined Empower in 2024. In his role, he is responsible for distribution and advisory services nationally. He has over 35 years of experience in the financial services industry and was previously at Fidelity Investments, where he was the Head of Distribution for Private Wealth Management, Executive Services, Workplace Planning and Advice, and Stock Plan Services. Certified Financial Planner Board of Standards Inc. (CFP Board) owns the certification marks CFP®, CERTIFIED FINANCIAL PLANNER™, CFP® (with plaque design), and CFP® (with flame design) in the U.S., which it authorizes use of by individuals who successfully complete CFP Board’s initial and ongoing certification requirements. 11  Item 9 — Disciplinary Information EAG, as a registered investment adviser, is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of EAG or the integrity of EAG’s management. EAG has the following disciplinary event to report relative to this item: On August 29, 2025, EAG and its broker/dealer affiliate, Empower Financial Services, Inc. (EFSI), settled a matter with the SEC. The SEC found that, from July 1, 2019 through December 31, 2022, certain retirement plan advisors of EFSI and EAG, all of whom were both registered representatives associated with EFSI and investment adviser representatives associated with EAG, did not sufficiently disclose whether retirement plan advisors were acting as a registered representative or an investment adviser representative when recommending that a plan participant enroll in EAG’s managed account service. Additionally, EFSI and EAG did not adequately disclose the conflicts of interest presented by certain incentive compensation arrangements, leading to misleading statements made to plan participants. Finally, the SEC found that EFSI did not establish, maintain and enforce written policies and procedures reasonably designed to identify and address conflicts of interest in connection with recommendations to enroll in EAG’s managed account service. As a result, the SEC determined that EAG violated section 206(2) of the Investment Advisers Act of 1940 (“Advisers Act”) and EFSI failed to comply with the disclosure and conflict of interest obligations of Regulation Best Interest (“Reg BI”), thereby violating Reg BI’s General Obligation (Exchange Act Rule 15l-1(a)(1)). Without admitting or denying the findings, EFSI and EAG entered into a settlement with the SEC, pursuant to which EAG was censured; ordered to cease and desist from committing or causing any future violations of Section 206(2) of the Advisers Act thereunder; and EAG agreed to pay a civil monetary penalty in the amount of $750,000; and disgorgement of $4,063,569.80. Item 10 – Other Financial Industry Activities and Affiliations EAG is a wholly owned direct subsidiary of ESH US, which is owned by EAICA. Due to the ownership and organizational structure, EAG has other financial industry affiliations with related entities described below. EAG may provide services to, receive services from, or direct or receive business to or from other members of the Empower organization. In some instances, EAG has arrangements that are material to its advisory business with related entities outlined below. Licensed representatives of EAG and other EAG’s advisory staff are employed by Empower Retirement, LLC (Empower) and are Empower Associates. EAG is not a registered broker-dealer, however, there are a very limited number of licensed EAG representatives that an affiliated broker/dealer, Empower Financial Services, Inc. (EFSI), also supervises. Other Financial Industry Affiliations Recordkeeping and Administrative Services Company Empower Retirement, LLC (Empower) is a comprehensive administrative and recordkeeping services provider for financial institutions and employers, which include educational, advisory, enrollment, and communication services for employer-sponsored defined contribution plans and associated defined benefit plans under Internal Revenue Code Section 401(a), 401(k), 403(b), 408, and 457. Insurance Companies Empower Annuity Insurance Company of America (EAICA) is an insurance company domiciled in the State of Colorado. EAG is a wholly owned subsidiary of ESH US, which is owned by EAICA. EAICA, pursuant to various agreements, may provide investment products, recordkeeping, and other administrative services through its affiliates. Empower Life & Annuity Insurance Company of New York (ELAINY) is an insurance company domiciled in the State of New York. EAG is under common control with ELAINY and is an affiliate of ELAINY where EAICA indirectly owns EAG and is the sole owner of ELAINY. ELAINY, pursuant to various agreements, may provide investment products and administrative services through its affiliate, Empower, to retirement plans for which affiliated investment advisers may also provide services. 12  Empower Annuity Insurance Company (EAIC) is an insurance company domiciled in the State of Connecticut. EAG is under common control with EAIC and is an affiliate of EAIC where EAICA indirectly owns EAG and is the sole owner of EAIC. EAIC, pursuant to various agreements, may provide investment products and administrative services individually and through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Broker-Dealer Empower Financial Services, Inc. (EFSI), an affiliate of EAG, is a registered limited broker-dealer and wholly owned subsidiary of EAICA. EFSI may provide wholesaling, direct sales, or enrollment and/or communication services to retirement plans and their participants. Specifically, EFSI may act as an endorser of EAG’s investment advisory services for qualified or eligible plan participants. Trust Company Empower Trust Company, LLC (ETC) is a trust company and affiliate of EAG. ETC is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. ETC is chartered under the laws of the State of Colorado. Investment Company Empower Funds, Inc. (EFI or Empower Funds), an investment company registered under the Investment Company Act of 1940, is affiliated with EAG. ECM is the investment adviser to EFI, as discussed below. Investment Advisers Empower Capital Management, LLC (ECM), an affiliate of EAG, is a registered investment adviser under the Advisers Act and is the investment adviser for Empower Funds. It is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. Irish Life Investment Management, Limited (ILIM) is a Dublin, Ireland based SEC registered investment adviser. ILIM is part of the Lifeco group of companies; Lifeco has operations in Canada, the United States, Europe, and Asia through ownership of companies including EAICA. EAG is an indirect wholly owned subsidiary of EAICA. EAICA is an indirect wholly owned subsidiary of Lifeco EAICA is an indirect wholly owned subsidiary of Lifeco, which controls ILIM. ILIM manages the index series of Empower Funds. Holding Company Great-West Lifeco Inc. (Lifeco), EAG’s indirect parent company, owns approximately 6% of Franklin Templeton Investments’ parent company, Franklin Resources, Inc. (Franklin) as of January 1, 2024. Franklin or certain of its investment management subsidiaries (collectively, the Franklin Group entities) may provide management, advisory or sub-advisory services to investment funds that may be investment options in a Managed Account. Franklin and Lifeco have entered into arrangements under which Lifeco has committed to allocate Lifeco and affiliate assets over a period of time to be managed by Franklin’s investment managers and to support the availability of Franklin Group entity products and services on enterprise platforms. As a result, Empower and Lifeco will derive an economic benefit to the extent that Franklin Group entities provide management, advisory or sub-advisory services to funds or products. If Franklin achieves certain revenue thresholds under those arrangements, Lifeco will receive contingent transaction consideration and Lifeco and other Empower affiliates will derive an economic benefit if assets are allocated to a Franklin investment option. Branding The affiliated companies of EAG, Empower Personal Wealth, ECM, EFSI, EAICA, EAIC, ELAINY, Empower Funds, Empower, and ETC operate under the multiple brands of Empower and Empower Institutional depending upon the products, services and retirement markets involved. These brands do not materially affect the internal structure of EAG or EAG’s corporate ownership. Conflicts of Interest EAG has authorized EFSI, an affiliate broker/dealer of EAG, and its licensed agents and registered representatives who are Empower employees (collectively referred to as Agents) to refer prospective clients to EAG. In this arrangement, in addition to their salary, such Agents may earn bonus compensation based upon successful referrals 13  or endorsements. Empower also indirectly compensates other Agents and EAG representatives through bonus compensation, in addition to their salary, in the event that a referred prospect becomes a new client of EAG’s Services. The compensation paid to Agents or EAG representatives does not increase the fees paid by the client. EAG also has conflicts of interest to the extent that it makes investment recommendations to clients or suggests use of affiliated financial products or services which will pay additional compensation to its affiliates. Conflicts related to increased use and promotion of the Services: • Increased advisory fee income. EAG’s representatives may recommend that you use the Services. If you enroll in certain Services, EAG will earn additional compensation in the form of advisory fees. • Increased affiliate fee income. When you use the Services, EAG may recommend you increase contributions or utilize other savings or investment strategies. EAG’s affiliates provide a bundle of recordkeeping, trust, custody, brokerage, investment, and other related services to retirement plans and other investment accounts. If you pay for these related services through an arrangement where our affiliates charge a direct fee, EAG’s affiliates may receive additional fees for these services. These additional fees result from EAG’s recommendations because you may contribute, invest, or transact in more assets with EAG’s family of companies. • Representative Compensation. EAG has authorized EFSI, an affiliate of EAG, and its Agents to solicit, refer and market EAG’s services. In addition to their salary, Agents may earn bonus compensation based upon engaging plan sponsors to offer EAG’s services. Additionally, Agents and EAG representatives receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to rollover plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent or EAG representative involved, an Agent or EAG representative also receives incentive compensation paid by Empower when the referred participant ultimately rolls over their assets into and funds an advisory account with EAG. Empower indirectly compensates other Agents and EAG representatives through bonus compensation, in addition to their salary, for communication, education and/or assisting plan participants to enroll in EAG’s Services. Compensation paid to Agents or EAG representatives does not increase the fees paid by the plan, plan sponsor, Members, and/or account holders. The incentive compensation an EAG representative receives depends on position type but Empower generally calculates incentive compensation based on Empower’s and/or EAICA’s profitability and the achievement of individual performance goals that may include factors unrelated to an account holder’s adoption of investment products or services offered through Empower or EAG. Agents’ and EAG representatives’ individual performance goals and their related incentive compensation are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained as result of the engagements. The rate of incentive compensation considers the total amount of retained or accumulated assets, compared with the monthly asset goal, as determined by EAG on a periodic basis. The asset goal is generally set on an annual basis and may differ by product or account type. Additional factors include certain qualitative factors, such as leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Other Business Activity Certain senior managers and officers of EAG may also serve as executive officers of EAG’s parent company EAICA, and other EAG affiliates. Investment Lines of Credit/Loan Advances EAG will make introductions for investment lines of credit or loan advances in certain situations. Both are offered by Pershing/Bank of New York who serves as the custodian and broker-dealer but is otherwise an unaffiliated financial institution. These offerings are opened only at the client’s sole discretion and EAG does not receive payment or remuneration for making these introductions or in the event that any credit or loan advance is made. 14  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading EAG Code of Ethics EAG has adopted a Code of Ethics (EAG’s Code) pursuant to Advisers Act Rule 204A-1. EAG’s Code sets forth a standard of business conduct expected of advisory personnel. It requires EAG’s advisory personnel, among other things, to report their personal securities holdings and transactions in accordance with the Advisers Act. EAG requires its officers, managers, and certain employees (Access Persons) to comply with EAG’s Code. EAG will provide a copy of EAG’s Code to current or prospective clients, upon request. EAG’s Code includes provisions related to: • Fiduciary responsibility to clients/Members; • Compliance with federal securities laws; • Protection and safeguarding of confidential information; • Giving and receiving gifts, gratuities, and entertainment; • Political contributions; • Reporting and monitoring personal securities transactions; • Avoiding and disclosing conflicts of interest; and • Reporting violations of the EAG’s Code. Personal Trading EAG’s Code requires pre-clearance of certain securities transactions. Access Persons may trade for their own personal accounts in securities that EAG recommends to and/or purchases for its advisory clients. However, because EAG’s Code would permit Access Persons to invest in the same securities as clients in some circumstances, there is a possibility that employees could benefit from market activity by a client in a security held by an Access Person. As a result, EAG continuously monitors trading in accordance with EAG’s Code and federal securities laws. EAG intends for EAG’s Code to ensure that the personal securities transactions and the outside business activities of EAG’s Access Persons do not interfere with making decisions in the best interest of advisory clients or Members. Principal Trading EAG has adopted a policy and practice not to engage in any principal transactions. EAG holds no investments for its own accounts that EAG could buy from, or sell to, an advisory client. In the event of any change in EAG’s policy, management must approve any such change. EAG would only permit a principal transaction after meeting the review and approval requirements described under the anti-fraud section of the Advisers Act. Item 12 – Brokerage Practices Brokerage Selection; Best Execution Transactions recommended for the Advisory Services discussed in this Brochure are executed through Pershing. Personal Strategy+ Services transactions are executed through the respective plan’s financial institution where the employer- sponsored retirement account is held. Soft Dollar Practices As a matter of policy, EAG does not utilize research, or other products or services from third parties in connection with client securities transactions on a soft-dollar commission basis. 15  Trade Aggregation EAG’s Managed Accounts client trades are batched throughout the day to leverage operational and market efficiencies. Client-directed transactions and liquidations may not be executed on a same-day basis. Portfolio transaction requests, including liquidations, can be monitored via the Dashboard, or via the custodian’s website; however, neither site is real-time with respect to liquidations and transactions. EAG trades Managed Accounts exclusively with Pershing and this creates a conflict of interest because of the operational support services Pershing provides to EAG. In recognition of this conflict, we have implemented a periodic analysis to evaluate execution quality and a cross-functional Best Execution Committee which oversees the review process. EAG communicates Personal Strategy+ trade orders through a third-party (Third-Party Service Provider). The Third- Party Service Provider communicates orders to the financial institution where a client’s Personal Strategy+ account is held, and the financial institution is responsible for executing the trades. Personal Strategy+ trade orders will not be executed on the day they are communicated by EAG and may be delayed due to circumstances outside of our control. Generally, the Third-Party Service Provider will communicate trades to the financial institution within 36 hours, but some orders may take longer for multi-part trades. Once an order has been successfully communicated, execution of the trade typically takes one business day, but will depend on the financial institution. If a client elects to invest in the Private Equity offering, the client will invest in a registered closed end fund product advised by iCapital, which is responsible for fund investment selection and portfolio management in private equity securities. Supplemental information on this program is provided to Private Clients upon request. EAG seeks to effect orders correctly, promptly, and in the best interests of our clients. In the event an error occurs in the handling of any client transaction, due to our actions, or inaction, we will offer to correct the error upon discovery (within the confines of the account requirements and restrictions) and without disadvantaging the client. Compensation or consideration for the error loss may be paid to clients through the offer of fee waivers or fee credits for management Services in lieu of cash or securities. Negative investment performance returns resulting from the implementation of an investment strategy are not considered a trade error for purposes of our policy. Item 13 – Review of Accounts EAG utilizes portfolio management software in concert with the client’s Advisor to monitor and manage clients’ accounts on a continual basis. Exception reporting is monitored by Portfolio Manager Deviations from an account’s determined asset allocation parameters and the addition or removal of a specific security from the designated model portfolio may trigger periodic rebalancing. For clients who enroll in our Personal Strategy+ program, our Portfolio Management Team monitors underlying investment allocations using the Third-Party Service Provider’s application, which identifies when a client’s account is out of alignment with their Personal Strategy+ allocation. The Portfolio Management Team will also periodically revisit the client’s allocation relative to underlying investment lineup changes and make changes, as necessary. EAG provides clients with online access to their financial information through the Dashboard. In addition, EAG provides a detailed monthly report to each client. Clients also continue to receive account statements and confirmations from the designated Broker (Pershing) or Personal Strategy+ plan administrator (if applicable). Clients are urged to periodically compare statements prepared by EAG and their Broker (Pershing) or Personal Strategy+ plan administrator (if applicable) with specific emphasis on activity, holdings, and valuations. Item 14 – Client Referrals and Other Compensation Promotions EAG has periodic promotions offering various items, such as technology products, fee waivers on management fees, or reduced management fees. Client referrals, or other referral arrangements as outlined below, may, from time to time, be combined with promotional offers. Any combination of referral benefits and promotional items will not result in a client paying a higher advisory fee. EAG will disclose the terms of promotional offers to clients at the time of the offers. 16  Client Referrals From time to time, EAG offers free Advisory Services for a certain period for existing clients who refer new clients to EAG. When the referred client signs up and begins trading, both the existing client and referred client receive fee- waived Advisory Services for the same period of time. From time to time, Advisors may also offer other incentives for client referrals. EAG will disclose the details of those incentives to existing and referred clients at the time of the offer. Prospective clients that are referred by existing clients should be aware that the referring client will receive an economic benefit for making the referral. The free Advisory Services awarded, or any other incentive provided by EAG, do not increase the fees or costs for the referring or referred client. Referrals by Affiliates EAG has an Endorsement Agreement in place with EFSI, an affiliated broker-dealer, whereby EFSI or EFSI registered representatives will refer certain high-net worth clients to EAG. EFSI or EFSI registered representatives may receive direct or indirect compensation for these referrals. Agents and EAG representatives receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to rollover plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent or EAG representative involved, an Agent or EAG representative also receives incentive compensation paid by Empower when the referred participant ultimately rolls over their assets into and funds an advisory account with EAG. Any affiliated referral compensation arrangement will not increase costs for clients. Third-Party Client Introductions EAG also has referral arrangements with unaffiliated third parties for client referrals. These third parties introduce prospective clients to EAG and will receive compensation in the form of cash payments for these introductions. These third parties are eligible for compensation even if the referred prospect does not become a client. Such compensation will be paid pursuant to a written agreement. These referral arrangements will not result in increased fees or costs for clients. Testimonials and Endorsements EAG enters into agreements with clients and non-client Third Parties (Promoters) to provide testimonials or endorsements of our Advisory Services. Any advertisement that displays a testimonial or endorsement provided by a Promoter will disclose clearly and prominently whether the Promoter i) is a client of EAG; ii) is paid or unpaid; and iii) creates any other material conflict of interest. If the Promoter is paid, EAG confirms that the Promoter is not disqualified under Federal Securities Laws and discloses the compensation range. Individuals who become clients as a result of our various referral programs acknowledge in our client agreement that they have reviewed, read, and understood our disclosures and Part 2A of EAG’s Form ADV. Affiliate Marketing Program Empower Personal Wealth offers an Affiliate Marketing Program (AMP) to web-based authors and participates in co-registration agreements, where the participants (affiliate or affiliates) are compensated for each person who uses the affiliates’ webpages to register with the Dashboard and link at least $100,000 in new investable assets to the Dashboard. These affiliates are eligible for compensation even if the referred person does not become a client. Affiliates will financially benefit from referring users to EAG or affiliates. This creates a conflict of interest and incentivizes affiliates to present content favorable to EAG or affiliates of EAG because of the compensation structure of the AMP. No additional fees or costs are charged to persons who register with the Dashboard and become a client as a result of the AMP. Other Referral Arrangements Empower Personal Wealth enters into referral agreements with third parties who refer prospective clients to the Dashboard (Referrer or Referrers) under which Referrers receive compensation for each individual who acknowledges that they have at least $100,000 in investable assets. Individuals referred by Referrers to the Dashboard and subsequently become clients do not pay any increased fees to EAG as a result of the referral arrangement. 17  Item 15 — Custody EAG does not maintain actual custody of its clients’ cash, bank accounts, or securities. If applicable, clients receive periodic account statements (at least quarterly) from their custodian and should carefully review these statements. Item 16 – Investment Discretion Personal Strategy+ Services EAG offers clients Personal Strategy+ Services, which are ongoing, discretionary wealth management Services on employer- sponsored retirement accounts. This is a distinct offering from our point-in-time retirement plan allocation services that are available to all Core Managed Account clients upon request. EAG’s Personal Strategy+ Services are limited to providing investment advice and management of the assets in a client’s employer-sponsored retirement account(s) and the plan administrator continues to act as the qualified custodian for these accounts. Any transaction or performance information provided by EAG is for informational purposes only, as the plan administrator for the employer-sponsored retirement account(s) is the official custodian and recordkeeper for all performance and transaction information. If the client would like to use the advice provided, the client will need to ensure a trade is placed in accordance with the plan’s rules since EAG does not have custody of the plan account. Item 17 — Voting Client Securities EAG uses a third-party proxy voting service to help fulfill our voting obligations in voting proxy ballots for our clients. Votes are cast through the Broadridge ProxyEdge® platform, which provides access to proxy voting recommendations as well as historical voting information. Services provided to us through ProxyEdge® include reporting, auditing, and recordkeeping. With the assistance of Broadridge, Glass Lewis & Co. (“Glass Lewis”) provides EAG recommendations based on Glass Lewis’ own internal guidelines, research, and analysis. Votes are generally cast consistent with Glass Lewis guidelines and recommendations; however, EAG will vote otherwise, or abstain, if it is deemed in the best interest of its clients to do so. EAG votes proxies for SRI accounts in the same manner as the Core Personal Strategy portfolios, which use the Glass Lewis standard policy. This policy does not take an activist or ESG-specific approach. Clients with at least $5 million in AUM in Personal Strategy are permitted to vote their own proxies by “opting out” of proxy voting services during the account opening process, or at any time, by submitting a request in writing to EAG. If a client chooses to “opt out,” they do so on an “all or none” basis and agree to respond to their own proxies independently of EAG. Additionally, to the extent a client holds a foreign direct security that is not a Personal Strategy position, Glass Lewis is unable to vote proxy ballots for those client-mandated holdings. EAG does not vote proxies for holdings in Personal Strategy+ advised accounts. EAG maintains relevant and appropriate proxy records. A client may obtain a complete copy of the Policies & Procedures related to proxy voting by requesting this information in writing to their Advisor. The client may also request in writing, from their Advisor, information concerning the manner in which proxy votes have been cast on behalf of the client during the prior annual period. Such information is provided in writing as soon as practicable. Item 18 — Financial Information As previously discussed, under certain circumstances EAG has discretionary authority over certain client funds and securities. Accordingly, EAG must disclose only information about its financial condition that is reasonably likely to impair EAG’s ability to meet contractual commitments to its clients. EAG has no financial commitment that impairs its ability to meet contractual commitments to its clients, nor has EAG been the subject of a bankruptcy proceeding. Finally, EAG does not require or solicit prepayment of fees of more than $1,200 per client/Member more than six months in advance. This is not an Offer to Purchase or Sell Securities. The information contained in this Brochure, including information regarding Empower Funds, is for disclosure and other informational purposes only. It is not an offer to sell or a solicitation of an offer to buy any securities and may not be relied upon in connection with the purchase or sale of any security. 18