THRIVENT FINANCIAL FOR LUTHERANS

TFL is a fraternal benefit society organized under the laws of the State of Wisconsin. TFL is owned by and operated for its members, and its primary business is that of a fraternal benefit society that offers insurance products to its members. TFL is also registered with the SEC as an investment adviser. TFL and its affiliates have been in the investment advisory business since 1986. TFL and its affiliates are not publicly traded entities, and TFL has no stockholders. TFL has no principal owners and is not subject to the control of any affiliated persons. TFL provides discretionary investment advice to Thrivent Series Fund, Inc. (“TSF”), a registered investment company under the Investment Company Act of 1940 (the “Investment Company Act”) that comprises several mutual fund series. These mutual fund series serve as investment options for variable products sponsored by TFL and separate accounts of insurance companies not affiliated with TFL. TFL also provides discretionary investment advisory services to, an affiliated pension plan and another registered investment company – Thrivent Cash Management Trust (“TCMT”). TFL provides non-discretionary investment advisory services to one non-affiliated entity (the “Separate Account Client”). Additionally, TFL provides discretionary investment advice to a private fund (“Private Fund” or “Fund”). TFL is the managing member of a general partner that manages the day-to-day operations of the Private Fund. The Private Fund invests primarily in public securities. The only investor in the Private Fund is TFL. The general partner of the Private Fund (“General Partner”) is affiliated with TFL. The General Partner is deemed to be registered under the Investment Advisers Act of 1940 (the “Advisers Act”), pursuant to TFL’s registration, in accordance with SEC staff guidance. This Brochure also describes the business practices of the General Partner, which operates as a single advisory business together with TFL. The Private Fund is managed in accordance with its investment objectives, as described in its offering documents. For the Separate Account Client, TFL is responsible for making specific securities and investment recommendations to the client. However, the Separate Account Client, in its sole discretion, is responsible for acting on TFL’s recommendations. TFL has no responsibility for arranging or effecting any purchase or sale transactions for the Separate Account Client, except that the Separate Account Client may purchase certain investments through a brokerage account set up by a TFL-affiliated financial adviser. Neither TFL nor the financial adviser will receive any fee or other compensation in connection with that brokerage account. Some of the Separate Account Client’s investments are in registered funds sponsored or advised by TFL and its affiliates and, as a result, those assets of the Separate Account Client may be held in one or more accounts maintained directly with the mutual funds’ transfer agent based on the type of registered fund investment. TFL does not participate in any wrap fee programs. As of December 31, 2025, TFL managed, on a discretionary basis, approximately $128,728,427,712 billion in assets. Of this amount, approximately $111.2 million was assets of the Private Fund. As of this date, TFL did not manage any assets on a non-discretionary basis that are included in regulatory assets under management.

The General Partner is entitled to receive performance fees following the return of capital contributions, expenses, and the payment of a hurdle percentage to the limited partner. TFL is the managing member of the General Partner and receives all of the General Partner’s performance fees. The General Partner of the Private Fund is entitled to a performance fee of 3.5% of net gains above the stated hurdle rate as specified in the Private Fund’s limited partnership agreement. The performance fee that the General Partner may receive, to the extent earned, is distributed pursuant to the distribution provisions of the limited partnership agreement (generally, at least annually with respect to dividend and income payments, and whenever a portfolio investment is sold, assuming that there is an applicable gain). Neither TFL nor the General Partner receives a management fee from the Private Fund. In addition to the performance fee discussed above, investors, through their interests in the Private Fund, bear their proportional share of the Private Fund’s costs, expenses, liabilities and obligations relating to the Private Fund’s activities, investments and business (to the extent not borne or reimbursed by a portfolio company), as set forth in the limited partnership agreement. As noted elsewhere in this document, TFL is currently the only investor in the Private Fund. The Private Fund may incur brokerage fees through normal trading practices. Please see Item 12 – Brokerage Practices for a more thorough description of the brokerage practices and expenses. The Private Fund does not pre-pay the performance fee to its General Partner. TFL receives no direct compensation for managing the Separate Account Client on a nondiscretionary basis; however, the Separate Account Client is subject to the expenses of its investments in registered funds sponsored or advised by TFL and its affiliates. TFL receives no direct compensation for managing the affiliated pension plan; however, the affiliated pension plan is subject to the expenses of its investments in registered funds sponsored or advised by TFL and its affiliates.

Loss TFL manages the Separate Account Client in accordance with the investment policies and guidelines applicable to such client, and commonly recommends that the Separate Account Client invest account assets substantially or exclusively in registered funds advised by entities affiliated with TFL. The risks of investing in such funds are included in the prospectuses and statements of additional information applicable to such funds. TFL manages the affiliated pension plan in accordance with the investment policies and guidelines applicable to such client and may invest account assets in registered funds advised by entities affiliated with TFL. The risks of investing in such funds are included in the prospectuses and statements of additional information applicable to such funds. With respect to the Private Fund’s investments in public securities, TFL invests in publicly traded fixed income and equity securities or exchange traded derivatives. TFL seeks investments that offer favorable risk-adjusted returns and conducts its own due diligence. Investing in the Private Fund is subject to several risks, including the following. Future and Past Performance. The performance of the General Partner’s portfolio managers’ prior investments is not necessarily indicative of the Private Fund’s future results. While the General Partner intends for the Private Fund to make investments that have estimated returns commensurate with the risks undertaken, there can be no assurances that the targeted internal rate of return will be achieved. On any given investment, loss of principal is possible.

Concentration of Investments. The Private Fund will participate in a limited number of investments in certain asset classes. As a result, the Private Fund’s investment portfolio could become highly concentrated in that asset class or as a percentage of the Fund, and the performance of a few holdings may substantially affect the Fund’s aggregate return. Prepayment Risk. When interest rates fall, certain obligations are paid off by the obligor more quickly than originally anticipated, and a fund may have to invest the proceeds in securities with lower yields. In periods of falling interest rates, the rate of prepayments tends to increase (as does price fluctuation) as borrowers are motivated to pay off debt and refinance at new lower rates. During such periods, reinvestment of the prepayment proceeds by the management team will generally be at lower rates of return than the return on the assets that were prepaid. Prepayment generally reduces the yield to maturity and the average life of the security. The Private Fund is subject to the following risks related to public securities investments: Allocation Risk. The Fund’s investment performance depends upon how its assets are allocated across broad asset categories and applicable sub-classes within such categories. Some broad asset categories and sub-classes may perform below expectations or the securities markets generally over short and extended periods. For example, underperformance in the equity or debt markets could have a material adverse effect on the Fund’s total return if it has a significant allocation to those types of securities. Therefore, a principal risk of investing in the Fund is that the allocation strategy used and the allocation decisions made will not produce the desired results. Closed-End Fund (“CEF”) Risk. Investments in CEFs are subject to various risks, including reliance on management’s ability to meet a CEF’s investment objective and to manage a CEF’s portfolio; fluctuation in the market value of a CEF’s shares compared to the changes in the value of the underlying securities that the CEF owns (i.e., trading at a discount or premium to its net asset value); and that CEFs are permitted to invest in a greater amount of “illiquid” securities than typical mutual funds. The fund is subject to a pro-rata share of the management fees and expenses of each CEF in addition to the fund’s management fees and expenses, resulting in fund shareholders subject to higher expenses than if they invested directly in CEFs. Credit Risk. Credit risk is the risk that an issuer of a debt security to which a fund is exposed may no longer be able or willing to pay its debt. As a result of such an event, the debt security may decline in price and affect the value of a fund. Similarly, there is a risk that the value of a debt security may decline because of concerns about the issuer’s ability or willingness to make interest and/or principal payments. Debt securities are subject to varying degrees of credit risk, which are often reflected in credit ratings. The credit rating of a debt security may be lowered if the issuer suffers adverse changes in its financial condition, which can lead to more volatility in the price of the security and in shares of a fund. Emerging Markets Risk. The risks and volatility of investing in foreign securities is increased in connection with investments in emerging markets. The economic, political and market structures of developing countries in emerging markets, in most cases, are not as strong as the structures in the U.S. or other developed countries in terms of wealth, stability, liquidity and transparency. The fund may not achieve its investment objective and portfolio performance will likely be negatively

affected by portfolio exposure to countries and corporations domiciled in, or with revenue exposures to, countries in the midst of, among other things, hyperinflation, currency devaluation, trade disagreements, sudden political upheaval or interventionist government policies, and the risks of such events are heightened within emerging market countries. Fund performance may also be negatively affected by portfolio exposure to countries and corporations domiciled in, or with revenue exposures to, countries with less developed or unreliable legal, tax, regulatory, accounting, recordkeeping and corporate governance systems and standards. In particular, there may be less publicly available and transparent information about issuers in emerging markets than would be available about issuers in more developed capital markets because such issuers may not be subject to accounting, auditing and financial reporting standards and requirements comparable to those to which U.S. companies are subject. Emerging markets may also have differing legal systems, many of which provide fewer security holder rights and practical remedies to pursue claims than are available for securities of companies in the U.S. or other developed countries, including class actions or fraud claims. Significant buying or selling actions by a few major investors may also heighten the volatility of emerging market securities. Some emerging market countries restrict to varying degrees foreign investment in their securities markets. In some circumstances, these restrictions may limit or preclude investment in certain countries or may increase the cost of investing in securities of particular companies. Equity Security Risk. Equity securities held by the fund may decline significantly in price, sometimes rapidly or unpredictably, over short or extended periods of time, and such declines may occur because of declines in the equity market as a whole, or because of declines in only a particular country, geographic region, company, industry, or sector of the market. From time to time, a fund may invest a significant portion of its assets in companies in one particular country or geographic region or one or more related sectors or industries, which would make the fund more vulnerable to adverse developments affecting such countries, geographic regions, sectors or industries. Equity securities are generally more volatile than most debt securities. The prices of individual stocks generally do not all move in the same direction at the same time. Certain funds may invest in private equity funds, which are less liquid and more difficult to value than publicly traded equity securities. A variety of factors can negatively affect the price of a particular company’s stock. These factors may include, but are not limited to: poor earnings reports, a loss of customers, litigation against the company, general unfavorable performance of the company’s sector or industry, or changes in government regulations affecting the company or its industry. ETF Structure Risk. The Fund is structured as an ETF and is subject to risks related to exchange trading, including: •

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The Fund’s shares are listed for trading on a national securities exchange (the “Exchange”) and are bought and sold on the secondary market at market prices. Although it is expected that the market price of Fund shares will typically approximate the Fund’s net asset value (“NAV”), there may be times when the market price reflects a significant premium or discount to NAV. Although the Fund’s shares are listed on the Exchange, it is possible that an active trading market in the Fund’s shares may not be maintained. The Fund could potentially face trading halts and/or delisting from the Exchange. This risk

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is heightened in times of market stress, including at both the Fund share level and at the Fund holdings level. Only an authorized participant (an “Authorized Participant”) may engage in creation or redemption transactions directly with the Fund, and none of those Authorized Participants is obligated to engage in creation and/or redemption transactions. The Fund has a limited number of institutions that may act as Authorized Participants on an agency basis (i.e., on behalf of other market participants). To the extent that Authorized Participants exit the business or are unable to proceed with creation or redemption orders with respect to the Fund and no other Authorized Participant is able to step forward to create or redeem Creation Units, Fund shares may be more likely to trade at a premium or discount to NAV and possibly face trading halts or delisting.

Foreign Currency Risk. The fund is also subject to the risk that the value of a foreign currency may decline against the U.S. dollar, which would reduce the dollar value of securities denominated in that currency. The overall impact of such a decline of foreign currency can be significant, unpredictable, and long lasting, depending on the currencies represented, how each one appreciates or depreciates in relation to the U.S. dollar, and whether currency positions are hedged. Further, exchange rate movements are volatile, and it is not possible to effectively hedge the currency risks of many developing countries. Foreign Securities Risk. To the extent the fund is exposed to foreign securities, it is subject to various risks associated with such securities. Foreign securities are generally more volatile than their domestic counterparts, in part because of potential for higher political and economic risks, lack of reliable information and fluctuations in currency exchange rates where investments are denominated in currencies other than the U.S. dollar. Certain events in foreign markets may adversely affect foreign and domestic issuers, including interruptions in the global supply chain, market closures, war, terrorism, natural disasters and outbreak of infectious diseases. Foreign securities also may be more difficult to resell than comparable U.S. securities because the markets for foreign securities are often less liquid. Even when a foreign security increases in price in its local currency, the appreciation may be diluted by adverse changes in exchange rates when the security’s value is converted to U.S. dollars. Foreign withholding taxes also may apply and errors and delays may occur in the settlement process for foreign securities. Securities of foreign companies in which a fund invests generally carry more risk than securities of U.S. companies. The economies and financial markets of certain regions—such as Latin America, Asia, Europe and the Mediterranean region—can be highly interdependent and may decline at the same time. Certain European countries in which the fund may invest have recently experienced significant volatility in financial markets and may continue to do so in the future. The potential departure of one or more countries from the European Union (“EU”), such as the United Kingdom’s intended departure from the EU (commonly known as “Brexit”), may have significant political and financial consequences for global markets and may adversely impact fund performance. The long-term impact of Brexit is unknown and the risks related to Brexit could be more pronounced if one or more additional EU member states seek to leave the EU. Other risks result from the varying stages of economic and political development of foreign countries; the differing regulatory environments, trading days, and accounting standards of foreign markets; and higher transaction costs. A fund’s investment in any country could be subject to

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As stated earlier in Item 4, TFL provides investment advice to the Separate Account Client, TSF, TCMT and, through the General Partner, to the Private Fund. The Private Fund invests primarily in public securities. The Private Fund is exempt from registration as an investment company under the Investment Company Act pursuant to Sections 3(c)(1) and/or 3(c)(7) under the Investment Company Act. TFL is currently the only limited partner of the Private Fund, and each limited partner must be an “accredited investor” as defined in the rules and regulations under the Securities Act and a “qualified purchaser” under the Investment Company Act. TFL also manages the assets of the Thrivent Financial Defined Benefit Plan Trust, which is an affiliated defined benefit plan. Employees of TFL manage TFL’s insurance general account simply as employees of TFL and not pursuant to any agreement or for any compensation.

The General Partner receives performance-based fees, to the extent earned. TFL is the managing member of the General Partner and receives all of the performance fees. These fees are based on realized net gains from the disposition of portfolio investments. The receipt of a performance fee creates a potential conflict of interest because TFL is incentivized to take greater risks and to direct the best investment ideas to, or to allocate investments in favor of, the account that pays a more favorable performance fee. This conflict is mitigated by TFL’s investment allocation policy. The Private Fund may invest in investments in which the TSF mutual fund series or TCMT can also invest. The Private Fund charges a performance-based fee, and TSF mutual fund series and TCMT charge an asset-based fee. This could create a conflict of interest to the extent that the different accounts invest in the same public securities. This conflict is addressed by TFL’s investment allocation policy. As a registered investment adviser under the Advisers Act, TFL is under an obligation to treat each of its clients fairly. As a result, TFL has adopted an allocation policy that sets forth its procedures when allocating an investment opportunity among accounts. Pursuant to this policy, TFL makes allocation determinations based upon the appropriateness of the investment for the client. The

allocation policy prohibits TFL from favoring one client over another client. TFL’s allocation policy also prohibits its investment professionals from allocating investments to enhance the performance of one account over another account or to favor any affiliated account or any other account in which an employee has any interest. In instances when TFL has clients with overlapping investment mandates and objectives, it will generally allocate investments proportionally among those clients.

TFL is affiliated with several other entities that are in the financial services industry. In addition, certain of the executive officers and managers of TFL are executive officers and/or directors/managers of these affiliated entities. The entities described below are subsidiaries of Thrivent Financial Holdings, Inc., a wholly owned subsidiary of TFL. Bank Thrivent Bank is an indirect wholly owned subsidiary of Thrivent and serves as an FDIC-insured, Utah industrial bank offering deposits, loans and other services. Broker-Dealers TFL is affiliated with Thrivent Distributors, LLC (“TDL”), a registered broker-dealer serving as the principal underwriter and distributor for TSF and Thrivent Mutual Funds, a registered investment company under the Investment Company Act that comprises various mutual fund series (“TMF”). TDL is also the named principal underwriter and distributor for TCMT and Thrivent Core Funds (“TCF”), a registered investment company under the Investment Company Act that comprises various mutual fund series. TDL does not serve as distributor and principal underwriter to Thrivent ETF Trust but provides certain marketing and distribution related services. TDL is an indirect, wholly owned subsidiary of TFL. TDL does not execute any portfolio brokerage for anyone (including its affiliated mutual funds and ETFs). TFL is affiliated with Thrivent Investment Management, Inc. (“TIMI”), a dually registered brokerdealer and investment adviser. In its capacity as a broker-dealer, TIMI actively markets mutual fund shares, variable insurance contracts and general securities to its clients through its registered representatives. TIMI also serves as the principal underwriter and distributor of variable annuities and insurance issued by Thrivent. TIMI sells shares of TMF and Thrivent ETFs pursuant to a distribution agreement. TIMI does not execute any portfolio brokerage for any of its affiliated mutual funds or ETFs. Investment Advisers Thrivent Asset Management, LLC (“TAM”) serves as adviser to TMF, TCF, and Thrivent ETF Trust (“TETF”), a registered investment company under the Investment Company Act comprising exchange-traded funds. TAM personnel also construct and maintain certain model portfolios on a non-discretionary basis for managed account programs sponsored by other registered investment advisers, broker-dealers and other financial intermediaries, including TIMI. Thrivent Investment Management, Inc. (“TIMI”) is a dually registered broker-dealer and investment adviser. In its capacity as a broker-dealer, TIMI distributes general securities, including mutual fund shares, and variable insurance contracts to its clients through its registered representatives. TIMI serves as the principal underwriter and distributor of variable annuities and insurance issued by Thrivent and also sells shares of Thrivent Mutual Funds and Thrivent. In its capacity as an investment adviser, TIMI offers dedicated planning services and managed account programs to

clients through its investment advisor representatives. TIMI sponsors managed account programs that use model portfolios provided by TAM. When TIMI’s clients own these products, TFL and TAM are paid from fees and/or premiums that are charged to clients. When TIMI’s clients invest in Thrivent Mutual Funds and ETFs, TAM receives fees for serving as the investment manager for the mutual funds and ETFs and for providing administrative and accounting services to the funds pursuant to an Administrative Services Agreement. Thrivent Investment Capital Advisors, LLC (“TICA”) is a registered investment adviser and an indirect wholly-owned subsidiary of TFL. TICA provides investment advisory services to certain private funds. TFL’s insurance general account invests directly in the private funds alongside other investors, which may give it additional economic interests not shared by all investors.

Thrivent Advisor Network, LLC (“TAN”) is a licensed insurance agency and a registered investment adviser. In its capacity as a licensed insurance agency, TAN offers certain insurance products on a commission basis through licensed independent insurance producers. When TAN’s clients own these products, TFL is paid from fees and/or premiums charged to its clients. In its capacity as an investment adviser, TAN provides investment advisory services to individuals, high-net-worth individuals, families, trusts, estates, businesses and retirement plans through a network of investment advisor representatives. TFL has business and financial arrangements with each of TAM and TIMI and the Thriventsponsored investment companies. These arrangements relate to (1) financial and operational issues concerning these affiliated entities and (2) the allocation and payment of expenses, and the transfer and accounting of funds, among these affiliated entities. As described above, TFL recommends that the Separate Account Client invest account assets substantially or exclusively in registered funds advised by entities affiliated with TFL including, but not limited to, TAM. In managing the assets of the affiliated defined benefit plan account, TFL may invest account assets in registered funds advised by entities affiliated with TFL including, but not limited to, TAM. Investment Companies TAM serves as investment adviser to TMF, TCF and TETF. TAM is also responsible for providing administrative and accounting services to TMF and TCF. 1 Trust Companies Thrivent Trust Company is a wholly owned subsidiary of TFL and serves as a limited-purpose federal savings bank offering professional fiduciary and investment management services. Insurance

1 TFL has established a securities lending program for certain affiliated entities (i.e., TMF, TSF, TCF and other mutual funds advised by TFL or TAM that may be added to the program from time to time). Each fund that participates in this lending program invests cash collateral received from securities lending activity in TCMT, a government money market fund that complies with Rule 2a-7 under the Investment Company Act.

TFL, a not-for-profit nonstock membership organization, is licensed to conduct business as a fraternal benefit society in all states and the District of Columbia and markets fixed and variable insurance and annuities in all 50 U.S. states and the District of Columbia. Thrivent Insurance Agency Inc., also a wholly owned indirect subsidiary of TFL, is a life and health insurance agency engaged in the distribution of non-proprietary life and health insurance products. Sponsor or Syndicator of Limited Partnership As discussed above, certain entities affiliated with TFL serve as general partner to limited partnerships. Other Certain Supervised Persons of TFL (as defined under the Advisers Act) provide investment advisory services to a non-affiliated entity, the Separate Account Client, and assist in managing the portfolios of the pension plan sponsored by TFL. Employees of TFL manage TFL’s insurance general account simply as employees of TFL and not pursuant to any agreement or any compensation. Neither TFL nor its affiliates provide tax, legal, or accounting advice. Consult with your tax professional, legal advisor, or accountant, as applicable, for tax planning, tax preparation services, legal issues, or accounting questions.

Transactions and Personal Trading TFL and TAM (together, the “Advisers”) manage certain mutual funds, exchange-traded funds, and other accounts with the same portfolio managers, utilizing similar strategies for all or a portion of an account, and their investment advisory personnel largely overlap. As a result, their compliance programs largely overlap. The Advisers may give advice and take action with respect to any funds or accounts they manage, or for their own account, that may differ from action taken by them on behalf of other funds or accounts. The Advisers are not obligated to recommend, buy or sell, or to refrain from recommending, buying or selling, any security that they or their Access Persons (as defined under the federal securities laws) may buy or sell for their own accounts or for the accounts of their clients. The Advisers or their Access Persons are not obligated to refrain from investing in securities held by funds or accounts that the Advisers manage except to the extent that such investments violate the code of ethics adopted by the Advisers and the registered funds that they manage or other firm-wide policy (e.g., insider trading policy). From time to time, employees and principals of the Advisers or any other related persons may have interests in securities owned by or recommended to TFL’s advisory clients (or securities related to those securities). As these situations may represent a potential conflict of interest (possibly encouraging advisory personnel to put their economic interests ahead of the Advisers’ clients), the

Advisers have adopted procedures relating to personal securities transactions and insider trading, which are designed to mitigate these potential conflicts. The Advisers will, from time to time, recommend to clients, or buy or sell for accounts, securities in which the Advisers or their affiliates have a material financial interest. Such financial interests include seed capital contributed by an Adviser or an affiliate to a fund that such Adviser manages. In addition, with respect to the Separate Account Client, TFL recommends that the client invest account assets substantially or exclusively in registered funds advised by entities affiliated with TFL, including TAM. Such recommendations represent a potential conflict of interest because the affiliates of TFL will receive management fees from the mutual funds recommended by TFL to the Separate Account Client. Notwithstanding the foregoing, such conflicts of interest are mitigated because the Separate Account Client is managed on a non-discretionary basis and all decisions to approve recommendations made by TFL to invest in affiliated registered funds are solely the responsibility of the Separate Account Client and TFL receives no direct compensation for providing non-discretionary advisory services to such client. The Advisers have adopted a code of ethics in accordance with the federal securities laws (the “Code”) to govern personal transactions by Access Persons and to help ensure that the interests of Access Persons do not conflict with the interests of the Advisers’ clients. The Code restricts personal trading by certain investment personnel in reportable securities (as defined by the federal securities laws) within seven (7) calendar days before or after a transaction in the same security by a client portfolio for which the individual’s team has responsibility for individual security selection, subject to applicable exemptions and any approved exceptions or waivers. In addition, pursuant to the Code and related compliance procedures, Access Persons are generally prohibited from effecting a personal transaction in a non‑exempt reportable security while an order for a client is open or pending, subject to limited exceptions and any approved exception or waiver. All Access Persons must also request pre-clearance through Employee Compliance Manager, an electronic reporting system utilized by TFL’s compliance department (“Compliance”), in order to make personal securities transactions in certain reportable securities believed to present a potentially meaningful risk of a conflict of interest (including acquisitions of securities as part of an initial public offering or private placement). Further, all Access Persons must certify to quarterly reports of their personal transactions within 30 days of the end of each calendar quarter (or, in the alternative, the Access Person could have his/her Thrivent-approved broker provide confirmations or periodic statements to Compliance). A copy of TFL’s Code is available to any client or prospective client upon request by calling (612) 844-8593. In addition, TFL has a Code of Conduct that requires all Access Persons and all Supervised Persons of TFL to comply with ethical restraints relating to, among other things, giving gifts to, and receiving gifts from, service providers. In connection with the Code, the Advisers have also adopted an insider trading policy. The Advisers and their related persons may, from time to time, come into possession of material nonpublic and other confidential information which, if disclosed, might affect an investor’s decision to buy, sell or hold a security. The Advisers and their related persons are prohibited from improperly disclosing or using such information for their own personal benefit or for the benefit of any other person, regardless of whether such other person is a client of the Advisers. Accordingly, should such persons come into possession of material nonpublic or other confidential information with respect

to any company, they are prohibited from communicating such information to their respective clients or from using such information for their own benefit or the benefit of their respective clients. Any officer, director, elected manager or employee of the Advisers subject to the Code who fails to comply with the requirements of the Code and the insider trading policy risks being subject to grave sanctions, including dismissal and personal liability. In addition to the conflicts presented by the personal trading of advisory personnel, TFL's affiliation with other entities that offer Thrivent products to the public presents potential conflicts of interest. Principal or Cross Transactions; Applicable Conflicts Section 206 of the Advisers Act governs principal transactions between an adviser and its clients. Principal transactions are transactions where an Adviser (or one of its affiliates) is deemed to be acting for its own account by buying a security from, or selling a security to, an advisory client. Because TFL has full ownership interest in the Private Fund, cross transactions between the Private Fund and other accounts managed by TFL or its affiliates could often be viewed as principal transactions. As a general matter, the Advisers do not engage in cross transactions or principal transactions. TFL has established policies and procedures to comply with the requirements of law and of the Private Fund’s and other client account’s documents as they relate to cross and principal transactions, including providing any required disclosures and obtaining any necessary consents before the completion of each such transaction. Because TFL has full ownership interest in the Private Fund, which may be more than its interest in another client account or account managed by an affiliate, TFL faces potential conflicts of interest in effecting any cross transaction between the Private Fund and these other accounts, because they also can be viewed as principal transactions that could potentially accrue to the benefit of TFL.

With respect to investments in private securities, TFL focuses on securities transactions of private companies and generally purchases and sells such interests through privately-negotiated transactions in which the services of a broker-dealer may be retained. However, TFL may also cause the Private Fund to distribute securities to investors in the Private Fund or sell such securities, including through using a broker-dealer, if a public trading market exists. Additionally, TFL intends to regularly engage in public securities transactions for the Private Fund. To the extent TFL engages in public securities transactions with respect to the Private Fund, it will follow the brokerage practices described below. Except with respect to the Separate Account Client, depending upon the terms of the agreement entered into with each client, TFL generally has discretionary authority to make the following determinations without client consultation or consent prior to effecting each transaction: •

which securities are to be bought or sold;

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the total amount of the securities to be bought or sold;

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the broker-dealer through which securities are to be bought or sold; and

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the commission rates at which securities transactions for client accounts are effected.

With respect to each discretionary account, however, TFL’s authority is subject to certain limits, including applicable investment objectives, policies and restrictions. These limitations may be based on a variety of factors, such as regulatory constraints, and policies imposed by a client or its governing body. For each advisory client, TFL follows the guidelines specified in the client’s advisory contract and for TFL’s insurance general account, applicable guidelines and limits as provided by the Board of Directors. Selection Criteria for Brokers-Dealers TFL selects broker-dealers to execute client transactions based on several factors. As a general matter, broker-dealers are subjected to an initial approval process. This approval process may involve the review of financial and related quantitative and qualitative information concerning a broker-dealer. Such qualitative factors may include but are not limited to: general reputation of the firm and regulatory history of the firm. Under certain circumstances, it may be necessary for a trader to execute a transaction with a broker-dealer that has not been subject to an initial approval process. This exception process may only be used to grant a broker-dealer approval for the specific transaction being contemplated and only after following established procedures. In arranging for the purchase and sale of clients’ portfolio securities, TFL takes into consideration any legal restrictions, such as those imposed under the securities laws, and any client-imposed restrictions. Within these constraints, TFL employs or deals with members of the securities exchanges and other brokers and dealers that, in TFL’s judgment, implement TFL’s policy, consistent with its fiduciary obligations, to seek best execution of portfolio transactions. TFL’s overriding objective in selecting brokers and dealers and in effecting portfolio transactions is to seek to obtain the best combination of price and execution with respect to its clients’ portfolio transactions. The best net price, giving effect to brokerage commissions or spreads, if any, and other transaction costs, is normally an important factor in this decision, but a number of other judgmental factors may be considered relevant to analyzing whether TFL has obtained “best execution” for a particular trade. Such factors include, but are not limited to: the execution capabilities required by the transactions; the importance to the account of speed, efficiency and confidentiality; the broker or dealer’s apparent familiarity with sources from or to whom particular securities might be purchased or sold; the ability and willingness of the broker or dealer to facilitate the accounts’ portfolio transactions by participating for its own account or committing capital to the transaction; TFL’s knowledge of negotiated commission rates currently available; the nature of the security being traded; the size and type of the transaction; the nature and character of the markets for the security to be purchased or sold; the desired timing of the trade; the activity existing and expected in the market for the particular security; the execution, clearance and settlement capabilities of the broker or dealer both with respect to the specific transaction and its overall service to TFL, as well as the reputation and perceived soundness of the broker-dealer selected, both in its own right and as compared to other broker dealers which are considered; the financial stability of the broker or

dealer; TFL’s knowledge of actual or apparent operational problems of any broker-dealer; the broker-dealer’s execution services rendered on a continuing basis and in other transactions; the reasonableness of commissions; the brokerage and research services provided by the broker or dealer; and any other matters that TFL, in its judgment, deems relevant to the selection of a broker or dealer for portfolio transactions for any account. TFL does not adhere to any rigid formula in making the selection of the applicable broker or dealer for portfolio transactions but weighs a combination of the preceding factors. The criteria used for best execution is reviewed periodically by the Brokerage Practices Committee (the “Brokerage Committee”). TFL may use an Electronic Communications Network (“ECN”) or Alternative Trading Systems (“ATS”) to effect such trades when, in TFL’s judgment, the use of an ECN or ATS may result in equal or more favorable overall executions for transactions. TFL endeavors to be aware of current charges of eligible broker-dealers and to minimize the expenses incurred for effecting portfolio transactions to the extent consistent with the interests and policies of their advisory accounts. However, TFL will not select broker-dealers solely on the basis of “posted” commission rates nor always seek in advance competitive bidding for the most favorable commission rate applicable to any particular portfolio transaction. Although TFL generally seeks competitive commission rates, it will not necessarily pay the lowest commission. Transactions may involve specialized services on the part of the broker-dealer involved resulting in higher commissions than would be the case with transactions requiring more routine services. The reasonableness of commissions is based on the broker’s ability to provide professional services, competitive commission rates, research, and other services, which will help TFL in providing investment management services to its advisory clients. TFL may, therefore, use a broker that provides useful research and securities transaction services even though a lower commission may be charged by another broker. TFL generally purchases fixed income securities from the issuer or a broker-dealer acting as principal for the securities on a net basis, with no stated brokerage commission paid by the client. However, for fixed income securities purchased in the secondary market, the price typically reflects undisclosed compensation to the broker-dealer; transactions through broker-dealers reflect the spread between the bid and asked prices. In addition, fixed income securities purchased through an underwriter typically include underwriting fees. Research and Other Soft Dollar Benefits Consistent with the duty to seek best execution, brokerage commissions on client accounts’ portfolio transactions may be directed to broker-dealers in recognition of research furnished by them, as well as for services rendered in the execution of orders by such broker-dealers. The commissions used to acquire research in these arrangements are known as “soft dollars.” Under an SEC interpretation, the term “commission” includes a markup, markdown, commission equivalent or other fee paid by an account to a dealer for executing a transaction where the fee and transaction price are fully and separately disclosed on the confirmation and the transaction is reported under conditions that provide independent and objective verification of the transaction price by a selfregulatory organization. As a result, fees charged in relation to certain NASDAQ-reported riskless

principal transactions are eligible for use in soft dollar arrangements in addition to traditional agency commissions charged on equity securities transactions. Broker-dealers may provide execution services and proprietary research, including research reports and access to analysts and traders. TFL also may obtain third-party research through commission sharing arrangements (“CSAs”). Under a CSA, an executing broker-dealer agrees that a portion of the commissions it earns on certain equity trades will be allocated to a centralized commission aggregator, which facilitates payment to one or more third-party research providers for research and/or brokerage and research services. Section 28(e) of the Securities Exchange Act of 1934 provides a statutory safe harbor that, subject to specified conditions, permits an investment adviser to use soft dollars to obtain eligible brokerage and research services, and TFL receives such brokerage and research services through these arrangements. The receipt of research and/or brokerage products and services in exchange for soft dollars benefits TFL by allowing it, at no cost to itself, to supplement its own research and analysis activities, to receive the views and information of individuals and research staffs of other securities firms, and to gain access to persons having special expertise on certain companies, industries, areas of the economy and market factors. To the extent the receipt of such soft dollar services supplants services TFL would have acquired on its own, TFL’s expenses are reduced. TFL therefore may have an incentive to select or recommend a broker-dealer based on its interest in receiving research or other products or services, rather than on the advisory clients’ interest in receiving most favorable execution. TFL, however, has a fiduciary duty to its advisory clients, which it takes seriously, and other controls, described below, which limit this incentive’s effect. Where more than one broker-dealer is believed to be capable of providing the best combination of price and execution with respect to a particular portfolio transaction, TFL often selects a brokerdealer that furnishes brokerage and research services, including, but not limited to, reports on the economy, industries, sectors and individual companies or issuers; subscriptions to certain financial publications and research compilations; compilations of securities prices, earnings, dividends and similar data; financial and market databases; quotation services; and services of economic and other consultants providing advice with respect to portfolio strategy. TFL only uses client brokerage commissions to acquire research and/or brokerage products and services that fall within the statutory “safe harbor.” TFL maintains an internal allocation procedure to identify those brokers that have provided brokerage and research services and the amount of brokerage and research services they provided, and endeavors to direct sufficient commissions to them to ensure the continued receipt of brokerage and research services that TFL believes are useful, consistent with the duty to seek best execution. The determination and evaluation of the reasonableness of the commissions paid in connection with portfolio transactions are based primarily on the professional opinions of the person responsible for the placement of such transactions and oversight of the Brokerage Practices Committee. The general level of commissions paid is also reviewed at least quarterly by TFL through its Brokerage Committee. It is not possible to place a dollar value on the special executions or on the research services TFL receives from broker-dealers effecting transactions in portfolio securities. Accordingly, brokerdealers selected by TFL may be paid commissions for effecting portfolio transactions for client

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Other than the soft dollar arrangements that are described in Item 12 above, no non-advisory client provides TFL with an economic benefit for providing investment advice or other advisory services.

No person receives compensation for referring advisory clients to TFL. TIMI, TAN and Thrivent Trust Company, however, have arrangements in place where Financial Advisors of TIMI or TAN may receive compensation for client referrals. A TIMI Financial Advisor who refers clients to another Financial Advisor may share in the fee for the services provided. These fees may be a single payment or ongoing in nature. This arrangement is only allowed if the Financial Advisor making the referral is appropriately licensed and state registered. Any payments to the Financial Advisor making a referral will not increase the Planning Fee, Program Fee or any fees associated with accounts, products or services that they buy, sell or hold with TIMI. TIMI and its Financial Advisors compensate unaffiliated third parties to refer prospective clients to them. This compensation can consist of cash or non-cash compensation. An example of a noncash compensation arrangement would be a mutual understanding of a cross-referral relationship between a Financial Advisor and an unaffiliated third party such as some other professional service provider. The terms of any such cash or non-cash compensated referral arrangement will be disclosed to the prospective client at the time of the referral. TIMI receives compensation from TAN for soliciting or referring prospective clients to TAN for investment advisory services. A TAN Advisory Person who refers prospective clients or clients to another TAN Advisory Person may share in the fee for the services provided. These fees may be a single payment or ongoing. TAN Advisory Persons may be eligible to receive compensation for referring individuals who become Advisory Persons of TAN. The compensation paid to the referring Advisory Person is based on the referred individual becoming an Advisory Person of TAN coupled with revenue from Advisor Management Fees earned by the referred individual. Thrivent Trust Company compensates TIMI Financial Advisors and TAN Advisory Persons for referring clients to them for professional trust, estate, and investment management services. Thrivent Trust Company will pay ongoing management fees instead of referral fees to the Financial Advisor or Advisory Person, as applicable, if they provide advisory services to assets. Any such compensation payment will be disclosed to the client, when applicable and as required by state law, and will not increase the client’s fees. Such payments may be made for the duration of the client’s accounts held with Thrivent Trust Company. TFL pays TAN Advisory Persons and TIMI Financial Advisors for their work in bringing donor gifts to Thrivent Charitable to the extent these donor gifts are invested in a donor-advised fund available through Thrivent Charitable. This fee does not increase the cost of the product to clients. Thrivent Charitable is not an affiliate of TAN, TIMI or TFL.

Neither TFL nor any of its officers, directors, employees or other management persons have been involved in any legal or disciplinary event that would require disclosure in response to this Item 9.

TFL regularly monitors to confirm that the Private Fund is maintained in accordance with its stated objectives. The Private Fund will provide to its limited partners (i) audited financial statements annually, and (ii) annual tax information necessary for each partner’s U.S. tax returns. The Private Fund and other client accounts, excluding the Separate Account Client, are reviewed by TFL’s Portfolio Compliance group and applicable investment advisory team on a daily basis for compliance with investment policies and for risk evaluation. On a periodic basis, TFL’s senior investment personnel review each account using various risk metrics. It is TFL’s policy that the utmost care be taken in making and implementing investment decisions on behalf of client accounts. To the extent that an error occurs, it is subject to TFL’s Error Correction Policy.

With the exception of any investments in “privately offered securities,” per Rule 206(4)-2 under the Advisers Act (the “Custody Rule”), all of the Private Fund’s assets are held in custody by

unaffiliated broker-dealers or banks acting in the capacity as “qualified custodians.” Notwithstanding the foregoing, TFL’s role as investment manager to the Private Fund enables TFL personnel to access Private Fund assets, and TFL has developed procedures that ensure the safeguarding and protection of the assets. The Private Fund is subject to an annual audit, and the audited financial statements are distributed to each investor. TFL delivers Private Fund client investor audited financial statements for the Private Fund client within a reasonable period of time following the last day of the Private Fund’s fiscal year end. Any custodian, if necessary, for the Separate Account Client is selected by the client and complies with the requirements of the Custody Rule.

TFL has discretionary authority to manage investments on behalf of the Private Fund. As a general policy, TFL does not allow the limited partner to place limitations on this authority. TFL assumes this discretionary authority pursuant to the terms of the constituent documents and powers of attorney executed by the limited partner of the Private Fund. TFL has discretionary authority to manage investments on behalf of TSF, TCMT, the Thrivent Financial Defined Benefit Plan Trust, and TFL’s insurance general account, all pursuant to applicable advisory contract requirements and/or guidelines and limits otherwise provided by the client.

TFL does not have any responsibility to vote proxies with respect to portfolio securities held by the Separate Account Client; in such cases, the client is solely responsible for voting any proxies. When TFL votes securities on behalf of its clients, it does so according to the policy described below.

Responsibility to Vote Proxies Overview. Thrivent Financial for Lutherans and Thrivent Asset Management, LLC (collectively, in their capacity as investment advisers, “Thrivent”) have adopted Proxy Voting Policies and Procedures (“Policies and Procedures”) for the purpose of establishing formal policies and procedures for performing and documenting Thrivent’s fiduciary duty with regard to the voting of client proxies, including investment companies which it sponsors and for which it serves as investment adviser (“Thrivent Funds”) and by institutional accounts who have requested that Thrivent be involved in the proxy process. Fiduciary Considerations. It is the policy of Thrivent that decisions with respect to proxy issues will be made primarily in light of the anticipated impact of the issue on the desirability of investing in

the portfolio company. Thrivent seeks to vote proxies solely in the interests of the client, including Thrivent Funds, and in a manner consistent with its fiduciary obligations and responsibilities. Logistics involved may make it impossible at times, and at other times disadvantageous, to vote proxies in every instance. The procedural requirements contained in these Policies and Procedures do not apply in the case of requests for consents related to investments in private funds. With respect to private fund investments, the procedures described below under “Consents Related to Private Investments” apply.

Administration of Policies and Procedures Thrivent has formed a committee that is responsible for establishing positions with respect to corporate governance and other proxy issues, among other oversight functions related to Thrivent’s responsible investment processes (“Committee”). Annually, the Committee reviews the Policies and Procedures, including in relation to recommended changes reflected in applicable benchmark policies and voting guidelines of Institutional Shareholder Services Inc. (“ISS”). As discussed below, Thrivent may, with the approval of the Committee, vote proxies other than in accordance with the applicable voting guidelines in the Policies and Procedures.

How Proxies are Reviewed, Processed and Voted Proxy Voting Process Overview Thrivent's proxy voting process is designed to act in the best interests of the Thrivent Funds and other accounts it manages, adhering to legal and fiduciary standards. This process involves a careful evaluation of management and shareholder proposals pursuant to Thrivent’s Proxy Voting Guidelines, incorporating a wide range of factors that are financially material to portfolio companies’ and Thrivent clients’ objectives. Thrivent's global approach is informed by various sources, including management’s recommendation, the recommendation of proxy voting advisory firms, and internal assessments. Thrivent’s Proxy Voting Guidelines are crafted to help clients and portfolio companies understand its voting rationale, maintaining flexibility to adapt to individual situations. Thrivent expects to vote proxies on behalf of clients in many cases in accordance with the Voting Guidelines. Thrivent retains the discretion, however, to vote any proxy on behalf of all or one or more clients in a manner inconsistent with the Voting Guidelines if Thrivent determines that doing so is in each applicable client’s best interest. In making such a determination, Thrivent may consider any information it deems relevant, including each applicable client’s investment objectives, strategies and processes. In such cases, the person requesting to diverge from the Voting Guidelines or process is required to document in writing the rationale for their vote and submit all written documentation to the Committee for review and approval. In determining whether to approve any particular request, the Committee will determine that the request is not influenced by any conflict of interest and is in the best interests of the applicable client(s). As a result, there may be instances when, with respect to a particular proxy vote item, Thrivent votes proxies on behalf of some clients in a manner that differs from how Thrivent votes proxies for other clients.

Notwithstanding any of the above, Thrivent may also vote proxies in any matter as directed by a client. Retention of a Third Party Proxy Adviser In order to facilitate the proxy voting process, Thrivent has retained ISS, an unaffiliated third-party proxy service provider, to provide proxy voting-related services, including custom vote recommendations, research, vote execution, reporting, auditing and consulting assistance for the handling of proxy voting responsibilities. ISS specializes in providing a variety of fiduciary-level proxy advisory and voting services. ISS analyzes each proxy vote of Thrivent’s client accounts and prepares a recommendation and/or materials for Thrivent’s consideration which reflect ISS’s application of the Policies and Procedures. In determining how to vote proxies, Thrivent’s Proxy Voting Guidelines leverage the ISS Benchmark Proxy Voting Guidelines (“Benchmark Guidelines”) where applicable. For certain proposal types, Thrivent will provide standing instructions to ISS to vote proxies based on the recommendation of the Benchmark Guidelines; for other proposal types, Thrivent’s investment and/or other personnel, as the circumstances warrant, may leverage research and recommendations issued pursuant to the Benchmark Guidelines as part of the determination process. The Benchmark Guidelines can be found at https://www.issgovernance.com/policygateway/voting-policies/. Thrivent utilizes ISS’s voting agent services for notification of upcoming shareholder meetings of portfolio companies held in client accounts and to transmit votes on behalf of Thrivent’s clients. ISS provides comprehensive summaries of proxy proposals, publications discussing key proxy voting issues, and specific vote recommendations regarding portfolio company proxies to assist in the proxy voting process. The final authority and responsibility for proxy voting decisions remains with Thrivent, unless otherwise directed by a client. Decisions with respect to proxy matters are made primarily in light of the anticipated impact of the issue on the desirability of investing in the company from the viewpoint of our respective clients, while adhering to legal and fiduciary standards to maximize shareholder value. Shareholder Proposals For shareholder proposals where Thrivent uses research and recommendations issued pursuant to the Benchmark Guidelines and a voting determination is made by investment and/or other Thrivent personnel, Thrivent has developed evaluation frameworks designed to thoroughly assess each proposal, ensuring alignment with the best interests of company shareholders. Aspects of these frameworks may also be used for other proposals where Thrivent uses research and recommendations issued pursuant to the Benchmark Guidelines and a voting determination is made by investment and/or other Thrivent personnel. Supplement Applicable to Quantitative/Index Strategies

Certain of Thrivent’s client accounts are accounts (or a portion thereof) that employ a quantitative strategy that relies on factor-based models or an index-tracking approach rather than primarily on fundamental security research and analyst coverage that an actively managed portfolio using fundamental research would typically employ (“Quantitative/Index Accounts”); often, Quantitative/Index Accounts hold a high number of positions. Accordingly, in light of the considerable time and effort that would be required to review ISS research and recommendations and the differing strategies for these accounts, absent client direction, for securities held only in Quantitative/Index Accounts, for certain categories of proposals, Thrivent uses a different process to review and determine a voting outcome that is used for other accounts. For these categories of proposals, Thrivent provides, consistent with the best interest of its clients, standing instructions to ISS to vote proxies for Quantitative/Index Accounts based on the recommendation of ISS pursuant to the Benchmark Guidelines. When securities are also held in accounts (or a portion thereof) that rely on fundamental security research and analyst coverage, the Quantitative/Index Accounts will generally vote in accordance with the voting determination of those fundamental account(s), subject to any exceptions that may arise consistent with these guidelines and policies.

Monitoring and Resolving Conflicts of Interest The Committee is responsible for monitoring and resolving possible material conflicts between the interests of Thrivent and those of its clients with respect to proxy voting. Examples of situations where conflicts of interest can arise are when i) the issuer is a vendor whose products or services are material to Thrivent’s business; ii) the issuer is an entity participating to a material extent in the distribution of proprietary investment products advised, administered or sponsored by Thrivent; iii) an Access Person 2 of Thrivent also serves as a director or officer of the issuer; and iv) there is a personal conflict of interest (e.g., familial relationship with company management). Other circumstances or relationships can also give rise to potential conflicts of interest. All material conflicts of interest will be resolved in the interests of the clients. Application of the Policies and Procedures’ applicable voting guidelines to vote client proxies is generally relied on to address possible conflicts of interest since the voting guidelines are pre-determined by the Committee. Where there is discretion in the voting guidelines, voting as recommended under an ISS policy may be relied on to address potential conflicts of interest. In cases where Thrivent is considering overriding these Policies and Procedures’ applicable voting guidelines, or in the event there is discretion in determining how to vote (for example, where or the guidelines provide for a case by case internal review) matters presented for vote are not governed by such guidelines, the Committee will follow these or other similar procedures: •

Compliance will conduct a review to seek to identify potential material conflicts of interest. If no material conflict of interest is identified, the proxy will be voted as determined by the Committee or the appropriate Thrivent personnel under these policies and procedures. The Compliance review process for identifying potential conflicts of interest will be reviewed by the Committee and may include a review of factors indicative of a potential conflict of interest or a

2 "Access Person" has the meaning provided under the current Thrivent Code of Ethics.

determination that voting in accordance with ISS's recommendation(s) can reasonably be relied on to address potential conflicts of interest. •

If a material conflict of interest is identified, the Committee will be apprised of that fact and the Committee will evaluate the proposed vote in order to ensure that the proxy ultimately is voted in what Thrivent believes to be the best interests of clients, and without regard for the conflict of interest. The Committee will document its vote determination, including the nature of the material conflict, the Committee’s analysis of the matters submitted for proxy vote, and the reasons why the Committee determined that the votes were cast in the best interests of clients.

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TFL does not solicit prepayment of fees from the Private Fund nor has it been the subject of a bankruptcy petition at any time during the past ten years. TFL has never filed for bankruptcy and is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to its clients.