Description of Advisory Firm Established in 2000, Voya Retirement Advisors, LLC (“VRA,” “we,” or “us”) is a federally registered investment adviser. It is a direct wholly owned subsidiary of Voya Retirement Insurance and Annuity Company, which, in turn, is wholly owned by Voya Holdings Inc., which is owned by Voya Financial, Inc. VRA’s primary business is acting as a Registered Investment Advisor and spends less than 5% of its time engaged in related activities. VRA provides investment advisory services to retirement plan participants. The services VRA provides are elective, additional services adopted by the plan sponsor and made available to plan participants where its affiliates, Voya Institutional Plan Services, LLC and Voya Retirement Insurance and Annuity Company act as administrators and record-keepers to the retirement plan. VRA cannot and does not guarantee future financial results or the achievement of your financial goals through implementation of any advice or recommendations provided to you. VRA does not monitor the day-to-day performance of your specific investments. Services Offered with Edelman Financial Engines VRA offers two advisory programs, one advisory program is point in time allocation-based advice (Online Advice), the second is a discretionary fee-based ongoing advice service (Professional Management). The Professional Management service includes an educational retirement assessment service (Retirement Evaluation) and an income focused supplemental component Income Beyond Retirement (“IBR”). Each service listed above relies upon the investment options the plan sponsor selected for the plan and the investment methodology and computer programs (the “Workstation”) of Financial Engines Advisors (“FEA”), an unaffiliated registered investment advisor. The investment options are selected by the plan sponsor and made available to plan-participants for self-directed investing or as the underlying investment options upon which the Workstation leverages to generate advice recommendations. The Workstation generates financial analysis, asset allocation and investment recommendations relevant to retirement planning. VRA provides advisory services online, via telephone and email through its Investment Advisor Representatives (“Advisor”). VRA offers Online Advice (‘OA”) and Professional Management (“PM”) services to certain retirement plan participants. The OA is an investment advisory tool participants can access and use online to receive a point-in-time investment recommendations on their account. PM is a discretionary managed account program where participants can enroll (online, via an enrollment form or via an Advisor) and receive ongoing advice to their account, including updated investment recommendations and allocation changes. For additional information on the “OA” and “PM” programs see below. Retirement Evaluation You can request a Retirement Evaluation (“RE”) electronically or printed, providing an assessment of your current savings and/or investment decisions relative to your retirement plan account. The RE is designed to communicate some or all of the following information:
• a summary of the current value of your plan account;
• a forecast of how much the plan account investments, and other investments that you submit for analysis, might be worth at retirement;
• whether a change is recommended to your current contribution rate, risk and diversification, unrestricted company stock holdings, if applicable, or investment style and allocation;
• investment proposals; and a projection of how much annual income can be anticipated at retirement, based on how much the plan account plus Social Security and certain other benefit accounts could provide. This projection is based on information provided and/or verified by you to the Advisor during your discussion and is not a guarantee of future results and can and will change over time. You can also request an updated RE at any time by contacting an Advisor. P a g e | 5 Online Advice If you prefer to receive point-in-time investment advice using a self-service and self-implementation approach without the help of an Advisor, you can access the OA program directly via the internet. OA is an online investment advice service provided by FEA, which is an independent investment advisor. FEA is a wholly owned subsidiary of Financial Engines, Inc. and serves as a sub-advisor to VRA. OA is a computer model and incorporates financial analysis and asset allocation methods consistent with FEA guidelines and generally accepted financial planning and asset allocation principles. OA is based on a point-in-time analysis and is not an ongoing management service. This program is designed to:
• assist you in setting retirement goals;
• provide goal-appropriate saving and investment recommendations;
• help you monitor your retirement account; and
• permit you to perform “what-if” modeling. The OA program will provide specific investment allocation recommendations among the funds made available in your employer’s retirement plan. These recommendations are not an endorsement of any particular investment. OA will also generate an estimate of the likelihood of you reaching your retirement goals. This estimate is based on information provided and/or verified by you and is not a guarantee of future results and can and will change over time. The OA program does not include continued monitoring of the investment advice provided for your account. You must implement the recommendations received and revisit the OA site in order to update your information and receive updated recommendations. You maintain full control of your account and are under no obligation to implement the recommendations received. Professional Management In retirement plan accounts of certain plan sponsors, we provide an optional managed account program called Professional Management (“PM”). For purposes of this program, VRA shall act as an “investment manager” as defined under Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). This means that VRA implements its investment recommendations and may make changes designed to keep your savings rate and investment allocation aligned with your goals. To learn if this program is available to you, you may either call us to speak with an Advisor or read your plan’s fact sheet. VRA recommendations consider your current savings, number of years to your assumed retirement age and a personalized level of risk. PM output is delivered by Advisors who are contacted by calling your plan’s toll-free information line. Alternatively, you have the ability to enroll in the PM service through your employer sponsored plan website. You will also be provided a Welcome kit with an assessment of your current investment risk and forecast of your probability of achieving your retirement goal upon your enrollment in the PM program, whether enrollment occurs online, by phone or paper. The investment transactions are then transmitted to your plan’s record- keeper and implemented on your behalf. Central to the delivery of PM is the Advisor’s use of the advice workstation. Information about your retirement plan account that is provided from your plan’s record-keeper and the fact finding and goal defining conversation between you and the advisor is input into the workstation. Based upon your responses during the interview and the data and information you provide to an Advisor, the advisor provides a forecast of the probability of achieving your desired retirement income goal(s), which is based exclusively on the output of the advice workstation. The workstation relies on the proprietary methodology developed and maintained by FEA to create target allocations and forecasts for participants. The forecasts generated by the advice workstation focus on a personalized analysis and are designed to answer the following questions:
• What is the chance that I might reach my retirement goal(s)?
• How much value might I lose over the next year?
• What is the range of income I might expect in retirement?
• How much might my portfolio be worth at retirement? The forecasted retirement income is based on income provided by the following sources:
• Your retirement accounts (including individual retirement plan accounts and other accounts designated for retirement);
• your pension; P a g e | 6
• Social Security estimates; and
• other sources of retirement-designated income. The advisor also solicits responses from you regarding your tolerance for risk or loss (in percentage and/or dollar terms) and consequences of financial transactions (for example, withdrawals and outflows). The objective of this process is to provide a personalized asset allocation and personalized retirement savings strategy. The result is a personalized, inflation-adjusted retirement income forecast. VRA uses the forecasts described above to offer strategies designed to help improve your understanding of, and ability to achieve your retirement goal(s). For example, if the illustrations show a shortfall of retirement income (as compared to your expected needs), one or a combination of the following actions would be discussed:
• increase contributions to the retirement plan account;
• change investment mix;
• retire later or supplement your income during retirement; and
• reduce retirement income expectations. Making adjustments to your current savings, investments and portfolio risk can have a significant impact on the probability of achieving your retirement goal(s). Your advisor will model assumed changes to savings rates and investment allocations and communicate the results to you during the course of your conversation. This approach is designed to help you understand how actions such as reallocating investments or increasing your savings may improve your chances to achieve your retirement goal(s). If you enroll in the PM program, you authorize VRA to provide discretionary ongoing management of your retirement plan account(s) which would include a personalized combination of the following actions with the objective of achieving your retirement goals: automatically increasing your contributions, rebalancing and/or re-optimizing and updating your investment allocation and adjusting your allocation overtime based on your changing retirement time horizon. Rebalancing and re-optimization occur periodically, but no less frequently than annually. Income Beyond Retirement Program and Planning Tool Participants age 55 or older and within 7 years of retirement can elect to focus all or a portion of their investment allocation on an income-generating strategy, referred to herein as the “income objective”. Participants are presented with an online planning tool that allows them to evaluate the impact of assigning different portions of their investment allocation to the “income” and standard “growth” objectives on retirement income payouts. Participants may choose to implement the output from the tool on their own at no cost or enroll in PM with the Income Beyond Retirement (“IBR”) feature for a fee and have their strategy implemented and monitored monthly, with the option for VRA to manage recurring payouts. The Income Beyond Retirement feature of Professional Management provides you with a customized investment allocation that combines both the standard “growth” objective and “income” objective with optional payout capabilities and the ability to generate lifetime income from your retirement account(s). You can work with an Advisor to further customize your plan by including other household investments, retirement benefits, and/or exploring different retirement dates. You maintain full access to the funds in your account subject to restrictions related to your specific investments and/or retirement plan. You have the option to work with an Advisor to further customize your plan by including other household investments, retirement benefits, and/or exploring different retirement dates. Once in or near retirement, your account transitions to your target investment mix with the option to generate payments from the” income” and/or “growth” components of your account Optional monthly income payouts:
• Are set on an annual basis and subject to market conditions
• Balances grow with capital preservation
• Can last for life (with optional out-of-plan annuity purchase)
• Can go up with market appreciation
• Are flexible, and can be started or stopped at any time You maintain full access to the funds within your account subject to restrictions related to your specific investments and/or retirement plan. At every stage of retirement, you have unlimited access to an Advisor to help answer questions and refine P a g e | 7 your retirement plan. The following additional terms apply to the IBR feature and form a part of the terms and conditions. Unless otherwise specified, the terms used have the same meaning as in the Fact Sheet, Advisory Services Agreement, and elsewhere in this ADV. Investment Strategy for the Income portion of your account: With the IBR feature, a portion of your account will be allocated to the “income” objective. In the “income” objective, we design your investment strategy for the managed Plan accounts with a primary goal of seeking to generate income in retirement. In managing your accounts and determining the amount of income you could receive in retirement from the Plan accounts assets (see “Distributions and Payouts”), we also designate a portion of your accounts to increase the likelihood that you are able to make an optional annuity purchase for a lifetime income guarantee. IBR allows Participants additional flexibility to designate all or a portion of their account(s) to the income objective, with the remainder managed to the standard growth-oriented objective. Income Beyond Retirement can facilitate steady payouts, at a Participant’s request. Activation and Removal of the IBR feature: In order to be eligible for the IBR feature, you must: 1) be a Program member and a participant in a Plan offering this feature; 2) meet then-current eligibility requirements for the Program (as described in the terms and conditions); and 3) meet then- current eligibility requirements for the feature (currently age 55 or older and within 7 years of retirement). We reserve the right to change eligibility requirements for the IBR feature at any time without notice. If you no longer meet the eligibility requirements, the IBR feature will be removed from your account(s). This would occur for a number of reasons, including but not limited to the following: personal account eligibility status changes; or changes in your Provider’s or Plan’s eligibility for and ability to support the IBR feature (changes to Plan provisions or the fund lineup, for instance). You have the ability to request to remove the IBR feature at any time without penalty by contacting an Advisor during business hours. When the IBR feature is removed, you will continue to remain enrolled in the PM program for the applicable managed Plan accounts until you request to cancel. If you remove the IBR feature but remain enrolled in the Program, you will receive an updated Retirement Plan if your investment strategy is changed; otherwise, we will continue to manage your account based on the assumptions indicated in the communications we send to you. After the IBR feature is removed, you must contact VRA in order to request

distributions from your accounts. If the IBR feature is activated or removed for any of your managed Plan accounts, it will also be activated or removed for all of your other managed Plan accounts. Delegation of Authority: In addition to the authority delegated to VRA for the Program, if you decide to request any distributions from your accounts through the IBR feature, you delegate to VRA all powers, duties and responsibilities necessary to effectuate any requested distributions, including without limitation the power for VRA to specify the time and amount of distributions, to instruct Provider and other parties as needed to process distribution requests, and to provide such consents as may be required for making distributions. Distributions and Payouts: Plan distributions (sometimes also referred to as “plan withdrawals” or “plan payments”) are withdrawals from Plan accounts. The IBR feature includes an option for you to request recurring distributions from your managed Plan account through (“Distributions and Payouts”) or non-recurring distributions from those accounts (collectively, “distributions”). All distributions under this program are withdrawn from the assets in your managed Plan account. Non-Managed Assets: If you are enrolled in IBR and/or you’ve requested recurring distributions, we do not consider any assets that are not managed by us. Your Representations. By requesting a distribution, you are representing that you are legally authorized to request such distributions from the specified accounts and that you have obtained any additional consents from third parties as may be required under Plan provisions or other applicable law. Transition Period: If you activate the IBR feature and start Payouts, we shorten or remove your transition period as P a g e | 8 appropriate and issue Account Directions to move your Plan account directly towards an allocation target as appropriate for your investment strategy and Payout request. This may mean significant changes to your account allocation during a short period of time, including the sale of Company Stock, and may result in incurring various fees, such as fund redemption fees. Types of Distribution: Payouts: You can request to start or terminate Payouts from your accounts that are activated with the IBR feature. You may request the form of such distribution (for instance, by check to your primary mailing address on file with the Provider or by direct deposit to an account you have specified to the Provider) Unless you have specified otherwise, the Payout will be sent as a check to your primary mailing address on file. In order to start Payouts for your account, the IBR feature must be activated and you must also meet then- current Payout eligibility requirements. If eligible, you can request to start Payouts by calling us. We reserve the right to change Payout eligibility requirements at any time without notice. You understand that by requesting to start Payouts, you are authorizing a recurring distribution from your account at the frequency (typically monthly) and in the manner you’ve agreed to and for such amounts as VRA may specify. You also understand that if you request to start Payouts through the IBR feature, we may change or cancel any existing recurring distributions (such as installments) from your Plan account. After starting Payouts, you should contact VRA to request any additional distributions. If you process a distribution from your account without contacting VRA, we will discontinue your recurring payouts. When Payouts start, we provide you with information on the estimated dates and amounts of future planned Payouts. Although we manage your account to seek to provide steady Payouts, future Payout amounts are not guaranteed and have the possibility of declining due to various factors, including but not limited to material changes in market conditions and changes to your Plan account balance such as due to additional distributions. Your future planned Payout amounts assume continued enrollment in the Program, receiving Payouts from accounts activated with the feature, and are based in part on current market conditions and on your manageable current account balance(s), which include unvested dollars and not reflect recent distributions you have taken. Payouts are not guaranteed to last throughout your retirement or your lifetime. The timing of the first Payout depends on system cycles and other factors that impact the ability of VRA, the Provider, and any necessary third parties (such as custodians) to process the request. Please allow sufficient time for processing and contact us if you haven’t received your first distribution after 8 weeks. We will terminate payouts from your account for the following reasons, including but not limited to personal account eligibility status changes; you process a distribution without consultation with an Advisor, changes in your Provider’s or Plan’s eligibility for and ability to support Payouts. You can also request to terminate Payouts, and any cancellable Payouts may be terminated after your request has been processed by us and by the Provider, typically after a business day. Note that some recurring distributions may not be cancellable due to the timing of Payout processing. If you terminate Payouts and then restart them at a later time, we will reassess your new Payout amounts, which may be less than your previous Payout amounts. After Payouts are terminated, your accounts will remain activated for the IBR feature and enrolled in the Program until you request to remove the IBR feature or cancel from the Program. In addition, after the termination of Payouts, you must contact your Provider directly in order to request distributions. Your Payout status will apply to all of your managed Plan accounts. Therefore, if Payouts are terminated for any of your managed Plan accounts, Payouts will also be terminated for all of your managed Plan accounts. Additional Distributions: You can also request a non-recurring distribution from your accounts that are activated with the IBR feature by calling your plan’s information line and speaking with an Advisor. Additional distributions may decrease the amount of Payouts. Note: If you process an additional distribution without consulting with an Advisor, your scheduled payouts will be discontinued. P a g e | 9 After making a distribution request, please allow sufficient time for processing and contact us if you haven’t received your distribution after two weeks. You can request to cancel a distribution request, and any cancellable distributions will terminate after your request has been processed by us and by the Provider, typically after a business day. Note that some distributions may not be cancellable due to the timing of the distribution processing. Tax: Distributions may have tax consequences. You acknowledge that in connection with any distributions, where applicable, you have received and reviewed a copy of the required tax notice about plan distributions and that a copy of such notice may also be requested by contacting your Provider. Actual distributions received will be reduced by any applicable federal and state tax withholdings and other expenses, including Provider fees. Distributions made before age 59 ½ may be subject to early withdrawal penalties under the Internal Revenue Code. Please consult your tax advisor for more information. Payouts may meet the annual minimum distribution amount required under applicable Internal Revenue Service regulations but are not guaranteed to do so. VRA does not ensure compliance with required minimum distributions. Your Provider may make additional distributions from your account in order to satisfy required minimum distributions. Services Offered with Morningstar Investment Management VRA offers two advisory programs with Morningstar Investment Management, collectively referred to as “VRA powered by Morningstar”. One advisory program is a point in time investment recommendation advice (Online Advice), the second is a discretionary fee-based ongoing advice service (Professional Management). Each program relies upon the investment options the plan sponsor selected for the plan and the investment methodology and computer programs (the “Workstation”) of Morningstar Investment Management (“Morningstar”), an independent financial expert/sub-adviser and a wholly owned subsidiary of Morningstar, Inc. The investment options are selected by the plan sponsor and made available to plan-participants for self-directed investing or as the underlying investment options upon which the Workstation leverages to generate advice recommendations. The Workstation generates financial analysis, asset allocation and investment recommendations relevant to retirement planning. VRA provides advisory services online and via through its Investment Advisor Representatives (“Advisor”) VRA offers individualized participant investment advice and account management services (the "Program") called Online Advice (“OA”) and Professional Management (“PM”) services to certain retirement plan participants. The OA is an investment advisory tool participants can access and use online to receive a point-in-time asset allocation recommendation on their account. PM is a discretionary managed account program where participants can enroll (online, via an enrollment form or via an Advisor) and receive ongoing advice to their account, including updated investment recommendations and allocation changes. For additional information on the “OA” and “PM” programs see below. Online Advice If you prefer to receive point-in-time investment advice using a self-service and self-implementation approach without the help of an Advisor, you can access the OA program directly via the internet. OA is an online investment advice service provided by Morningstar. OA is a computer model and incorporates financial analysis and asset allocation methods consistent with Morningstar guidelines and generally accepted financial planning and asset allocation principles. OA is based on a point-in-time analysis and is not an ongoing management service. This program is designed to:
• assist you in setting retirement goals;
• provide goal-appropriate saving and investment recommendations;
• help you monitor your retirement account; and
• permit you to perform “what-if” modeling. The OA program will provide specific investment allocation recommendations among the funds made available in the participant’s retirement plan by the plan sponsor. These recommendations are not an endorsement of any particular investment. OA will also generate an estimate of the likelihood of the participant reaching their retirement goals. This estimate is based P a g e | 10 on information provided and/or verified by the participant and is not a guarantee of future results and can and will change over time. The OA program does not include continued monitoring of the investment advice provided for the participant’s account. Participants must implement the recommendations received themselves and revisit the OA site in order to update their information and receive updated recommendations. Participants maintain full control of their account and are under no obligation to implement the recommendations received. Professional Management In retirement plan accounts of certain plan participants, we provide an optional managed account program called Professional Management (“PM”). For purposes of this program, VRA shall act as an “investment manager” as defined under Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). This means that VRA implements its investment recommendations and may make changes designed to keep your savings rate and investment allocation aligned with your goals. To learn if this program is available to you, you may either call us to speak with an Advisor or read your plan’s fact sheet. VRA recommendations consider your current savings and number of years to your assumed retirement age along with a number of other inputs. PM output is delivered by Advisors who are contacted by calling your plan’s toll-free information line. Alternatively, you have the ability to enroll in the PM service through your employer sponsored plan website. Central to the delivery of PM is the Advisor’s use of the advice workstation The workstation relies on the proprietary methodology developed and maintained by Morningstar to create target allocations and forecasts for participants. The forecasts generated by the advice workstation focus on a personalized analysis and are designed to answer the following questions:
• What is the chance that I might reach my retirement goal(s)?
• What is the range of income I might expect in retirement?
• How much might my portfolio be worth at retirement? The forecasted retirement income is based on income provided by the following sources:
• Your retirement accounts (including individual retirement plan accounts and other accounts designated for retirement);
• Your pension;
• Social Security estimates; and
• other sources of retirement-designated income. The objective of this process is to provide a personalized asset allocation and personalized retirement savings strategy. The result is a personalized, inflation-adjusted retirement income forecast. VRA uses the forecasts described above to offer strategies designed to help improve your understanding of, and ability to achieve your retirement goal(s). For example, if the illustrations show a shortfall of retirement income (as compared to your expected needs), one or a combination of the following actions would be discussed:
• increase contributions to the retirement plan account;
• change investment mix;
• retire later or supplement your income during retirement; and
• reduce retirement income expectations. If you elect to enroll in the PM program through an Advisor, the Advisor will model assumed changes to savings rates and investment allocations and communicate the results to you during the course of your conversation. This approach is designed to help you understand how actions such as reallocating investments or increasing your savings may improve your chances to achieve your retirement goal(s). If you enroll in the PM program, you authorize VRA to provide discretionary ongoing management of your retirement plan account(s) which would include a personalized combination of the following actions with the objective of achieving your retirement goals: rebalancing, updating your investment allocation and adjusting your allocation overtime based on your changing retirement time horizon. Rebalancing and re-optimization occur quarterly. P a g e | 11 Income Secure Income Secure is a feature offered through both OA and PM, where Participants age 50 and older and within 5 years of their retirement age are presented with an annual spending plan for the duration of their retirement. The spending plan includes a detailed overview of the income sources that comprise their annual income so they know how much to consider withdrawing each year from their accounts. Pre-retirees (within one year of default retirement age of 65 or user-selected retirement age) and retirees also have access to a user interface specifically designed to provide a more tailored and insightful planning experience. Assets Under Management As of 12/31/2023, VRA managed $ 27,040,741,408.00 in total assets on a discretionary basis in the Professional Management program. VRA does not manage assets on a non-discretionary basis.