Empower Representative Compensation

Introduction

This disclosure describes compensation practices for employees of Empower who interact with individual investors, such as plan participants in retirement plans recordkept by Empower, or individual accountholders of individual retirement or brokerage accounts offered through Empower or its affiliates. This disclosure describes practices as of May 2026 and may be updated periodically.

Our compensation practices affect how we motivate Empower employees to perform their jobs.

Empower employees who interact with individual investors are generally registered representatives of Empower Financial Services, Inc. (“EFSI”), a broker-dealer registered with the U.S. Securities and Exchange Commission (“SEC”). Depending on the employee’s role, some of these EFSI representatives may also be investment adviser representatives of Empower Advisory Group, LLC (“EAG”), an investment adviser registered with the SEC. EFSI and EAG are affiliates of Empower.

General Compensation Practices

Empower employees who interact with individual investors receive a base salary that varies depending on experience, performance, and other factors. Most of these employees are also generally eligible for incentive or bonus compensation. Bonus compensation depends on a number of factors including, but not limited to, Empower’s profitability and attainment of the employee’s performance goals. Goals do not consider the adoption of Empower or its affiliates’ products or services by an individual investor, unless described below. An employee’s manager has discretion to measure progress against goals and award bonuses as the manager deems appropriate. Additionally, employees may receive a small percentage of their compensation through occasional one-time events or through receipt of non-cash compensation, but only if permitted by law and by Empower’s corporate policies.

Employee Categories

1. Call center representatives

a. Service representatives. These employees help investors perform service-related tasks for the investor’s account, such as processing a retirement plan loan. Service representatives receive a salary and are eligible for additional compensation described in the “General Compensation Practices” section.

b. Workplace Planning Consultants. These employees have educational discussions with investors that may include discussions about plan and account-specific issues, saving, investing, financial wellness, advisory solutions, moving money between accounts and providers, retirement income and other financial topics. Workplace Planning Consultants receive a salary and are eligible for bonus compensation based on total asset growth and retention at Empower, alignment to historic rollover-to-stay-in-plan ratios, volume of funded Empower serviced accounts, and client satisfaction. The bonus compensation is calculated and paid periodically.

c. Workplace Planning Advisors. These employees may provide recommendations to investors on account transactions including recommendations on investment options available in the account and on account distribution and rollover options. Workplace Planning Advisors receive a salary and are eligible for bonus compensation based on total asset growth and retention at Empower, alignment to historic rollover-to-stay-in-plan ratios, volume of funded Empower serviced accounts, and client satisfaction. The bonus compensation is calculated and paid periodically

d. Wealth Solutions Advisors. These employees have advisory conversations with investors about saving, investing, financial wellness, advisory solutions, account-specific issues, transactions, moving money between accounts and providers, and retirement income and other financial topics. Advisors receive a salary and are eligible for additional compensation based on net asset accumulation and retention. However, compensation rates vary by product “grade” (or tier). Specifically, Grade 1 products, which include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP), provide the least additional bonus compensation; Grade 2 products, which include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts, provide more bonus compensation than Grade 1 products but less than Grade 3 products; and Grade 3 products, which include Personal Strategy, Personal Strategy+, and Premier Managed accounts, provide the highest bonus compensation among the product categories. Payout rates are based on individual product complexity and the requisite expertise required for the Advisors to discuss and open such products. The bonus compensation is calculated and paid periodically.

e. Financial planners. These employees are Advisers who also provide financial planning services. Financial planners receive a salary and are eligible for additional compensation described in the “General Compensation Practices” section. Financial planners do not have separate compensation incentives tied to providing financial planning services to investors.

2. Field representatives

a. Retirement Plan Counselors. These employees meet with retirement plan investors to educate investors about plan options and services, account-specific issues, saving and investing options, and specific transactions. Counselors receive a salary and are eligible for additional compensation based on meeting activity, plan enrollments, participant actions, and participant satisfaction.

b. Retirement Plan Advisors. These employees meet with retirement plan investors and perform more extensive financial counseling and advisory services than the consulting provided from Retirement Plan Counselors. Advisors receive a salary and are eligible for additional compensation based on meeting activity, participant diversification metrics, participant actions, and participant satisfaction

3. Plan relationship managers

Relationship managers spend the majority of their time interacting with retirement plan sponsors, and the advisers to these plan sponsors. However, some relationship managers perform retirement plan enrollment meetings with individual investors. Relationship managers receive a salary and are eligible for additional compensation described in the “General Compensation Practices” section.

4. Manager positions

Empower employees who manage the positions described in this disclosure receive a salary and are eligible for additional compensation described in the “General Compensation Practices” section. Managers also receive bonus compensation in part based on whether the employees they manage attain the employees’ own performance goals.