Thrivent Financial for Lutherans: investment adviser

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 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.

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.

Employees of TFL manage TFL’s insurance general account simply as employees of TFL and not pursuant to any agreement or for any compensation.

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: •

• •

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

•

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

governmental actions such as capital or currency controls, nationalizing a company or industry, expropriating assets, or imposing punitive taxes that would have an adverse effect on security prices and impair a Fund’s ability to repatriate capital or income. High Yield Risk. High yield securities — commonly known as “junk bonds” — are considered predominantly speculative with respect to the issuer’s continuing ability to make principal and interest payments. If the issuer of the security is in default with respect to interest or principal payments, the value of a fund may be negatively affected. High yield securities may be more susceptible to real or perceived adverse economic conditions than investment grade securities, and they generally have more volatile prices and carry more risk to principal. In addition, high yield securities generally are less liquid than investment grade securities. Interest Rate Risk. Interest rate risk is the risk that prices of debt securities decline in value when interest rates rise for debt securities that pay a fixed rate of interest. Debt securities with longer durations (a measure of price sensitivity of a bond or bond fund to changes in interest rates) or maturities (i.e., the amount of time until a bond’s issuer must pay its principal or face value) or maturities tend to be more sensitive to changes in interest rates than debt securities with shorter durations or maturities. Changes in general economic conditions, inflation, and monetary policies, such as certain types of interest rate changes by the Federal Reserve, could affect interest rates and the value of some securities. A fund also may be subject to a greater risk of rising interest rates when inflation rates are high or rising. Issuer Risk. Issuer risk is the possibility that factors specific to a company to which the fund’s portfolio is exposed will affect the market prices of the company’s securities and therefore the value of the fund. Some factors affecting the performance of a company include demand for the company’s products or services, the quality of management of the company and brand recognition and loyalty. To the extent that the fund invests in common stock, common stock of a company is subordinate to other securities issued by the company. If a company becomes insolvent, interests of investors owning common stock will be subordinated to the interests of other investors in and general creditors of, the company. Large Cap Risk. Large-sized companies may be unable to respond quickly to new competitive challenges such as changes in technology. They may also not be able to attain the high growth rate of successful smaller companies, especially during extended periods of economic expansion. Liquidity Risk. Liquidity is the ability to sell a security relatively quickly for a price that most closely reflects the actual value of the security. Certain securities (e.g., small-cap stocks, foreign securities, private equity funds, and high-yield bonds) often have a less liquid resale market. Liquid investments may become illiquid after purchase by the adviser, particularly during periods of market turmoil. As a result, the adviser may have difficulty selling or disposing of securities quickly in certain markets or may only be able to sell the holdings at prices substantially less than what the adviser believes they are worth. Less liquid securities can also become more difficult to value. In addition, when there is illiquidity in the market for certain securities, a fund, due to limitations on illiquid investments, may be subject to purchase and sale restrictions. To the extent that dealers do not maintain inventories of bonds that keep pace with the growth of bond markets over time, relatively low levels of dealer inventories could lead to decreased liquidity

and increased volatility in the fixed income markets, particularly during periods of economic or market stress. In addition, inventories of municipal bonds held by brokers and dealers have decreased in recent years, lessening their ability to make a market in these securities. As a result of this decreased liquidity, the adviser may have to accept a lower price to sell a security, sell other securities to raise cash, or give up an investment opportunity, any of which could have a negative effect on performance. Market Risk. Over time, securities markets generally tend to move in cycles with periods when security prices rise and periods when security prices decline. The value of a fund’s investments may move with these cycles and, in some instances, increase or decrease more than the applicable market(s) as measured by a fund’s benchmark index(es). The securities markets may also decline because of factors that affect a particular industry or market sector. Price declines may occur in response to general market and economic conditions or events, including conditions and developments outside of the financial markets such as significant changes in interest and inflation rates and the availability of credit. In addition, domestic or global events, including regulatory events, economic downturn, government shutdowns, the spread of an infectious illness such as the outbreak of COVID-19, public health crises, war, terrorism, social unrest, recessions, natural disasters or similar events could reduce consumer demand or economic output, result in market closures, travel restrictions or quarantines, and generally have a significant impact on the world economies, which in turn could adversely affect the fund’s investments. Any investment is subject to the risk that the financial markets as a whole may decline in value, thereby depressing the investment’s price. Mortgage-Backed and Other Asset-Backed Securities Risk. The value of mortgage-related and asset- backed securities are influenced by the factors affecting the housing market and the assets underlying such securities. As a result, during periods of declining asset value, difficult or frozen credit markets, swings in interest rates, or deteriorating economic conditions, mortgagerelated and asset-backed securities may decline in value, face valuation difficulties, become more volatile and/or become illiquid. In addition, both mortgage-backed and asset-backed securities are sensitive to changes in the repayment patterns of the underlying security. If the principal payment on the underlying asset is repaid faster or slower than the holder of the assetbacked or mortgage-backed security anticipates, the price of the security may fall, particularly if the holder must reinvest the repaid principal at lower rates or must continue to hold the security when interest rates rise. This effect may cause the value of a fund to decline and reduce the overall return of the fund. Mortgage-backed securities are also subject to extension risk, which is the risk that when interest rates rise, certain mortgage-backed securities are paid in full by the issuer more slowly than anticipated. This can cause the market value of the security to fall because the market may view its interest rate as low for a longer-term investment. Other Funds Risk. The performance of a Fund that invests in other funds is dependent, in part, upon the performance of the other funds. As a result, the Fund is subject to the same risks as those faced by the other funds’ underlying portfolios. Those risks may include, among others, market risk, issuer risk, volatility risk, foreign securities risk, foreign currency risk, emerging markets risk, derivatives risk, credit risk, interest rate risk, high-yield risk and investment adviser risk. As a shareholder of the Fund, you will bear your share of the Fund’s operating expenses as well as the Fund’s share of the other funds’ operating expenses. Consequently, an investment in the Fund

would result in higher aggregate operating costs than investing directly in other funds that are also portfolios. Prepayment Risk. When interest rates fall, certain obligations are paid off by the obligor more quickly than originally anticipated, and the 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. Quantitative Investing Risk. Securities selected according to a quantitative analysis methodology can perform differently from the market as a whole based on the model and the factors used in the analysis, the weight placed on each factor and changes in the factor’s historical trends. Such models are based on assumptions relating to these and other market factors, and the models may not take into account certain factors, or perform as intended, and may result in a decline in the value of a Fund’s portfolio. If models or data used in the models are incorrect or incomplete, any decisions made in reliance thereon expose a Fund to potential risks. If incorrect market data is entered into even a well-founded model, the resulting information will be incorrect and could lead to losses for a Fund. For example, the data on which a model is based may be imprecise or become stale due to new events or changing circumstances. Market performance can be affected by nonquantitative factors (for example, investor fear or over-reaction or other emotional considerations) that are not easily integrated into quantitative analysis, which could adversely affect performance of these models and, in turn, a Fund. The performance of a model may also be impaired by technical issues with the construction and implementation of quantitative models such as software or other technology system malfunctions, or programming inaccuracies. Human judgment plays a role in building, utilizing, testing and modifying the financial algorithms and formulas underlying the models and accordingly such models are subject to the risk of human error and biases. Sovereign Debt Risk. Sovereign debt securities are issued or guaranteed by foreign governmental entities. These investments are subject to the risk that a governmental entity may delay or refuse to pay interest or repay principal on its sovereign debt, due, for example, to cash flow problems, insufficient foreign currency reserves, political considerations, the relative size of the governmental entity’s debt position in relation to the economy or the failure to put in place economic reforms required by the International Monetary Fund or other multilateral agencies. If a governmental entity defaults, it may ask for more time in which to pay or for further loans. There is no legal process for collecting sovereign debts that a government does not pay nor are there bankruptcy proceedings through which all or part of the sovereign debt that a governmental entity has not repaid may be collected.

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.

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.

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;

•

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

•

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

•

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

accounts in excess of amounts other broker-dealers would have charged for effecting similar transactions if TFL determines in good faith that such amounts are reasonable in relation to the value of the brokerage and/or research services provided by those broker-dealers, viewed either in terms of a particular transaction or TFL’s overall fiduciary obligations to its discretionary accounts. In determining whether a service or brokerage product qualifies as research or execution, TFL evaluates whether the service or product provides lawful and appropriate assistance to TFL in carrying out its investment decision-making responsibilities. TFL does not usually attempt to allocate the relative costs or benefits of research and/or brokerage products and services among client accounts because it believes that, in the aggregate, the research and/or brokerage products and services received benefits clients and assists TFL in fulfilling its overall duty to its respective clients. As a general matter, research and/or brokerage products and services received in exchange for soft dollars may be shared across all of the accounts managed by the Advisers (i.e., TAM and TFL) and their Supervised Persons. However, research and/or brokerage products and services obtained with soft dollars may not be utilized for the specific account that generated the soft dollars and not every research service may be used to service every account managed by these Advisers. For example, it is expected that research can be freely shared in cases where there is a platform access arrangement that grants enterprise-wide access to research. Investment personnel outside the equity investment group may not use research services that are paid for through commissions generated by equity transactions unless there is no incremental cost associated with the use of such research. TFL will not enter into any agreement or understanding with any broker-dealer that would obligate it to direct a specific amount of brokerage transactions or commissions to that broker-dealer in return for research services. However, certain brokers may specify in advance the amount of brokerage commissions they require for certain services and the applicable cash equivalent. TFL may use its available soft dollar credits to obtain a particular product and pay cash to make up any difference. In some cases, TFL receives products or services that are used both as investment research and for administrative, marketing or other non-research purposes (“mixed use” items). In such instances, TFL makes a good faith effort to determine the relative proportions of such products or services that may be considered as investment research and may use soft dollars for the research portion and pay cash for the non-research portion. Although the allocation between soft dollars and cash is not always capable of precise calculation, and accordingly represents a conflict of interest for TFL, TFL will make a good faith effort to allocate such items reasonably. Records of any such allocations and payments are prepared and maintained by TFL in accordance with federal securities laws. Client-Directed Brokerage Transactions Advisory clients are not generally permitted to direct TFL to use specified broker-dealers in performing portfolio transactions. To the extent that a client may direct TFL to use a particular broker-dealer to execute transactions under terms negotiated by the client with a particular broker-dealer, however, such direction may result in higher commissions, greater spreads or less favorable net prices than might be the case if TFL could negotiate commission rates or spreads freely or select broker-dealers based on best execution. In addition, in a directed brokerage account, the client may pay higher brokerage commissions because TFL may not be able to aggregate orders to reduce transaction costs.

Batch Transaction and Allocation Policy Occasions may arise when two or more client accounts intend to purchase or sell the same security at approximately the same time on a combined basis. These transactions are referred to as “bunched” or “batched” trades. Due to differences in strategies, some securities may be held in more than one client account but not traded at the same time. On those occasions when “bunched” trades are made, authorized traders will seek to achieve the same net unit price of the securities for each account. Where the aggregate order is executed by the same broker in a series of transactions at various prices on a given day, each participating portfolio receives a proportionate share of such order reflecting the same average net price paid or received with respect to the total order. When orders are not aggregated clients may pay prices for transactions that are more or less than the client would have paid had the order been aggregated. A determination may be made not to aggregate orders for a number of reasons, including that it may be impractical because of specific trade directions received from the portfolio manager, the order involves a different trading strategy, or if the trader otherwise determines that aggregation is not consistent with seeking best execution. From time to time, especially in the case of equity or fixed income new issues, an order may be only partially filled. In these instances, the executed portion of the order will generally be allocated on a pro rata basis based on original order size or portfolio assets. On some occasions, it may be necessary to change the allocation to one or more accounts given the circumstances at the time of the trade or client guidelines. In such circumstances, the partially filled order would be allocated across the remaining accounts based on the following exceptions: •

De minimis allocations. Exceptions may be justified based upon large differences in asset sizes. This de minimis exception permits smaller accounts, or accounts with a small initial allocation after pro rata calculations, to receive their entire allocation before larger accounts are given their pro rata amount.

•

Uneconomic lot sizes. Proportionate allocations may be rounded off to avoid holding uneconomic share quantities, which might result in lower bids when the securities are eventually sold. Tracking uneconomic lot sizes may be accomplished by tracking both an absolute figure of an economic lot size (e.g., 50 share increments) in conjunction with the total asset size of each participating account.

•

Cash flow disparities. Proportionate allocations may also be affected by the differing cash flow situations of each portfolio at the time of the transaction.

•

Specialized accounts. Where there is an insufficient number of securities to satisfy all orders, portfolios with specialized investment policies may take priority over other clients for acquisitions of particular securities which satisfy that portfolio’s specialized needs. Tracking specialized account considerations may be accomplished by allocating portions based upon a pro rata allocation using the relative asset size of each participating account’s benchmark’s holdings in securities of the same class as those being requested.

•

Strategy driven. The pro rata allocation could be adjusted if is not in not in alignment with the account’s investment strategy and/or objectives or the account is already at its target weighting for the investment.

TFL is not obligated to provide the same investment advice to each account it manages, including the purchase of, or participation in, initial public offerings (“IPOs”). In general, each portfolio manager is responsible for determining whether any particular IPO is an appropriate investment for the account he/she manages, based on investment objectives, investment restrictions and trading strategies. Accounts may not participate in such transactions if to do so would be inconsistent with their investment objectives or trading practices. As a result, certain accounts managed by TFL may have greater opportunities than others to participate in IPOs. Portfolio managers may purchase IPOs for the Thrivent Financial Defined Benefit Plan Trust and TFL’s insurance general account. While this is an inherent conflict of interest, TFL and its affiliated investment adviser, TAM, take steps to ensure that it does not disadvantage client accounts by allowing Thrivent Financial Defined Benefit Plan Trust and TFL’s insurance general account to participate only on the same terms and at the same price as client accounts. Money Market portfolio managers may allocate “bunched” trades to client accounts based on a number of factors including pro-rata as determined by the size of the original order, based on oddlot size of the allocation received, based on updated cash or liquidity levels, or based on block size and/or current portfolio holding concentrations (i.e., issuer and sector concentrations). Due to the potential for large swings in cash movement or where investable cash numbers may not be available until after the market has commenced trading, a Money Market portfolio manager may allocate such trades after they are executed. Securities traded for this asset class are considered substitutable, meaning the characteristics of a security can be easily replicated by other available securities in the marketplace to achieve the desired investment objective.

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.

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.

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.

Certain Thrivent Funds ("top tier fund") may own shares of other Thrivent Funds (''underlying fund"). If an underlying fund submits a matter to a shareholder vote, the top tier fund will generally vote its shares in the same proportion as the other shareholders of the underlying fund. If there are no other shareholders in the underlying fund (or no other shareholders other than Thrivent-advised accounts), Thrivent may vote the accounts invested in the underlying fund in what Thrivent believes to be the client’s best interest. Shareblocking Shareblocking is the practice in certain foreign countries of “freezing” shares for trading purposes in order to vote proxies relating to those shares. Thrivent generally refrains from voting shares in shareblocking countries unless the matter has compelling economic consequences that outweigh the loss of liquidity in the blocked shares. Applying Proxy Voting Policies to non-U.S. Companies Thrivent applies a two-tier approach to determining and applying global proxy voting policies. The first tier establishes baseline policy guidelines for the most fundamental issues, which apply without regard to a company's domicile. The second tier takes into account various idiosyncrasies of different countries, making allowances for standard market practices, as long as they do not violate the fundamental goals of good corporate governance. The goal is to enhance shareholder value through effective use of the shareholder franchise, recognizing that applying policies developed for U.S. corporate governance may not be appropriate for all markets. Securities Lending From time to time, certain clients may participate in a securities lending program. Thrivent will not have the right to vote shares on loan as of record date. Thrivent will generally not seek to recall shares on loan in order to vote, unless it determines that a vote would have a material effect on an investment in such loaned security. Thrivent will use reasonable efforts to recall securities. The ability to vote recalled shares is subject to administrative considerations, including the feasibility of a timely recall prior to record date. Thrivent may also restrict lending of securities in consideration of individual account and/or aggregate client investment in a company, or other criteria established from time to time.

Oversight, Reporting and Record Retention

Retention of Proxy Service Provider and Oversight of Voting In overseeing proxy voting generally and determining whether or not to retain the services of ISS, Thrivent performs the following functions, among others, to determine that Thrivent continues to vote proxies in the best interest of its clients: i) periodic sampling of proxy votes; ii) periodic reviews of Thrivent’s Policies and Procedures to determine they are adequate and have been implemented effectively, including whether they continue to be reasonably designed to ensure that proxies are voted in the best interest of Thrivent’s clients; iii) periodic due diligence on ISS designed to monitor ISS’s a) capacity and competency to adequately analyze proxy issues, including the adequacy and quality of its staffing and personnel, as well as b) its methodologies for developing vote recommendations and ensuring that its research is accurate and complete; and iv) periodic reviews of ISS’s procedures regarding their capabilities to identify and address conflicts of interest. Proxy statements and solicitation materials of issuers (other than those which are available on the SEC’s EDGAR database) are kept by ISS in its capacity as voting agent and are available upon request. Thrivent retains documentation on shares voted differently than the Thrivent Policies and Procedures voting guidelines, and any document which is material to a proxy voting decision such as the Thrivent Policies and Procedures voting guidelines and the Committee meeting materials. ISS provides Vote Summary Reports for each Thrivent Fund. The report specifies the company, ticker, other applicable identifier (e.g., Cusip, SEDOL, etc.), meeting dates, proxy proposals, and votes which have been cast for the Thrivent Fund during the period, the position taken with respect to each issue and whether the Thrivent Fund voted with or against company management.

Copies of Voting Records and Policies A copy of Thrivent’s detailed voting guidelines and the voting records of client accounts are available to Thrivent’s clients upon request.

Consents Related to Private Investments From time to time, the Thrivent Funds or other clients may invest in private investments. When these private investments request consent to change the terms or other conditions of their securities, Thrivent will promptly review these solicitations. Thrivent is committed to voting in the best interests of its clients, taking into account any potential conflicts of interest. The responsibility to vote on consents is delegated to certain of the Investment Personnel, as defined in the Thrivent Code of Ethics, of the Private Investments Group. The Private Investments Group, alongside the Chief Compliance Officer, or his or her designee, will document and assess any potential conflicts of interest related to the consent voting process. If a conflict is deemed material by the Chief Compliance Officer, or his or her designee, the Committee will be apprised. The Committee will then determine the best way to manage the conflict, ensuring votes serve the clients' best interests.

Thrivent’s Proxy Voting Guidelines Specific voting guidelines have been adopted by the Committee for regularly occurring categories of management and shareholder proposals. The detailed voting guidelines are available to Thrivent’s clients upon request. The following is a summary of significant Thrivent policies, which are generally consistent with the Benchmark Guidelines referenced above.

Board of Directors and Corporate Governance Voting on Director Nominees in Uncontested Elections Generally, Thrivent votes for director nominees, except under specific circumstances. Four fundamental principles apply when determining votes on director nominees: 1. Accountability: Boards should be sufficiently accountable to shareholders, including through transparency of the company's governance practices and regular board elections, by the provision of sufficient information for shareholders to be able to assess directors and board composition, and through the ability of shareholders to remove directors. It is expected that boards will engage in critical self-evaluation of themselves and of individual members. Individual directors, in turn, are expected to devote significant amounts of time to their duties and to limit the number of directorships they accept. 2. Responsiveness: Directors should respond to investor input, such as that expressed through significant opposition to management proposals, significant support for shareholder proposals (whether binding or non-binding), and tender offers where a majority of shares are tendered. 3. Composition: Companies should ensure that directors add value to the board by having sufficient time and commitment to serve effectively. Boards should be of a size appropriate to accommodate expertise and independence, while ensuring active and collaborative participation by all members. 4. Independence: Thrivent believes boards are expected to have a majority of directors independent of management. The independent directors are expected to organize much of the board’s work, even if the chief executive officer also serves as chairperson of the board. Key committees (audit, compensation, and nominating/corporate governance) of the board are expected to be entirely independent of management. Circumstances under which Thrivent may abstain, vote against or withhold votes from directors, pursuant to the Benchmark, include:

• •

• •

Independence-related issues such as non-independent directors on a board with < 50% independence. Composition-related issues such as low attendance or overboarding. Responsiveness-related issues such as poor responsiveness to a low say-on-pay vote. Accountability-related issues such as problematic takeover defenses, capital structure, and/or governance structure (including poison pill, unequal voting rights, classified board, removal of shareholder discretion, problematic governance structure, unilateral bylaw/charter amendments, restrictions on shareholder proposals, director performance

evaluations, problematic audit practices, pledging, climate accountability, other governance failures). Voting on Director Nominees in Contested Elections Thrivent votes case-by-case on the election of directors in contested elections. Other Proposals Related to Board Structure & Accountability Thrivent believes boards should be sufficiently accountable to shareholders, including through transparency of the company's governance practices and regular board elections, by the provision of sufficient information for shareholders to be able to assess directors and board composition, and through the ability of shareholders to remove directors. Thrivent may vote case-by-base on proposals related to age & term limits, proposals to establish or amend director qualifications, proposals to establish a new board committee, proposals to separate the board chair and CEO position, proposals related to director and officer indemnification, liability protection, and exculpation, and other proposals related to routine/standard board-related items. Thrivent votes against management efforts to stagger board member terms because a staggered board may act as a deterrent to takeover proposals. For the same reason, Thrivent votes against proposals to eliminate cumulative voting and votes for proposals that seek to fix the size of the board. Ratification of Auditors Thrivent votes for proposals to ratify auditors, unless an auditor has a financial interest in or association with the company, and is therefore not independent; there is reason to believe that the independent auditor has rendered an opinion that is neither accurate nor indicative of the company’s financial position; non-audit fees paid represent 50 percent or more of the total fees paid to the auditor; or poor accounting practices are identified that rise to a serious level of concern. Executive and Director Compensation Well-designed incentive programs play a crucial role in guiding executive management decisions towards long-term value enhancement. Conversely, incentive programs with unsuitable performance targets or design flaws can hinder the alignment between management's incentives and the interests of investors. We believe that as proactive investors, it's our duty to comprehend the compensation structures of the companies in our portfolio and to offer constructive feedback — via our proxy voting and direct interactions — whenever we identify areas of concern. Advisory Vote on Executive Compensation (Say on Pay) Shareholder votes to approve executive compensation — generally votes of an advisory nature — have become common in markets around the world. It is challenging to apply a rules-based

framework to compensation votes because every pay program is a unique reflection of the company’s performance, industry, size, geographic mix, and competitive landscape. Additionally, factors such as executives’ individual performance, achievement of goals, experience, tenure, skills, and leadership should be taken into account in evaluating the overall compensation context. For these reasons, Thrivent votes on executive and director compensation proposals following a caseby-case evaluation. Generally, Thrivent opposes compensation packages that provide what we view as excessive awards to a few senior executives or that contain excessively dilutive stock option grants based on a number of criteria such as the costs associated with the plan, plan features, and dilution to shareholders. Factors considered in our evaluation of “Say on Pay” votes includes an annual pay-forperformance analysis for companies in the S&P 1500, Russell 3000 or Russell 3000E Indices, conducted by ISS. This evaluation includes two primary factors: • Peer Group Alignment: This assesses the relationship between the company's total shareholder return (TSR) rank and the CEO's total pay rank within a peer group, measured over five years. It also considers the CEO's pay multiple relative to the peer group median. • Absolute Alignment: This examines the alignment between the trend in CEO pay and company TSR over the previous five fiscal years. If this analysis indicates significant misalignment, Thrivent may include qualitative factors for a deeper evaluation, such as the ratio of performance- to time-based incentives, the rigor of performance goals, and transparency of pay program disclosures. Additionally, Thrivent scrutinizes problematic pay practices on a case-by-case basis, focusing on practices that contravene global pay principles. Thrivent generally votes for holding annual advisory votes on compensation, which provide the most consistent and clear communication channel for shareholder concerns about companies' executive pay programs. Equity-Based and Other Incentive Plans We believe long-term equity plans, used appropriately, provide strong alignment of interests between executives and investors. These plans can be effective in linking executives’ pay to the company’s performance as well as attracting and retaining management talent. We evaluate requests to approve or renew equity plans on a case-by-case basis, taking into account a combination of certain plan features and equity grant practices, where positive factors may counterbalance negative factors, and vice versa, as evaluated using an "Equity Plan Scorecard" (EPSC) approach with three pillars: Plan Cost: The total estimated cost of the company’s equity plans relative to industry/market cap peers, measured by the company's estimated Shareholder Value Transfer (SVT) in relation to peers and considering both:  SVT based on new shares requested plus shares remaining for future grants, plus outstanding unvested/unexercised grants; and  SVT based only on new shares requested plus shares remaining for future grants.

Plan Features:  Quality of disclosure around vesting upon a change in control (CIC);  Discretionary vesting authority;  Liberal share recycling on various award types;  Lack of minimum vesting period for grants made under the plan;  Dividends payable prior to award vesting.  Disclosure of non-employee directors’ cash-denominated award limits. Grant Practices:  The company’s three year burn rate relative to its industry/market cap peers;  Vesting requirements in CEO'S recent equity grants (3-year look-back);  The estimated duration of the plan (based on the sum of shares remaining available and the new shares requested, divided by the average annual shares granted in the prior three years);  The proportion of the CEO's most recent equity grants/awards subject to performance conditions;  Whether the company maintains a sufficient claw-back policy;  Whether the company maintains sufficient post exercise/vesting share-holding requirements. Negative Overriding Factor: If the plan lacks sufficient positive features under the Plan Features pillar, despite an overall passing score. Other Compensation Plans Thrivent has varying approaches for evaluating other compensation-related proposals, guided by a set of principles aimed at ensuring fair and effective compensation practices. Capital Structure and Incorporation Thrivent generally votes on a case-by-case basis on proposals related to capital structure and incorporation and seeks to vote in a way that protects shareholders’ value in the companies in which the Thrivent funds invest. When voting on capital structure issues, Thrivent considers the dilutive impact to shareholders and the effect on shareholder rights. Thrivent will evaluate reincorporation proposals on a case-by-case basis. Considerations include: • Regulations of both states or countries • Required fundamental policies • Increased flexibility available Increases in Common Stock Thrivent's policy for voting on proposals to increase the number of authorized shares of common stock is nuanced and case-by-case, guided by specific criteria. For general corporate purposes, the policy is to vote for an increase in authorized shares depending on the percentage of share usage: up to 50% increase if less than 50% of current shares are used, up to 100% if usage is between 50% and 100%, and up to the current share usage if it exceeds the authorized shares. However, Thrivent generally votes against increases, even within these parameters, if the proposal

or the company’s use of shares is problematic, such as seeking to increase shares with superior voting rights or having a non-shareholder approved poison pill. Exceptions are made for increases beyond these ratios in cases where non-approval poses severe risks, like imminent bankruptcy or requirements by government bodies. In states allowing unilateral capital increases without shareholder approval, Thrivent may vote against all nominees if the increase doesn't conform to these policies. For specific authorization requests linked to transactions (like acquisitions or SPAC transactions), the policy is generally to vote for the increase, with the allowable increase being the greater of twice the amount needed for the transactions or the calculated increase for general issuances. Multi-Class Share Structures Thrivent generally recommends voting against proposals to create a new class of common stock, except in specific circumstances where the company provides a compelling rationale for a dualclass capital structure. Such exceptions include situations where the company's auditor expresses substantial doubt about the company's ongoing viability, or when the new share class is intended to be temporary. Additionally, Thrivent may support the creation of a new class if it is aimed at financing purposes with minimal or no short-term and long-term dilution to current shareholders, and it is not structured to preserve or enhance the voting power of insiders or significant shareholders. The policy underscores a cautious approach to changes in capital structure that could impact shareholder rights and company governance. Mergers and Acquisitions Thrivent votes on mergers and acquisitions on a case-by-case basis, taking into account and balancing the following: anticipated financial and operating benefits, including the opinion of the financial advisor, market reaction, offer price (cost vs. premium) and prospects of the combined companies; how the deal was negotiated; potential conflicts of interest between management’s interests and shareholders’ interests; and changes in corporate governance and their impact on shareholder rights. Anti-takeover and Shareholder Rights Plans Thrivent adopts a nuanced approach towards voting on anti-takeover provisions, with a policy anchored in the principles of flexibility, fairness, and transparency in corporate governance. This approach involves critical evaluation of various factors, including the dilutive impact of capital structure changes, the balance of authority between the board and shareholders, especially in amending bylaws, and the careful scrutiny of provisions related to control share acquisitions, fair price, and poison pills. Thrivent also assesses the implications of litigation rights, voting disclosure, and mechanisms that empower shareholders, such as the ability to act by written consent or call special meetings. We believe in maintaining a market for corporate control that functions without undue restrictions, as it often leads to acquisitions that increase shareholder value. Consequently, Thrivent typically votes against the adoption of anti-takeover provisions like shareholder rights plans (poison pills), which can lead to management entrenchment and reduced board accountability, aiming to support proposals that enhance shareholder value and rights and oppose those that restrict or harm these interests.

Shareholders Rights Plans (“poison pills”) For shareholder proposals requesting the submission of a poison pill to a vote or its redemption, Thrivent generally votes in favor, except when there is an existing shareholder-approved poison pill or a policy that allows the board to adopt a pill under specific conditions, including immediate shareholder ratification. Such pills must be put to a shareholder vote within 12 months of adoption or they will expire. In cases where management proposes ratification of a poison pill, Thrivent's vote is case-by-case, focusing on the rights plan's attributes like a trigger no lower than 20%, a maximum term of three years, the absence of features that limit a future board's ability to redeem the pill, and a shareholder redemption feature. The company's rationale for adopting the pill is also critically assessed, along with its governance structure, including board independence and existing defenses. When it comes to poison pills aimed at preserving Net Operating Losses (NOLs), Thrivent votes against proposals if the term exceeds the shorter of three years or the exhaustion of the NOLs. For management proposals to ratify NOL pills with a shorter term, the vote is case-by-case, considering factors like the ownership threshold, the value of the NOLs, shareholder protection mechanisms, the company’s governance structure, and other relevant factors. Shareholder Ability to Call a Special Meeting & Act by Written Consent Thrivent's policy regarding shareholder rights to act by written consent and to call special meetings is focused on maintaining and enhancing shareholder participation and influence in corporate governance. Generally, Thrivent votes against any proposals that seek to restrict or prohibit shareholders' ability to act by written consent. We generally support proposals that enable shareholders to act by written consent, considering factors such as the existing rights, consent thresholds, any exclusionary language, the investor ownership structure, and the history of shareholder support and management responses to related proposals. When it comes to shareholders' ability to call special meetings, Thrivent typically votes against proposals that restrict or prohibit this right. We generally support management or shareholder proposals that facilitate the ability of shareholders to call special meetings, paying attention to current rights, the minimum ownership threshold necessary for calling meetings (with a preference for a 10% threshold), any prohibitive language in the proposals, the investor ownership structure, and the track record of both shareholder support and management's responses to past proposals. Voting Requirements Thrivent generally supports management proposals to adopt a majority of votes cast standard for directors in uncontested elections. Thrivent generally opposes proposals to require a supermajority shareholder vote and generally supports proposals to reduce supermajority vote requirements. However, for companies with shareholder who have significant ownership levels, Thrivent may vote case-by-case, taking into account: Ownership structure; Quorum requirements; and Vote requirements.

Thrivent generally votes case-by-case on proposals regarding proxy voting mechanics, taking into consideration whether implementation of the proposal is likely to enhance or protect shareholder rights. Specific issues include, but are not limited to, confidential voting of individual proxies and ballots, confidentiality of running vote tallies, and the treatment of abstentions and/or broker nonvotes in the company's vote-counting methodology. Environmental and Social Management Proposals Thrivent will generally vote in accordance with the ISS Benchmark recommendations with regard to management proposals relating to environmental and social topics, such as those related to approval of political donations.

Shareholder Proposals At Thrivent, we evaluate shareholder proposals with the overarching goal of aligning our voting decisions with the best interests of shareholders and maximizing long-term value. Shareholder proposals are reviewed on a case-by-case basis starting with thoughtful and consistent framework processes that consider the materiality of the issue to the company’s business, the company’s current practices and disclosures, the context and credibility of the proposal and its proponent, alignment with shareholder interests, and the proposal’s prescriptiveness. We recognize that proposals can vary significantly in scope and impact, and our evaluation process reflects this diversity. While our actively managed fundamental strategies apply a detailed, research-driven approach to voting decisions, our quantitative and index strategies with investments not also held by actively managed fundamental strategies rely on processes that balance efficiency with shareholder value considerations. This distinction ensures that each proposal is assessed in a manner consistent with the strategy and objectives of the portfolios holding the security. Environmental and Social Shareholder Proposals When evaluating environmental and social proposals, we adopt a case-by-case analysis that balances the specific circumstances of each company with the broader context of market norms and regulatory requirements. The starting point of our evaluation is a framework that involves analyzing the relevance of a proposal in terms of its direct relation to the company's business activities, strategies, and performance. The framework considers the potential material impact of the proposal on the company's long-term value with a focus on financial performance or valuation. Additionally, Thrivent examines the company's current practices, policies, and disclosures relevant to the proposal, while considering industry-standard practices and trends (market norms) to provide a benchmark for evaluation. Understanding the legal and regulatory landscape, including existing laws and future regulatory trends, forms a part of this evaluation. The framework also encompasses identifying the proposal's proponents to understand their motivations and potential implications, as well as considering the proposal's potential reputational impact on the company. Assessing the reasonableness of the

proposal in terms of practicality, feasibility, and logic, and evaluating its persuasiveness based on clarity, logic, and evidence, are also integral components of the process. By leveraging this structured framework, Thrivent ensures that our voting decisions are informed and consider long-term value creation for shareholders. Consideration

Questions

Explanation

Materiality

Does the resolution address an issue that is material for this company? Does the proposal reflect an industryspecific, materiality-driven approach?

The relevance of the resolution is crucial in determining if it aligns with the core business and operations of the company. Materiality is key to understanding if the issue can significantly impact the company's long-term value.

Current Practice

Does the proposal address a current shortcoming? Has the company already announced intentions to address the shortcoming?

Current practices and disclosures are reviewed to check if the company has already taken steps to address the issue. Market norms provide context by showing industry standards and peer responses.

Context

Who are the proponents of the resolution, and are they tied to any particular interest groups? Do the proponent’s interests align with ours?

Understanding the proponent helps identify their motivations and alignment with the company's objectives. The reasonableness and persuasiveness of the proposal are essential to ensure it is practical and effectively communicated.

Shareholder Alignment

Are shareholders the optimal stakeholders to address the core issue that is the subject of the resolution? Does the proposal add value for shareholders? Does the proposal address substantive matters that may impact shareholders’ interests, including shareholders’ rights?

This involves assessing whether the issue falls within shareholder influence or if it's better addressed through regulatory compliance and legal mandates.

Prescriptiveness

Is the proposal NOT overly prescriptive? Do the proposal’s demands NOT unreasonably restrict management from conducting its business?

The reasonableness of the proposal is evaluated to ensure it is not excessively demanding. The company's current practices and disclosures are reviewed to determine if there is already a framework addressing the issue.

Other Shareholder Proposals Thrivent’s approach to evaluating other shareholder proposals reflects our commitment to responsible investment stewardship and alignment with shareholder value. Recognizing the wide range of issues addressed by these proposals—such as governance structures, shareholder rights, executive compensation, and operational practices—we apply a consistent and thorough framework as a starting point to ensure decisions are in the best interests of shareholders.

These shareholder proposals are evaluated on a case-by-case basis, balancing company-specific circumstances with broader governance standards and market practices. Our evaluation framework considers the materiality of the proposal, its relevance to the company’s business strategy, and its potential to create or protect shareholder value. In addition, we assess the company’s current practices and policies to identify any governance shortcomings the proposal seeks to address. The context and credibility of the proposal and its proponents are critical components of our analysis, helping to understand the proponents’ motivations and whether they are aligned with shareholder interests. We also evaluate whether the proposal enhances shareholder rights, better aligns management and shareholder objectives, and avoids unnecessary prescriptiveness that could hinder the company’s ability to operate effectively. By leveraging this structured framework, Thrivent ensures that our voting decisions are informed and consider long-term value creation for shareholders. Consideration

Questions

Explanation

Materiality

Is the issue material to the company’s business? Does the proposed action have the potential to materially impact the company?

The relevance of the proposal is essential to ensure it addresses core business operations and aligns with shareholder value creation. Materiality highlights the issue’s potential impact on financial and strategic outcomes.

Current Practice

Does the proposal remedy a governance weakness? Has the company already announced intentions to address the shortcoming?

Reviewing current practices and disclosures helps identify existing efforts to address the issue. Governance improvements may align with industry standards or address peer comparisons.

Context

Who are the proponents of the resolution, and are they tied to any particular interest groups? Do the proponent’s interests align with ours?

Understanding the proponents’ motivations ensures alignment with shareholder objectives. Proposals should be reasonable and communicated effectively.

Shareholder Alignment

Does the proposal enhance shareholder rights or create value for shareholders? Does the proposal have the potential to better align executive and/or directors’ interests with those of shareholders?

Evaluating shareholder alignment ensures the proposal strengthens governance practices, improves shareholder rights, and aligns interests with long-term value creation.

Prescriptiveness

Is the proposal NOT overly prescriptive? Does the proposal’s demands NOT unreasonably restrict management from conducting its business?

Proposals should not impose excessive restrictions on management. They must balance practicality and flexibility with achieving the intended objectives.

Disclosure-Related Proposals

In assessing proposals that request enhanced disclosure, Thrivent focuses on several critical factors, such as the company’s current level of disclosure, its compliance with relevant regulations and guidelines, and any significant controversies or fines that might have arisen. Thrivent's policy is to vote on a case-by-case basis on shareholder proposals seeking greater disclosure, as well as any associated risks and liabilities. The goal is to ensure that disclosures effectively balance the needs and interests of various stakeholders and are not overly onerous, diverting resources from core business operations. Action-Related Proposals Regarding proposals that require a company to take a certain action, our policy is to carefully scrutinize requests for the adoption of specific targets, goals, or changes in business practices. We acknowledge that while shareholders may not always have the intricate knowledge of a company's strategic operations, there are instances where such proposals can highlight areas needing improvement. Thrivent assesses each proposal based on the nature of the company’s business, the practicality and feasibility of implementing the proposed actions, and how these actions align with the company's overall strategy and operational capabilities. In considering these proposals, Thrivent pays close attention to the company’s ability to address the issues raised in the proposal, the proposal’s prescribed timetable and methods for implementation, and how the company's practices compare with those of its industry peers.

Copies of Voting Records and Policies A copy of Thrivent’s detailed voting guidelines and the voting records of client accounts are available to Thrivent’s clients upon request.