About the Adviser Empower Capital Management, LLC (“ECM” or the “Adviser”) is a Colorado limited liability company formed in 1994 as a corporation under the name Maxim Capital Management, LLC d/b/a GW Capital Management, Inc. In 1997, it converted to a limited liability company under the same name. On September 24, 2012, Maxim Capital Management, LLC d/b/a GW Capital Management, LLC rebranded as Great-West Capital Management, LLC (“GWCM”). On August 1, 2022, GWCM was rebranded as Empower Capital Management, LLC. The Adviser 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. Empower Holdings, Inc. 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 that it controls. Types of Services Provided by the Adviser; Clients The Adviser provides investment advisory services for the following clients:
• Empower Funds, Inc. (“EFI or the “Funds”) – an open-end management company affiliated with the Adviser. As of December 31, 2023, EFI consists of a series of 45 underlying portfolios, each with its own investment objective, policies, and strategy (each, a “Fund” of EFI). EFI operates under a manager-of-managers structure pursuant to an order issued by the SEC which permits the Adviser to enter into, terminate or materially amend sub-advisory agreements on behalf of each of the Funds without shareholder approval. This is discussed in greater detail below under Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss, Use of Sub- Advisers by the Adviser.
• Stable value separate accounts (stable value group annuity and/or group funding agreements), with 401(a), 401(k) and 457(b) plans (“Empower Accounts”).
• Multi-Manager Custom Stable Value Investment Management (“Diversified Stable Value Portfolios”) – a custom multi-manager stable value product structured as a separately managed account for clients

sponsoring 401(a), 401(k) and Government 457(b) plans.
• Corporate Owned Life Insurance – Variable Universal Life (“COLI-VUL”) – separate accounts for which EAICA is the sponsor.
• Farm Bureau Life Insurance Company of Michigan (“Farm Bureau”).
• Various collective investment trusts (“CITs”) – offered solely to the clients of Empower Trust Company, LLC (“ETC”), as trustee for those clients.
• Massachusetts Mutual Life Insurance Company (“MassMutual”) (as grantor of the Hartford Trust) (“Hartford Trust”) – a guaranteed interest account held in a trust for the benefit of legacy insurance policies that were part of the retirement business acquired by EAICA on December 31, 2020.
• Guaranteed interest contract separate accounts supporting certain legacy MassMutual insurance policies (“MassMutual SIAs”) that were part of the retirement business acquired by EAICA on December 31, 2020.
• ECM is also the collateral manager for several collateralized loan obligations (“CLOs”) and related warehouse facilities. For the following clients, the Adviser’s agreements for its investment advisory services can be terminated by the Adviser, a Fund specifically or the Funds in entirety, a COLI-VUL separate account, EAICA and ELAINY on behalf of an Empower Account(s), Farm Bureau, or ETC on behalf of a CIT(s), as the case may be, at any time, by giving notice to the other party as set forth in the agreement: EFI, Empower Accounts, Diversified Stable Value Portfolios, COLI-VUL, MassMutual SIAs, Farm Bureau, and CITs fees charged to the Adviser’s Clients are calculated in arrears as discussed in Item 5 – Fees and Compensation. The Adviser, as a matter of policy and practice, does not sponsor any wrap fee program, nor act as an adviser or sub- adviser in any wrap fee program. Assets under Management with the Adviser The SEC adopted a uniform method for advisers to calculate assets under management for regulatory purposes which it refers to as an adviser’s “regulatory assets under management.” Other than EFI and the CITs, regulatory assets under management generally includes the adviser’s gross assets, i.e., assets under management without deduction for outstanding indebtedness or other accrued but unpaid liabilities. The Adviser reports its regulatory assets under management in Item 5 of Part 1 of Form ADV, located at www.adviserinfo.sec.gov. As of December 31, 2023: Discretionary Assets under management: $59,915,919,562 Non-Discretionary Asset under management: $4,964,609,122 Total (discretionary and non-discretionary) assets under management: $64,880,528,684