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Affiliate GWLA or GWL&ANY Proprietary Investments <br /> Investment options into which participant or accountholder assets may be allocated, pursuant to the OA or the MA services <br /> may be through a fixed and variable deferred annuity issued by GWLA or GWL&ANY. Because Morningstar Investment <br /> Management is unaffiliated with AAG,GWLA,GWL&ANY and their affiliates,AAG does not believe there is a conflict of interest. <br /> However,in all instances,AAG's affiliation with GWLA and/or GWLA's affiliates,as applicable,will be disclosed. <br /> Item 12 — Brokerage Practices <br /> Brokerage Selection;Best Execution <br /> For retirement plans or the Empower Premier IRA,the plan sponsor,its agent,or the IRA platform provider selects the broker- <br /> dealer used by the retirement plan and determines the reasonableness of the compensation. AAG does not select or <br /> recommend broker-dealers for stock transactions or self-directed brokerage accounts and does not determine the <br /> reasonableness of broker-dealer's compensation. Transactions recommended by Morningstar Investment Management for <br /> the Service are processed by AAG's affiliated recordkeeper, Empower Retirement,and generally executed through GWFS. <br /> Soft Dollar Practices <br /> As a matter of policy,AAG does not utilize research or other products or services from third parties in connection with client <br /> securities transactions on a soft-dollar commission basis. <br /> Directed Brokerage <br /> The plan sponsor may elect to offer brokerage services to participants in the retirement plan.AAG does not participate in such <br /> decisions and does not provide recommended portfolios or investment recommendations on assets held in a brokerage <br /> account under the retirement plan. <br /> Trade Aggregation <br /> AAG does not bunch orders or engage in block trades to execute equity orders for clients. Client accounts are generally held <br /> in trust per regulatory requirements. Further, most trades are mutual funds where trade aggregation does provide any <br /> additional client benefits. <br /> Item 13—Review of Accounts <br /> At least annually,AAG personnel review the methodologies used by Morningstar Investment Management to power the OIG, <br /> OA and MA services to ensure that they are consistent with investment advisory best practices,current technology,applicable <br /> law and the terms of the agreement between AAG and Morningstar Investment Management. <br /> Neither AAG nor Morningstar Investment Management review the personal financial information of participants/account <br /> holders as provided by the participants/account holders or the Plan Sponsor and do not assume responsibility for any <br /> incomplete or erroneous information.Such information,which includes date of birth,salary,gender and/or state of residence, <br /> must be reviewed periodically by the participant and/or the Plan Sponsor or the account holder who in turn are responsible <br /> for notifying AAG of any changes,errors or omissions to such information. <br /> AAG conducts the following review of its clients'accounts: <br /> Online Investment Guidance <br /> AAG does not conduct any review or other oversight for participants/account holders enrolled in this service. <br /> Online Advice <br /> AAG does not conduct review of its participant's/account holder's accounts in respect to investment oversight, monitoring,or <br /> rebalancing. Participants/account holders receive from AAG's investment recommendations based on the investment options <br /> provided in their specific retirement plan or in the Empower Retirement Premier IRA. It is the responsibility of OA clients to <br /> review and update their accounts to adjust for changes in the investments they own and to determine whether the <br /> recommendations are suitable for their particular investment needs. OA clients should also review and update their <br /> accounts if significant changes occur in their personal circumstances. <br /> 17 <br />