EMPOWER ANNUITY INSURANCE COMPANY

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o .Agents and. GAG representatives' Individual performance goals and their.related incentive compensation is 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 or Incentive compensation considers the total amount of retained or accumulated assets, compared with the monthly asset goal, as determined by FAG 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. - EAG's affiliates may receive payments from other firms, non-proprietary investment funds or products, or C.-. providers, such as revenue sharing payments, In connection with the investments made pursuant to our recommendation or investment management. Other Business Activities Certain senior managers and officers of FAG may also serve as executive officers of EAG's parent company, EAIC and other affiliates of FAG. Item 11--Code of Ethits, Participation or lntorest in Cin IIoM Tmnsaa[ions end Personal Tmdin¢ EAG's Coda of Ethics FAG has adopted a written Code of Ethics (the Code) in compliance with Rule 204A,-1 of the Investment Advisers Act of 1940 (Advisers Act). The Code sets forth standards of business conduct expected of advisory personnel. It requires certain of EAG's advisory personnel to report their personal securities holdings and transactions in accordance with the Advisers Act. EAG's advisory personnel are required to comply with the Code. A copy of the Corte will be provided to current or prospective clienb upon request. The Code includes provisions related to: • Fiduciary responsibility to clients; • Compliance with federal securities laws; • Protection and safeguarding ofconfldential 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 ofthe Code. Personal Trading The Code requires pre -clearance of certain securities transactions. Officers, managers, and certain employees of FAG (collectively, Access Persons) may trade for their own personal accounts in securities which are recommended m and/or purchased for EAG's advisory clients. However, because the 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 cllent,h a seunity held by an Access Person. As a result, trading Is continually monitored In accordance with the Code and federal securities laws. The Code Is Intended to ensure that the personal securities transactions and the outside business activities of FAG's Access Persons do not Interfere with making, decisions In the best Interest of advisory clients: - - - Principal Trading .. FAG has adopted a policy and practice not to engage In any principal transactions. FAG holds no Investments for its own accounts which could be bought from, or sold to, an advisory client. In the event of any change In EAC's policy, any such change must be approved by management. Any principal transactions would be permitted only after meeting the review and approval requirements described under the anti -fraud section of the Advisers Act, 16 City Council 19 -• 94 9/19/2023