SYMETRA SEPARATE ACCOUNT SL Form N-6 Filed 2021-06-10

SECURITIES AND EXCHANGE COMMISSION

FORM N-6 Registration statement for separate accounts (unit investment trusts)

Filing Date: 2021-06-10 SEC Accession No. 0000806180-21-000038

(HTML Version on secdatabase.com)

FILER SYMETRA SEPARATE ACCOUNT SL Mailing Address Business Address 777 108TH AVE NE 777 108TH AVE NE CIK:806180| IRS No.: 910742147 | State of Incorp.:WA | Fiscal Year End: 1231 SUITE 1200 SUITE 1200 Type: N-6 | Act: 40 | File No.: 811-04909 | Film No.: 211007623 BELLEVUE WA 98004 BELLEVUE WA 98004 877-796-3872 SYMETRA SEPARATE ACCOUNT SL Mailing Address Business Address 777 108TH AVE NE 777 108TH AVE NE CIK:806180| IRS No.: 910742147 | State of Incorp.:WA | Fiscal Year End: 1231 SUITE 1200 SUITE 1200 Type: N-6 | Act: 33 | File No.: 333-256975 | Film No.: 211007622 BELLEVUE WA 98004 BELLEVUE WA 98004 877-796-3872

File Nos. ______/811-04909 SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

FORM N-6 REGISTRATION STATEMENT X UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. Post-Effective Amendment No. REGISTRATION STATEMENT X UNDER THE INVESTMENT COMPANY ACT OF 1940 Amendment No. 43 X

(Check appropriate box or boxes.) SYMETRA SEPARATE ACCOUNT SL (Exact Name of Registrant) Symetra Life Insurance Company (Name of Depositor)

777 108th Ave NE, Suite 1200, Bellevue, WA 98004 (Address of Depositor's Principal Executive Offices) (Zip Code)

Depositor’s Telephone Number, including Area Code (425) 256-8000

Name and Address of Agent for Service

Rachel Dobrow Stone Symetra Life Insurance Company Senior Counsel 777 108th Ave NE, Suite 1200 Bellevue, Washington 98004

Approximate date of Proposed Public Offering: As Soon as Practicable after Effective Date of this registration statement

The Registrant hereby amends this registration statement on such dates as may be necessary to delay its effective date until the Registrant shall file a further amendment which specifically states that this registration statement shall thereafter become effective in

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document accordance with Section 8(a) of the Securities Act of 1933 or until the registration statement shall become effective on such date as the Commission, acting pursuant to said Section 8(a), may determine.

Title of securities being registered: Units of interest in a separate account under individual flexible premium variable life policies.

ACCUMULATOR VARIABLE UNIVERSAL LIFE Issued through: SYMETRA SEPARATE ACCOUNT SL (the "Variable Account") By SYMETRA LIFE INSURANCE COMPANY

This prospectus describes Accumulator Variable Universal Life, a flexible premium adjustable variable life insurance policy (“Policy”), offered by Symetra Life Insurance Company (“Symetra Life,” the “Company,” “We,” “Us” or “Our”).

As permitted by regulations adopted by the Securities and Exchange Commission effective January 1, 2021, paper copies of the shareholder reports for the Funds available under Your Policy will not be sent by mail, unless You specifically request paper copies of the reports from Us. Instead, the reports will be made available on a website, and You will be notified by mail each time a report is posted and provided with a website link to access the report. You may elect to receive all future reports in paper free of charge. You can inform Us that You wish to continue receiving paper copies of Your shareholder reports by calling 1-800-796-3872. Your election to receive reports in paper will apply to all Funds available under Your Policy.

Before investing, please read this prospectus carefully, along with the accompanying prospectuses for the Funds, and keep them for future reference. This prospectus does not constitute an offering in any jurisdiction in which the Policy may not lawfully be sold. Additional information about certain investment products, including variable life insurance, has been prepared by the SEC’s staff and is available at Investor.gov.

If You are a new investor in the Policy, You may cancel Your Policy within 10 days of receiving it without paying fees or penalties (the "Cancellation Period"). In some states this Cancellation Period may be different. See APPENDIX B: STATE VARIATIONS. Upon cancellation, You will receive a refund of the premium payments made, minus any loans taken. You should review this prospectus, or consult with Your investment professional (all references to "investment professionals" shall by definition include registered representatives), for additional information about the specific cancellation terms that apply.

The Policies are not deposits or obligations of, or guaranteed or endorsed by, any financial institution and are not federally insured by the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other agency.

Neither the SEC nor any state securities commission has approved or disapproved of these securities or determined if this prospectus is accurate or complete. Any representation to the contrary is a criminal offense.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document TABLE OF CONTENTS Page DEFINITIONS 1 KEY INFORMATION 3 OVERVIEW OF THE POLICY 5

FEE TABLE 7

POLICY DIAGRAM 10 PRINCIPAL RISKS OF INVESTING IN THE POLICY 11 POLICY RISKS 11 SYMETRA LIFE, SYMETRA SEPARATE ACCOUNT SL, THE GENERAL ACCOUNT, THE FIXED 12 ACCOUNT AND THE FUNDS

SYMETRA LIFE 12

SYMETRA SEPARATE ACCOUNT SL 12 THE GENERAL ACCOUNT 13 THE FIXED ACCOUNT 13

THE FUNDS 13 VOTING RIGHTS 13 CHARGES AND FEES 14 PREMIUM CHARGE 14 MONTHLY DEDUCTION 14

SURRENDER CHARGE 15

WITHDRAWAL PROCESSING FEE 16

TRANSFER PROCESSING FEE 16

INTEREST CREDITED ON LOAN COLLATERAL 16

TAXES 16 COMMISSIONS PAID TO BROKER-DEALERS 16 FUND EXPENSES 17

VARIATION IN CHARGES 17

PURCHASING A POLICY 17

INITIAL PREMIUM PAYMENT 17

CANCELLATION PERIOD 17

OWNERSHIP RIGHTS 17

PREMIUMS 19

PLANNED PERIODIC PAYMENTS 20

ADDITIONAL PREMIUMS 20

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document TABLE OF CONTENTS Page ALLOCATION OF NET PREMIUM PAYMENTS AND POLICY VALUE 20

CALCULATION OF POLICY VALUE 21

VARIABLE POLICY VALUE 21

UNITS 21

FIXED POLICY VALUE 21

TRANSFER OF POLICY VALUE 22

TRANSFER TRANSACTIONS AVAILABLE 22 SCHEDULED TRANSFERS 22 LIMITS ON EXCESSIVE TRANSFERS AND MARKET TIMING ACTIVITY 23

DEATH BENEFIT 24

DEATH BENEFIT PROCEEDS 24

DEATH BENEFIT OPTIONS 25 CHANGES IN DEATH BENEFIT OPTION 25 DECREASING THE SPECIFIED AMOUNT 26 OTHER BENEFITS AVAILABLE UNDER THE POLICY 26 ACCELERATED DEATH BENEFIT FOR CHRONIC ILLNESS RIDER 27

ACCELERATED DEATH BENEFIT FOR CHRONIC ILLNESS PLUS RIDER 27

ACCELERATED DEATH BENEFIT FOR TERMINAL ILLNESS RIDER 27

CHARITABLE GIVING BENEFIT RIDER 28 OVERLOAN LAPSE PROTECTION RIDER 28 SUPPLEMENTAL PROTECTION RIDER 29 SURRENDER VALUE ENHANCEMENT RIDER 29 WAIVER OF MONTHLY DEDUCTIONS RIDER 29 ACCESS TO YOUR POLICY VALUE 29

LOANS 29

WITHDRAWALS 30

SURRENDER 31

CONSEQUENCES OF LOANS, WITHDRAWALS AND SURRENDERS 31 TRANSACTION AUTHORITY 32 POLICY LAPSE AND REINSTATEMENT 32

TAXES 33

TAX STATUS OF THE POLICY 33

INVESTOR CONTROL 33

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document TABLE OF CONTENTS Page MODIFIED ENDOWMENT CONTRACTS 34

DISTRIBUTIONS (OTHER THAN DEATH BENEFITS) FROM MODIFIED ENDOWMENT 34 CONTRACTS DISTRIBUTIONS (OTHER THAN DEATH BENEFITS) FROM POLICIES THAT ARE NOT MODIFIED 34 ENDOWMENT CONTRACTS POLICY LOANS 35

CONTINUATION BEYOND AGE 100 35

TAX WITHHOLDING 35

BUSINESS USE OF THE POLICY 35

NON INDIVIDUAL OWNERS AND BUSINESS BENEFICIARIES OF THE POLICY 36

EMPLOYER OWNED LIFE INSURANCE POLICIES 36

TAX SHELTER REGULATIONS 36

OTHER TAX CONSIDERATIONS 36

MEDICARE TAX ON INVESTMENT INCOME 36

LIFE INSURANCE PURCHASES BY RESIDENTS OF PUERTO RICO 36

LIFE INSURANCE PURCHASES BY NON-RESIDENT ALIENS AND FOREIGN CORPORATIONS 37

POSSIBLE TAX LAW CHANGES 37

OUR INCOME TAXES 37

OTHER INFORMATION ABOUT THE POLICY 37

POLICY MATURITY 37

SETTLEMENT OPTIONS 37

PAYMENTS WE MAKE 38

MISSTATEMENT OF AGE OR GENDER 38 REPORTS TO POLICY OWNERS 38 POLICY TERMINATION 39

ASSIGNMENT 39

DISTRIBUTION OF THE POLICIES 39

DISTRIBUTION 39

STATE VARIATIONS 40

GOOD ORDER 40

UNCLAIMED OR ABANDONED PROPERTY 40

LEGAL PROCEEDINGS 40

FINANCIAL STATEMENTS 40 APPENDIX A: PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY A-1

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document TABLE OF CONTENTS Page APPENDIX B: STATE VARIATIONS B-1 APPENDIX C: OPTIONAL BENEFIT EXAMPLES C-1 PROSPECTUS BACK COVER Back Page

DEFINITIONS

Accumulated No Lapse Guarantee Premium: An amount equal to the sum of the No Lapse Guarantee Premiums for each month since the Issue Date.

Adjusted Premium: An amount equal to the sum of all premiums received since the Issue Date minus any withdrawals, and minus the Loan Amount.

Administrative Office: Either the Company’s mailing address for general correspondence and Written Notices (P.O. Box 34690, Seattle, Washington 98124), or the Company’s mailing address for premium payments after the Policy is issued (P.O. Box 34815, Seattle, Washington 98124).

Attained Age: The Insured’s age as of the nearest birthday on the Policy Date, plus the number of complete Policy Years since the Policy Date.

Beneficiary: The person or persons to whom the Death Benefit Proceeds are paid upon the death of the Insured. The Owner may designate primary, contingent and irrevocable Beneficiaries. A primary or Contingent Beneficiary named on the application may be changed as provided in the Policy.

Death Benefit: The amount payable to the Beneficiary, before adjustment for riders, loans and certain deductions, if the Insured dies while the Policy is in force.

Fixed Account: Part of the Company’s General Account to which Policy Value may be transferred or Net Premium Payments may be allocated under a Policy.

Fixed Policy Value: The Policy Value in the Fixed Account.

Fund: Any open-end management investment company or investment portfolio thereof, or unit investment trust or series thereof, in which a Subaccount invests.

General Account: The assets of the Company other than those allocated to the Variable Account or any other separate account of the Company.

Initial Premium Payment: The amount that the Owner pays before the Policy is issued.

Initial Specified Amount: The Specified Amount on the Issue Date.

Insured: The individual whose life is insured by the Policy. The Owner can be, but does not have to be, the same as the Insured.

Issue Age: The Insured’s age as of the nearest birthday on the Policy Date.

Issue Date: The date the Policy is issued and coverage begins under the Policy. The Policy is considered to be “in force” starting on the Issue Date.

Lapse: Termination of the Policy, without value, at the expiration of a Grace Period while the Insured is still living and before the Maturity Date.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Loan Account: A portion of the Company’s General Account to which Variable Policy Value or Fixed Policy Value is transferred to provide collateral for any loan taken under the Policy.

Loan Account Value: The Policy Value in the Loan Account.

Loan Amount: At any time other than a Policy Anniversary, the Loan Account Value plus any interest charges accrued on the Loan Account Value up to that time. On the Policy Anniversary, the Loan Amount equals the Loan Account Value.

Monthly Anniversary Day: The same day as the Policy Date for each succeeding month. Whenever the Monthly Anniversary Day falls on a date other than a Valuation Day, the Monthly Anniversary Day will be deemed to be the immediately succeeding Valuation Day.

Net Amount at Risk: As of any Monthly Anniversary Day, the Death Benefit (discounted for the upcoming month) minus the Policy Value (before deducting the Monthly Deduction).

Net Premium Payment: The premium payment minus any premium charge.

Net Surrender Value: The Surrender Value minus any Loan Amount.

No Lapse Guarantee Period: Any period when the Adjusted Premium is greater than or equal to the Accumulated Minimum Monthly Premium prior to the Lapse Protection expiry date shown on the Policy specifications page.

Owner (You, Your): The person (or persons) who owns (or own) the Policy and who is (are) entitled to exercise all rights and privileges provided in the Policy. Ownership may be transferred, as provided in the Policy. Following a transfer of ownership, “You” and “Your” will refer to the new Owner. Singular references to Owner include all Owners if there is more than one. In the case of joint Owners, references to actions by the Owner shall mean all Owners acting jointly.

Planned Periodic Payment: The premium payment selected by the Owner that he or she (or they) plan(s) to pay on a monthly, quarterly, semi-annual, or annual basis over the life of the Policy.

Policy Anniversary: The same date in each Policy Year as the Policy Date.

Policy Date: The date used to determine the Issue Age. The Policy Date may be the Issue Date or any date up to six months prior to the Issue Date. Policy Years, Policy months, and Policy Anniversaries are measured from the Policy Date. The Policy Date is never the 29th, 30th or 31st of a month.

Policy Value: The sum of the Variable Policy Value, the Fixed Policy Value and the Loan Account Value.

Policy Year: A twelve-month period beginning on the Policy Date or on a Policy Anniversary.

Specified Amount: A dollar amount selected by the Owner that is used to determine the amount of the Policy’s Death Benefit. The Initial Specified Amount is shown in Your Policy. The actual amount We pay on the death of the Insured may be affected by tax law requirements and may be adjusted as described in the Policy.

Subaccount: A subdivision of the Variable Account, the assets of which are invested in a corresponding Fund.

Subaccount Value: The Policy Value in a Subaccount.

Surrender Value: The Policy Value minus any applicable surrender charge.

Unit: A unit of measure used to compute Subaccount Value.

Valuation Day: For each Subaccount, each day on which the New York Stock Exchange is open for business except for certain holidays listed in the prospectus for the Policy and days that a Subaccount’s corresponding Fund does not value its shares.

Valuation Period: The period that starts at the close of regular trading on the New York Stock Exchange on any Valuation Day and ends at the close of regular trading on the next succeeding Valuation Day.

Written Notice: A written notice or request in a form satisfactory to the Company that is signed and dated by the Owner and received at Our Administrative Office. Alternatively, an instruction to the Company by the Owner on the Company’s website through the Owner’s online account pursuant to protocols established by the Company.

KEY INFORMATION

Important information You should consider about the Policy.

FEES AND EXPENSES Charges for Early We will deduct a surrender charge if You surrender Your Policy during the first For more information, see Withdrawals nine (9) Policy Years. The surrender charge is assessed per $1,000 of Initial SURRENDER CHARGE. Specified Amount. The maximum surrender charge is $57.96 per $1,000 of Initial Specified Amount. If You surrender Your Policy during the first nine (9) Policy Years, You could pay a surrender charge of up to $5,796 on a $100,000 Initial Specified Amount.

Upon each withdrawal, We may charge a $25 Withdrawal Processing Fee. This charge is currently waived.

Transaction Charges In addition to surrender charges, You may also be charged for other transactions. For more information, see • A Premium Charge will apply to each Premium made to Your Policy. CHARGES AND FEES. • A Transfer Processing Fee of $25 may apply upon each transfer in excess of 24 transfers in a Policy Year. This charge is currently waived.

Ongoing Fees and In addition to surrender charges and transaction charges, an investment in the For more information, see Expenses (annual Policy is subject to certain ongoing fees and expenses, including fees and CHARGES AND FEES. charges) expenses covering the cost of insurance under the Policy and the cost of optional benefits available under the Policy. These fees and expenses are set based on characteristics of the insured such as Attained Age, Issue Age, Risk Class of the Insured, and if permitted by state law, sex. You should view the Policy specifications page of Your Policy for rates applicable to Your Policy.

You will also bear expenses associated with the Funds made available under the Policy. For the fiscal year ended December 31, 2020, the minimum and maximum total operating expenses were as follows:

Annual Fees Minimum Maximum Fund Fees and Expenses 0.10% 0.36%

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document RISKS Risk of Loss You may lose money by investing in the Policy. For more information, see PRINCIPAL RISKS OF INVESTING IN THE POLICY

Not a Short-Term The Policy is not suitable as a short-term savings vehicle and, therefore, may not For more information, see Investment be the right kind of policy if You plan to withdraw money or surrender the Policy PRINCIPAL RISKS OF for short term needs. You may pay substantial charges if You surrender Your INVESTING IN THE Policy. POLICY

Risks Associated with Investment in the Policy is subject to the risk of poor investment performance of For more information, see Investment Options the Funds and can vary depending on the performance of the Funds available PRINCIPAL RISKS OF under the Policy. Each Fund and the Fixed Account has its own unique risk. You INVESTING IN THE should review these investment options before making an investment decision. POLICY

RISKS Insurance Company Investment in the Policy is subject to the risks related to Symetra Life. Any For more information, see Risks obligations, including obligations related to the Fixed Account, guarantees and THE GENERAL benefits provided for under the Policy are subject to Our financial strength and ACCOUNT. claims paying ability. More information about Us, including Our financial strength ratings, is available upon request by calling 1-800-796-3872, or visiting Us at www.symetra.com/regulatoryreports.

Policy Lapse The Policy will Lapse if the Net Surrender Value is not sufficient to cover the For more information, see Monthly Deduction due and the Policy is not in a No Lapse Guarantee Period. POLICY LAPSE AND This could happen due to poor Subaccount investment performance, withdrawals, REINSTATEMENT. and unpaid loans and loan interest. The Death Benefit will not be paid if a Policy Lapses.

We will reinstate a Lapsed Policy only if our requirements for reinstatement are satisfied, including as to continued insurability of the Insured Person, and You will incur costs in connection with any reinstatement.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document RESTRICTIONS Investments You may allocate amounts under the Policy to one or more of the Subaccounts For more information, see and to the Fixed Account. APPENDIX A: PORTFOLIO We reserve the right to add, combine, restrict, or remove any Subaccount as an COMPANIES AVAILABLE investment option under Your Policy. We further reserve the right to restrict or UNDER THE POLICY. remove the Fixed Account as an investment option available under the Policy. Optional Benefits Accelerated Death Benefit for Chronic Illness Rider For more information, see This rider may not be exercised if You have exercised the Accelerated Death OTHER BENEFITS Benefit for Terminal Illness Rider.We may modify or stop offering this rider at AVAILABLE UNDER THE any time. POLICY.

Accelerated Death Benefit for Chronic Illness Plus Rider This rider may not be exercised if You have exercised the Accelerated Death Benefit for Terminal Illness Rider. We may modify or stop offering this rider at any time.

Accelerated Death Benefit for Terminal Illness Rider This rider may not be exercised if You have exercised the Accelerated Death Benefit for Chronic Illness or the Accelerated Death Benefit for Chronic Illness Plus Rider. We may modify or stop offering this rider at any time.

Overloan Lapse Protection Rider This rider is only exercisable after Attained Age 75 and once the Policy has been in force for 15 completed Policy Years. Your Policy must utilize the Guideline Premium Test for Life Insurance and cannot be a Modified Endowment Contract at the time of exercise. Once exercised, Your Variable Policy Value will be transferred to the Fixed Account. We may modify or stop offering this rider at any time.

Waiver of Monthly Deductions Rider This rider is only available if total disability, as defined in the rider, begins prior to Attained Age 65 and has existed continuously for at least 6 months. We may modify or stop offering this rider at any time.

TAXES Tax Implications You should consult a competent tax professional before purchasing the Policy to For more information, see determine the tax implications of an investment in the Policy. TAXES.

Withdrawals may be subject to ordinary income tax and may be subject to additional taxes.

Lapse of a Policy on which there is an outstanding loan may have adverse tax consequences.

CONFLICTS OF INTEREST Investment Investment professionals who solicit sales of the policies receive a portion of For more information, see Professional the commission payable to the broker-dealer firm, depending on the agreement DISTRIBUTION. Compensation between the broker-dealer and the investment professional. We pay commissions as a percentage of premiums invested in the Policy.

An investment professional may receive different compensation for selling different investment products and may have a financial incentive to offer or recommend the Policy over another investment product. Exchanges An investment professional may have a financial incentive to offer You a new For more information, see policy in the place of a policy You already own. DISTRIBUTION.

You should not exchange this Policy for a new one unless You determine, after comparing the features fees and risks of both policies, that the exchange is preferable for You.

OVERVIEW OF THE POLICY

The Policy can be used for insurance protection and estate planning, as well as for other long-term financial goals. You should consider the Policy in conjunction with other insurance You own. It is designed to help meet long-term financial objectives. This Policy may be appropriate if You have a long investment time horizon and are looking to maximize the Death Benefit available to Your Beneficiaries after Your (or another insured’s) death.

Premiums. If the Insured is between the ages of 0 to 85, You may purchase a Policy and begin submitting premium payments. You may establish a schedule of monthly, quarterly, semi-annual or annual premium payments, but You are not required to pay premiums according to the schedule. You can change the frequency and amount of, skip, or make unplanned, premium payments. Payment of insufficient premiums may result in a Lapse of the Policy. However, failing to pay premiums, alone, will not cause the Policy to Lapse, and paying planned premiums will not guarantee that the Policy will remain in force. For more information, see PREMIUMS.

We reserve the right, at any time and without prior notice, to limit the amount or frequency of premium payments or refuse to accept a premium payment under the Policy.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Investment Options. You may allocate Your Net Premium Payments and Policy Value to one or more of the Subaccounts, each of which invests in a designated Fund. You may also allocate Net Premiums or Policy Value to the Fixed Account, which credits interest at a rate not less than the guaranteed interest rate.

A discussion of each Fund available as an investment option under the Policy can be found in APPENDIX A: PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY.

Death Benefit. The primary benefit of this Policy is life insurance coverage. For more information, see DEATH BENEFIT.

No Lapse Guarantee. Your Policy has a no lapse guarantee that provides a period of time where Your Policy will not enter the Grace Period even if Your Net Surrender Value is insufficient to cover the Monthly Deduction due. In addition, Your Policy includes riders that will help You manage some of the risk of Policy Lapse. The Overloan Lapse Protection Rider will prevent a Policy from lapsing due to insufficient Policy Value, as long as certain conditions are met. In addition, You can elect to add a Waiver of Monthly Deductions Rider that will help prevent the Policy from lapsing during a period of total disability, as

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Table of Contents Definitions defined in the rider. For more information on these and other riders, see OTHER BENEFITS AVAILABLE UNDER THE POLICY.

Access to Your Policy Value. Subject to certain restrictions, You can access the money in Your Policy by taking a loan against Your Net Surrender Value, making withdrawals after the first Policy Year, and by surrendering Your Policy for the Net Surrender Value. In addition, You can transfer Policy Value between or among any of the Subaccounts and the Fixed Account.

Supplemental Benefits and Riders. The Policy offers the following riders that provide supplemental benefits under the Policy.

1. Accelerated Death Benefit for Chronic Illness Rider 2. Accelerated Death Benefit for Chronic Illness Plus Rider 3. Accelerated Death Benefit for Terminal Illness Rider 4. Charitable Giving Benefit Rider 5. Overloan Lapse Protection Rider 6. Supplemental Protection Rider 7. Surrender Value Enhancement Rider 8. Waiver of Monthly Deductions Rider

An additional charge or fee upon exercising the benefit may apply to optional riders. For more information, see OTHER BENEFITS AVAILABLE UNDER THE POLICY.

FEE TABLE

The following tables describe the fees and charges that You will pay (directly or indirectly) when buying, owning and surrendering or making withdrawals from Your Policy. If the amount of the charge depends on the personal characteristics of the Insured, the fee table lists the minimum and maximum charges We assess under the Policy, as well as the fees and charges of a typical Insured, with the characteristics set forth in the table. These fees and charges may not be typical of the fees and charges that You will pay. Please refer to Your Policy for information about the specific fees You will pay each year based on the options You have elected.

The first table describes the fees and charges that You will pay at the time You buy the Policy, pay premiums, make withdrawals from the Policy, surrender the Policy, or transfer Policy Value among the Subaccounts and (if available) the Fixed Account.

TRANSACTION FEES

Charge When Charge is Deducted Amount Deducted

PREMIUM CHARGE Upon payment of each premium 20% Guaranteed Maximum Charge

SURRENDER CHARGE (1)(2) At the time of any surrender during the first 9 Policy Years

Minimum and Maximum Charge Minimum charge is $3.78 and maximum charge is $57.96 per $1,000 of Initial Specified Amount

Charge for 45-year old Male Super Preferred Charge is $37.39 per $1,000 of Initial Non-Tobacco user (3) Specified Amount

WITHDRAWAL PROCESSING FEE (4) Upon each withdrawal $25

TRANSFER PROCESSING FEE (4) Upon each transfer in excess of 24 transfers $25 in a Policy Year

ADDITIONAL ILLUSTRATION CHARGE (4) Upon request for more than one illustration in $25 a Policy Year

(1) A surrender charge is deducted if the Owner surrenders the Policy during the first 9 Policy Years. This charge varies by Policy duration and the Issue Age, and if permitted by state law, the sex of the Insured. (2) If You have elected the Surrender Value Enhancement Rider, an alternate Surrender Charge schedule will apply. See the Periodic Charges Other Than Annual Fund Expenses below. (3) The rates shown are for a 45-year-old male super preferred non-tobacco user for the first Policy Year only. The rates will change each Policy Year thereafter to reflect the Insured’s Attained Age. For more information on the rate that would apply to You, please contact Your investment professional or Us at our Administrative Office. (4) The charge shown is the maximum charge. This charge is currently waived.

The next table describes the fees and charges that You will pay periodically during the time that You own the Policy, not including Portfolio Company fees and expenses.

PERIODIC CHARGES OTHER THAN ANNUAL FUND EXPENSES

Cost of Insurance (without extra ratings) (1) On the Policy Date and on each Monthly (2) Anniversary Day

Minimum and Maximum Charge Minimum charge is $0.01 and maximum charge is $83.33 per $1,000 of Net Amount at Risk

Charge for 45-year-old Male Super Preferred Charge is $0.21 per $1,000 of Net Amount at Non-Tobacco user (3) Risk

Variable Policy Value Charge On the Policy Date and on each Monthly For All Policy Years: 0.1% of Variable Policy (As a % of Variable Policy Value) Anniversary Day Value

Expense Charge On the Policy Date and on each Monthly Anniversary Day

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Charge When Charge is Deducted Amount Deducted Minimum and Maximum Charge Minimum charge is $0.21 and maximum charge is $8.83 per $1,000 of Initial Specified Amount

Charge for 45-year-old Male Super Preferred Charge is $1.28 per $1,000 of Initial Specified Non-Tobacco user (3) Amount

Administrative Charge On the Policy Date and on each Monthly $60 Guaranteed Maximum Charge Anniversary Day

OPTIONAL BENEFIT CHARGES

Accelerated Death Benefit for Chronic Illness On the Policy Date and on each Monthly Plus Rider Anniversary Day

Minimum and Maximum Charge Minimum charge is $0.00 and maximum charge is $22.65 per $1,000 of Net Amount at Risk

Charge for 45-year-old Male Super Preferred For Policy Year 1 Charge is $0.13 per $1,000 of Net Amount at Non-Tobacco user (3) Risk

Overloan Lapse Protection Rider At the time of exercise

Minimum and Maximum Charge Minimum charge is 4.50% and maximum charge is 5.00% of Policy Value at the time of exercise

Charge for 45-year-old Male Super Preferred At Attained Age 75 Charge is 4.50% of Policy Value at the time of Non-Tobacco user (3) exercise

Supplemental Protection Rider On the Policy Date and on each Monthly Anniversary Day

Minimum and Maximum Charge Minimum charge is $0.1 and maximum charge is $83.33 per $1,000 of Net Amount of Risk

Charge for 45-year-old Male Super Preferred Charge is $0.21 per $1,000 Net Amount of Risk Non-Tobacco user (3)

Surrender Value Enhancement Rider On the Policy Date $500

Surrender Charge under the Surrender Value At the time of any surrender during the first 9 Enhancement Rider Policy Years

Minimum and Maximum Charge Minimum charge is $1.95 and maximum charge is $39.96 per $1,000 of Initial Specified Amount

Charge for 45-year-old Male Super Preferred Charge is $3.73 per $1,000 of Initial Specified Non-Tobacco user (3) Amount

Waiver of Monthly Deduction Rider On the Policy Date and on each Monthly Anniversary Day

Minimum and Maximum Charge Minimum charge is $0.60 and maximum charge is $34.30 per $100 of benefit amount

Charge for 45-year-old Male Super Preferred Charge is $8.46 per $100 of benefit amount Non-Tobacco user (3)

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (1) Current cost of insurance rates vary and may change based on a number of factors. See “Monthly Cost of Insurance Charge” in CHARGES AND FEES. The cost of insurance charges shown in the table likely do not represent the charges You will pay. For more information on the cost of insurance charge that would apply to You, please contact Your investment professional or Us at our Administrative Office.

(2) We may place an Insured in a substandard Risk Class with extra ratings that reflect higher mortality risks and that result in higher cost of insurance rates. For certain Risk Classes, We may add a surcharge to the cost of insurance rates.

(3) The rates shown are for a 45-year-old male super preferred non-tobacco user for the first Policy Year on Face Amounts over $1 million. The rates will change each Policy Year thereafter to reflect the Insured’s Attained Age. For more information on the rate that would apply to You, please contact Your investment professional or Us at our Administrative Office.

ANNUAL FUND EXPENSES

The Total Annual Fund Expense Table shows the minimum and maximum total operating expenses (before any fee waiver or expense reimbursement) charged by any of the Funds that You may pay periodically during the time You own a Policy. These expenses may be different in the future. A complete list of Funds available under the Policy, including their annual expenses, may be found at the back of this document in APPENDIX A: PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY.

Total Annual Fund Expenses Minimum Maximum

Total Annual Fund Expenses (total of all expenses that are deducted from Fund 0.10% 0.36% assets, including management fees, distribution (12b-1) fees and other expenses)

POLICY DIAGRAM

PRINCIPAL RISKS OF INVESTING IN THE POLICY

POLICY RISKS

Investment Risk. You may allocate Your Policy Value to one or more of the Subaccounts, each of which invests in a designated Fund. Depending upon market conditions, You can make or lose Policy Value in any of these Subaccounts; Your Policy Value will increase or decrease as a result of investment performance. If investment performance is very poor, You could lose everything that You invest and Your Policy could Lapse without value. There is no assurance that any Fund will achieve its stated objective.

Risk of Lapse. Net Premiums that do not offset prior Monthly Deductions, poor Subaccount investment performance, withdrawals, and unpaid loans and loan interest, may cause a Policy to Lapse, which means that You will no longer have insurance coverage. If the Overloan Lapse Protection Rider is exercised, Your Policy will not lapse due to insufficient Policy Value as long as the requirements of that Rider are met. If You have elected the Waiver of Monthly Deductions Rider, We will waive the Monthly Deductions while the Insured is totally disabled, as defined in the rider. This will help ensure that the Policy does not lapse during a period of total disability. Unless Your Policy is in a No Lapse Guarantee Period,Your Policy will remain in force only as long as the Net Surrender Value is sufficient to cover Your Monthly Deductions. A Policy Lapse may have adverse tax consequences.

Risk of Withdrawals or Surrender. The Policy is designed to help meet long-term financial objectives by paying a Death Benefit to the named Beneficiary(ies). The Policy is not suitable as a short-term savings vehicle and, therefore, may not be the right kind of policy if You plan to withdraw money or surrender the Policy for short-term needs. You may pay substantial charges or additional taxes if You surrender or make withdrawals from Your Policy. Please discuss Your insurance needs and financial objectives with Your investment professional.

Risk of an Increase in Current Fees and Charges. Certain fees and charges are currently assessed at less than their guaranteed maximum levels. In the future, these charges may be increased up to the guaranteed maximum levels. If fees and charges are increased, You may need to increase the amount and/or frequency of premiums to keep the Policy in force. Because of its fees and charges, it may not provide as great a growth in Policy Value as some other variable universal life insurance policies on the market today.

Risk of Loans. There are risks involved in taking a Policy loan, including possible adverse tax consequences. For example, if Your Policy is a MEC, the loan may be taxable and may be subject to a 10% additional tax. If a loan is outstanding and Your Policy Lapses, the amount of any unpaid loans will be treated as a distribution and will be taxable to the extent of gain in the Policy. See “Modified Endowment Contracts” in TAXES for more information. You should consult a tax professional before taking out a Policy loan.

Risks of Limited Access to Cash Value. Withdrawals are not available in the first policy year; however, full surrenders are permitted. We reserve the right to reject a withdrawal request that would cause the Specified Amount of a Policy to be reduced below a minimum amount shown in Your Policy. The minimum withdrawal is $250 and the maximum withdrawal is Your Net Surrender Value minus three months' worth of Policy charges. There may be little to no cash value available for loans and withdrawals in the Policy’s early years.

Risk of Adverse Tax Consequences. Certain transactions (including, but not limited to, withdrawals, surrenders and loans) may lead to a taxable event. Under certain circumstances, Your Policy may become a “Modified Endowment Contract” (MEC). Under federal tax law, loans, collateral assignments, withdrawals, and other pre-death distributions received from a MEC Policy are taxed as income first and recovery of cost basis, second. Also, distributions includable in income received before You attain age 59½ may be subject to a 10% additional tax. Existing tax laws that benefit this policy may change at any time.

Risk of Limits Imposed on Transfers. We do not currently charge for transfers, but we reserve the right to charge up to $25 per transfer, after the first 24 transfers in a Policy Year. We have adopted procedures to limit excessive transfer activity. In addition, each Fund may restrict or refuse certain transfers among, or purchases of shares in their Portfolios as a result of certain market timing

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document activities. You should read each Fund’s prospectus for more details. The minimum amount You may transfer is $100. If, after the transfer, the amount remaining in the Subaccount(s) or the Fixed Account would be less than the minimum amount that may be transferred, We reserve the right to transfer the entire Subaccount Value or Fixed Policy Value instead of the requested amount. The maximum amount an Owner may transfer from the Fixed Account each Policy Year after the first Policy Year is the greater of (i) 25% of the Fixed Policy Value measured on the preceding Policy Anniversary and (ii)

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Table of Contents Definitions the total dollar amount transferred from the Fixed Account in the immediately preceding Policy Year. Due to this limit, it could take a number of years to fully transfer or withdraw a current balance from the Fixed Account. We may also limit the number of investment options to which you may transfer cash value, and, under certain conditions, we may have to approve transfers to the Fixed Account.

Risks Associated with the Company. Investment in the Policy is subject to the risks related to Symetra Life. Any obligations, including obligations related to the Fixed Account, guarantees, and benefits provided for under the Policy are subject to Our financial strength and claims paying ability. The assets of Our General Account support Our insurance and annuity obligations and are subject to Our general liabilities from business operations and to claims by Our creditors. Policy Value in the Fixed Account, plus any guarantees under the Policy that exceed Your Policy Value (such as those that may be associated with the Death Benefit), are paid from Our General Account. We maintain a minimum amount of capital in excess of assets that offset reserves, which acts as a cushion in the event that we suffer financial impairment, based on certain risks in Our operations. For the Company, such risks include those associated with losses that We may incur as the result of defaults on the payment of interest or principal on assets held in Our General Account, which include bonds, loans secured by mortgages, and equity securities, as well as the loss in value of these investments resulting from a loss in their market value.

SYMETRA LIFE, SYMETRA SEPARATE ACCOUNT SL, THE GENERAL ACCOUNT, THE FIXED ACCOUNT, AND THE FUNDS

SYMETRA LIFE Symetra Life Insurance Company provides individual and group life, accident and health insurance, and annuity products and is licensed to do business in the District of Columbia, Puerto Rico and all states except New York. Our Home Office is located at 777 108th Avenue NE, Bellevue, Washington 98004.

SYMETRA SEPARATE ACCOUNT SL The Variable Account is divided into Subaccounts, each of which invests in the shares of a specific Fund. These Subaccounts buy and sell Fund shares at net asset value without any sales charge. Any dividends and distributions from a Fund are reinvested at net asset value in shares of that Fund.

Under Iowa law, the assets in the Variable Account are the property of Symetra Life. Variable Account assets are held separately from Symetra Life’s other assets and are not part of Our General Account. Variable Account assets may not be used to pay any of Our liabilities other than those arising from the Policies and other variable life insurance policies We issue through the Variable Account. Income, gains and losses realized or unrealized from the assets allocated to a Subaccount are credited to or charged against such Subaccount without regard to other income, gains or losses of Symetra Life. If the Variable Account’s assets exceed the required reserves and other liabilities, We may transfer the excess to Our General Account.

Promises We make in the Policy are general obligations of Symetra Life and are not dependent on assets in the Variable Account.

Changes to the Variable Account. Where permitted by applicable law, We reserve the right to make certain changes to the structure and operation of the Variable Account, which may include:

• Transferring assets supporting the Policies from one Subaccount to another or from the Variable Account to another separate account; • Removing, combining, or adding Subaccounts, and making the combined or added Subaccounts available for allocation of premium payments; • Closing certain Subaccounts to allocations of new premium or transfer of Policy Value by existing or new Owners;

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document • Substituting shares of a Fund, which may have different fees and expenses, for shares of a Fund in which a Subaccount currently invests; • Combining the Variable Account with other separate accounts and/or creating new separate accounts; • Deregistering the Variable Account under the 1940 Act, or operating the Variable Account or any Subaccount as a management investment company, or as any other form permitted by law; • Managing the Variable Account under the direction of a committee at any time; • Making any changes required by applicable law or regulation; and • Modifying the provisions of the Policy to reflect changes to the Subaccounts and the Variable Account and to comply with applicable law.

We will notify You of any changes. We reserve the right to make other structural and operational changes affecting the Variable Account.

THE GENERAL ACCOUNT The Fixed Account is part of Symetra Life’s General Account. Unlike premium payments and Policy Value allocated to the Variable Account, We assume the risk of investment gain or loss on amounts held in the Fixed Account. The assets of the General Account may be used to pay the claims of any of Our policy owners as well as Our creditors. The General Account invests its assets in accordance with state insurance law.

The assets of Our General Account support Our insurance and annuity obligations and are subject to Our general liabilities from business operations and to claims by Our creditors. Policy Value in the Fixed Account, plus any guarantees under the Policy that exceed Your Policy Value (such as those that may be associated with the Death Benefit), are paid from Our General Account. The Company complies with State insurance laws and regulations require that life insurance companies, including the Company, to hold assets in its General Account equal to a special liability called “reserves” which, under such laws and regulations, are considered by the insurance regulators to be sufficient for the Company to meet its contractual obligations to policyholders. State insurance regulators also require life insurance companies to maintain a minimum amount of capital in excess of assets that offset reserves, which acts as a cushion in the event that the insurer suffers financial impairment, based on the specific risks in the insurer’s operations.

THE FIXED ACCOUNT The Fixed Account consists of assets owned by Symetra Life other than those in the Variable Account.

Policy Value in the Fixed Account will be credited with interest based on rates that are set by Us. The credited interest rates will never be less than the minimum shown in Your Policy. You bear the risk that the rate of interest that We credit will not exceed that minimum. We may declare more than one interest rate for different money based upon the date of allocation or transfer to the Fixed Account. For purposes of crediting interest, Policy Value deducted, transferred or withdrawn from the Fixed Account is accounted for on a “first-in, first-out” basis.

Net Premium is placed in the Fixed Account during the Cancellation Period. See "Cancellation Period” in PURCHASING A POLICY for more information. We reserve the right to restrict or remove the Fixed Account as an investment option available under the Policy.

Interests in the Fixed Account are not securities and therefore Our offering of such interests pursuant to the Policies has not been registered with the SEC.

THE FUNDS Each Subaccount of the Variable Account invests in shares of a corresponding Fund. A description of the Funds available under the Policy, including each Fund’s type, name, investment advisor and any sub-advisor, current expenses and performance is available under APPENDIX A: PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY.

You can also find more detailed information about the Funds in the Fund prospectuses. You can obtain free copies of the Fund prospectuses by contacting Us at 1-800-796-3872 or by visiting www.symetra.com/regulatoryreports. You should read the Fund prospectuses carefully. If You received a summary prospectus for a Fund listed below, please follow the directions on the first page of the summary prospectus to obtain a copy of the full prospectus.

VOTING RIGHTS Symetra Life is the owner of the Funds’ shares. However, when a Fund solicits proxies in connection with a shareholder vote, We will ask You for instructions as to how to vote those shares attributable to Your Variable Policy Value indirectly invested in that Fund. Before a vote of a Fund’s shareholders occurs, You will receive voting materials in accordance with the procedures established by the Fund.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document You will have the right to instruct Us on the number of Fund shares that corresponds to the amount of Policy Value that You have in that Fund. Your number of votes is calculated separately for each Subaccount and may include fractional votes.

We vote Fund shares for which no timely instructions are received from Owners in proportion to the voting instructions that are received from other Owners with respect to that Fund. For this reason, a small number of Owners may control the outcome of a vote. Should We determine that We are permitted by law to do so, We will vote the shares in Our own right. You have no voting rights with respect to values in the Fixed Account.

Disregard of Voting Instructions. Symetra Life may, when required to do so by state insurance authorities, vote shares of the Funds without regard to instructions from Owners if such instructions would require the shares to be voted to cause any Fund to make (or refrain from making) investments which would result in changes in the sub classification or investment objectives of the Fund. Symetra Life may also disapprove changes in the investment policy initiated by the owners or trustees of the Funds. Symetra Life will disapprove such changes if it believes disapproval is reasonable and it determines in good faith that the change would:

• violate state or federal law; • be inconsistent with the investment objectives of the Funds; or • vary from the general quality and nature of investments and investment techniques used by other funds with similar investment objectives and underlying other variable policies offered by Symetra Life.

In the event that Symetra Life does disregard voting instructions, a summary of this action and the reasons for such action will be included in the next semi-annual or annual report to Owners.

CHARGES AND FEES

This section describes the charges and deductions that We make under the Policy in consideration for the services and benefits We provide, the costs and expenses We incur, and the risks We assume. We may profit from the charges and fees and We may use any such profits for any purpose, including payment of distribution expenses. The current and maximum guaranteed levels of the charges and deductions are presented in the Fee Table. We may, in our sole discretion, charge less than the maximum guaranteed levels.

In the determination and redetermination of any charges or fees described in this section, We, in Our sole discretion, may consider factors including, but not limited to: (a) Policy duration, (b) the sex, Attained Age, Issue Age and Risk Class of the Insured, (c) Our expectations as to future mortality experience, (d) Our expectations as to future Policy persistency experience, (e) taxes, (f) capital and reserve requirements, (g) investment earnings, (h) other expenses, and (i) Company profit objectives. We review charges and fees on an ongoing basis based on Our expectations as to factors (a) – (i) and other factors in Our sole discretion. In addition, changes in charges or fees are made on a uniform basis for Insureds of the same class as defined by Attained Age, Issue Age, Risk Class, Specified Amount, Policy duration, and if permitted by state law, sex. Charges and fees will never be greater than the Guaranteed charges and fees stated in Your Policy. This paragraph does not apply to the surrender charge, which is a guaranteed charge, described in this section below.

PREMIUM CHARGE Upon payment of each premium, We will deduct a premium charge before We allocate the Net Premium Payments to the Subaccounts or the Fixed Account. The guaranteed maximum premium charge is shown on the Policy specifications page. The premium charge compensates Us for certain sales expenses and state and federal tax liabilities associated with the Policies.

MONTHLY DEDUCTION Each month We will deduct an amount from Your Policy Value to pay for the benefits provided by Your Policy. This is referred to as the "Monthly Deduction" and consists of the:

• the monthly administrative charge; plus • the monthly expense charge; plus • the monthly cost of insurance charge; plus • the monthly Variable Policy Value charge; plus • the monthly cost of additional benefits provided by riders.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document We deduct this charge on the Policy Date and on each Monthly Anniversary Day thereafter until the Policy Anniversary nearest the Insured's 120th birthday ("Maturity Date"). We reduce Subaccount Values by liquidating Units and any Fixed Policy Value either in the proportion that each Subaccount Value and any Fixed Policy Value bears to the Policy Value (less any Loan Account Value), or as directed by the Owner. Because portions of the Monthly Deduction (such as cost of insurance) can vary, the Monthly Deduction will also vary. The guaranteed maximum amounts of these charges are shown on the Policy specifications page.

Monthly Administrative Charge. We deduct a monthly administrative charge from Your Policy Value to compensate Us for issue and administrative costs. The guaranteed maximum monthly administrative charge is shown on the Policy specifications page.

Monthly Expense Charge. We deduct a monthly expense charge from Your Policy to compensate Us for Our costs for sales, administration, capital, taxes, and a variety of other expenses. This charge is expressed as an amount per $1,000 of Initial Specified Amount. If the Specified Amount decreases, the monthly expense charge will not reflect the change in the Specified Amount. If the Specified Amount increases, Your Policy will incur an additional monthly expense charge based upon the Specified Amount increase and the insured’s Attained Age at that time.

Monthly Cost of Insurance Charge. The monthly cost of insurance charge depends upon a number of variables that cause the charge to vary from Policy to Policy and from month to month. The charge is computed as of the beginning of each Policy month and is equal to the cost of insurance rate multiplied by the Net Amount at Risk.

The "Risk Class" is a category in which each prospective Insured is placed by the Company as a result of underwriting the Owner's application. Risk Classes reflect the Company's assessment of the life expectancy of the Insureds in the class and will affect the cost of insurance rates. In determining underwriting classifications, We apply certain criteria that are based on an assessment of the Insured’s life expectancy. We currently place Insureds into preferred or standard Risk Classes: standard nicotine, preferred nicotine, standard non- nicotine, standard plus non-nicotine, preferred non-nicotine, super preferred non-nicotine. We also place Insureds in substandard Risk Classes with extra ratings that reflect higher mortality risks and will result in higher cost of insurance rates. Examples of reasons an Insured may be placed into a substandard Risk Class include (where permitted by state law), but are not limited to, medical history, avocation, occupation, driving record, or planned future travel.

The guaranteed rates for standard classes are based on the 2017 Commissioners' Standard Ordinary Composite Mortality Tables, and if permitted by state law, Male or Female ("2017 CSO Tables"). The guaranteed rates for substandard classes are based on multiples of or additions to the 2017 CSO Tables that are relevant to Your Policy. Cost of insurance rates for an Insured in a non-nicotine class are less than or equal to rates for an Insured of the same age and if permitted by state law, sex in a nicotine class.

For a better understanding of how the cost of insurance and other charges affect Policy Values, You should request a personalized illustration from Your investment professional.

Monthly Variable Policy Value Charge. We deduct a monthly charge as a percentage of Your Variable Policy Value. We may use revenue from this charge to cover a variety of types of expenses, including sales expenses.

If this charge, combined with other Policy fees and charges, does not cover Our total actual costs for services rendered and expenses incurred, We will absorb the loss. Conversely, if the charge covers more than Our actual costs, then the excess is a profit for Us. We expect to profit from this charge. The maximum monthly Variable Policy Value charge is shown on the Policy specifications page.

Monthly Cost of Additional Benefits Provided by Riders The Monthly Deduction will include any charges for certain supplemental benefits that You add to Your Policy by rider. See OTHER BENEFITS AVAILABLE UNDER THE POLICY for more information on rider charges.

SURRENDER CHARGE The surrender charge compensates Us for expenses incurred in connection with the sale of the Policy.

Your Policy will be issued with a surrender charge schedule. We will deduct a surrender charge if You surrender Your Policy during the first nine (9) Policy Years. This charge varies by Policy duration and by the Issue Age, and if permitted by state law, sex. The charge is also a function of the Initial Specified Amount. The surrender charge is assessed per $1,000 of Initial Specified Amount. If

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document a Policy is reinstated, the amount of the surrender charge is reinstated. See "Reinstatement" in POLICY LAPSE AND REINSTATEMENT for more information.

If the Specified Amount decreases, the surrender charge will not reflect the change in the Specified Amount. If the Specified Amount increases, Your Policy will incur an additional surrender charge based upon the Specified Amount increase and the insured’s Attained Age at that time.

The surrender charge does not apply to withdrawals.

The table below provides an example of the surrender charge applied to a Policy with a male, age 45 on the Issue Date and Super Preferred Non-Tobacco user. For more information on the rate that would apply to You, please contact Your investment professional or Us.

Sample Surrender Charges 45 year-old Male Super Preferred Non Tobacco user

Surrender Occurring during Amount per $1,000 of Surrender Occurring during Amount per $1,000 of Policy Year: Specified Amount Policy Year: Specified Amount

1 $37.39 6 $27.38 2 $36.61 7 $20.53 3 $35.82 8 $13.69 4 $35.03 9 $6.84 5 $34.22 10+ $0.00

WITHDRAWAL PROCESSING FEE The Withdrawal Processing Fee of $25 is currently waived, however, We reserve the right to deduct the fee to cover the costs We incur in processing withdrawals. Unless You instruct Us otherwise, We will deduct the withdrawal and any withdrawal processing fee from the Fixed Policy Value and Subaccount Value in the same proportion as We take Monthly Deductions. If this is not possible, We will deduct withdrawals and withdrawal processing fees proportionately from the Subaccounts and any Fixed Accounts in which You are invested.

TRANSFER PROCESSING FEE We currently allow You to make twenty-four (24) transfers among and between the Subaccounts and the Fixed Account each Policy Year free of charge. The Transfer Processing Fee of $25 is currently waived but We reserve the right to deduct a charge for additional transfers. If we do impose this fee, We would deduct the transfer processing fee from the amount being transferred and the following exceptions would apply:

1. Each transfer request, regardless of the number of Subaccounts affected by the transfer, would be considered a single transfer. 2. Transfers resulting from automatic rebalancing, dollar cost averaging, Policy loans, or expiration of the Cancellation Period, would not count as transfers.

INTEREST CREDITED ON LOAN COLLATERAL We credit the amount in the Loan Account with interest at an effective annual rate that will not be lower than the minimum guaranteed interest rate for loan collateral as shown in Your Policy.

TAXES Premium Taxes. States and municipalities may charge Us premium taxes ranging from 0% to 3.5%. These taxes vary by jurisdiction and are subject to change. We deduct the applicable tax as a part of the Premium Charge.

Income or Other Taxes. We reserve the right to deduct a charge from Your Policy to cover the expense of taxes We pay attributable to Your Policy.

COMMISSIONS PAID TO BROKER-DEALERS Registered representatives who solicit sales of the policies receive a portion of the commission payable to the broker-dealer firm, depending on the agreement between the broker-dealer and the registered representative. We generally pay commissions as a percentage

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document of premiums invested in the Policy. The amount and timing of the commission may differ depending on the agreement between Us and the broker-dealer but is not expected to be more than:

• 130% of premiums paid during the first Policy Year up to a premium level that varies by sex, Issued Age, and Risk Class; • 5% on excess premiums paid in Policy Year 1; and • 2% of premiums paid during Policy Years 2 through 10.

No commission is paid after Policy Year 10.

Ask Your registered representative for further information about the compensation Your registered representative and the selling firm that employs Your registered representative may receive in connection with Your purchase of the

Policy. You also should inquire about any compensation arrangements that We and Our affiliates have with the selling firm, including conflicts of interest that such arrangements may create.

FUND EXPENSES There are deductions from and expenses paid out of the assets of the various Funds. These expenses are summarized in the Total Annual Fund Expenses table of this prospectus. For more detailed information, You should refer to the Fund prospectuses.

VARIATION IN CHARGES There may be circumstances that result in sales or administrative expenses or insurance risks that are different from those normally associated with this Policy. Under such circumstances, We may vary the charges and other terms of the Policies, but in no event will the charges exceed the maximum charges identified in the fee tables in this prospectus. Any reduction in charges associated with the Policy must be consistent with applicable law, will be applied in a manner that is not unfairly discriminatory to Owners, and will reflect the differences in costs of services provided.

PURCHASING A POLICY

If the Insured is between the ages of 0 to 85, You may purchase a Policy by submitting an application, the Initial Premium Payment, and providing evidence of insurability satisfactory to Us. Before approving an application, We conduct underwriting to determine the Risk Class. Insurance coverage becomes effective on the date We issue the Policy (generally the date on which We accept Your application, determine You meet Our underwriting and administrative requirements, and receive any required Initial Premium Payment.)

INITIAL PREMIUM PAYMENT If You choose to make Your Initial Premium Payment by check, it can be delivered either directly to Us at our new business address or to Your registered representative. Your check must be sufficient to keep the Policy in force for at least two months. If You choose to make Your Initial Premium Payment by EFT, the Initial Premium Payment is equal to one Planned Periodic Premium Payment. You may change the method of paying premiums at any time without charge. See PREMIUMS for more information.

Upon receipt of the Initial Premium Payment and before a Policy is issued, We may provide temporary insurance, subject to a maximum amount. If You make Your Initial Premium Payment through Electronic Funds Transfer (“EFT”) and a specific draft date is requested, Your Issue Date will be at least three business days after the requested draft date. If no specific date is requested, Your Policy will be dated as of the date all information is received by Us to issue the Policy, including but not limited to underwriting approval, with the draft date being three business days prior.

The Monthly Deductions under the Policy are measured from and deducted as of the Policy Date. In certain situations, Your Policy Date may pre-date Your Issue Date. You should speak with Your sales representative about setting Your Policy Date and see CHARGES AND FEES for more information. Choosing a Policy Date that pre-dates the Issue Date will cause charges to be deducted prior to Your Issue Date.

CANCELLATION PERIOD You may examine the Policy and, if for any reason You are not satisfied, You may cancel the Policy by returning it with a written request to cancel the Policy to Our Administrative Office or to the sales representative who sold it to You within 10 calendar days, or if Your Policy is a replacement 30 calendar days after the Issue Date. This is known as the "Cancellation Period". In some states, this cancellation period may be different. See APPENDIX B: STATE VARIATIONS for more information. If You decide to cancel Your Policy during the cancellation period, We will refund the premium payments made, minus any loans taken, promptly, and will treat the Policy as if it had never been issued.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document We hold the Net Premium Payments received for Your Policy during the Cancellation Period in the Fixed Account. At the expiration of the Cancellation Period, We will reallocate the Net Premium Payment(s) less Monthly Deductions, plus credited interest, held in the Fixed Account to the investment options available under an Owner’s Policy, based on the Owner’s allocation instructions in effect at that time.

OWNERSHIP RIGHTS The Policy belongs to the Owner named in the application unless changed. The Owner, may exercise all of the rights and options described in the Policy. The Insured is the Owner unless the application specifies a different person as Owner. If the Owner dies before the Insured and no contingent Owner is named, then ownership of the Policy will pass to the Owner’s estate (subject to applicable community property laws).

The principal rights an Owner may exercise are to:

1. select the Tax Compliance Test; 2. designate or change any Beneficiary or Contingent Beneficiary before the death of the Insured; 3. change the Owner; 4. select or change a contingent Owner of the Policy; 5. allocate Net Premium Payments and Policy Value among and between the Subaccounts and any Fixed Accounts; and 6. surrender, take a loan, or assign the Policy.

Tax Compliance Tests. Under Section 7702 of the Internal Revenue Code of 1986, as amended (the "Code"), a policy will generally be treated as life insurance for federal tax purposes if, at all times, it meets either a Guideline Premium Test (“GPT”) or a Cash Value Accumulation Test (“CVAT”). The Owner must elect either the GPT or CVAT on the Policy application. Once the Policy is issued, You may not change to a different test. The amount of the Death Benefit will vary depending on which test is used, and it may affect the amount of premiums You may pay, and the amount of Policy fees and charges You pay.

In deciding whether to choose the CVAT, You should consider that the CVAT generally permits more premiums to be contributed to a Policy, but may require the Policy to have a higher Death Benefit, which may increase certain charges.

The GPT has two components, a premium limit component and a corridor component. The premium limit restricts the amount of premium that can be paid into the Policy. The corridor requires that the Death Benefit be at least a certain percentage (varying each year by Attained Age of the Insured) of the Policy Value. The CVAT does not have a premium limit, but does have a corridor that requires that the Death Benefit be at least a certain percentage (varying based on the Attained Age, sex and Risk Class of the Insured) of the Policy Value, adjusted for certain riders.

The corridor under the CVAT is different from the corridor under the GPT. Specifically, the CVAT corridor generally requires more Death Benefit in relation to Policy Value than is required by the GPT corridor. Therefore, for a Policy in the corridor with no riders, as Your Policy Value increases, Your Death Benefit will generally increase more rapidly under CVAT than it would under GPT.

The Death Benefit factor is the minimum multiple of Policy Value We must pay as the Death Benefit under federal tax requirements. The Death Benefit factor is shown in Your Policy for the Insured's Attained Age as of his or her death. The following table indicates the Death Benefit factors for the GPT for different Attained Ages:

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Attained Age Death Benefit Factor 40 and under 2.50 41 to 45 2.50 minus 0.07 for each age over Attained Age 40 46 to 50 2.15 minus 0.06 for each age over Attained Age 45 51 to 55 1.85 minus 0.07 for each age over Attained Age 50 56 to 60 1.50 minus 0.04 for each age over Attained Age 55 61 to 65 1.30 minus 0.02 for each age over Attained Age 60 66 to 70 1.20 minus 0.01 for each age over Attained Age 65 71 to 75 1.15 minus 0.02 for each age over Attained Age 70 76 to 90 1.05 91 to 94 1.05 minus 0.01 for each age over Attained Age 90 95 to 99 1.01 100 and older 1.01

If the Code requires Us to determine the Death Benefit by reference to these Death Benefit factors, then the Policy is described as “in the corridor.” An increase in the Policy Value will increase Our risk, and We will increase the cost of insurance We deduct from the Policy Value.

Guideline Premium Test Example: Assume that the Insured's Attained Age is under 40 and that there is no Loan Amount. A Policy with a $100,000 Specified Amount will generally pay $100,000 in Death Benefit. However, because the Death Benefit must be equal to or be greater than 2.50 times the Policy Value, any time the Policy Value exceeds $40,000, the Death Benefit will exceed the $100,000 Specified Amount. The figure $40,000 is derived by solving for Policy Value in the following calculation: $100,000 = 2.50 multiplied by the Policy Value. Each additional dollar added to the Policy Value above $40,000 will increase the Death Benefit by $2.50.

Similarly, for this Policy, as long as the Policy Value exceeds $40,000, each dollar taken out of the Policy Value will reduce the Death Benefit by $2.50. If at any time the Policy Value multiplied by the Death Benefit factor is less than the Specified Amount, then the Death Benefit will equal the Specified Amount of the Policy.

Under the Cash Value Accumulation Test, the Death Benefit equals the greater of:

1. The Specified Amount; or 2. A specified percentage, shown in Your Policy, multiplied by the Policy Value on the Insured's date of death.

The Death Benefit factor under CVAT is calculated as specified under Section 7702 of the Code. It is based on the Insured’s sex, Risk Class, and Attained Age at the beginning of each Policy Year.

Cash Value Accumulation Test Example: Assume that a Policy has no Loan Amount. Also assume that the Policy has a Specified Amount of $1,000,000 and the Death Benefit factor is 2.97. Under the Level Option, a Policy with a $1,000,000 Specified Amount will generally pay $1,000,000 in Death Benefits. However, because the Death Benefit for the Policy must be equal to or be greater than 2.97 times the Policy Value, any time the Policy Value exceeds $336,700, the Death Benefit of the Policy will exceed the $1,000,000 Specified Amount. The figure of $336,700 is derived by solving for Policy Value in the calculation $1,000,000 = 2.97 multiplied by Policy Value. Each additional dollar added to the Policy Value above $336,700 will increase the Death Benefit of the Policy by $2.97. Similarly, for this Policy, as long as the Policy Value exceeds $336,700, each dollar taken out of the Policy Value will reduce the Death Benefit of the Policy by $2.97. If at any time the Policy Value multiplied by the Death Benefit factor is less than the Specified Amount, the Death Benefit of the Policy will equal the Specified Amount of the Policy.

Choosing the Beneficiary. The Owner designates the Beneficiary (the person to receive the Death Benefit when the Insured dies) in the application. If the Owner designates more than one Beneficiary in a class, then each Beneficiary in the class shares equally in any Death Benefit unless the Beneficiary designation states otherwise. If the primary Beneficiary dies before the Insured, then the Contingent Beneficiary becomes the Beneficiary. If both the primary Beneficiary and Contingent Beneficiary die before the Insured, then the Death Benefit will be paid to the Owner or the Owner's estate upon the Insured's death.

Owner and Beneficiary Changes. The Owner of a Policy may change the Owner and change any Beneficiary or Contingent Beneficiary by Written Notice to Us, in good order. The request will take effect as of the date such Written Notice is signed by the Owner. We are not liable, however, for payment or other action taken by Us before We receive such Written Notice. Changing the Owner may have tax consequences. You should consult a tax advisor before changing the Owner.

Conversion: The Policy can not be converted.

PREMIUMS

Premium payments should be made payable to Symetra Life Insurance Company and in a form acceptable to Us. You may choose to pay annual, semi-annual, quarterly or monthly premiums by personal check drawn on U.S. funds or by Electronic Funds Transfer (EFT).

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document You may choose to make premium payments directly to Our Administrative Office or through a pre-authorized transfer from a bank account. You can make Planned Periodic Payments using EFT by:

1. electing the EFT payment option on Your application or providing Us with a bank draft authorization form; and 2. providing Us with a voided check for account and bank routing information.

You may change the method of paying premiums at any time without charge.

Monthly Planned Periodic Payments must be made by EFT.

PLANNED PERIODIC PAYMENTS You can schedule the amount and frequency of premium payments. We refer to these scheduled premiums as “Planned Periodic Payments”. You can choose to pay them either annually, semi-annually, quarterly, or monthly. Subject to Our approval, You can change the amount and frequency of Planned Periodic Payments. We will send Owners reminder notices for Planned Periodic Payments.

Making Planned Periodic Payments is optional. If You make Planned Periodic Payments on time and in full, there is still no guarantee that the Policy will not Lapse (i.e., terminate without value). See POLICY LAPSE AND REINSTATEMENT for more information.

ADDITIONAL PREMIUMS Additional premium payments may be made at any time before the Maturity Date while the Policy is in force and may be necessary to prevent Lapse. Additional premium payments or other changes to the Policy can jeopardize a Policy’s tax status. We will notify an Owner if a premium payment may result in a Policy becoming a MEC, and will refund any portion of any premium payment We determine to be in excess of the premium limit established by law to qualify the Policy as life insurance.

Unless You specify otherwise in a Written Notice, We will consider any unplanned premium payment made while a loan is outstanding as a loan repayment.

Premium payments received in good order are credited to Your Policy on the business day We receive them at Our Administrative Office. However, payments received at Our Administrative Office without all of the information necessary to process them may postpone the crediting of Your payment to Your Policy. In addition, if Your check is received without the necessary information We need to process it, processing delays will occur as We attempt to contact You to get the necessary information.

In all cases, We will accept additional premium necessary to prevent the Policy from lapsing.

To the extent the Net Amount at Risk under Your Policy increases as a result of a premium payment, We may require evidence of insurability satisfactory to Us. We will make appropriate adjustments, prospectively, to the Monthly Deductions or any supplemental benefits that are consistent with such an increase.

ALLOCATION OF NET PREMIUM PAYMENTS AND POLICY VALUE You designate how Your Net Premium Payments are to be allocated when You apply for a Policy. All percentage allocations must be in whole numbers. The sum of the allocations must equal 100%.

We allocate Net Premium Payments We receive during the Cancellation Period (including the Initial Premium Payment) to the Fixed Account. At the end of the Cancellation Period, the Net Premium Payment(s) less Monthly Deductions and plus credited interest is (are) reallocated to any Subaccount that You selected, based on Your allocation instructions. Net Premium Payments received after the Cancellation Period are allocated to the Subaccounts and/or the Fixed Account, according to the allocation instructions We have at that time.

You may change Your allocation instructions without charge at any time by Written Notice or by telephone. The change will be effective as of the end of the Valuation Period on which We receive Your Written Notice or telephone call.

Whenever You allocate Net Premiums or transfer Policy Value into a Subaccount, We will credit Your Policy with the number of Units for that Subaccount that can be acquired for such premium or transfer amount. We price each Subaccount Unit on each Valuation Day using the Unit value determined at the closing of the regular business session of the New York Stock Exchange (“NYSE”) (usually at 4:00 p.m. Eastern time). We will credit amounts to the Subaccounts only on a Valuation Day. Your Policy Value will vary with the investment experience of the Subaccounts in which You invest.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document If a selected Subaccount is not available, Your allocation or transfer will not be carried out. We will contact You for further instructions.

You are responsible for allocating Variable Policy Value among the Subaccounts that are appropriate for Your own individual circumstances and Your investment goals, financial situation, and risk tolerance. Because investment risk is borne by You, You should carefully consider any decisions that You make regarding investment allocations. You should periodically review how Your Policy Value is allocated among the Subaccounts and the Fixed Account because market conditions and Your overall financial objectives may change. You bear the risk of any decline in Your Policy Value resulting from the performance of the Funds You have chosen.

CALCULATION OF POLICY VALUE

VARIABLE POLICY VALUE The Variable Account reflects the investment experience of the Subaccounts to which it is allocated, any Net Premium Payments and loan repayments allocated to the Subaccounts, transfers out of the Subaccounts, any withdrawals of Subaccount Value, any Loan Amount transferred to the Loan Account, and that portion of any withdrawal processing fee, transfer processing fee, or the Monthly Deduction attributable to the Subaccounts. The Variable Policy Value at any time is the sum of the Subaccount Values for the Policy on the Valuation Day most recently completed. There is no minimum Variable Policy Value.

UNITS The value of the variable portion of Your Policy will go up or down depending upon the investment performance of the Subaccount(s) You choose. To keep track of this, We use a unit of measure called a Unit. The number of Units credited is determined by dividing the dollar amount directed to each Subaccount by the value of the unit for that Subaccount.

The Unit value for each Subaccount was arbitrarily set initially at $10 when the Subaccount began operations. Thereafter, the Unit value at the end of every Valuation Day is the Unit value at the end of the previous Valuation Day multiplied by the Net Investment Factor, as described below. The Subaccount Value for a Policy on any day is equal to the number of Units credited to the Policy in that Subaccount multiplied by the Unit value for the Subaccount on that day.

The net investment factor is used to measure the change in Unit value for each Subaccount from one Valuation Period to the next. The net investment factor may be greater or less than one, which means that the value of a Unit may increase or decrease from Valuation Day to Valuation Day. The net investment factor for any Subaccount is determined by dividing (1) by (2), where:

(1) is the result of a. the Net Asset Value Per Share of a Fund held in the Subaccount, determined at the end of the current Valuation Period; plus b. the per share amount of any dividend or income distributions made by the Fund to the Subaccount, if the “ex-dividend” date occurs during the current Valuation Period; plus or minus c. a per share charge or credit for any taxes reserved for, which is determined by Symetra Life to have resulted from the operations of the Subaccount; and

(2) is the Net Asset Value Per Share of the Fund held in the Subaccount, determined at the end of the immediately preceding Valuation Period.

When You make Net Premium Payments or transfers into a Subaccount, We credit Your Policy with Units. Conversely, Units are liquidated when You request a withdrawal or a transfer of money from a Subaccount, when the Monthly Deduction is assessed, a loan is taken, the Policy is surrendered, or Death Benefit Proceeds are paid. In either case, the increase or decrease in the number of Your Units is determined by taking the amount of the Net Premium Payment, transfer, withdrawal and dividing it by the value of a Unit on the date the transaction occurs.

Example: Assume that on Monday, We receive a $1,000 Net Premium Payment from You before the NYSE closes. You have told Us that You want this to go to the Fund A Subaccount. When the NYSE closes on that Monday, We determine that the value of a Unit of the Fund A Subaccount is $20. We then divide $1,000 by $20 and credit Your Policy on Monday night with 50 Units for the Fund A Subaccount.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document FIXED POLICY VALUE The Fixed Policy Value under a Policy at any time is equal to: (i) Net Premium Payments allocated to the Fixed Account, plus (ii) Policy Value transferred to the Fixed Account; plus (iii) interest credited to the Fixed Account; minus (iv) transfers from the Fixed Account (including any transfer fees deducted); minus (v) withdrawals from the Fixed Account (including any withdrawal processing fee deducted); minus (vi) any applicable Monthly Deductions.

TRANSFER OF POLICY VALUE

While the Policy is in force and the Insured is still living, You can transfer Policy Value among and between any available Subaccounts and the Fixed Account.

The following apply to transfers under the Policy:

• The minimum amount that may be transferred is $100 with the exception of Dollar Cost Averaging. If a transfer will result in the remaining balance in a Subaccount(s) or the Fixed Account being less than $100, We reserve the right to transfer the entire Subaccount Value or Fixed Policy Value instead of the requested amount. • The maximum amount an Owner may transfer from the Fixed Account each Policy Year after the first Policy Year may not exceed the greater of both (i) 25% of the Fixed Policy Value measured on the preceding Policy Anniversary and (ii) the total dollar amount transferred from the Fixed Account in the immediately preceding Policy Year.

TRANSFER TRANSACTIONS AVAILABLE We will accept transfers by Written Notice or by telephone, or, if available, electronically by the Internet, if We have a signed authorization on file. Each transfer must identify:

• Your Policy; • the amount of the transfer; and • which investment options are affected.

Transfer requests received by Us with all the information We need to process the request will be effective and valued as of the next close of the NYSE. This is usually 4:00 p.m. Eastern Time. If for any reason the NYSE is closed when We receive Your transfer request, it will be valued as of the close of the NYSE on its next business day.

Transfers by telephone will be accepted if we have properly signed authorization on record. You may authorize someone else to make transfers by telephone on Your behalf. Symetra Life will not be liable for any failure to question or challenge such request for transfer as long as there is a valid signed authorization on record at Symetra Life.

Transfers by Internet will be accepted if You provide Us with certain identification information, including a personal identification number (“PIN”). However, we do not accept transfer requests sent by e-mail. Transfer instructions You send electronically through the Internet are considered to be received by Us at the time and date stated on the electronic acknowledgment we return to You. If You do not receive an electronic acknowledgment, You should telephone Us as soon as possible.

We cannot guarantee that telephone transactions will always be available. In addition, if the volume of calls is unusually high, we may not have someone immediately available to receive Your order. Likewise, We cannot guarantee that online transactions processed via the Internet will always be possible. Telephone and computer systems, whether Yours, Your Internet service provider’s, Your Symetra Life registered representative’s, or Symetra Life’s, can experience outages or slowdowns for a variety of reasons. These outages or slowdowns may prevent or delay our receipt of Your request.

You also should protect Your PIN because self-service options will be available to anyone who provides Your PIN. We will not be able to verify that the person using Your PIN and providing instructions is You or a person authorized by You.

We reserve the right to modify, suspend, or terminate transfer privileges at any time for some or all Policy Owners. In addition, if we receive a transfer request that is to be allocated to the Fixed Account and we are not able to invest the money such that we can credit at least the minimum guaranteed interest rate, we reserve the right to reject the portion of the transfer request that was to be allocated to the Fixed Account.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document SCHEDULED TRANSFERS Your Policy offers two investment strategies that are available at no charge. Any transfer made using these strategies will not count against Your 24 free transfers. Under these strategies, We may impose restrictions on the number of transfers that can be initiated during each Policy Year or on the investment options available for transfers. If such restriction is imposed or We change the Subaccounts available, We will notify You in writing. Dollar Cost Averaging ("DCA"). This strategy is designed to achieve a lower average cost per unit over time. It does not assure a profit or protect against a loss. You can systematically transfer set amounts each month or quarter from the Fixed Account to any of the Subaccounts available under Your Policy. If DCA is elected at the time of application, Your initial Net Premium Payment will be moved to the Fixed Account. In addition, You can choose to have subsequent Net Premium Payments subject to DCA and moved to the Fixed Account. If You elect DCA after Your Policy has been

issued, You must tell Us how much of Your Policy Value You want designated for DCA and it will be moved to the Fixed Account. Transfers under DCA will occur on a Monthly Anniversary Day based on the frequency You select, either monthly or quarterly. The amounts of each transfer and the Subaccounts to which the transfer is allocated will be chosen by You and may be changed at any time by providing Written notice to Us. Once started, dollar cost averaging will continue until You instruct Us to stop or all money has been transferred out of the Fixed Account. Automatic Rebalancing. After Your Policy Value has been invested, the performance of the Subaccounts may cause the percentage in each Subaccount to change from Your original allocations. You can instruct Us to adjust Your investment in the Subaccounts and the Fixed Account to maintain a predetermined mix on a quarterly basis. Once started, automatic rebalancing will continue until You request Us to stop. You can request to start or stop automatic rebalancing by telephone or by Written Notice.

LIMITS ON EXCESSIVE TRANSFERS AND MARKET TIMING ACTIVITY Effects of Excessive Transfers and Market Timing Activity. The Policy and the Funds are not designed for short term trading or market timing, or for persons that make large, or frequent transfers. Such trading activity may be disruptive to portfolio management strategies by causing forced and unplanned portfolio turnover, and increased trading and transaction costs. In addition, these activities may require a Fund to maintain a higher level of cash than would otherwise be the case, resulting in lost opportunity costs that must be indirectly borne by all Owners invested in the affected Subaccounts, not just those making the transfers. These disruptive activities may increase expenses and adversely affect Fund performance, thereby negatively impacting long-term Owners.

Detection and Deterrence. Symetra Life discourages and does not accommodate frequent transfers or market timing activity. Due to the potential adverse consequences to Owners, the Funds, Fund shareholders, and the Variable Account, We have established certain policies and procedures to attempt to detect and deter market timing and disruptive trading. Under these policies and procedures, various analytics are used to evaluate factors that may be indicative of frequent trading. For example, transactions in Funds that exceed certain monetary thresholds may be scrutinized. Symetra Life also may review transactions that occur close in time to other transactions in the same Policy or in multiple Policies under common ownership or influence. Trading activity that is identified through these procedures, or as a result of any other information available, will be evaluated to determine whether such activity might constitute frequent trading. These procedures may be modified from time to time as appropriate to improve the detection of frequent trading, to facilitate monitoring for frequent trading in particular retirement plans or other accounts, and to comply with applicable laws. Despite Our monitoring, however, We may not be able to detect or halt all harmful trading. In addition, because other insurance companies (and retirement plans) with different policies and procedures may invest in the Funds, We cannot guarantee that all harmful trading will be detected or that a Fund will not suffer from market timing and disruptive trading among Subaccounts of variable products issued by these other insurance companies or retirement plans.

In addition to the broad ability to restrict potentially harmful trading as described above, Symetra Life has adopted a policy under which any Owner transferring $100,000 or more from a Subaccount may not transfer Policy Value back into that Subaccount for 90 days. Symetra Life will grant two exceptions to the 90-day policy, per rolling 12 month period. We will notify You in writing after You trigger each exception to the 90-day policy.

We may impose other restrictions on transfers, or even prohibit transfers for any Owner who, in Our view, has abused or appears likely to abuse, the transfer privilege, on a case-by-case basis. We may, at any time and without prior notice, discontinue transfer privileges, modify Our procedures, impose holding period requirements, or limit the number, size, frequency, manner or timing of the transfers that We permit. If We modify Our procedures, they will be applied uniformly to all Owners. We also reserve the right to reverse a transfer if a Fund refuses or reverses Our order; in such instances some Owners may be treated differently than others in that some transfers may be reversed and others allowed. For all of these purposes, We may aggregate two or more variable insurance products that We believe are connected by Owners or persons engaged in trading on behalf of Owners.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document In addition to Our internal policies and procedures, We will administer Your Policy to comply with any applicable state, federal, and other regulatory requirements concerning transfers. We may implement, administer, and charge You for any fee or restriction, including redemption fees, imposed by any Fund. To the extent permitted by law, We also may defer the transfer privilege at any time that We are unable to purchase or redeem shares of any of the Funds.

If a transfer request is rejected or Your transfer privileges have been restricted for any reason, We will attempt to inform You by telephone the next business day. If We do not succeed in reaching You by telephone, We will send a letter to the last known address of the Owner and/or the last known address of an assignee of record.

Our ability to detect market timing or other disruptive trading may be limited by operational and technological systems, as well as by Our ability to predict strategies employed by Owners (or those acting on their behalf) to avoid detection. As a result, despite Our efforts to prevent harmful trading activity among the Subaccounts available under this Policy, there is no assurance that We will be able to detect or deter market timing or disruptive trading by such Owners or intermediaries acting on their behalf. Moreover, Our ability to discourage and restrict market timing or disruptive trading may be limited by terms of the Policy and by decisions of state regulatory bodies and court orders that We cannot predict.

Fund Frequent Trading Policies. The Funds to which We submit purchase and redemption orders may also detect large or unusual patterns of trades submitted by Us on behalf of all Our variable annuity contract owners and variable life policy owners. Those Funds may require Us to investigate whether any of Our contract owners are engaged in market timing or other similar activity and to cooperate with them to discourage such activity. If a Fund believes You are engaged in market timing activity, it may require Us to block You from making transfers or purchases to the Fund. In addition, federal regulations may require Us to provide individual transaction and contract owner information to the Funds when requested.

In addition to Our market timing procedures, the Funds to which We submit purchase and redemption orders may have their own market timing policies and restrictions. Those policies and procedures, when applicable, are described in the prospectuses for each of the Funds available for investment by You. We reserve the right to enforce the Funds' policies and procedures. Under SEC rules, We are required to: (i) enter into a written agreement with each Fund or its principal underwriter that obligates Us to provide to the Fund promptly upon request certain information about the trading activity of individual Owners, and (ii) execute instructions from the Fund to restrict or prohibit further purchases or transfers by specific Owners who violate the market timing policies established by the Fund.

In cases of large or frequent transfers, Fund managers or Symetra Life may reject trades that are determined to be detrimental to other Fund investors or violate the Funds’ policies and procedures. Therefore, to the extent permitted by law, We may delay or refuse to honor a transfer request to a Subaccount that invests in a Fund, or to reverse such a transfer request, at any time We are unable to purchase or redeem shares of any of the Funds because of the Fund’s refusal or restriction on purchases or redemptions.

We further reserve the right to implement, administer, and collect any fee or restriction, including redemption fees, imposed by any Fund. Redemption fees, transfer limits, and other procedures or restrictions may be more or less successful than ours in deterring market timing or other disruptive trading and in preventing or limiting harm from such trading. You should read the prospectus of each Fund for more information about the Fund’s ability to refuse or restrict purchases or redemptions of its shares and to impose redemption fees. DEATH BENEFIT

DEATH BENEFIT PROCEEDS Upon receipt of Due Proof of Death of the Insured while the Policy is in force, We will pay the Death Benefit Proceeds to the primary Beneficiary(ies), if living, or to a Contingent Beneficiary. If no primary Beneficiary or Contingent Beneficiary survives the Insured, We will pay the Death Benefit Proceeds to the Owner or the Owner’s estate. We will pay the Death Benefit in a single sum or under a payment option provided under the Policy that the Owner or the Beneficiary(ies) select(s). See “Settlement Options” in OTHER INFORMATION ABOUT THE POLICY.

Proof of Death acceptable to Us may consist of a certified copy of a death record, a certified copy of a court decree reciting a finding of death, or any other proof satisfactory to Us.

The Death Benefit Proceeds equal: • The Death Benefit; plus • Any Death Benefit under any rider to the Policy; minus • Any liens; minus • Any Loan Amount; minus

We may further adjust the amount of the Death Benefit if We contest the Policy based on Your misstatement of the Insured's Age and/or, if permitted by state law, sex.

We will pay interest on the Death Benefit Proceeds from the date of death to the date of payment. Interest will accrue at the Two Year Treasury Constant Maturity Rate as published by the Federal Reserve. We will pay additional interest at an annual rate of 10% starting thirty-one (31) days following the latest of (1), (2) or (3) below until the date the Death Benefit Proceeds are paid.

1. The date We receive Due Proof of Death at Our Administrative Office; 2. The date We receive sufficient information to determine Our liability, the extent of the liability, and the person(s) entitled to the Death Benefit Proceeds; or 3. The date that legal impediments to payment of the Death Benefit Proceeds that depend on actions of parties other than Symetra Life such as the establishment of guardianship and conservatorships, the appointment and qualification of trustees, and the submission of information necessary to satisfy state and federal reporting obligations are removed to Our satisfaction.

DEATH BENEFIT OPTIONS If the Insured dies while the Policy is in force, We will pay a Death Benefit to the Beneficiary. You select Your Policy’s initial amount of insurance coverage, its Initial Specified Amount, and Death Benefit option "A", "B" or "C" on Your application.

Death Benefit Option "A". The Death Benefit is the greater of the Specified Amount on the date of the Insured’s death or the applicable “corridor” percentage of the Policy Value as of the Insured’s date of death, as shown in Your Policy. The amount of the Death Benefit is as of the Insured's date of death. We also refer to the applicable corridor percentage as the “Death Benefit factor,” and that concept is explained in detail above under “OWNERSHIP RIGHTS—The Tax Compliance Test.”

Death Benefit Option "B". The Death Benefit is the greater of the Specified Amount plus the Policy Value on the date of the Insured’s death, or the Policy Value on the date of the Insured's death multiplied by the applicable “corridor” percentage of the Policy Value, as shown in Your Policy.

Death Benefit Option "C". The Death Benefit is the greater of (1) or (2) where: (1) is equal to: • the Specified Amount on the date of the Insured’s death; plus • the sum of the premiums paid; minus • the sum of withdrawals, and any applicable charges taken.

The total of (1) will never be greater than the Option "C" Death Benefit Limit as shown in Your Policy.

(2) is equal to: • The Policy Value on the date of the Insured's death multiplied by the applicable “corridor” percentage of the Policy Value, as shown in Your Policy.

The Policy is intended to qualify under Section 7702 of the Code as a life insurance policy for federal tax purposes. The Death Benefit is intended to qualify for the federal income tax exclusion. The provisions of the Policy and any attached endorsement or rider will be interpreted to ensure such qualification, regardless of any language to the contrary.

CHANGES IN DEATH BENEFIT OPTIONS Prior to the Maturity Date and while the Insured is still living, You can change from one Death Benefit to another. However, changes to Option "C" are not allowed. You must request a change by Written Notice and We may require evidence of insurability prior to making any change. Any change in Death Benefit Option becomes effective on the Monthly Anniversary Day on or next following the date that We approve the request.

Changing from Option "A" to Option "B". If You change from Option "A" to Option "B", We will decrease the Specified Amount by the amount of Your Policy Value on the date of change. We reserve the right to decline to make such change if it would reduce the Specified Amount below the Minimum Specified Amount as shown in Your Policy.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Changing from Option "B" to Option "A". If You change from Option "B" to Option "A", We will increase the Specified Amount by the amount of Your Policy Value on the date of change.

Changing from Option "C" to Option "A". If You change from Option "C" to Option "A", We will increase the Specified Amount by the sum of the premiums paid minus the sum of any withdrawals taken as of the date of the change. If this amount is negative, the Specified Amount will not change. The Specified Amount will not be increased above the Option C Death Benefit Limit as shown in Your Policy.

Changing from Option "C" to Option "B". If You change from Option "C" to Option "B", We will adjust the Specified Amount by an amount equal to, as of the date of the change:

1. the change to the Specified Amount for a Death Benefit Option change from Option C to Option A; minus 2. the amount of Your Policy Value.

We reserve the right to decline to make such change from Option "C" to Option "B" if it would reduce the Specified Amount below the Minimum Specified Amount as shown in Your Policy.

DECREASING THE SPECIFIED AMOUNT After the first Policy Year, You can request a decrease of at least $10,000 in the Specified Amount by Written Notice to Us. Decreases in the Specified Amount will allow You to decrease the planned premium amount and will decrease the guideline premium. Changes take effect on the first Monthly Anniversary Day on or next following the date We approve the change. We may decline to make a change that would decrease Your Specified Amount of insurance to less than the minimum amount shown in Your Policy, or that would disqualify Your Policy as life insurance under tax law. We do not permit decreases in Specified Amount during a Grace Period.

OTHER BENEFITS AVAILABLE UNDER THE POLICY

In addition to the standard death benefit associated with Your Policy, other standard and optional benefits may also be available to You. The following table summarizes the information about these benefits. Information about the fees associated with each benefit included in the table may be found in the Fee Table.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Name of Benefit Purpose Standard or Description of Restrictions/ Optional Limitations Accelerated Death Benefit for You can access up to 50% of the Death Standard • Not available for Policies issued Chronic Illness Rider Benefit (subject to a $500,000 with substandard ratings. maximum) under the Policy if a • You may not exercise the licensed health care practitioner Accelerated Death Benefit for certifies during the prior 12-month Terminal Illness Rider if this rider period that the Insured meets certain is exercised. criteria. Accelerated Death Benefit for You can access up to 100% of the Death Optional • You may not exercise the Chronic Illness Plus Rider Benefit under the Policy if a licensed Accelerated Death Benefit for health care practitioner certifies during Terminal Illness Rider if this rider the prior 12-month period that the is exercised. Insured meets certain criteria. Accelerated Death Benefit for You can access up to 75% of the Death Standard • Not available for Policies issued Terminal Illness Rider Benefit (subject to a $500,000 with substandard ratings. maximum) under the Policy if a • Can only be exercised once. licensed physician certifies that the • You cannot exercise any other Insured is terminally ill with less than accelerated death benefits 12 months to live. available under the Policy. Charitable Giving Benefit Rider Upon the Insured’s death, this rider Optional • Only available for Policies with a provides an additional benefit of 1% of Specified Amount greater than the Specified Amount of the Policy (up $100,000. to $100,000) to the qualified charity of the Owner’s choice. Overloan Lapse Protection Rider This rider prevents the Policy from Standard • Only available if Your Policy lapsing due to insufficient Policy Value utilizes the Guideline Premium under certain conditions. Test for Life Insurance and is not a Modified Endowment Contract at the time of exercise. • Only exercisable after the 15th Policy Year • Only available if the Policy Death Benefit is Option "A"

Name of Benefit Purpose Standard or Description of Restrictions/ Optional Limitations Supplemental Protection Rider This rider provides an amount of Optional • Only available at the time of supplemental coverage on the Insured. Policy issue Surrender Value Enhancement This rider waives a portion of Your Optional • Only available at the time of Rider Surrender Charges over the first 5 Policy issue Policy Years by providing an alternate Surrender Charge schedule. Waiver of Monthly Deductions This rider may help prevent the Policy Optional • Only available at the time of Rider from lapsing during a period of total Policy issue disability by waiving Monthly • Only available if total disability Deductions. occurs prior to Attained Age 65 and has existed continuously for at least 6 months. Once exercised, You can not add other Riders to Your Policy. • Any increase in Specified Amount will terminate the rider.

ACCELERATED DEATH BENEFIT FOR CHRONIC ILLNESS RIDER Under this rider, up to 50% of the Death Benefit (subject to a $500,000 maximum) under the Policy can be accessed in advance if a licensed health care practitioner (as defined in the rider) certifies during the prior 12-month period that the Insured:

1. is unable to perform (without substantial assistance from another person) at least two activities of daily living for at least 90 days due to a loss of functional capacity; or 2. has a severe cognitive impairment that requires substantial supervision to ensure the health and safety of the Insured and others.

This rider is added to the Policy at issue, unless the Policy is issued with substandard ratings. There is no separate charge for this rider. If this rider is exercised, You may not exercise the Accelerated Death Benefit for Terminal Illness rider. When the rider is exercised, the accelerated death benefit is a lien against the Death Benefit. After the rider is exercised, Your death benefit under the Policy will be equal to the greater of Your remaining death benefit or $5,000. The accelerated death benefit may be taken as a single sum or in monthly installments. No surrender charge will apply to the payment of an accelerated death benefit under this rider. There is no minimum benefit amount that must be taken. If monthly payments will continue for more than 12 months, an annual recertification is required. For more information, see APPENDIX C: OPTIONAL BENEFIT EXAMPLES.

ACCELERATED DEATH BENEFIT FOR CHRONIC ILLNESS PLUS RIDER This rider must be applied for at the time of application and full underwriting is required to qualify for issuance. Under this rider, up to 100% of the Death Benefit under the Policy can be accessed, in advance, if the Insured:

1. is certified by a licensed health care practitioner (as defined in the rider), during the prior 12-month period, as being unable to perform (without substantial assistance from another person) at least two activities of daily living for at least 90 days due to a loss of functional capacity; or 2. has a severe cognitive impairment requiring substantial supervision to ensure the health and safety of the Insured and others; and 3. is annually recertified by a licensed health care practitioner residing and practicing in the U.S. to continue receiving benefits.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document The benefit can be paid as a single sum or through monthly payments and must be mailed to a U.S. address or U.S. financial institution. Once You access the Death Benefit under this rider, no additional premium payments will be due and all charges under the Policy will be waived. There is a charge for this rider that is expressed as an amount per $1,000 of Net Amount at Risk and will vary by the Issue Age, Risk Class, Policy duration (i.e., how long the Policy has been in force), and if permitted by state law, sex. For more information, see APPENDIX C: OPTIONAL BENEFIT EXAMPLES.

ACCELERATED DEATH BENEFIT FOR TERMINAL ILLNESS RIDER Unless the Policy is issued with substandard ratings, this rider is added to the Policy at issue. There is no separate charge for this rider. The benefit, which may only be taken as a single sum, allows an Owner to access up to 75% percent of the Death Benefit (subject to a $500,000 maximum) under the Policy in advance if a licensed physician (as defined in the rider) certifies

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Table of Contents Definitions that the Insured is terminally ill with less than 12 months to live. You may only exercise the rider once and doing so will preclude You from exercising any other accelerated death benefits available under the Policy.

Upon exercise of the rider, the remaining Policy Value is transferred to the Fixed Account. When exercised, this rider will reduce the Death Benefit and the Surrender Value proportionally to the amount accelerated. No surrender charge will apply to the payment of an accelerated death benefit under this rider. There is no minimum benefit amount that must be taken. For more information, see APPENDIX C: OPTIONAL BENEFIT EXAMPLES.

CHARITABLE GIVING BENEFIT RIDER This rider must be elected at issue and is only available for Policies with a Specified Amount greater than $100,000. There is no separate charge for this rider. Upon the Insured’s death, this rider provides an additional benefit of 1% of the Specified Amount of the Policy (up to $100,000) to the qualified charity of the Owner’s choice. The charity must be designated at the time of Policy issue and may be changed by providing Us Written Notice. For more information, see APPENDIX C: OPTIONAL BENEFIT EXAMPLES.

OVERLOAN LAPSE PROTECTION RIDER Unless the Policy is issued with the CVAT tax compliance test, this rider is added to the Policy at issue and can only be exercised at any time after the Policy has been in force for at least fifteen Policy Years. Once exercised, the rider prevents the Policy from lapsing due to insufficient Policy Value. You must submit a request by Written Notice to Our Administrative Office in order to exercise this rider, and the following requirements must be met:

• the Policy cannot be a MEC at the time of exercise; • the Insured must have reached Attained Age 75; • the Policy Death Benefit Option must be Option "A"; • the Policy Value multiplied by the applicable percentage for the Insured's Attained Age, as shown in the Table of Applicable Percentages for the Guideline Premium Test on the Policy specifications page, must exceed the Specified Amount; and • The Loan Amount must be greater than 93% of the Policy Value or the Policy Value after the charge for the rider has been deducted, whichever is less.

There is a separate one-time charge for this rider which is calculated and deducted at the time You exercise the rider. The rider charge is equal to the Policy Value at the time of exercise multiplied by the rider exercise charge rate for Your Attained Age. The rider exercise charge rate can be found on the rider specification page.

Once the rider is exercised and the rider charge has been deducted, the following will occur: • Your Variable Policy Value will be transferred to the Fixed Account and You will no longer be invested in the Subaccounts; • Interest credited to the Fixed Account will only be the minimum rate of 1%; • No Monthly Deductions or additional charges will be taken from the Policy Value; • No further loans or withdrawals will be allowed; • No premium payments will be accepted; • No loan repayments will be accepted; • Loan interest and interest credited to the Loan Account will only be the minimum rate of 1%; and • No changes to the Specified Amount or Death Benefit Option will be accepted.

The Death Benefit Proceeds will be calculated as described in DEATH BENEFIT PROCEEDS, however, the Death Benefit Proceeds will never be less than $5,000.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document You can request to terminate this rider by sending a Written Notice to Us at our Administrative Office. The date of rider termination will be the Monthly Anniversary Day on or next following the date we received Your Written Notice. If Your Policy becomes a MEC or the Policy terminates, the rider will terminate. For more information, see APPENDIX C: OPTIONAL BENEFIT EXAMPLES.

Neither the IRS nor the courts have ruled on the tax consequences of exercising the Overloan Lapse Protection Rider. It is possible that the IRS or a court could assert that the Policy has been effectively terminated and that the outstanding loan balance should be treated as a distribution, all or a portion of which could be taxable when the Overloan Lapse Protection Rider is exercised. In addition, this Overloan Protection Rider may not be appropriate for Your particular circumstances. Consult with a tax professional regarding the risks associated with exercising this Rider.

SUPPLEMENTAL PROTECTION RIDER This rider must be elected at issue and an additional charge will be deducted. The rider provides an amount of supplemental coverage on the Insured as long as the Policy is in force and the rider is not terminated Under the rider, the Specified Amount is increased for purposes of defining the Death Benefit. No further increases will be allowed but You can request a decrease in Specified Amount as discussed under "Decreasing the Specified Amount" under the section DEATH BENEFIT. The no lapse guarantee premium for the Policy will be increased by the rider as shown in the Policy. There is a charge for this rider that is expressed as an amount per $1,000 of Net Amount at Risk and will vary by the Issue Age, Risk Class, Policy duration (i.e., how long the Policy has been in force), and if permitted by state law, sex. For more information, see APPENDIX C: OPTIONAL BENEFIT EXAMPLES.

SURRENDER VALUE ENHANCEMENT RIDER This rider must be elected at issue and replaces the surrender charge schedule for Your Policy with a new schedule of surrender charges. There is a one-time charge for the rider which is deducted as part of the first Monthly Deduction taken for Your Policy. For more information, see APPENDIX C: OPTIONAL BENEFIT EXAMPLES.

WAIVER OF MONTHLY DEDUCTIONS RIDER This rider must be elected at issue and additional charges will be deducted. The rider waives the Monthly Deductions for the Policy that come due while the Insured is totally disabled, if such disability began prior to the Insured's Attained Age 65 and has existed continuously for six months. We must receive Written Notice of proof of Total Disability while the Insured is alive before waiving Monthly Deductions. We may require proof of continued Total Disability while the rider is being exercised, at Our expense. There is a charge for this rider that is expressed as an amount per $100 of benefit amount equal to the total monthly deductions and will vary by the Issue Age, Risk Class, Policy duration (i.e., how long the Policy has been in force), and if permitted by state law, sex. For more information, see APPENDIX C: OPTIONAL BENEFIT EXAMPLES.

Once this rider is exercised, You will no longer be able to make increases in Your Policy's Specified Amount, Accelerate the Specified Amount for purposes of this rider, change Your Death Benefit option, or add any new Riders to Your Policy.

Total Disability. "Total Disability" is defined under the rider as the Insured's inability, due to bodily injury or disease, to perform substantially all of the duties of the Insured's regular occupation for 24 consecutive months. After 24 consecutive months, total disability will be defined as the Insured's inability, due to bodily injury or disease, to perform substantially all of the duties of any occupation for which the Insured is reasonably suited by education, training or experience.

Waiver of Monthly Deductions. If Total Disability begins prior to the Insured's Attained Age 60, We will waive Monthly Deductions as long as Total Disability continues. If Total Disability begins after the Insured's Attained Age 60, We will waive Monthly Deductions for either two years from the beginning of such disability, or the date the Insured reaches Attained Age 65, whichever is later. Monthly Deductions that come due while we are determining eligibility will be deducted from Your Policy but will be credited back to Your Policy Value once We approve your request to exercise the rider. We will credit any Monthly Deductions taken back to the date Total Disability began but no more than one year from receipt by Us of Written Notice of proof of Total Disability.

Waiver of Monthly Deductions Rider Charge. The charge for this rider is deducted on each Monthly Anniversary Day and is calculated by taking the sum of Your Policy's Monthly Deductions and multiplying it by a factor found on the Rider Specifications Page.

ACCESS TO YOUR POLICY VALUE

You can access money in Your Policy in the following ways:

• by taking loans against Your Net Surrender Value;

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document • by requesting withdrawals after the first Policy Year; and • by surrendering Your Policy.

LOANS While a Policy is in force, the Owner may borrow money from the Policy using the Policy’s Net Surrender Value as the only security for the loan. A loan that is taken from and secured by a Policy may have tax consequences. See “Policy Loans” in TAXES.

Policy loans are subject to certain conditions:

• The minimum Loan Amount is $250. • The maximum amount an Owner may borrow (subject to any applicable state law requirement) is shown in the Policy.

When an Owner takes a loan, We will withdraw an amount equal to the requested loan from each of the Subaccounts and any Fixed Account based on allocation instructions from the Owner, and transfer that amount to the Loan Account. The Loan Account is part of Symetra Life’s General Account. No charge will be imposed for these transfers of Policy Value into the Loan Account, and these transfers are not treated as transfers in calculating any transfer processing fee.

If the Owner does not specify the allocation, We will deduct the amount of the loan taken from the Subaccount Value(s) and the Fixed Policy Value (excluding Loan Account Value) in the same proportion as We make Monthly Deductions. If that is not possible, then We will make the allocation based on the proportion that each Subaccount Value and the Fixed Policy Value (excluding Loan Account Value) bear to the Policy Value (less the Loan Account Value) as of the date that the transfer is made. If unpaid interest is due from an Owner on a Policy Anniversary, Policy Value in the amount of the interest is transferred to the Loan Account as of that anniversary and is added to the Loan Amount. The Policy Value transferred in connection with unpaid loan interest is allocated on the same basis as other Policy Value that We transfer to the Loan Account.

We normally pay the amount of the loan taken within seven days after We receive a loan request by Written Notice signed by the Owner, assignee, and any irrevocable Beneficiary. We will not be liable for processing a loan request if We believe the request is genuine. We may postpone payment of loans under certain conditions.

The interest rate We charge on borrowed amounts is the fixed loan rate shown in Your Policy. There is a Loan Account Value that is held as collateral for the loan. We will credit the amount in the Loan Account Value with interest at an effective annual rate that will not be lower than the guaranteed minimum interest rate for loan collateral shown in Your Policy.

Loan interest is payable in advance on the date of the loan and on each subsequent Policy Anniversary until the loan is repaid. Loan interest that is not paid on the date due increases the outstanding Loan Amount and is charged loan interest. You can repay a loan at any time while the Insured is living and the Policy is in force. Loan repayments must be sent to Our Administrative Office and will be credited as of the Valuation Day it is received in good order. We will consider each unplanned premium payment made while a loan is outstanding as a loan repayment, unless You specify otherwise in a Written Notice. Loan repayments first pay down interest, then any additional loan repayment goes toward paying down the loan principal. Unless the Owner instructs Us otherwise, We will allocate any repayment of loan principal to the Subaccounts and/or the Fixed Account in accordance with the Owner’s allocation instructions for Net Premium Payments in effect at the time of such repayment.

Effect of Policy Loans. A Policy loan reduces the Death Benefit Proceeds and Surrender Value by an amount equal to the sum of any unpaid Policy loan and accrued loan interest (the Loan Amount). Repaying the loan causes the Death Benefit Proceeds and Surrender Value to increase by the amount of the repayment. As long as a loan is outstanding, We hold an amount in the Loan Account equal to the amount of the Loan Amount as of the last Policy Anniversary plus any accrued interest. Loaned amounts do not participate in the investment performance of the Variable Account and may not be credited with the interest rates accruing on the portion of Policy Value in the Fixed Account. Loan Amount is not available for withdrawal or surrender.

Loans also reduce the number of Units in the Subaccounts and/or the value in the Fixed Account, which, in turn, increases:

• the risk that You will not accumulate enough Policy Value to meet Your future financial needs. • the potential for a Policy to Lapse if projected earnings, taking into account any Loan Amount, are not achieved and, for example, as a result, the Loan Account Value exceeds the Surrender Value. • the risk that Your Beneficiary will receive less money.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document WITHDRAWALS After the first Policy Year, You can request a cash withdrawal of a portion of Your Net Surrender Value subject to certain conditions. The minimum withdrawal amount is $250. The maximum withdrawal amount is equal to Your Net Surrender Value minus three months’ worth of Policy charges.

Withdrawals reduce Policy Value by the amount of the requested withdrawal plus any applicable withdrawal processing fee. If Your Death Benefit is Option "A", withdrawals will reduce the Specified Amount as described in Your Policy. There is no decrease in Specified Amount if Your Death Benefit is Option "B" or "C". If an Owner takes a withdrawal, We will reduce the number of Units in the Subaccounts and/or the value of the Fixed Account. As a result, withdrawals have an effect on Your Surrender Value and the Death Benefit payable under Your Policy. Withdrawals may also have tax consequences. See TAXES.

Withdrawal requests made by Written Notice received at Our Administrative Office before the NYSE closes, are priced using the Subaccount Unit value determined at the close of that regular business session of the NYSE (usually, 4:00 p.m. Eastern Time). If We receive the Written Notice at Our Administrative Office after the NYSE closes, or on a day that the NYSE is not open for trading, We will process the withdrawal request using the Subaccount Unit value determined at the close of the next regular business session of the NYSE. Your request must be submitted in good order to avoid a delay in processing the transaction.

Unless otherwise indicated in the request for a withdrawal, We will deduct amounts withdrawn and any withdrawal processing fees based on the allocation of Monthly Deductions. If that is not possible, then We will deduct withdrawals and any related withdrawal processing fee from the Subaccount Values and Fixed Policy Value based on the proportion that each Subaccount Value and the Fixed Policy Value bear to the Policy Value (excluding the Loan Account Value). If an Owner requests a decrease in Specified Amount as of the same date as a withdrawal, We will effect the withdrawal after the requested decrease in Specified Amount.

We currently do not assess a charge for withdrawals but reserve the right to charge a processing fee of $25 for each withdrawal taken. In addition, We reserve the right to reject a withdrawal request that would cause the Specified Amount of a Policy to be reduced below a minimum amount shown in Your Policy. We also reserve the right to reject any withdrawal request that would reduce the Specified Amount below the minimum We require for Policy issue or that would disqualify the Policy as life insurance under tax law.

SURRENDER You may end the insurance coverage under this Policy and receive the Net Surrender Value at any time by sending Written Notice to Us while the Insured is living and the Policy is in force. Once a Policy is surrendered, all coverage and other benefits under it cease and it cannot be reinstated.

If the Owner surrenders the Policy during the first nine (9) Policy Years (referred to here as the “surrender charge schedule”), We will deduct a surrender charge. See “Surrender Charge” in CHARGES AND FEES. The Net Surrender Value is equal to the Policy Value minus: (i) any applicable surrender charges; and (ii) any Loan Amount. The Surrender Value may be subject to additional taxes. See TAXES.

We will compute the Surrender Value as of the date We receive Your Written Notice in good order at Our Administrative Office. The "Surrender Value" is equal to the Policy Value minus any applicable surrender charge. We will make a single sum payment to You, unless You request an alternate settlement option by Written Notice. See Settlement Options under OTHER INFORMATION ABOUT THE POLICY. We have the right to postpone payment as permitted by law.

CONSEQUENCES OF LOANS, WITHDRAWALS AND SURRENDERS Making a withdrawal or taking a loan may:

• Reduce Your Policy’s Specified Amount. • Reduce the Death Benefit Proceeds paid to Your Beneficiary(ies). • Make Your Policy susceptible to Lapse. • Cause Your Policy to lose its tax status. • Trigger federal income taxes and possibly an additional tax.

Withdrawals reduce Your Policy Value. Withdrawals, especially those taken during periods of poor investment performance by the Subaccounts, could considerably reduce or eliminate some benefits or guarantees of the Policy.

The Loan Account Value does not participate in earnings from the Subaccounts or receive higher interest rates that may be available in the Fixed Account. Accordingly, loans, whether or not repaid, have a permanent effect on the amount of Policy Value You are able to

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document accumulate. Loans may also result in Policy Lapse if the Loan Amount reduces the Net Surrender Value to zero. You should consult a tax advisor before borrowing money from Your Policy.

You may be subject to income tax if:

• You take any withdrawals or surrender the Policy; or • Your Policy Lapses and You have not paid any outstanding Policy loans.

If Your Policy is treated as a MEC, withdrawals, surrenders, assignments, pledges and loans that You receive or make during the life of the Policy may be taxable and subject to an additional federal tax equal to 10% of the taxable amount if taken before age 59½. See “Modified Endowment Contracts” in TAXES.

You should consult a tax advisor to apply the law to Your particular circumstances.

TRANSACTION AUTHORITY Certain transactions may be permitted by telephone and electronically on the Internet and may require that we have properly signed authorization for your Policy on record. In addition, You may authorize someone else to make transactions by telephone, and if available on the Internet, on Your behalf. Symetra Life will not be liable for any failure to question or challenge such requests as long as there is a valid signed authorization on record at Symetra Life. Transactions submitted by Internet will require certain identification information, such as a password or personal identification information.

Although we use reasonable procedures, including recording all telephone instructions and requiring certain personal identification information to prevent unauthorized account access, we cannot assure You that telephone or Internet activity will be completely secure or free of delays or malfunctions. If You choose to make transactions by telephone or Internet, You must be willing to assume the risk of loss that may occur despite our reasonable efforts to verify identity. We are not responsible for the negligence or wrongful acts of third parties. POLICY LAPSE AND REINSTATEMENT

Failure to pay Planned Periodic Premium Payments will not necessarily cause a Policy to Lapse (terminate without value). Nor will paying all Planned Periodic Premium Payments necessarily prevent a Policy from lapsing. The Policy will Lapse if the Net Surrender Value is not sufficient to cover the Monthly Deduction and the Policy is not in a No Lapse Guarantee Period. More specifically, the Policy will be in default and a Grace Period of 61 days will begin if the Net Surrender Value on any Monthly Anniversary Day is less than the amount of the Monthly Deduction due on that date. This could happen if investment experience has been sufficiently unfavorable that it has resulted in a decrease in Net Surrender Value or the Net Surrender Value has decreased because the Owner has not paid sufficient Net Premium Payments to offset prior Monthly Deductions.

The Owner has a 61-day Grace Period to make a payment of premium at least sufficient to keep the Policy in force for two Policy months following the end of the Grace Period. We will mail to the Owner and to any assignee of record at their last known Address(es) of Record, notice of the premium payment or loan repayments required to prevent Lapse and to keep the Policy in force for two Policy months following the end of the Grace Period. Coverage under the Policy will continue during the Grace Period. If the Insured dies during the Grace Period, the Death Benefit payable to the Beneficiary(ies) will reflect a reduction for the Monthly Deductions due on or before the date of the Insured’s death as well as any Loan Amount or liens. Unless the amount of premium stated in the notice is paid before the Grace Period ends, the Policy will Lapse and all coverage under the Policy will end. (For this purpose, We consider payments mailed to Us as being received by Us on the date they are post-marked.) Policy Lapse may have tax consequences. See TAXES for more information.

No Lapse Guarantee. Your Policy has a no lapse guarantee that provides a period of time that Your Policy will not enter the Grace Period, even if the Net Surrender Value is insufficient to cover the Monthly Deduction. As long as You are in a No Lapse Guarantee Period, Your Policy will not enter the Grace Period and will not lapse. The amount of Your no lapse guarantee premium is shown on the Policy specifications page. After the No Lapse Guarantee period ends, the Policy Value may be insufficient to keep the Policy in force without additional premium payments made, and may lapse.

Attained Age 120. On the Monthly Anniversary Day immediately following the Insured’s reaching Attained Age 120, the Monthly Deductions will no longer apply and the Death Benefit will be changed to Death Benefit Option "A".

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Reinstatement. If Your Policy lapses, You have up to three (3) years from the end of the Grace Period and while the Insured is living, to request reinstatement of Your Policy. You cannot reinstate a Policy that has been surrendered or has reached the Maturity Date. Reinstatement allows You to keep Your original Policy Date, and the surrender charge is determined using that Policy Date.

To reinstate Your Policy, You must:

• provide Us satisfactory evidence of insurability; • pay premium in an amount sufficient to result (along with any loan repayments) in a positive Net Surrender Value; and

• pay premium that results in Net Premium Payments in an amount that covers or exceeds the amount of Monthly Deductions for at least three months following the reinstatement date.

Coverage that We reinstate under Your Policy becomes effective on the Valuation Day that falls on or next follows the later of the date that: (i) We approve Your application for reinstatement; and (ii) We receive any premium payment required for reinstatement.

Upon reinstatement, We will reinstate any Loan Amount at the time of Policy Lapse. In addition, the surrender charge and the following riders available under the Policy will be reinstated: Accelerated Death Benefit for Chronic Illness; Accelerated Death Benefit for Chronic Illness Plus; Accelerated Death Benefit for Terminal Illness; Charitable Giving Benefit; Overloan Lapse Protection; Supplemental Protection Rider; Surrender Value Enhancement Rider; and the Waiver of Monthly Deductions Rider.

The Policy Value of a reinstated Policy is the Policy Value on the date the Policy lapsed plus the amount of the Net Premium Payments submitted with the application for reinstatement.

Unlike many companies, We do not ask You to pay premium for the period after the Policy Lapsed and before reinstatement; nor is there insurance coverage for this period.

TAXES

This section discusses how federal income tax applies to the Policy in general. This information is not complete and is not intended as tax advice. Tax laws and their interpretations are complex and subject to change. This discussion is based upon Our understanding of the present federal income tax laws. Although the likelihood of legislative changes is uncertain, there is always the possibility that the tax treatment of the Policy could change by legislation or otherwise. We cannot represent that the present federal income tax laws or their interpretation will continue. You should consult counsel or another competent tax advisor about Your individual circumstances.

TAX STATUS OF THE POLICY If Your Policy meets certain requirements under the Code, it will be treated as life insurance for federal tax purposes and receive the tax treatment normally accorded life insurance contracts under federal tax law. Guidance as to how these requirements are to be applied is limited. Nevertheless, We believe that a policy issued on a standard class basis should satisfy the applicable requirements. There is less guidance, however, with respect to policies issued on a substandard basis, and it is not clear whether such policies will in all cases satisfy the requirements. We will monitor compliance of Your Policy with these requirements. If it is subsequently determined that a Policy does not satisfy the applicable requirements, We may take appropriate steps to bring the Policy into compliance with such requirements. We reserve the right to restrict Policy transactions in order to do so.

INVESTOR CONTROL In general, owners of variable life insurance policies receive tax deferral while the insured is living. This favorable tax treatment allows You to control the selection of and transfer among the Subaccounts without paying income tax unless You take money out of the Policy. In certain circumstances, however, owners of variable life insurance policies have been considered for federal income tax purposes to be the owners of the Subaccounts’ assets due to the ability of the owners to exercise investment control over those assets. Where this is the case, the policy owners were taxed on income and recognized gains attributable to the subaccounts’ assets. We believe Your Policy does not give You investment control over assets of the subaccounts. However, there is little guidance in the Code or Treasury Regulations in this area, and some features of the Policies, such as the flexibility to allocate premiums among Subaccounts, have not been explicitly addressed under federal tax law. If such guidance was issued, it could be applied either prospectively or retroactively and subject You to income tax consequences. The IRS issued Revenue Ruling 2003-91, which provides a safe harbor whereby the owner of a variable contract will not be treated as the owner of the underlying assets, and up to 20 investment options and 12 free transfers per year are

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document allowed. We reserve the right to modify the Policies, such as limiting the number of transfers allowed under the Policies, to prevent You from being treated as the owner of the assets supporting the Policy.

In addition, the Code requires that the investments of the Subaccounts meet certain diversification standards set by Treasury Regulations in order for the Policies to be treated as life insurance policies for federal income tax purposes. It is intended that the Subaccounts will satisfy these diversification requirements.

The following discussion assumes that the Policy will qualify as a life insurance contract for federal tax purposes.

As long as You do not transfer, assign, or sell Your Policy, We believe that the Death Benefit under Your Policy will not be included in Your Beneficiary’s gross income when the insured dies. If the death benefit is not received in a lump sum, however, and is instead applied under a proceeds option agreed to by Us and the Beneficiary, payments generally will be prorated between amounts attributable to the death benefit, which will be excludable from the Beneficiary’s income, and amounts attributable to interest (occurring after the Insured’s death), which will be includable in the Beneficiary’s income.

Federal, state and local transfer, and other tax consequences of ownership or receipt of policy proceeds depend on the circumstances of each Owner or Beneficiary. A tax advisor should be consulted on these consequences.

Generally, You will not pay income tax on the Policy Value until there is a distribution. When distributions from a Policy occur or when loans are taken out from or secured by a Policy, the tax consequences depend on whether the Policy is classified as a “Modified Endowment Contract” (“MEC”) as described in the Code and more fully described below.

MODIFIED ENDOWMENT CONTRACTS Under the Code, life insurance policies that are MECs are treated less favorably with respect to lifetime distributions than other life insurance policies. Because of the flexibility of the Policies as to premiums and benefits, the individual circumstances of each Policy will determine whether it is classified as a MEC. In general, Your Policy will be a MEC if the amount of premiums paid into the Policy causes the Policy to fail the “7-pay test.” A Policy will fail the 7-pay test if at any time in the first seven Policy Years, the amount paid into the Policy exceeds the total premiums that would have been paid for a Policy providing for paid-up future benefits after the payment of seven level annual premiums.

A Policy received in a tax-free exchange for a life insurance policy that was a MEC will also be classified as a MEC. If there is a reduction in the benefits under the Policy during the first seven Policy Years, for example, as a result of a withdrawal, the 7-pay test will have to be reapplied as if the Policy had originally been issued at the reduced Specified Amount. If there is a “material change” in the Policy’s benefits or other terms, even after the first seven Policy Years, the Policy may have to be retested as if it were a newly issued Policy. A material change can occur, for example, when there is an increase in the Death Benefit, including increases due to the payment of unnecessary premium. Unnecessary premiums are premiums paid into the Policy that are not needed to provide a death benefit equal to the lowest death benefit that was payable in the first seven Policy Years. To prevent Your Policy from becoming a MEC, it may be necessary to limit premium payments or to limit reductions in benefits. If Your Policy was not a MEC at issue, We will monitor it to determine whether a policy transaction will cause the Policy to be classified as a MEC. If a deposit received causes Your Policy to be a MEC, We will reverse the transaction and only deposit the portion of the transaction that does not result in MEC status. You should consult with a competent advisor to determine whether a policy transaction will cause the Policy to be classified as a MEC.

DISTRIBUTIONS (OTHER THAN DEATH BENEFITS) FROM MODIFIED ENDOWMENT CONTRACTS If Your Policy is a MEC, amounts You take out while the insured is living may be taxable income. All distributions other than death benefits, including surrenders and withdrawals, will be treated first as taxable income and then as tax-free recovery of the investment in the Policy after all gain in the Policy has been distributed. Loans taken or secured by the Policy will also be treated as distributions and taxed accordingly. There also may be 10% additional tax on distributions unless You are age 59½ or older, disabled, or take the distribution as a series of substantially equal periodic payments over Your life expectancy or the joint life expectancies of You and Your Beneficiary.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document If a Policy becomes a MEC, distributions that occur during the Policy Year will be taxed as distributions from a MEC. Distributions from a Policy within two years before the Policy becomes a MEC will also be taxed as distributions from a MEC. This means that a distribution made from a Policy that is not a MEC could later become taxable as a distribution from a MEC.

All MECs that are issued by Us (or Our affiliates) to You during any calendar year are treated as one MEC for purposes of determining the amount includable in Your income when a taxable distribution occurs.

DISTRIBUTIONS (OTHER THAN DEATH BENEFITS) FROM POLICIES THAT ARE NOT MODIFIED ENDOWMENT CONTRACTS If Your Policy is not a MEC, then distributions from Your Policy other than death benefits are generally treated first as a recovery of Your “investment in the policy,” and then as taxable income. Your investment in the Policy is generally the sum of

Your premiums. When a distribution is taken from Your Policy, Your investment in the Policy is reduced by the amount of the distribution that is tax-free. This means that withdrawals are generally treated as first recovering the premiums You paid into the Policy and then as taxable income. However, certain distributions that must be made in order to enable the Policy to continue to qualify as a life insurance policy for federal income tax purposes may be treated in whole or in part as ordinary income subject to tax.

Loans from, or secured by, the Policy are generally not treated as distributions. You should consult a tax advisor as to the tax treatment of such loans. Furthermore, a surrender or termination of the Policy by Lapse may have tax consequences if the Surrender Value plus outstanding Loan Amount is greater than premium paid into the Policy. If the Insured is alive on the Maturity Date and the Owner has elected not to extend insurance coverage beyond the Maturity Date, the Owner may have to pay federal income tax on the Policy Value (including any outstanding Loan Amount) that is attributable to earnings in the Subaccounts and interest in any available Fixed Account(s). Finally, neither distributions from, nor loans from or secured by, a Policy that is not a MEC are subject to the 10% additional income tax described above.

POLICY LOANS In general, interest on a Policy loan will not be deductible. If a Policy loan is outstanding when a Policy is canceled or Lapses, the amount of the outstanding insufficiency of Policy Value will be added to the amount distributed and will be taxed accordingly. Before taking out a Policy loan, You should consult a tax advisor as to the tax consequences.

CONTINUATION BEYOND AGE 100 The federal tax consequences of continuing the Policy beyond the Insured’s Attained Age 100 are unclear. The IRS has issued Revenue Procedure 2010-28 that provides a safe harbor concerning the application of the Code requirements to life insurance contracts that have mortality guarantees based on the 2001 CSO Table and which may continue in force after an insured attains age 100. If a contract satisfies all the Code requirements using all of the Age 100 SafeHarbor Testing Method requirements set forth in Rev. Proc. 2010-28, the IRS will not challenge the qualification of that contract as life insurance under the Code. Rev. Proc. 2010-28 also states that “No adverse inference should be drawn with respect to the qualification of a contract as a life insurance contract under §7702, or its status as not a MEC under §7702A, merely by reason of a failure to satisfy all of the requirements of the Age 100 Safe Harbor.” Revenue Procedure 2018-20 modifies and supersedes Revenue Procedure 2010-28 to the extent life insurance contracts have mortality guarantees based on the 2017 CSO Table.

You should consult a tax advisor if You intend to keep the Policy in force past the Insured's Attained Age 100.

TAX WITHHOLDING To the extent that the Policy distributions are taxable, they are generally subject to withholding at a rate of 10% for the distribution recipient’s federal income tax liability. Recipients may generally elect, however, not to have tax withheld or to have withholding done at a different rate. We may be required to withhold at a rate of 30% under the Foreign Account Tax Compliance Act (“FATCA”) on certain distributions to foreign financial institutions and non-financial foreign entities holding accounts on behalf of and/or the assets of U.S. persons unless the foreign entities provide Us with certain certifications regarding their status under FATCA on the applicable IRS forms. Prospective purchasers with accounts in foreign financial institutions or non-financial foreign entities are advised to consult with a competent tax advisor regarding the application of FATCA to their purchase situation.

BUSINESS USE OF THE POLICY Businesses may use the Policy in various business arrangements, including non-qualified deferred compensation plans, split dollar insurance plans, executive bonus plans, tax exempt and nonexempt welfare benefit plans, and retiree medical benefit plans. The tax consequences of such plans will vary depending on the circumstances of the arrangement. If You are purchasing the Policy for any arrangement the value of which depends in part on its tax consequences, You should consult a qualified tax advisor.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document In recent years, moreover, Congress has adopted new rules relating to life insurance owned by businesses. The Internal Revenue Service and the Treasury Department have issued guidance that substantially affects split-dollar arrangements. Any business considering the purchase of a new Policy or a change in an existing Policy should consult a tax advisor.

Furthermore, federal corporate governance legislation known as the Sarbanes-Oxley Act of 2002 (the “Act”) prohibits publicly traded companies from extending personal loans to their directors and officers. Under the Act, split-dollar life insurance arrangements for directors and officers of such companies may be considered a prohibited loan. It is unclear whether premiums paid in connection with such split-dollar life insurance arrangements will be considered prohibited loans under the Act.

Although the prohibition on loans is generally effective as of July 30, 2002, there is an exception for loans outstanding as of the date of enactment, so long as there is no material change to the loan terms and the loan is not renewed after July 30, 2002. Any affected business contemplating the payment of a premium on an existing Policy, or the purchase of a new Policy, in connection with a split- dollar life insurance arrangement should consult legal counsel.

NON-INDIVIDUAL OWNERS AND BUSINESS BENEFICIARIES OF POLICIES If a Policy is owned or held by a corporation, trust or other entity that is not a natural person, this could jeopardize some or all of such entity’s interest deduction under Code section 264, even where such entity’s indebtedness is in no way connected to the Policy. In addition, under Code section 264(f)(5), if a business (other than a sole proprietorship) is directly or indirectly a Beneficiary of a Policy, the Policy could be treated as held by the business for purposes of the Code section 264(f) entity-holder rules. A qualified tax advisor should be consulted before any non-natural person is made an Owner or holder of a Policy, or before a business (other than a sole proprietorship) is made a Beneficiary of a Policy.

EMPLOYER-OWNED LIFE INSURANCE POLICIES Pursuant to Code section 101(j), unless certain eligibility, notice and consent requirements are satisfied, the amount excludable as a death benefit payment under an employer-owned life insurance policy will generally be limited to the premiums paid for such policy (although certain exceptions may apply in specific circumstances). An employer-owned life insurance policy is a life insurance policy owned by an employer that insures an employee of the employer and where the employer is a direct or indirect beneficiary under such policy. It is the employer’s responsibility to verify the eligibility of the intended Insured under employer-owned life insurance policies and to provide the notices and obtain the consents required by Code section 101(j). These requirements generally apply to employer owned life insurance policies issued or materially modified after August 17, 2006. A tax adviser should be consulted by anyone considering the purchase of an employer-owned life insurance policy.

TAX SHELTER REGULATIONS We do not believe that any purchase of a Policy by an Owner pursuant to this offering will be subject to the tax shelter registration, customer list or reporting requirements under the Code and implementing regulations. Prospective owners that are corporations should consult a tax advisor about the treatment of the Policy under the Treasury Regulations applicable to corporate tax shelters.

OTHER TAX CONSIDERATIONS The transfer of the Policy or designation of a Beneficiary may have federal, state, and/or local transfer and inheritance tax consequences, including the imposition of gift, estate, and generation-skipping transfer taxes. For example, the transfer of the Policy to, or the designation as a Beneficiary of, or the payment of proceeds to, a person who is assigned to a generation which is two or more generations below the generation assignment of the Owner may have generation skipping transfer tax consequences under federal tax law. Treasury Regulations issued under the Code may require Us to deduct the tax from Your Policy, or from any applicable payment, and pay it directly to the Internal Revenue Service. The individual situation of each Owner or Beneficiary will determine the extent, if any, to which federal, state, and local transfer and inheritance taxes may be imposed and how ownership or receipt of policy proceeds will be treated for purposes of federal, state and local estate, inheritance, generation skipping and other taxes.

For 2021, the federal estate tax, gift tax, and generation skipping transfer tax exemptions are $11,700,000 for an individual ($23,400,000 for a married couple) and maximum rates are 40%.

The potential application of these taxes underscores the importance of seeking guidance from a qualified adviser to help ensure that Your estate plan adequately addresses Your needs and those of Your beneficiaries under all possible scenarios.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document The uncertainty as to how the current law might be modified in coming years underscores the importance of seeking guidance from a qualified adviser to help ensure that Your estate plan adequately addresses Your needs and those of Your beneficiaries under all possible scenarios.

MEDICARE TAX ON INVESTMENT INCOME The 3.8% Medicare tax on investment income applies to individuals whose income exceeds certain threshold amounts. You should consult a tax advisor about the impact of this tax on distributions from the Policy.

LIFE INSURANCE PURCHASES BY RESIDENTS OF PUERTO RICO In Rev. Rul. 2004-75, 2004-31 I.R.B. 109, the Internal Revenue Service announced that income received by residents of Puerto Rico under life insurance contracts issued by a Puerto Rico branch of a United States life insurance company is U.S.-source income that is generally subject to United States federal income tax.

LIFE INSURANCE PURCHASES BY NONRESIDENT ALIENS AND FOREIGN CORPORATIONS Purchasers that are not U.S. citizens or residents will generally be subject to U.S. federal withholding tax on taxable distributions from life insurance policies at a 30% rate, unless a lower treaty rate applies. In addition, purchasers may be subject to state and/or municipal taxes and taxes that may be imposed by the purchaser’s country of citizenship or residence. Prospective purchasers that are not U.S. citizens or residents are advised to consult with a qualified tax adviser regarding U.S. and foreign taxation with respect to a life insurance policy purchase.

POSSIBLE TAX LAW CHANGES Although the likelihood of legislative changes is uncertain, there is always the possibility that the tax treatment of the Policy could change by legislation or otherwise. Consult a tax adviser with respect to legislative developments and their effect on the Policy.

OUR INCOME TAXES Under current federal income tax law, We are not taxed on the Variable Account’s operations. Thus, currently We do not deduct a charge from the Variable Account for federal income taxes. We reserve the right to charge the Variable Account for any future federal income taxes We may incur.

Under current laws in several states, We may incur state and local taxes (in addition to premium taxes). These taxes are not now significant and We are not currently charging for them. If they increase, We may deduct charges for such taxes.

OTHER INFORMATION ABOUT THE POLICY

POLICY MATURITY The “Maturity Date” is the Policy Anniversary nearest the date when the Insured reaches Attained Age 120. A Policy that is in force on the Maturity Date will automatically continue in force (unless otherwise elected by the Owner) until the death of the Insured (unless loans cause the Loan Account to exceed the Surrender Value), at which time the Death Benefit Proceeds will be paid to the Beneficiary(ies). If, however, an Owner notifies Us in writing of the Owner’s election not to extend insurance coverage beyond the Maturity Date, then the Policy will terminate and We will pay the Owner the Net Surrender Value, if any, in a single sum or, alternatively, in a settlement option (as described below) on the Maturity Date.

Note: • If a Policy is in a Grace Period on the Maturity Date, the minimum amount required to get out of the Grace Period must be paid before that Policy can be continued. • Coverage beyond the Maturity Date will not be extended if a Policy would fail the definition of life insurance under the Code. • Continuing a Policy beyond the Insured’s Age 100 may have tax consequences. You should contact a tax advisor if You intend to keep the Policy in force beyond the Insured’s Age 100. See TAXES for more information.

If insurance coverage is extended beyond the Maturity Date:

• 100% of an Owner’s Policy Value (less any Loan Account Value) must be transferred to the Fixed Account. Interest will be credited monthly to the Owner’s account value at an effective annual rate of at least the guaranteed minimum rate then available under the Policy. • The Death Benefit will be changed to "Option A"; • No premium payments will be accepted. • No monthly deductions will be taken. • No transfers or withdrawals can be requested. • New loans will be allowed and loan interest will continue to be charged on any Loan Amount. Loan repayments can be made.

SETTLEMENT OPTIONS We will pay Owners (including contingent Owners) or Beneficiaries (including any Contingent Beneficiaries)-each a “Payee”-the amount of any surrender proceeds, withdrawal proceeds, or Death Benefit Proceeds in a single sum unless the Owner has, by Written Notice, chosen an alternate settlement option that We make available at the time such proceeds and insurance benefits become payable. Contact Us at Our Administrative Office to obtain information about alternate settlement options.

We will transfer to the Fixed Account any amount (“Proceeds”) placed under an alternate settlement option, which amount will not be affected thereafter by the investment performance of the Variable Account. When the Proceeds are payable, We will

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Table of Contents Definitions inform the Payee of the rate of interest We will credit to the amounts left with Us. We will credit a minimum guaranteed rate of interest and may pay interest in excess of that guaranteed rate.

Alternate Settlement Options. The following alternate settlement options are available. Other forms of payout may be requested but are subject to the Company’s approval. Once payouts under a settlement option begin, the selected alternate settlement option cannot be changed.

1. Payments for a Specified Period. If the payments for a Specified Period Option is selected, the Company will make equal payments to the Payee for a specified number of years, at specified intervals-i.e., every 1 year, 6 months, 3 months or 1 month. The duration of the payout period and the frequency of the payments is specified at the time the settlement option is selected. The amount of each settlement payment is computed using the factors shown in Your Policy. If the Payee dies before the expiration of the specified number of years, unless instructed otherwise at the time that this settlement option is selected, the Company pays the value of the remaining payments in a single sum to the Payee’s estate.

Conditions.

1. The amount of proceeds being applied to an alternate settlement option must be at least $5,000; otherwise, the proceeds will be paid in a single sum by check. 2. The frequency of payments under a settlement option must result in installment payments of not less than $100. 3. If the Owner or Beneficiary (including any Contingent Beneficiary) receiving payment is an executor, administrator, trustee, or not a natural person, payment is made in a single sum unless We consent to payment under an alternate settlement option. 4. If the Owner has not selected a method for payment of Death Benefit Proceeds before the time of the Insured’s death, then the Beneficiary (or Contingent Beneficiary) can choose a method of payment before such Death Benefit Proceeds are paid. 5. The Owner may elect to receive the Net Surrender Value or the amount of a withdrawal in the form of an alternate settlement option at any time before payment of the surrender proceeds or withdrawal proceeds is made.

PAYMENTS WE MAKE We usually pay the amounts of any surrender, withdrawal, or Death Benefit Proceeds involving Variable Policy Value within seven calendar days after We receive all applicable Written Notices and/or Due Proof of Death in good order at Our Administrative Office. However, We can postpone such payments if:

• the NYSE is closed (other than customary weekend or holiday closings); or • trading on the NYSE is restricted, as determined by the SEC; or • an emergency exists that would make the disposal of securities held in the Variable Account, or determination of their value, not reasonably practicable; or • the SEC permits, by an order, the postponement for the protection of Owners.

If You have submitted a recent check or draft, We have the right to defer payment of surrenders, withdrawals, loans, life insurance benefit proceeds, or payments under a settlement option until such check or draft has been honored. In addition, We reserve the right to defer payment of transfers, loans, withdrawals, or surrender from the Fixed Account for the period permitted by law, but not for more than six months.

Federal laws designed to counter terrorism and prevent money laundering by criminals might, in certain circumstances, require Us to reject a premium payment and/or block an Owner’s account and thereby refuse to pay any request for transfers, withdrawals, surrenders, loans, or life insurance benefits until instructions are received from the appropriate regulators. We may also be required to provide additional information about You or Your Policy to government regulators.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document MISSTATEMENT OF AGE OR GENDER If the age or, if permitted by state law, sex of the Insured was stated incorrectly in the application (or any supplemental application), then the Death Benefit and any benefits provided under the Policy by rider or endorsement will be adjusted to the amount that would have been payable at the correct age and, if permitted by state law, sex, based on the deduction for cost of insurance and other charges (and the cost of any benefits provided by rider or endorsement) in effect on the Policy Date.

REPORTS TO POLICY OWNERS We will send You the following statements and reports:

• a confirmation for many significant transactions, such as changes in future premium allocations, transfers among Subaccounts, and address changes; and • semi-annual and annual reports of the Funds.

In addition, at least annually, or more often as required by law, We will send to Owners at the last known address of the Owner and/or the last known address of an assignee of record, reports showing the following items at the end of the report period:

• current Policy Value, Surrender Value, Net Surrender Value, and Death Benefit; • current Variable Policy Value (including each Subaccount Value), Fixed Policy Value and Loan Account Value; • current Loan Amount; • any premium payments, withdrawals or surrenders made, and any charges deducted since the last report; • current Net Premium Payment allocations; and • other information required by law.

On request, We will send You a current statement in a form similar to that of the annual statement described above. We reserve the right to limit the number of such requests or impose a reasonable charge for additional requests.

POLICY TERMINATION Your Policy will terminate and all benefits under it will cease on the earliest of the following:

1. The date the Policy Lapses. 2. The date We receive, in good order, Your written request to surrender or terminate the Policy. 3. The date of the Insured’s death.

ASSIGNMENT You may assign the Policy while the Insured is alive. The assignment will become effective when We receive Written Notice in good order at Our Administrative Office. We are not bound by any assignment unless we receive Written Notice of the assignment, in good order, at our Administrative Office. Your rights and those of any other person under the Policy are subject to the assignment. We are not responsible for the validity of any assignments and we are not liable for any action We take or payment We make prior to Our receipt of Written Notice. Your assignee may not change the Owner or the Beneficiary, and may not elect or change an optional method of payment. Any amount payable to the assignee will be paid in a lump sum. An absolute assignment will be considered a change of ownership. We are not bound by any assignment which results in adverse tax consequences to the Owner, Insured or Beneficiary(ies). Assigning the Policy may have tax consequences. You should consult a tax advisor before assigning the Policy.

DISTRIBUTION OF THE POLICIES

DISTRIBUTION The Policies are distributed by Symetra Securities, Inc. (“SSI”). They are sold by individuals who, in addition to being licensed to sell variable life insurance for Symetra Life, are also registered representatives of broker-dealers who have a current sales agreement with SSI and Symetra Life. SSI is an affiliate of Symetra Life and is located at 777 108th Avenue NE, Suite 1200, Bellevue, WA 98004. It is registered as a broker- dealer with the SEC under the Securities Act of 1934 and is a member of the Financial Industry Regulatory Authority (FINRA). No amounts are retained by SSI for acting as principal underwriter for Symetra Life policies.

Registered representatives who solicit sales of the Policies receive a portion of the commission payable to the broker-dealer firm, depending on the agreement between the broker-dealer and the registered representative. A broker-dealer firm or registered

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document representative may receive different commissions for selling one variable life insurance policy over another and may favor one provider over another due to different compensation rates.

We pay commissions as a percentage of premiums invested in the Policy.

To the extent permitted by rules of the FINRA, promotional incentives or payments may also be provided to broker-dealers based on sales volumes, the assumption of wholesaling functions or other sales-related criteria. Other payments may be made for other services that do not directly involve the sale of the Policies. These services may include the recruitment and training of personnel, production of promotional literature, and similar services.

No specific charge is assessed directly to Owners or the Variable Account to cover commissions and other incentives or payments described above. We do intend to recoup commissions and other sales expenses We pay, however, through fees and charges deducted under the Policy and other corporate revenue.

Because differences in compensation or incentives that a registered representative may receive for selling one product over another may create an incentive for the selling firm or its sales representatives to recommend or sell the Policy to You. You may wish to take such incentives into account when considering and evaluating any recommendations relating to the Policy.

STATE VARIATIONS This prospectus describes the material rights, benefits and obligations under the Policy. Certain provisions of the Policy may be different from the general description in this prospectus because of variations required by state law. For example, state law may require different “free-look” (or cancellation) periods, which is the amount of time allowed to examine the Policy and return it for a refund. The state in which Your Policy is issued also governs whether certain riders, options, charges or fees are available or will vary under Your Policy. Please see APPENDIX B: STATE VARIATIONS for a listing of state variations as well as Your Policy for any state specific variations applicable to You. Any such state variations will be included in Your Policy or in endorsements or riders attached to Your Policy. You should refer to Your Policy for specific variations applicable to You. If You would like to review a copy of Your Policy and its endorsements and riders, if any, contact Our Administrative Office or Your sales representative.

GOOD ORDER We will execute Written Notices and telephone transactions only if these are in “good order”. For Written Notices, good order means using the form provided by Us for the request or transaction, or providing in writing all the information required by the form. We accept documents constituting Written Notices by mail and facsimile transmission. Generally, for most transactions our forms require the Owner(s) name, Policy number, signatures of all Owners, assignees and irrevocable Beneficiaries, if any, and information necessary for Us to carry out the request (e.g., for transfers of Policy Value the Subaccount from which and to which Policy Value is to be transferred and the amount of the transfer; for withdrawals the Subaccount from which the withdrawal will be made and the amount of the withdrawal, as well as the party to whom a check for withdrawal proceeds must be made out to). Depending on the type of transaction, additional information may be required such as an Owner’s social security number or tax ID number, or the names or signatures of Beneficiaries or of an Owner’s spouse. For Written Notices via an Owner’s account on Our website, good order means providing PINs or meeting other security requirements. For telephone transactions, good order means We have the information on file that is required by the appropriate form or hearing that information in Your telephone instruction, as well as Us having on file a telephone transaction authorization form signed by the Owner.

Instructions relating to allocation of Net Premium Payments also must be in good order before We can apply such payments. Such instructions consist of fully completing the appropriate form or providing Us with such information by Written Notice (providing the exact name of the appropriate Subaccount).

UNCLAIMED OR ABANDONED PROPERTY Every state has unclaimed property laws that generally provide for escheatment to the state of unclaimed property (including Death Benefit Proceeds under the Policy) under various circumstances. In addition to state unclaimed property laws, We may be required to escheat property pursuant to regulatory demand, finding, agreement or settlement. To help prevent possible escheatment of Your property, it is important that You keep Your contact and other information on file with Us up to date, including the full names, complete addresses, and any other contact or identifying information for Owners, Insureds, and Beneficiaries.

LEGAL PROCEEDINGS We, like other life insurance companies, are subject to regulatory and legal proceedings, including class action lawsuits, in the ordinary course of Our business. Such legal and regulatory matters include proceedings specific to Us and other proceedings generally applicable to business practices in the industry in which We operate. In some lawsuits and regulatory proceedings involving insurers, substantial

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document damages have been sought and/or material settlement payments have been made. Although the outcome of any litigation or regulatory proceeding cannot be predicted with certainty, at the present time, We believe that there are no pending or threatened proceedings or lawsuits that are likely to have a material adverse impact on the Variable Account, on SSI’s ability to perform under its principal underwriting agreement, or on Our ability to meet Our obligations under the Policy.

FINANCIAL STATEMENTS The financial statements of Symetra Life and the Variable Account are included in the Statement of Additional Information and are prepared on a statutory basis. Our audited statutory-basis financial statements can be found online at www.symetra.com/

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Table of Contents Definitions regulatoryreports and are also included in the Statement of Additional Information (which is available at no charge by calling Us at 1-800-796-3872 or by writing Us at Our Administrative Office). In addition, the Statement of Additional Information is available on the SEC's website at https://www.sec.gov.

APPENDIX A: PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY

The following is a list of Funds available under the Policy. More information about the Funds is available in the prospectuses for the Funds, which may be amended from time to time and can be found online at www.symetra.com/regulatoryreports. You can also request this information at no cost by calling Us at 1-800-796-3872 or by sending an email request to [email protected].

The current expenses and performance information below reflects fees and expenses of the Funds, but do not reflect the other fees and expenses that Your Policy charges. Expenses would be higher and performance would be lower if these other charges were included. Each Fund’s past performance is not necessarily an indication of future performance.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document CURRENT AVERAGE ANNUAL TOTAL EXPENSES RETURN TYPE FUND NAME AND ADVISOR (As of 12/31/ (As of 12/31/2020) 2020) 1 Year 5 Year 10 Year

American Funds IS® Growth Fund - Class 1 U.S. Equity 0.36% 52.45% 23.06% 17.14% Capital Research and Management Company

(DFA) VIT Inflation - Protected Securities Portfolio Taxable Bond 0.14% 11.72% 5.22% NA Dimensional Fund Advisors, LP

Fidelity® VIP Extended Market Index Portfolio - Initial Class Fidelity Management & Research Company (FMR) is the fund's Investment U.S. Equity 0.13% 16.46% NA NA Advisor. FMR UK, FMR HK and FMR Japan serve as sub-advisers for the fund. (*)

Fidelity® VIP Index 500 Portfolio - Initial Class U.S. Equity Fidelity Management & Research Company (FMR) is the fund's Investment 0.10% 18.24% 15.09% 13.78% Advisor. Geode serves as sub-adviser for the fund. (*)

Goldman Sachs VIT Government Money Market Institutional Class Money Market 0.18% ** 0.43% 1.06% NA Goldman Sachs Asset Management, L.P.

Vanguard VIF - Balanced Portfolio Asset Allocation 0.20% 10.68% 10.77% 9.88% Wellington Management Company, LLP

Vanguard VIF - Conservative Allocation Portfolio Asset Allocation 0.13% 11.73% 8.10% NA The Vanguard Group, Inc.

Vanguard VIF - Diversified Value Portfolio U.S. Equity 0.28% 11.78% 10.30% 10.60% The Vanguard Group, Inc.

Vanguard VIF - High Yield Bond Portfolio Taxable Bond 0.26% 5.67% 7.22% 6.38% Wellington Management Company, LLP

Vanguard VIF - Mid-Cap Index Portfolio U.S. Equity 0.17% 18.07% 13.14% 12.26% The Vanguard Group, Inc.

Vanguard VIF - Total Bond Market Index Portfolio Taxable Bond 0.14% 7.58% 4.36% 3.71% The Vanguard Group, Inc.

Vanguard® VIF -Total International Stock Market Index Portfolio International Equity 0.10% 11.18% NA NA The Vanguard Group, Inc.

Vanguard VIF - Total Stock Market Index Portfolio U.S. Equity 0.13% 20.55% 15.23% 13.60% The Vanguard Group, Inc.

We do not guarantee that each Fund will always be available for investment through the Policy.

* Fidelity and the Fidelity Investments Logo are registered service marks of FMR LLC. Used with permission.

** Annual expenses reflect temporary fee reductions.

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APPENDIX B: STATE VARIATIONS

The following information is a summary of the states where the Accumulator Variable Universal Life Policy or certain features and/or benefits vary from the Policy's features and benefits as previously described in this prospectus. Certain provisions of the Policy may be different from the description in this prospectus due to variations required by state law. The state in which Your Policy is issued also governs whether or not certain riders, options, charges or fees are available or will vary under Your Policy. Any state variations will be included in Your Policy or in riders or endorsements attached to Your Policy.

STATE FEATURE OR BENEFIT VARIATION OR AVAILABILITY Delaware See "Death Benefit Proceeds" under the Death Benefit Proceeds will be paid from the date of death to the date of Section titled DEATH BENEFIT. payment as an annual interest rate of 1%. Florida See "Cancellation Period" under the If you reside in Florida, You may cancel Your Policy within 14 days Section titled PURCHASING A POLICY from the date You received it. If Your Policy is a replacement of another insurance or annuity contract, You may return it within 30 days from the date You received it. See "Death Benefit Proceeds" under the We will pay interest on the Death Benefit Proceeds from the date we Section titled DEATH BENEFIT receive Due Proof of Death to the date the claim is paid at an annual rate equal to or greater than the Moody’s Corporate Bond Yield Average. North Dakota See "Death Benefit Proceeds" under the Death Benefit Proceeds will be paid from the date of death to the date of Section titled DEATH BENEFIT. payment as an annual interest rate of 1%. South Dakota See "Death Benefit Proceeds" under the Death Benefit Proceeds will be paid from the date of death to the date of Section titled DEATH BENEFIT. payment as an annual interest rate of 1%.

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APPENDIX C: OPTIONAL BENEFIT EXAMPLES

EXAMPLE: ACCELERATED DEATH BENEFIT FOR CHRONIC ILLNESS RIDER Assume that the Policy is purchased by a 65 year-old male who is a non-nicotine user and requests to accelerate 50% of the available Death Benefit. On the day we calculate the accelerated death benefit payout, the Policy Value is $69,106.53 with an outstanding Policy loan of $5,000 and no additional premiums are due. Further assume, the Death Benefit is $100,000.

Based upon the assumptions above, the following shows how we would do the calculation. Death Benefit on the date we calculate rider benefit = $100,000

Requested amount to be accelerated (50% of $100,000) = $50,000

Less loan adjustment ($50,000 - $5,000) = $45,000

TOTAL ACCELERATED DEATH BENEFIT PAYOUT = $45,000

After the rider is exercised, the $50,000 rider accelerated amount is considered a lien and will result in the following reductions: After Acceleration Assuming No Acceleration Death Benefit Proceeds (Death Benefit minus any lien = $50,000 $100,000 amount)

Policy Value = $69,106.53 $69,106.53

Outstanding Loan and Loan interest = $0.00 $5,000

Net Surrender Value (Policy Value minus Loan Amount) = $69,106.53 $64,106.53

Lien Amount = $50,000.00 $0.00

Amount Available for Loans or Withdrawals = $19,106.53 $64,106.53

EXAMPLE: ACCELERATED DEATH BENEFIT FOR CHRONIC ILLNESS PLUS RIDER Under the Accelerated Death Benefit for Chronic Illness Plus Rider, You can access 100% of Your Death Benefit in advance if You meet the rider requirements. The benefit can be paid as either an annual single sum or through monthly payments over a 50-month period. Assume that the Owner requests to accelerate 100% of the Death Benefit, the Per Diem Limit is $400 and the Rider Benefit Balance is $115,326.

Monthly Payment of Accelerated Death Benefit Payout is the lesser of: • 2% of Your Rider Benefit Balance as of the day of the initial Payment Period; and • The Per Diem limit multiplied by 30

Monthly Payment for First Payment Period of 12-Months

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Based upon the assumptions above, the following shows how we would do the monthly payment calculation for the Initial Payment Period of 12 Months: 2% of Rider Benefit Balance (2% of $115,326) = $2,307

Per Diem Limit multiplied by 30 ($400 x 30) = $12,000

Determine Lesser Amount ($2,307 ≤ $12,000) = $2,307

TOTAL MONTHLY ACCELERATED DEATH BENEFIT PAYOUT = $2,307

Monthly Payment for Second Payment Period of 12-Months:

C-1

Based upon the assumptions above, the following shows how we would do the monthly payment calculation for the second Payment Period of 12-Months. Recalculate the Rider Benefit Balance (Death Benefit minus Payments Made) = $87,642 ($115,326 - (12 x $2,307) = $87,642) 2% of Rider Benefit Balance (2% of $87,642) = $1,752.84

Per Diem Limit multiplied by 30 ($400 x 30) = $12,000

Determine Lesser Amount ($1,752.84 ≤ $12,000) = $1,752.84

TOTAL MONTHLY ACCELERATED DEATH BENEFIT PAYOUT = $1,752.84

Lump Sum Payment of Accelerated Death Benefit Payout is the lesser of: • 2% of Your Rider Benefit Balance multiplied by the number of Months in the Payment Period; and • The per diem limit multiplied by 30 and multiplied by the number of Months in the Payment Period

Single Sum Payment for First Payment Period of 12-Months Based upon the assumptions above, the following shows how we would do the single sum payment calculation: 2% of Rider Benefit Balance (2% of $115,326 x 12) = $27,684

Per Diem Limit multiplied by 30 ($400 x 30 x 12) = $144,000

Determine Lesser Amount ($27,684 ≤ $144,000) = $27,684

TOTAL SINGLE SUM ACCELERATED DEATH BENEFIT PAYOUT = $27,684

Single Sum Payment for Second Payment Period of 12-Months:

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Based upon the assumptions above, the following shows how we would do the single sum payment calculation for the second Payment Period of 12-Months. Recalculate the Rider Benefit Balance (Death Benefit minus Payments Made) = $87,642 ($115,326 - $27,684 = $87,642)

2% of Rider Benefit Balance (2% of $87,642 x 12) = $21,034.08

Per Diem Limit multiplied by 30 ($400 x 30 x 12) = $144,000

Determine Lesser Amount ($21,034.08 ≤ $144,000) = $21,034.08

TOTAL SINGLE SUM ACCELERATED DEATH BENEFIT PAYOUT = $21,034.08

EXAMPLE: ACCELERATED DEATH BENEFIT FOR TERMINAL ILLNESS RIDER

Assume that the Policy is purchased by a 65 year-old male who is a non-nicotine user and requests to accelerate 70% of the available Death Benefit. On the day we calculate the accelerated death benefit payout, the Policy Value is $60,355 with an outstanding Policy loan of $5,200 and no additional premiums are due. Further assume, the Death Benefit is $800,000.

C-2

Based upon the assumptions above, the following shows how we would do the calculation. Death Benefit on the date we calculate rider benefit = $800,000

Requested amount to be accelerated (70% of $800,000) = $560,000

Requested Amount compared to Maximum Rider Amount $560,000 ≥ $500,000

Accelerate Death Benefit Amount = $500,000 Less Loan Amount ($500,000 - $5,200) = 494,800

TOTAL ACCELERATED DEATH BENEFIT PAYOUT = $494,800

After the rider is exercised, the following reductions will occur: Death Benefit Proceeds ($800,000 -$500,000) = $300,000 (Death Benefit minus Accelerated Death Benefit Amount)

Reduction Percentage ($500,000/$800,000) = 62.5% (Accelerated Amount compared to the Death Benefit at the time of exercise)

Policy Value Reduction (62.5% x $60,355) = $37,721.88

New Policy Value ($60,355 - $37,721.88) = $22,633.12

EXAMPLE: CHARITABLE GIVING BENEFIT RIDER Assume that the Policy is purchased by a 45 year-old male who is a standard non-nicotine user with a Specified Amount of $500,000. The Insured informs Us of their designed 501(f)(3) charity on the Issue Date. Upon the death of the Insured, the Charitable Giving Benefit Rider is exercised and the donation is calculated as follows:

Based upon the assumptions above, the following shows how we would do the calculation. Donation Amount (1% x $500,000) = $5,000 (1% x Specified Amount)

Compare Donation Amount to Rider Maximum = $5,000 ≤ $100,000 (Donation Amount Compared to $100,000)

TOTAL AMOUNT PAID TO CHARITY = $5,000

Assume the same facts above except that the Specified Amount is $20,000,000. Upon the death of the Insured, the Charitable Giving Benefit Rider is exercised and the donation is calculated as follows:

Compare Donation Amount to Rider Maximum = $200,000 ≥$100,000 (Donation Amount Compared to $100,000)

Because 1% of the Specified Amount is greater than the Rider Maximum, We will pay the designate charity the Rider Maximum Amount.

TOTAL AMOUNT PAID TO CHARITY = $100,000

C-3

EXAMPLE: OVERLOAN LAPSE PROTECTION RIDER The Overloan Lapse Protection Rider ("OLP Rider") prevents the Policy from Lapsing due to insufficient Policy Value by waiving all future monthly deductions and charges. Assume that the Insured has submitted a Written Request to exercise the rider and We have determined that all requirements for the rider are met. Assume the following facts are true:

• Specified Amount is $1,000,000 • Policy Value is $975,000 • Loan Balance is $906,750 • OLP Rider Exercise Charge Rate is 5.0%

Based upon the assumptions above, the following shows how we would calculate the OLP Rider charge. Policy Value multiplied by the OLP Rider Exercise Charge Rate = $48,750.00 ($975,000 x 5.0%) Determine if the Policy Value minus the outstanding Loan Amount is sufficient to cover the OLP Rider charge Policy Value - Loan Amount ($975,000 - $906,750 = $68,250) $68,250 ≥ $48,750 TOTAL OLP RIDER CHARGE = $48,750.00

After deduction of the OLP Rider charge, the remaining values would be: Policy Value after OLP Rider charge deduction = $926,250.00 ($975,000 - $48,750) Net Specified Amount = Specified Amount minus Loan Amount = $93,250.00 ($1,000,000 - $906,750)

EXAMPLE: SUPPLEMENTAL PROTECTION RIDER Under the Supplemental Protection Rider ("SPR"), the Specified Amount of the Policy is increased by the Rider Specified Amount and provides an additional amount of coverage upon the death of the Insured. Assume that the Policy is purchased by a 45 year-old male super preferred, non-nicotine user and the following facts are true:

• Specified Amount is $500,000 • Rider Specified Amount is $400,000 • SPR COI Rate is 0.21 • Death Benefit Option is A • Death Benefit discount factor is 1.0008295

The SPR Charge will be calculated on each Monthly Anniversary Day and is equal to the SPR Net Amount at Risk divided by $1,000; and multiplied by the cost of insurance rate.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Based upon the assumptions above, the following shows how we would calculate the SPR charge in Policy Year 1: Determine the SPR Net Amount at Risk (Death Benefit discounted for the upcoming month minus the Policy Value.) Determine discounted Death Benefit = $399,668.48 Death Benefit divided by the Death Benefit discount factor ($400,000/1.0008295) Because the SPR has no Policy Value, the SPR Net Amount at Risk is equal to $399,668.48-$0 = $399,668.48 Determine the SPR COI Charge (Net Amount at Risk multiplied by the SPR COI rate divided by $1,000) Multiple Net Amount at Risk by SPR COI Rate ($399,668.48 x 0.21) = $83,930.38 Divide amount in previous step by $1,000 ($83,930.38/$1,000) = $83.93 TOTAL SPR CHARGE FOR POLICY YEAR 1 (Deducted each Monthly Anniversary Day) = $83.93

C-4

EXAMPLE: SURRENDER VALUE ENHANCEMENT RIDER Under the Surrender Value Enhancement Rider, the Net Surrender Value of the Policy is increased by replacing the surrender charges with an alternate surrender charge schedule. Assume that the Policy is purchased by a 45 year-old male super preferred, non-nicotine user and the Specified Amount is $500,000. The table below shows the effect of the rider benefit.

Policy Issued without SVE Rider Policy Issued with SVE Rider Specified Amount $500,000.00 $500,000.00 Premium Payments made during Policy Year 1 $40,000.00 $40,000.00 Monthly Deductions $1,200.00 $1,200.00 SVE Rider Exercise Fee $0.00 $500.00 Policy Value at End of Policy Year 1 $38,800.00 $38,300.00 ($40,000 - $1,200 - SVE Rider Fee) Assume at the end of Policy Year 1, You request a full surrender of Your Policy Surrender Charge per $1,000 of Specified Amount $37.39 $3.73 Specified Amount Divided by $1,000 $500,000/$1,000 = $500 $500,000/$1,000 = $500 Surrender Charge Deducted $37.39 x 500 = $18,695 $3.73 x 500 = $1,865 (Surrender Charge per $1,000 of Specified Amount x $500) Deduct Surrender Charge From Policy Value $38,800 - $18,695 = $20,105 $38,300 - $1,865 = $36,435 NET SURRENDER VALUE $20,105.00 $36,435.00

EXAMPLE: WAIVER OF MONTHLY DEDUCTIONS RIDER Under the Waiver of Monthly Deductions Rider (“WMD Rider”), We will waive monthly deductions for Your Policy while the Insured is Totally Disabled, as defined in the rider. Assume that the Policy is purchased by a 45 year-old male super preferred, non- nicotine user and the sum of monthly deductions (including rider charges) is $1,200.

The WMD Rider Charge will be calculated on each Monthly Anniversary Day and is equal to: • The sum of Your Policy’s monthly deductions; multiplied by • The rider charge rate as shown on the WMD Rider Specification Page that is based upon Your Attained Age. The rider charge rate is per $100 of WMD benefit amount.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Based upon the assumptions above, the following shows how we would calculate the WMD Rider charge in Policy Year 1: Determine the monthly deduction amount for the Policy in Policy Year 1 = $1,200.00 Determine Rider Charge Rate for Attained Age 45 for a $1,200 monthly deduction = $120.00 $10 x (1,200/100) = 120 TOTAL WMD RIDER CHARGE FOR POLICY YEAR 1 (Deducted each Monthly = $120.00 Anniversary Day)

Based upon the assumptions above, the following shows how we would calculate the WMD Rider charge in Policy Year 11: Determine the monthly deduction amount for the Policy in Policy Year 11 = $1,200.00 Determine Rider Charge Rate for Attained Age 55 for a $1,200 monthly deduction = $300.00 $25 x (1,200/100) = TOTAL WMD RIDER CHARGE FOR POLICY YEAR 11 (Deducted each Monthly = $300.00 Anniversary Day)

C-5

Assume that during Policy Year 11, at Attained Age 55, the Insured submits a claim under the WMD Rider and the following dates apply: • Total Disability Began on January 1st • Claim received on September 1st • Monthly Anniversary Day is the 5th of every month • Claim approved September 15th

Based upon the assumptions above, once the WMD Rider claim was approved, We would take the following steps: Credit to the Policy Value the amount of monthly deductions taken since the date Total Disability = $2,700.00 began ($300 x 9 months (January to September)) = $2,700

Because the Total Disability began before Attained Age 60, we will waive all future monthly deductions for as long as the Total Disability continues.

Now assume that the insured submits a claim in Policy Year 18 at Attained Age 62 using the same dates above: Because the Total Disability began after Attained Age 60 but before Attained Age 65, we will waive all future monthly deductions until Attained Age 65 or for two years from the date Total Disability began, whichever is later. In this scenario, We would waive monthly deductions until Attained Age 65.

Now assume that the insured submits a claim in Policy Year 20 at Attained Age 64 using the same dates above: We would waive all future monthly deductions until Attained Age 65 or for two years from the date Total Disability began, whichever is later. In this scenario, We would waive monthly deductions for two years from the date Total Disability began.

C-6

PROSPECTUS BACK COVER

Personalized Illustrations of Policy Benefits. To help You understand how Your Policy Values could vary over time under different sets of assumptions, We will provide You upon request, with certain personalized hypothetical illustrations showing the Death Benefit, Surrender Value and Policy Value. These hypothetical illustrations will be based on the Attained Age and underwriting characteristics of the Insured under Your Policy and such factors as the Specified Amount, Death Benefit, premium payment amounts, and hypothetical rates of return (within limits) that You request. The illustrations are not a representation or guarantee of investment returns or Policy Value. We currently do not charge for these illustrations, but We reserve the right to charge up to $25 if We provide more than one illustration in a Policy Year.

INQUIRIES You can make inquiries regarding Your Policy, request additional information and get a free copy of this prospectus and SAI, a prospectus for any of the Funds, a personalized illustration or discuss Your questions about Your Policy by contacting Us.

1. If You choose to make Your Initial Premium Payment by check directly to Us, please contact Our new business address:

PO Box 35020 Seattle, WA 98124

2. For general correspondence and Written Notice, please contact Our Administrative Office at:

P.O. Box 34690 Seattle, WA 98124 Telephone: 1-800-796-3872 Facsimile: 1-866-719-3124

For premium payments after Your Policy is issued, please contact Us at:

P.O. Box 34815 Seattle, WA 98124

3. For overnight mail, please contact Us at Our Home Office, located at:

777 108th Ave. NE, Suite 1200 Bellevue, WA 98004

4. On the Internet, please go to: www.symetra.com/regulatoryreports

The SAI provides more detailed information about the Variable Account. The current SAI is on file with the SEC, and is incorporated into this prospectus by reference and is legally considered part of this prospectus.

Reports and other information about the Policy and the Variable Account are available on the SEC’s Web site at http://www.sec.gov You can also get copies, for a fee, by electronic request at the following email address: [email protected].

STATEMENT OF ADDITIONAL INFORMATION to ACCUMULATOR VARIABLE UNIVERSAL LIFE

FLEXIBLE PREMIUM ADJUSTABLE VARIABLE LIFE INSURANCE POLICY funded through

SYMETRA SEPARATE ACCOUNT SL

by SYMETRA LIFE INSURANCE COMPANY

Administrative Office: P.O. Box 34690 Seattle, WA 98124

This Statement of Additional Information ("SAI") is not a prospectus. Terms used in this SAI have the same meanings as in the prospectus for the Policy.

The prospectus for the Accumulator Variable Universal Life flexible premium adjustable variable life insurance policy concisely sets forth information that a prospective investor should know before investing. For a copy of the prospectus dated [______, 2021], visit Us at www.symetra.com/regulatoryreports, call 1-800-796-3872 or write to Symetra Life Insurance Company, P.O. Box 34690, Seattle, Washington 98124.

TABLE OF CONTENTS

Page

GENERAL INFORMATION 1

THE POLICY - GENERAL MATTERS 1

SERVICES 2 UNDERWRITING 3

PRINCIPAL UNDERWRITER - DISTRIBUTION 3

LEGAL MATTERS 3

FINANCIAL STATEMENTS 3

GENERAL INFORMATION

Symetra Life Insurance Company (“Symetra Life”, “We”, and “Us”) is an Iowa stock life insurance company and is engaged primarily in insurance and financial services businesses. Symetra Life was organized under Washington law on January 23, 1957, and redomesticated to Iowa in 2014. Symetra Life is a wholly owned subsidiary of Symetra Financial Corporation, which, in turn, is a wholly owned subsidiary of Sumitomo Life Insurance Company, a Japanese mutual life insurer (sougo kaisha) with its headquarters in Tokyo, Japan.

Symetra Separate Account SL (“Variable Account”) is a separate account that was established under Washington law on November 6, 1986, and reestablished under Iowa law on July 1, 2014. The Variable Account holds the assets that underlie Policy Values invested in the Subaccounts. The Variable Account is registered with the SEC as a unit investment trust under the Investment Company Act of 1940, as amended (“1940 Act”).

THE POLICY-GENERAL MATTERS

Our Right to Contest the Policy In issuing the Policy, We rely on all statements made by or for the Insured in the application (or in any supplemental application). Therefore, if You make any material misrepresentation of a fact in the application (or any supplemental application), then We may contest the Policy's validity or may resist a claim under the Policy for two years from the Issue Date.

When permitted by law in the jurisdiction in which the Policy is delivered, in the absence of fraud in the procurement of the Policy, We cannot bring any legal action to contest the validity of the Policy after the Policy has been in force during the Insured's lifetime for two years from the Issue Date, or if reinstated, for two years from the date of reinstatement.

Suicide Exclusion

If the Insured commits suicide, while sane or insane, within two years of the Issue Date, the Policy will terminate and Our liability is limited to an amount equal to the premiums paid, less any withdrawals and minus any Loan Amount. We will pay this amount to the Beneficiary in a single sum.

If the Policy lapses and is reinstated and the Insured later commits suicide, while sane or insane, within two years of the reinstatement date, the Policy will terminate and Our liability is limited to an amount equal to the Policy Value reinstated plus premiums paid after reinstatement, less any withdrawals and minus any Loan Amount. We will pay this amount to the Beneficiary in a single sum.

If the Insured commits suicide, while sane or insane, within two years from the effective date of any increase in Specified Amount that was requested by You and subject to evidence of insurability, We will not pay a Death Benefit on that increase. We will refund the monthly deductions for that increase.

Changes to the Policy

Any modifications or waiver of any rights or requirements under the Policy must be in writing and signed by an authorized officer of the Company. No agent may bind us by making any promise not contained in the Policy.

If any modifications are made, We will make any appropriate endorsements to the Policy. If any provision of the Policy conflicts with the laws of a jurisdiction that govern the Policy, the Policy provides that such provision be deemed to be amended to conform with such laws.

For a discussion of the potential conflicts of interest that may arise as a result of the sale of Fund shares to separate accounts that support variable annuity contracts, variable life insurance policies, and certain qualified pension and retirement plans, as well as the sale of Fund shares to the separate accounts of insurance companies that are not affiliated with Symetra Life, see the prospectuses for the Funds.

NON-PRINCIPAL RISKS

Cyber Security Risks We rely heavily on interconnected computer systems and digital data to conduct Our variable product business activities. Because Our variable product business is highly dependent upon the effective operation of Our computer systems and those of

Our business partners, Our business is potentially vulnerable to disruptions from utility outages and other problems, and susceptible to operational and information security risks resulting from information systems failure (hardware and software malfunctions) and cyber- attacks. These risks include, among other things, the theft, misuse, corruption and destruction of data maintained online or digitally, and unauthorized release of confidential customer information. For instance, cyber-attacks may: interfere with Our processing of Policy transactions, including the processing of orders from Our website or with the Funds; cause the release and possible destruction of confidential customer or business information; impede order processing; subject Us and/or Our service providers and intermediaries to regulatory fines and financial losses; and/or cause reputational damage. Cyber security risks may also affect the Funds.

Delays in Policy Administration Delays in Policy administration may occur in the event of severe weather, natural disasters, a public health crisis, pandemic, or the closure of one or more of our offices, or in the event of interruptions in mail delivery, telephone communications, or other electronic communications beyond our control.

SERVICES

Independent Registered Public Accounting Firm: The statutory-basis financial statements of Symetra Life Insurance Company, which comprise the balance sheets as of December 31, 2020 and 2019, and the related statements of operations, changes in capital and surplus and cash flow for each of the three years in the period ended December 31, 2020, and the related notes to the financial statements, and the financial statements of Symetra Separate Account SL as of December 31, 2020, and for each of the two years in the period ended December 31, 2020 are incorporated in the SAI by reference to the filed Form N-VPFS.

The financial statements for the fiscal year ending December 31, 2020 have been audited by [______], independent auditor, as set forth in their reports thereon appearing elsewhere herein, and are included in reliance upon such reports given on the authority of such firm as experts in accounting and auditing. The principal business address of [_____] is [______].

The financial statements for the fiscal year ending December 31, 2019 and 2018 have been audited by [______], independent registered public accounting firm, as set forth in their reports thereon appearing elsewhere herein, and are included in reliance upon such reports given on the authority of such firm as experts in accounting and auditing. The principal business address of [______] is [______].

UNDERWRITING

Symetra Life gathers certain information about an applicant's age, health, occupation, avocation, finances, if permitted by state law, sex and other factors that impact mortality risk. Such information is gathered through use of applications, medical examinations, attending physician statements, personal interviews and other authorized methods to determine the appropriate risk classification. Symetra Life uses the 2017 Commissioners’ Standard Ordinary Mortality Tables, and if permitted by state law, Male or Female to determine the maximum cost of insurance for each Insured.

PRINCIPAL UNDERWRITER - DISTRIBUTION

We currently offer the Policies on a continuous basis. We anticipate continuing to offer the Policies, but reserve the right to discontinue the offering.

Symetra Securities, Inc. ("SSI") acts as the principal underwriter for the Policies. SSI is an affiliate of Symetra Life and each is a wholly-owned subsidiary of Symetra Financial Corporation. SSI is located at 777 108th Avenue NE, Suite 1200, Bellevue, Washington 98004. SSI is registered as a broker-dealer with the SEC under the Securities Exchange Act of 1934 and is a member of FINRA.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document The Policies are offered to the public through sales representatives of broker-dealers ("selling firms") that have entered into selling agreements with Us and with SSI.

For the years ended December 31, 2020, 2019, and 2018, SSI received $3,668,872, $1,285,211.46 and $2,769,054, in commissions for the distributions of all policies funded through the Variable Account. SSI does not anticipate retaining any portion of any commissions paid for the distribution of Policies funded through the Variable Account.

LEGAL MATTERS

Rachel Dobrow Stone, Senior Counsel of Symetra Life Insurance Company, has provided legal advice on certain matters in connection with the issuance and operation of the Policy.

FINANCIAL STATEMENTS

The financial statements of the Separate Account as of December 31, 2020 and for each of the two years in the period ended December 31, 2020, the financial statements and related financial statement schedules of Symetra Life Insurance Company as of December 31, 2020 and December 31, 2019, for each of the three years in the period ended December 31, 2020, and the accompanying Reports of Independent Registered Public Accounting Firms appear in the Statement of Additional Information are incorporated herein by reference to the Form N-VPFS filed on [______.]

Item 30. Exhibits

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Exhibit Description Reference a. Resolution of Board of Directors of Symetra Life authorizing the Separate 8/ Account b. Custodian Agreement Not Applicable c. (i) Principal Underwriter's Agreement, as Amended 8/

(ii) Form of Broker-Dealer Selling Agreement 3/ d. (i) Flexible Premium Variable Adjustable Life Insurance Policy Filed Herewith (ii) Accelerated Death Benefit for Chronic Illness Rider 1/ (iii) Accelerated Death Benefit for Terminal Illness Rider 5/ (iv) Charitable Giving Benefit Rider 6/ (v) a. Accelerated Death Benefit for Chronic Illness Plus Rider 6/ b. Chronic Illness Plus Specifications Page 6/ (vi) Endorsement to Accelerated Death Benefit for Chronic Illness Rider and 6/ Accelerated Death Benefit for Chronic Illness Plus Rider (vii) Surrender Value Enhancement Rider Filed Herewith (viii) Overloan Protection Rider Filed Herewith (ix) Waiver of Monthly Deductions Rider Filed Herewith (x) Supplemental Protection Rider Filed Herewith e. Application Filed Herewith f. (i) Amended and Restated Articles of Incorporation of Symetra Life Insurance 2/ Company

(ii) Bylaws of Symetra Life Insurance Company Effective July 1, 2014 2/ g. Redacted Copy of Reinsurance Agreement To be filed by Amendment h. (i) Participation Agreement (American Funds) 4/

(ii) Participation Agreement (DFA) Filed Herewith

(iii) Participation Agreement (Fidelity) 9/ Amendment No. 1 to Participation Agreement (Fidelity) 7/ Amendment No. 2 to Participation Agreement (Fidelity) 13/ Amendment No. 3 to Participation Agreement (Fidelity) 12/ Amendment No. 4 to Participation Agreement (Fidelity) 11/ Amendment No. 5 to Participation Agreement (Fidelity) 10/ Amendment No. 6 to Participation Agreement (Fidelity) Filed Herewith

(v) Participation Agreement, as Amended (Vanguard) 3/ Amendment to Participation Agreement (Vanguard) 1/ i. Administrative Contracts Not Applicable j. Other Material Contracts Not Applicable k. Opinion and Consent of Counsel Filed Herewith l. Opinion and Consent of Actuary Not Applicable m. Sample Calculation Not Applicable n. Other Opinions (i) Consent of Independent Auditor To be filed by Amendment (ii) Consent of Independent Auditor To be filed by Amendment o. Omitted Financial Statements Not Applicable p. Initial Capital Agreements Not Applicable q. Redeemability Exemption: Description of Symetra Life Insurance Company's To be filed by Amendment Issuance, Transfer and Redemption Procedures for Policies r. Form of Initial Summary Prospectus Filed Herewith

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Reference Description 1/ Incorporated by reference to Pre-Effective Amendment No. 2 to Form N-6 registration statement of Registrant filed with the SEC on April 30, 2018 (File No. 333-213191). 2/ Incorporated herein by reference to Post-Effective Amendment No. 32 on Form N-4 registration statement of Separate Account C filed with the SEC on July 2, 2014 (File No. 33-69712). 3/ Incorporated herein by reference to Amendment No. 28 on Form N-6 registration statement of Registrant filed with the SEC on August 18, 2016 (File No. 333-213191). 4/ Incorporated by reference to Post-Effective Amendment No. 43 on Form N-4 registration statement of Resource Variable Account B filed with the SEC on January 30, 2013 (File No. 333-178461). 5/ Incorporated by reference to Post-Effective Amendment No. 4 to Form N-6 registration statement of Registrant filed with the SEC on August 9, 2019 (File No. 333-213191). 6/ Incorporated by reference to Pre-Effective Amendment No. 1 to Form N-6 registration statement of Registrant filed with the SEC on November 18, 2016 (File No. 333-213191). 7/ Incorporated by reference to Post-Effective Amendment No. 1 on Form N-4 registration statement of Registrant filed with the SEC on January 31, 2008 (File No. 333-137411). 8/ Incorporated by reference to Post-Effective Amendment No. 7 to Form N-6 registration statement of Registrant filed with the SEC on April 30, 2020 (File No. 333-213191). 9/ Incorporated by reference to Post-Effective Amendment No. 34 on Form N-6 registration statement of Registrant filed with the SEC on April 30, 2007 (File No. 333-30329). 10/ Incorporated by reference to Post-Effective Amendment No. 47 on Form N-4 registration statement of Resource Variable Account B filed with the SEC on April 30, 2014 (File No. 333-178461). 11/ Incorporated by reference to Post-Effective Amendment No. 29 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on April 30, 2012 (File No. 33-69712).

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Reference Description 12/ Incorporated by reference to Post-Effective Amendment No. 28 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on April 29, 2011 (File No. 33-69712). 13/ Incorporated by reference to Post-Effective Amendment No. 38 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on April 29, 2020 (File No. 33-69712).

Item 31. Directors and Officers of the Depositor

Set forth below is a list of each director and officer of Symetra Life who is engaged in activities relating to Symetra Separate Account SL or the variable life insurance policies offered through Symetra Separate Account SL.

Ashlock, Dena S. Senior Vice President, Chief Actuary 777 108th Avenue NE, Suite 1200 and Chief Risk Officer Bellevue, WA 98004

Balkovetz, Chantel L. Executive Vice President 777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Bouvier II, Phillippe D. Senior Vice President 777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Brooks, Tommie D. Director, Chief Financial Officer and 777 108th Avenue NE, Suite 1200 Executive Vice President Bellevue, WA 98004

Chandler, Darlene K. Senior Vice President and Associate 777 108th Avenue NE, Suite 1200 General Counsel Bellevue, WA 98004

Diouf, Anne-Marie Senior Vice President and Chief 777 108th Avenue NE, Suite 1200 Human Resources Officer Bellevue, WA 98004

Falls, Stephanie A. Vice President and Chief Compliance 777 108th Avenue NE, Suite 1200 Officer of the Separate Account Bellevue, WA 98004

Fry, Stephanie L. Vice President 777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Henderson, Maureen H. Senior Vice President and Chief 777 108th Avenue NE, Suite 1200 Compliance Officer Bellevue, WA 98004

Herzberg, Keren A. Vice President 777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Hunt, Mark E. Director, Chief Investment Officer and 777 108th Avenue NE, Suite 1200 Executive Vice President Bellevue, WA 98004

Kneisley, Joel C. Senior Vice President and Chief 777 108th Avenue NE, Suite 1200 Information Officer Bellevue, WA 98004

LaVoice, Richard G. Executive Vice President 777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Meister, Margaret A. Director and President 777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Monti, Harry S. Jr. CopyrightDirector © 2021 andwww Executive.secdatabase.com Vice . PresidentAll Rights Reserved. th Please Consider the Environment Before Printing This Document777 108 Avenue NE, Suite 1200 Bellevue, WA 98004 Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Name Positions with Symetra Principal Business Address

Murphy, Colleen M. Senior Vice President, Controller and 777 108th Avenue NE, Suite 1200 Treasurer Bellevue, WA 98004

Sasagawa, Muneo Director 777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Severin, Wesley W. Director and Executive Vice President 777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Sho, Tetsuya Director 777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Smolinksi, Richard P. Senior Vice President 777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Stenberg, Jon S. Director and Executive Vice President 777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Veneziani, Jacqueline M. Director, Senior Vice President, 777 108th Avenue NE, Suite 1200 General Counsel and Secretary Bellevue, WA 98004

Item 32. Persons Controlled By or Under Common Control With the Depositor or Registrant

No person is directly or indirectly controlled by Symetra Separate Account SL (“Registrant”). Symetra Life established Registrant by resolution of its Board of Directors. Symetra Life is a wholly owned subsidiary of Symetra Financial Corporation. Symetra Financial Corporation is organized under Delaware law and Symetra Life is organized under Iowa law. All subsidiaries are included in the financial statements. Following is the organizational chart of Symetra Financial Corporation.

As more fully set forth in its Bylaws, Symetra Life, to the maximum extent it is empowered by the Iowa Business Corporation Act, Iowa Code Chapter 490, shall indemnify and advance expenses to any person who was or is a party to or is threatened to be made a party to any threatened, pending or completed claim, action, suit or proceeding, whether civil, criminal, administrative or investigative (including a grand jury proceeding) and whether formal or informal, by reason of the fact that such person (a) is or was a director or officer of the corporation, or (b) while a director or officer of the corporation, is or was serving at the request of the corporation as a director, officer, employee, agent, partner or trustee (or in a similar capacity) of another corporation, partnership, joint venture, trust, other enterprise, or employee benefit plan, against reasonable expenses (including attorneys’ fees), judgments, fines, penalties, including an excise tax assessed with respect to an employee benefit plan, and amounts paid in settlement actually and reasonably incurred by such person in connection with such claim, action, suit or proceeding or any appeal thereof.

Under certain Director and Officer Indemnification Agreements (“Agreement(s)”) between Symetra Life’s parent company, Symetra Financial Corporation, and directors and/or certain officers of Symetra Life (“Indemnitees”), Symetra Financial Corporation indemnifies and holds harmless Indemnitees, to the full extent permitted by the laws of the State of Delaware in effect at the time the Agreement is

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document effective or as such laws may from time to time be amended, against all Indemnifiable Losses related to, resulting from or arising out of any Claim (subject to certain exceptions) where:

1. “Claim” means any threatened, pending or completed action, suit or proceeding, whether civil, criminal, administrative, arbitrative, investigative or other, in which the Indemnitee is a party or reasonably could be made a party, is threatened to be made a party or is involved by reason of the fact that (i) Indemnitee is or was a director,

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document officer, employee or agent of the Company and/or of a subsidiary of the Company, or (ii) Indemnitee is or was serving at the request of the Company as a director, officer, employee or agent of another corporation, partnership, non-profit organization, joint venture, trust or other enterprise. Inclusion of the Indemnitee’s role with such an enterprise (including, for example, service on the board of directors of a non-profit organization) on a list approved from time to time by the Chief Executive Officer or Chief Financial Officer of the Company shall constitute service “at the request of the Company” for purposes of clause (ii) in the preceding sentence.

2. “Expenses” includes all direct and indirect costs and expenses of any type whatsoever (including without limitation all attorneys’ and experts’ fees, expenses and charges) and all other costs, expenses and obligations actually and reasonably paid or incurred by Indemnitee in connection with investigating, defending, being a witness in or participating in (including on appeal), or preparing to investigate, defend, be a witness in or participate in, any Claim; and

3. “Indemnifiable Losses” means any and all Expenses, damages, losses, liabilities, judgments, fines, penalties and amounts paid in settlement (including without limitation all interest, assessments and other charges paid or payable in connection with or in respect of any of the foregoing) (collectively, “Losses”) reasonably incurred by Indemnitee relating to, resulting from or arising out of any Claim.

Insofar as indemnification for liabilities arising under the Securities Act of 1933 may be permitted to directors, officers and controlling persons of Symetra Life pursuant to such provisions of the bylaws, statutes, agreements, or otherwise, Symetra Life has been advised that in the opinion of the Securities and Exchange Commission, such indemnification is against public policy as expressed in said Act and is, therefore, unenforceable. In the event that a claim for indemnification against such liabilities (other than the payment by Symetra Life or Symetra Financial Corporation of expenses incurred or paid by a director, officer or controlling person of Symetra Life in the successful defense of any such action, suit or proceeding) is asserted by such director, officer or controlling person in connection with the contracts issued by the Separate Account, Symetra Life will, unless in the opinion of its counsel the matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question whether such indemnification by it is against public policy as expressed in said Act and will be governed by the final adjudication of such issue.

Item 34. Principal Underwriters a. Symetra Securities, Inc., the principal underwriter for the Policies, also acts as the principal underwriter for other Symetra Life individual flexible premium variable life insurance policies, Symetra Life individual variable annuity contracts, Symetra Life’s group variable annuity contracts and Symetra Life's index-linked annuity contracts. b. The following information is provided for each officer and director of the principal underwriter:

Balkovetz, Chantel L. Director 777 108th Ave NE, Suite 1200 Bellevue, WA 98004 Bodmer, Julie M. Assistant Secretary 777 108th Ave NE, Suite 1200 Bellevue, WA 98004 Chandler, Darlene K. Secretary 777 108th Ave NE, Suite 1200 Bellevue, WA 98004 Ellis, Courtney L. Chief Operating Officer 777 108th Ave NE, Suite 1200 Bellevue, WA 98004 Farrell, Andrew M. Chairman of the Board and President 777 108th Ave NE, Suite 1200 Bellevue, WA 98004 Hansen Jr., Stewart J. Assistant Treasurer 777 108th Ave NE, Suite 1200 Bellevue, WA 98004

Murphy, Colleen M. Director, Chief Financial Officer, 777 108th Ave NE, Suite 1200 Treasurer and Financial and Operations Bellevue, WA 98004 Principal Norberg, Kristin R. Vice President 777 108th Ave NE, Suite 1200 Bellevue, WA 98004 Pessoa, Melissa Assistant Treasurer 777 108th Ave NE, Suite 1200 Bellevue, WA 98004 Rabin, Kevin W. Director 777 108th Ave NE, Suite 1200 Bellevue, WA 98004 Sanders, Barbara Chief Compliance Officer 777 108th Ave NE, Suite 1200 Bellevue, WA 98004 c. During the fiscal year ended December 31, 2020, Symetra Securities, Inc. received $3,668,872 in commissions for the distribution of certain variable life insurance policies in connection with Registrant of which no payments were retained. Symetra Securities, Inc. did not receive any other compensation in connection with the sale of Registrant's policies.

Item 35. Location of Accounts and Records

This information is omitted as it is provided in the Registrant’s most recent report on Form N-CEN.

Item 36. Management Services

Not Applicable

Item 37. Fee Representations

Symetra Life hereby represents that the fees and charges deducted under the Accumulator Variable Universal Life Policy, in the aggregate, are reasonable in relation to the services rendered, the expenses expected to be incurred and risks assumed by Symetra Life.

As required by the Securities Act of 1933 and the Investment Company Act of 1940, the Registrant has duly caused this Registration Statement to be signed on its behalf, in the City of Bellevue and State of Washington, on this 10th day of June, 2021. Symetra Separate Account SL (Registrant) Symetra Life Insurance Company (Depositor) By: Symetra Life Insurance Company By: Margaret A. Meister Margaret A. Meister, Director By: Margaret A. Meister Margaret A. Meister, Director

Pursuant to the requirement of the Securities Act of 1933, this Registration Statement has been signed below by the following person in the capacities and on the date indicated below. NAME TITLE DATE Tommie D. Brooks Director, Chief Financial Officer,Executive Vice June 9, 2021 Tommie D. Brooks President (Principal Accounting Officer & Principal Financial Officer) Mark E. Hunt Director, Chief Investment Officer and Executive June 10, 2021 Mark E. Hunt Vice President

Margaret A. Meister Director and President (Principal Executive June 9, 2021 Margaret A. Meister Officer)

Harry S. Monti, Jr. Director and Executive Vice President June 9, 2021 Harry S. Monti, Jr.

Muneo Sasagawa Director June 9, 2021 Muneo Sasagawa

Wesley W. Severin Director and Executive Vice President June 9, 2021 Wesley W. Severin

Tetsuya Sho Director June 9, 2021 Tetsuya Sho

Jon S. Stenberg Director and Executive Vice President June 9, 2021 Jon S. Stenberg

Jacqueline M. Veneziani Director, General Counsel, Senior Vice President June 9, 2021 Jacqueline M. Veneziani and Secretary

Exhibit Description d. (i.) Flexible Premium Variable Adjustable Life Insurance Policy d. (vii) Surrender Value Enhancement Rider d. (viii) Overloan Protection Rider d. (ix) Waiver of Monthly Deductions Rider d. (x) Supplemental Protection Rider e. Application

h. (ii.) Participation Agreement (DFA) h. (iii) Amendment to Participation Agreement (Fidelity) h. (iv) Participation Agreement as amended (Goldman Sachs) k. Opinion and Consent of Counsel r. Form of Initial Summary Prospectus

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Symetra Life Insurance Company Home Office: [777 108th Ave NE Suite 1200, Bellevue, WA 98004] [Phone 1-800-796-3872] [www.symetra.com]

FLEXIBLE PREMIUM ADJUSTABLE VARIABLE LIFE INSURANCE POLICY In this Flexible Premium Adjustable Variable Life Insurance Policy (this “Policy”), Symetra Life Insurance Company is referred to as “We”, “Us”, “Our”, or the “Company”. “You” or “Your” refers to the Owner of the Policy.

The Company agrees to pay to the Beneficiary the Death Benefit Proceeds described in section 5 of this Policy upon receipt of Due Proof of the Insured’s death while the Policy is in force prior to the Maturity Date. PLEASE READ THIS POLICY CAREFULLY

It is a legal contract between You and Us.

NOTICE OF CANCELLATION PERIOD

If for any reason You are not satisfied with this Policy, You may cancel it by returning it to Us with a Written Notice for cancellation by delivering or mailing both to:

1. [P.O. Box 35020, Seattle, Washington, 98124], or 2. The agent through whom You purchased it within [10] calendar days after You receive it, or if this Policy was a result of a replacement, [30] calendar days after You receive it. Cancellation is effective upon receipt by Us and will be void as of its inception. The Company will promptly return Your premium payments.

Signed for Symetra Life Insurance Company at its Home Office in Bellevue, Washington on the Policy Issue Date.

[] []

[Margaret Meister] [Jacqueline Veneziani ] [President] [Secretary]

THE AMOUNT OF THE DEATH BENEFIT OR THE DURATION OF THE INSURANCE COVERAGE, OR BOTH, MAY INCREASE OR DECREASE UNDER THE CONDITIONS DESCRIBED IN THIS POLICY.

THE DEATH BENEFIT AND OTHER VALUES PROVIDED BY THIS POLICY, WHEN BASED ON THE INVESTMENT PERFORMANCE OF THE VARIABLE ACCOUNT, MAY INCREASE OR DECREASE DAILY AS A FUNCTION OF THE INVESTMENT PERFORMANCE OF THE SUBACCOUNTS SELECTED BY THE OWNER AND ARE NOT

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document GUARANTEED AS TO DOLLAR AMOUNT. NO MINIMUM VALUE IS GUARANTEED FOR PORTIONS OF THE POLICY VALUE IN THE SUBACCOUNTS.

This Policy does not pay dividends or otherwise participate in Our profits or surplus.

SYMETRA LIFE INSURANCE COMPANY

IF YOU HAVE ANY QUESTIONS, COMMENTS OR COMPLAINTS, PLEASE CONTACT SYMETRA AT [1-800-796-3872].

ICC21_LC1 Symetra® [is a registered service mark][are registered service marks] of Symetra Life Insurance Company.

Policy Specifications [2]

Section 1: Definitions [3]

Section 2: General Provisions 2.1 The Policy [6] 2.2 Representations and Contestability [6] 2.3 Misstatement of Age or Sex [6] 2.4 Suicide Exclusion [6] 2.5 Modification [7] 2.6 Periodic Reports [7] 2.7 When Coverage Begins [7] 2.8 When Coverage Ends [7] 2.9 Maturity Date [8] 2.10 Tax Considerations [8] 2.11 Conformity with IIPRC Standards [8] 2.12 Basis of Computations [8]

Section 3: Ownership 3.1 Ownership [9] 3.2 Changing the Owner [9] 3.3 Contingent Owner [9] 3.4 Assignment [9] 3.5 Selecting the Beneficiary [9] 3.6 Changing the Beneficiary [9]

Section 4: Premium Payments, Lapse and Reinstatement 4.1 Premium Payments [10] 4.2 Planned Periodic Premium Payments [10] 4.3 Unplanned Premium Payments [10] 4.4 Rejection of Premium Payments [10] 4.5 Grace Period and Policy Lapse [10] 4.6 No Lapse Guarantee [11] 4.7 Reinstatement [11]

Section 5: Death Benefit and Death Benefit Proceeds 5.1 The Death Benefit [11] 5.2 Death Benefit Proceeds [12] 5.3 Interest on Death Benefit Proceeds [12]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Section 6: The Variable Account 6.1 Variable Account [12] 6.2 Subaccounts [13] 6.3 Changes to the Variable Account [13] 6.4 Variable Policy Value [14] 6.5 Units [14] 6.6 Unit Value [14] 6.7 Net Investment Factor [14]

ICC21_LC1

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Section 7: The Fixed Account 7.1 Fixed Account [15] 7.2 Fixed Policy Value [15] 7.3 Interest Credited [15]

Section 8: Fees and Charges 8.1 Determination and Redetermination of Fees and Charges [15] 8.2 Monthly Deduction [16] 8.3 Monthly Administrative Charge [16] 8.4 Monthly Expense Charge [16] 8.5 Monthly Cost of Insurance Charge [16] 8.6 Monthly Variable Policy Value Charge [16] 8.7 Premium Charge [17] 8.8 Surrender Charge [17] 8.9 Transfer Processing Fee [17] 8.10 Withdrawals Processing Fee [17]

Section 9: Allocations and Transfers 9.1 Allocation of Net Premium Payments [17] 9.2 Transfer Privilege [17] 9.3 Restrictions on Transfers from the Fixed Account [18]

Section 10: Surrender and Withdrawals 10.1 Surrenders [18] 10.2 Withdrawals [18]

Section 11: Loans 11.1 Borrowing Privilege [19] 11.2 Interest Charged on Borrowed Amounts [19] 11.3 Collateral for Loans [19] 11.4 Interest Credited to the Loan Account [19] 11.5 Lapse due to Outstanding Loans [19] 11.6 Repayment of Loans [19]

Section 12: Policy Changes 12.1 Policy Changes [20] 12.2 Increase in Specified Amount [20] 12.3 Decrease in Specified Amount [20] 12.4 Change in Death Benefit Option [20] 12.5 Change in Risk Class [21]

Section 13: Payments 13.1 Payment of Benefits [22]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Section 14: Settlement Option 14.1 Payment of Benefits or Values [22] 14.2 Frequency of Payments [23] 14.3 First Payment [23] 14.4 Betterment of Rates [23] 14.5 Death of Payee [23] 14.6 Additional Interest Earnings [23] 14.7 Settlement Option, Payments for a Specified Period [23]

ICC21_LC1

[General Coverage Overview:]

Policy Number: [VV0000002]

Owner: [John Doe]

Insured: [John Doe]

Insured’s Age: [45] Insured’s Sex: [M] Risk Class: [Standard Non-Nicotine]

Issue Date: [12-25-2020] Policy Date: [12-25-2020] Maturity Date*: [12-25-2095]

Monthly Anniversary Day: [25th] Tax Compliance Test: [GPT or CVAT]

Guaranteed Minimum Interest Rate: 1.00%

Initial Specified Amount: $ [100,000.00]

Minimum Specified Amount: $[100,000.00]

Minimum Specified Amount Decrease: $[10,000.00] Minimum Specified Amount Increase: $[10,000.00]

Initial Death Benefit Option: [Option A] [Option C Death Benefit Limit. [Twice the Initial Specified Amount]]

Initial Premium Payment: $[1,200.00] Planned Periodic Premium Payment: $[1,200.00] [Annually]

No Lapse Guarantee Premium: $[125.60]

Minimum Loan Amount: $[250.00] Maximum Loan Amount: [90%] of Surrender Value

Guaranteed Minimum Interest Rate for Loan Collateral: [1.00%]

Policy Loan Annual Interest Rate: [4.25%]

Maximum Transfers per Policy Year without charge: [24]

Minimum Transfer Amount: $[100.00] Transfer Processing Fee: $[25.00] per transfer

Withdrawals Processing Fee: $[25.00] per withdrawal

[Surrender Value Enhancement Charge: $[500.00]]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Your state insurance department regulator may be contacted at: [name and telephone number of insurance department].

* The Policy might not mature even if Planned Periodic Premium Payments are paid, due to the fact that current cost of insurance and interest rates are not guaranteed, the investment performance of the funds in the Separate Account may be negative, Policy loans and partial withdrawals may be taken, and there may be requested changes to the Specified Amount. Even if coverage continues to the Maturity Date, there may in fact be little or no Net Surrender Value to be paid.

ICC21_LC1 [2a]

Coverage Overview:

Amount Coverage Expiry Date $[100,000.00] Life Insurance [05/25/2095] No Lapse Guarantee [05/25/2025] [Overloan Protection Rider] [05/25/2095]

ICC21_LC1 [2a]

FEES AND CHARGES

Maximum Premium Charge: [20%] of payment

Monthly Deduction: Maximum Monthly Administrative Charge: $[60.00] Maximum Monthly Variable Policy Value Charge: [0.100]% of Variable Policy Value Maximum Monthly Expense Charge: $[1.55]

SURRENDER CHARGE: Beginning of per $1,000 of Initial Specified Policy Year Amount [1 [$ 37.39 2 $ 36.61 3 $ 35.82 4 $ 35.03 5 $ 34.22 6 $ 27.38 7 $ 20.53 8 $ 13.69 9 $ 6.84 10+] $ 0.00]

MAXIMUM MONTHLY COST OF INSURANCE RATES PER $1,000 OF NET AMOUNT AT RISK See your Policy for details on how these rates are calculated.

The rates will not exceed those listed below in accordance with the [Ultimate 2017 CSO Male/Female, Unismoke, age nearest birthday] mortality table.

ICC21_LC1 [2b]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document At Beginning Life Insurance Rate of Policy Year [01 $[0.21195 02 $0.21780 03 $0.22282 04 $0.22867 05 $0.23452 06 $0.24455 07 $0.25793 08 $0.27382 09 $0.29222 10 $0.31313 11 $0.33824 12 $0.36670 13 $0.39936 14 $0.43623 15 $0.47982 16 $0.52931 17 $0.58723 18 $0.65192 19 $0.72507 20 $0.80587 21 $0.89181 22 $0.98376 23 $1.08088 24 $1.18660 25 $1.30517 26 $1.44345 27 $1.60750 28 $1.79919 29 $2.02130 30 $2.27151 31 $2.54665 32 $2.84439 33 $3.16586 34 $3.51657 35 $3.91184 36 $4.36379 37 $4.88763 38 $5.46690 39 $6.19129 40 $7.03014 Copyright © 2021 www.secdatabase.com. All Rights Reserved. 41 Please Consider$8.00749 the Environment Before Printing This Document 42 $9.14350 43 $10.44600 44 $11.92318 45 $13.53010 46 $15.25398 47 $17.04273 ICC21_LC1 [2b]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 48 $18.84889 49 $20.66178 50 $22.38628 51 $23.93836 52 $26.00183 53 $28.28101 54 $30.86253 55 $33.72178 56 $36.82893 57 $39.87065 58 $43.02541 59 $46.23878 60 $49.44991 61 $52.58615 62 $55.57224 63 $60.05144 64 $65.05535 65 $70.68603 66 $77.06844 67 $83.33333 68 $83.33333 69 $83.33333 70 $83.33333 71 $83.33333 72 $83.33333 73 $83.33333 74 $83.33333 75 $83.33333 76+] $83.33333]

[TABLE OF APPLICABLE PERCENTAGES FOR THE CASH VALUE ACCUMULATION TEST

This Policy complies with the cash value accumulation test in Section 7702 of the Internal Revenue Code of 1986, as amended, which requires that the total death benefit be greater than, or equal to, the Policy Value multiplied by the applicable percentage in the following table.

Attained Age of Applicable Attained Age of Applicable Attained Age of Applicable Insured Percentage Insured Percentage Insured Percentage [45 [201.72755% 64 146.35522% 83 114.34485% 46 198.27487% 65 144.11261% 84 113.24684% 47 194.87750% 66 141.93683% 85 112.21275% 48 191.53222% 67 139.82469% 86 111.24543% 49 188.23954% 68 137.77221% 87 110.34788% 50 184.99811% 69 135.77736% 88 109.52161% 51 181.81429% 70 133.83996% 89 108.76728% 52 178.69172% 71 131.96256% 90 108.07908% 53 175.63178% 72 130.14914% 91 107.44960% 54 172.63527% 73 128.40263% 92 106.86599% 55 169.70249% 74 126.72538% 93 106.31032% 56 166.83561% 75 125.11707% 94 105.76142% 57 164.03489% 76 123.57492% 95 105.18576% 58 161.30107% 77 122.09442% 96 104.53488% 59 158.63429% 78 120.67079% 97 103.78563% 60 156.03679% 79 119.30013% 98 102.86938% 61 153.50898% 80 117.98171% 99 101.67317% 62 151.05297% 81 116.71607% 100+] 100.00000%] 63 148.66828% 82 115.50513% ]

ICC21_LC1 [2b]

[TABLE OF APPLICABLE PERCENTAGES FOR THE GUIDELINE PREMIUM TEST

[Guideline Level Premium: $[1,817.71] Guideline Single Premium: $[23,506.37] 7-Pay Premium $[7,567.63]]

This Policy complies with the guideline premium test in Section 7702 of the Internal Revenue Code of 1986, as amended, which requires that the death benefit be greater than, or equal to, the Policy Value multiplied by the applicable percentage in the following table.

Attained Age of Applicable Attained Age of Applicable Attained Age of Applicable Insured Percentage Insured Percentage Insured Percentage 45 [215% 64 122% 83 105% 46 209% 65 120% 84 105% 47 203% 66 119% 85 105% 48 197% 67 118% 86 105% 49 191% 68 117% 87 105% 50 185% 69 116% 88 105% 51 178% 70 115% 89 105% 52 171% 71 113% 90 105% 53 164% 72 111% 91 104% 54 157% 73 109% 92 103% 55 150% 74 107% 93 102% 56 146% 75 105% 94 101% 57 142% 76 105% 95 101% 58 138% 77 105% 96 101% 59 134% 78 105% 97 101% 60 130% 79 105% 98 101% 61 128% 80 105% 99 101% 62 126% 81 105% 100+ 101%] 63 124% 82 105% ]

ICC21_LC1 [2b]

Accumulated No Lapse Guarantee Premium – An amount equal to the sum of the No Lapse Guarantee Premiums for each month since the Issue Date.

Address of Record – The last known address of the Owner and/or the last known address of an assignee of record. “Address” may include e-mail addresses.

Adjusted Premium - An amount equal to the sum of all premiums received since the Issue Date minus any withdrawals, and minus the Loan Amount.

Administrative Office – Either the Company’s mailing address for correspondence and Written Notices [(P.O. Box 34690, Seattle, Washington 98124)], or the Company’s mailing address for payments [(P.O. Box 34815, Seattle, Washington 98124)].

Attained Age – The Insured’s age as of the nearest birthday on the Policy Date, plus the number of complete Policy Years since the Policy Date.

Beneficiary – The person or persons to whom the Death Benefit Proceeds are paid upon the death of the Insured. The Owner may designate primary, contingent and irrevocable Beneficiaries. Singular references to Beneficiary, include all Beneficiaries if there is more than one Beneficiary.

Cancellation Period – The period described on the cover page of this Policy during which the Owner may cancel the Policy for a refund by returning it to the Company.

The Code – The Internal Revenue Code of 1986, as amended.

Contingent Beneficiary – The persons to whom the Death Benefit Proceeds are paid upon the death of the Insured if the primary Beneficiary (or Beneficiaries) is (are) not living.

Death Benefit – The amount payable to the Beneficiary as described in section 5.1 before adjustment for riders, loans and certain deductions, if the Insured dies while the Policy is in force.

Death Benefit Proceeds – The amount payable to the Beneficiary as described in section 5.2 if the Insured dies while the Policy is in force.

Due Proof of Death – Proof of death satisfactory to the Company. Due Proof of Death may consist of the following: (a) A certified copy of a death record; or (b) A certified copy of a court decree reciting a finding of death; and (c) Any other proof satisfactory to the Company.

Fixed Account – Part of the Company’s General Account to which Policy Value may be transferred or Net Premium Payments may be allocated under a Policy.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Fixed Policy Value – The Policy Value in the Fixed Account as defined in section 7.2.

Fund – Any open-end management investment company or investment portfolio thereof, or unit investment trust or series thereof, in which a Subaccount invests.

General Account – The assets of the Company other than those allocated to the Variable Account or any other separate account of the Company.

ICC21_LC1 [3]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Home Office – The Company’s offices at [777 108th Avenue, NE, Suite 1200, Bellevue, Washington 98004].

Initial Premium Payment – The amount shown on the Policy Specifications page that the Owner pays before the Policy is issued.

Initial Specified Amount – The Specified Amount on the Issue Date and shown on the Policy Specifications page.

Insured – The individual whose life is insured by the Policy.

Issue Age – The Insured’s age as of the nearest birthday on the Policy Date.

Issue Date – The date the Policy is issued and coverage begins under the Policy. The Policy is considered to be “in force” starting on the Issue Date. The Issue Date is shown on the Policy Specifications page.

Lapse – Termination of the Policy at the expiration of the Grace Period (defined in section 4.5) while the Insured is still living and also before the Maturity Date as explained in section 4.5.

Loan Account – A portion of the Company’s General Account to which Variable Policy Value or Fixed Policy Value is transferred to provide collateral for any loan taken under the Policy.

Loan Account Value – The Policy Value in the Loan Account.

Loan Amount – At any time other than a Policy Anniversary, the Loan Account Value plus any interest charges accrued on the Loan Account Value up to that time. On the Policy Anniversary, the Loan Amount equals the Loan Account Value.

Maturity Date – The date shown on the Policy Specifications page that is the Policy Anniversary nearest the Insured’s 120th birthday.

Monthly Anniversary Day – The same day as the Policy Date for each succeeding month.

Net Amount at Risk - As of any Monthly Anniversary Day, the Death Benefit (discounted for the upcoming month) less the Policy Value (before deduction of the monthly deduction).

Net Asset Value Per Share – The value per share of any Fund on any Valuation Day, generally as computed and provided by the Fund using the methodology described in the prospectus for that Fund.

Net Premium Payment – The premium payment less any premium charge.

Net Surrender Value – The Surrender Value minus any Loan Amount.

No Lapse Guarantee Period – Any period when the Adjusted Premium is greater than or equal to the Accumulated No Lapse Guarantee Premium.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Owner, You – The person (or persons) who owns (or own) the Policy and who is (are) entitled to exercise all rights and privileges provided in the Policy. Also, referred to herein as “Your.” Singular references to Owner, include all Owners if there is more than one Owner. Provisions relating to actions by the Owner mean, in the case of joint Owners, all Owners acting jointly.

ICC21_LC1 [4]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Planned Periodic Premium Payment – The premium payment selected by the Owner that he or she (or they) plans to pay on a monthly, quarterly, semi-annual, or annual basis over the life of the Policy.

Policy Anniversary – The same date in each Policy Year as the Policy Date.

Policy Date – The date shown on the Policy Specifications page used to determine the Issue Age. The Policy Date may be the Issue Date or any date up to six months prior to the Issue Date. Policy Years and various other periods described elsewhere herein are measured from the Policy Date. The Policy Date is never the 29th, 30th or 31st of a month.

Policy Value – The sum of the Variable Policy Value, the Fixed Policy Value and the Loan Account Value.

Policy Year – A twelve-month period beginning on the Policy Date or on a Policy Anniversary.

Risk Class – A category in which each prospective Insured is placed by the Company as a result of underwriting the Owner’s application. Risk Classes reflect the Company’s assessment of the life expectancy of the Insureds in the Class.

SEC –The U.S. Securities and Exchange Commission.

Specified Amount – A dollar amount selected by the Owner that is used to determine the Death Benefit.

Subaccount – A subdivision of the Variable Account, the assets of which are invested in a corresponding Fund.

Subaccount Value – The Policy Value in a Subaccount as defined in section 6.6.

Surrender Value – Policy Value minus any applicable surrender charge.

The Company, We, Us, Or Our – Symetra Life Insurance Company.

Unit – A unit of measure used to compute Subaccount Value.

Valuation Day – For each Subaccount, each day on which the New York Stock Exchange is open for business except for certain holidays listed in the prospectus for the Policy and days that a Subaccount’s corresponding Fund does not value its shares.

Valuation Period – The period that starts at the close of regular trading on the New York Stock Exchange on any Valuation Day and ends at the close of regular trading on the next succeeding Valuation Day.

Variable Account – Symetra Life Insurance Company Separate Account VL.

Variable Policy Value – The sum of all Subaccount Values.

Written Notice – A written notice or request in a form satisfactory to the Company that is signed and dated by the Owner and received at Our Administrative Office. Alternatively, an instruction to the Company by the Owner on the Company’s website through the Owner’s on-line account pursuant to protocols established by the Company.

2.1 The Policy We have issued this Policy in consideration of Your application and Your payment of the Initial Premium Payment shown on the Policy Specifications page. The entire Policy is made up of this Policy, any attached endorsements or riders, and the attached copy of the application and any supplemental applications. Any application for reinstatement of this Policy also becomes part of the Policy if the reinstatement is accepted by the Company.

2.2 Representations and Contestability In issuing this Policy, the Company relies on all statements made by or for the Insured in the application or in a supplemental application. We consider statements made in the application(s) to be representations and not warranties. The Company has the right to contest the validity of this Policy, or to resist a claim under it on the basis of any material misrepresentation of a fact stated in the application or any supplemental application. The Company also has the right to contest the validity of any change to the Policy on the basis of any material misrepresentation of a fact stated in the application or any supplemental application for such change.

When permitted by law in the jurisdiction in which the Policy is delivered, in the absence of fraud in the procurement of the Policy, the Company will not bring any legal action to contest the validity of this Policy after the Policy has been in force during the lifetime of the Insured for two years from the Issue Date or, if reinstated, for two years from the date of reinstatement.

2.3 Misstatement of Age or Sex If the age or sex of the Insured has been stated or recorded incorrectly in the application, any supplemental application, policy administration system, or taken into account incorrectly in the underwriting process, the Company will adjust the Death Benefit and any benefits provided by rider or endorsement it pays under this Policy to the amount that would have been payable at the correct age and sex based on the deduction for cost of insurance and other charges (and the cost of any benefits provided by rider or endorsement) in effect on the Policy Date. If the age of the Insured has been understated or overstated the Company will recalculate the Policy Value using the cost of insurance (and the cost of benefits provided by rider or endorsement) based on the Insured’s correct age and sex. If the correct age is outside the permitted issue ages for the Policy, the cost of insurance and the Death Benefit shall be actuarially extrapolated.

The Death Benefit after the recalculation will not be less than the Net Surrender Value that would have been paid had the Policy been surrendered on the date of death based on the misstated age. In addition, for these adjustments, the Company assumes that the Death Benefit for periods prior to the adjustment is the Death Benefit calculated based on the corrected age and sex of the Insured.

2.4 Suicide Exclusion If the Insured commits suicide, while sane or insane, within two years of the Issue Date, the Company’s liability is limited to an amount equal to the premium payments made less any Loan Amount and less any withdrawals.If the Insured commits suicide, while sane or insane, within two years of the date of reinstatement, the Company’s liability is limited to an amount equal to the Policy Value reinstated plus premium payments made after reinstatement, less any Loan Amount and less any withdrawals taken after reinstatement.

The Company will pay this amount to the Beneficiary in a single sum.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document If the Insured commits suicide, while sane or insane, within two years from the effective date of any increase in Specified Amount that was requested by You and subject to evidence of insurability, we will not pay a Death Benefit on that increase. We will refund the monthly deductions for that increase.

ICC21_LC1 [6]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 2.5 Modification Only an officer of the Company may modify this Policy or waive any of the Company’s rights or requirements of under this Policy. Any modification or waiver must be in writing. No agent may bind the Company by making any promise not contained in the Policy.

Upon notice to the Owner, the Company may modify the Policy to:

1. Conform the Policy or operations of the Company or of the Variable Account to the requirements of any law (or regulation issued by a government agency) to which the Policy, the Company or the Variable Account is subject; 2. Assure continued qualification of the Policy as a life insurance contract under the Code; or 3. Reflect a change (as permitted under the Policy) in the operation of the Variable Account.

In the event of any such modification, the Company will make appropriate endorsements to the Policy. If any provision of this Policy conflicts with the laws of a jurisdiction that govern the Policy, the provision is deemed to be amended to conform to such laws.

2.6 Periodic Reports At least annually, the Company will mail to Owners at their Address of Record a report showing the following items as of the end of the report period:

1. The beginning date and ending date of the current report period; 2. The Policy Value as of the beginning of the current report period and the end of the current report period; 3. The current Surrender Value, Net Surrender Value, Death Benefit, Variable Policy Value (including each Subaccount Value), Fixed Account Value, and Loan Account Value at the end of the current report period; 4. The Loan Amount, if any, at the end of the current report period; 5. Any Premium Payments, loans, withdrawals, or Surrenders made, and charges deducted during the current reporting period; 6. Current Net Premium Payment allocations; 7. If the Policy’s Net Surrender Value will not maintain the Policy in force until the next reporting period unless further payments are made, a notice to this effect will be included in the report; and 8. Other information required by law. 2.7 When Coverage Begins Coverage under this Policy applied for in the initial application begins on the Issue Date. Coverage that becomes reinstated by the Company under this Policy becomes effective on the date that: (a) the Company approves the application for reinstatement, and (b) the Company receives any premium payment required for the reinstatement.

2.8 When Coverage Ends Coverage under this Policy will terminate upon the earliest to occur of the following events:

1. The Insured dies; 2. The Owner surrenders the Policy; or 3. The Policy lapses.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Once coverage under this Policy terminates, this Policy is no longer “in force”. Coverage under this Policy continues beyond the Maturity Date. However, the Policy may not qualify as life insurance under the Code after the Maturity Date.

ICC21_LC1 [7]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 2.9 Maturity Date Your Policy is scheduled to mature on the Maturity Date as shown on Your Policy Specifications page. However, the Policy may not mature even if Planned Premiums are paid for a number of reasons. The choice of Planned Premium may be inadequate to mature the Policy, Subaccount performance may be lower than anticipated, current charges are not guaranteed, and Policy loans, withdrawals, Specified Amount changes, and Death Benefit Option changes may be made that were not anticipated when the Planned Premium was set.

If this Policy is in force on the Maturity Date, it will remain in force until the death of the Insured, unless You notify Us in writing that You do not wish to continue the Policy. If this Policy is in the Grace Period on the Maturity Date and You would like the Policy to continue, You will need to pay the minimum amount required to remove this Policy from the Grace Period, as described in section 4.5.

Coverage under this Policy, after the Maturity Date, will be subject to the following conditions: • The Death Benefit Option will be changed to Option A; • The Death Benefit will be determined as described under the Death Benefit and Death Benefit Proceeds provisions; • No Premium payments will be accepted and no monthly deductions will be taken; • Interest will continue to be credited monthly to Your Policy Value; • No withdrawals will be allowed, but new Policy loans will be allowed and Policy loan repayments will be accepted. Loan interest rates will apply as shown on the Policy Specifications page; and • All Variable Policy Value will be moved to the Fixed Account.

IF THIS POLICY IS EXTENDED PAST THE MATURITY DATE, YOUR POLICY MAY NO LONGER QUALIFY AS LIFE INSURANCE UNDER FEDERAL INCOME TAX LAW AND YOU OR YOUR BENEFICIARIES MAY BE SUBJECT TO ADVERSE TAX CONSEQUENCES. PLEASE CONSULT YOUR TAX PROFESSIONAL.

2.10 Tax Considerations The Company reserves the right to do the following in order to preserve the status of the Policy as a life insurance policy under the Code:

1. Decline to accept a premium payment. 2. Decline to process a withdrawal request. 3. Refund a premium payment, including any earnings thereon.

2.11 Conformity with IIPRC Standards This Policy is approved under the authority of the Interstate Insurance Product Regulation Commission and is issued under Commission standards. Any provision of the Policy that on the provision’s effective date is in conflict with the applicable Interstate Insurance Product Regulation Commission standards for this product type in effect as of the provision’s effective date of Commission policy approval is hereby amended to conform to the applicable Interstate Insurance Product Regulation Commission standards in effect as of the provision’s effective date of Commission policy approval.

2.12 Basis of Computations Guaranteed maximum cost of insurance rates and guaranteed surrender values are based on the mortality table on the Policy Specifications page. We have filed a detailed statement of the basis of the charges and the method of computation with the Interstate Insurance Product Regulation Commission.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Policy Values, Surrender Values and Net Surrender Values are at least equal to the values required by the NAIC Variable Life Insurance Regulation, model 270 using Actuarial Guideline XXIV.

ICC21_LC1 [8]

3.1 Ownership This Policy belongs to the Owner. The Owner, as shown on the Policy Specifications page, or as subsequently changed, may exercise all rights under this Policy. Subject to more specific provisions elsewhere herein, these rights include, but are not limited to, the right to: (a) change the Owner, (b) select or change a Contingent Owner, (c) select or change any Beneficiary or Contingent Beneficiary, (d) allocate Net Premium Payments among and between the Subaccounts and the Fixed Account, and (e) assign the Policy.

The Insured is the Owner unless the application specifies a different person as Owner.

3.2 Changing the Owner The Owner may change the Owner by Written Notice at any time while the Insured is alive and the Policy is in force prior to the Maturity Date. A change in ownership is effective as of the date that the Written Notice is signed by the Owner, unless otherwise specified by the Owner; however, the Company is not liable for payments or actions it makes before it receives a Written Notice of a change in Ownership.

3.3 Contingent Owner If the Owner is not the Insured, he or she may name a Contingent Owner in the application or by subsequent Written Notice. The Contingent Owner becomes the Owner in the event that the Owner dies before the Insured. If no Contingent Owner survives the Owner, then upon the death of the last surviving Owner, that Owner’s estate becomes the Owner.

3.4 Assignment The Owner may assign his or her rights under this Policy by Written Notice to the Company. The Company is not bound by the assignment unless it receives a duplicate of the original executed assignment at its Administrative Office. The Company is not responsible for the validity or sufficiency of any assignment and is not liable for any payment or actions it makes before receipt of the duplicate original assignment. Unless the Written Notice specifies otherwise, assignments are effective on the date the Notice is signed by the Owner. An assignment does not change or revoke a Beneficiary designation in effect at the time the assignment takes effect. If an assignment is absolute, the Owner’s rights and privileges under the Policy, including the right to change a Beneficiary, pass to the assignee. If an assignment is collateral, the collateral assignee has priority over the interest of any revocable Beneficiary or revocable Payee under any optional method of settlement selected pursuant to section 14. Any claim under any assignment is subject to proof of insurable interest in the Insured on the part of the assignee and the extent of the assignment. An assignment is subject to any Loan Amount.

3.5 Selecting the Beneficiary The Owner designates the Beneficiary in the application. Any beneficiary designation is revocable unless otherwise stated in the designation. Owners may designate one or more Contingent Beneficiaries. Where more than one Beneficiary or more than one Contingent Beneficiary is designated, each Beneficiary or Contingent Beneficiary, as appropriate, shares in any Death Benefit Proceeds equally unless the designation states otherwise.

3.6 Changing the Beneficiary The Owner may change a Beneficiary by Written Notice at any time while the Insured is alive and the Policy is in force before the Maturity Date. If, however, the Owner previously irrevocably named a Beneficiary, that Beneficiary’s written consent must be provided to the Company before a new Beneficiary may be designated. Any change of Beneficiary is

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document effective as of the date Written Notice is signed by the Owner, unless otherwise specified by the Owner, but the Company is not liable for any payments or actions it makes under the Policy prior to the time it receives Written Notice of a Beneficiary change.

ICC21_LC1 [9]

4.1 Premium Payments Unless otherwise approved by the Company, all premium payments must be made either by (a) check payable to “Symetra Life Insurance Company” and be received at Our Administrative Office, (b) an electronic funds transfer facility, or (c) a wire transfer.

4.2 Planned Periodic Premium Payments Owners may establish a schedule of monthly, quarterly, semi-annual or annual Planned Periodic Premium Payments that is shown on the Policy Specifications page. Subject to the Company’s approval, Owners may change the amount or frequency of Planned Periodic Premium Payments by Written Notice or call to Our telephone transfer facility. The Company will send Owners reminder notices for Planned Periodic Premium Payments not paid for using electronic funds transfer. Owners may arrange to make Planned Periodic Premium Payments through a pre-authorized electronic funds transfer facility. Owners are not required to pay Planned Periodic Premium Payments. Acceptance by the Company of a schedule of Planned Periodic Premium Payments does not guarantee that the Policy will remain in force, or that any benefit under the Policy will continue.

4.3 Unplanned Premium Payments Owners generally may make additional unplanned premium payments at any time before the Maturity Date while the Insured is alive and the Policy is in force. Unless the Owner specifies otherwise in a Written Notice accompanying the payment, the Company considers all unplanned premium payments first as repayments of any outstanding Loan Amount under the Policy.

4.4 Rejection Of Premium Payments

The Company reserves the right to refund any portion of a premium payment that it determines could cause the Policy to fail to qualify as a life insurance contract under the Code or applicable regulations or rulings thereunder. However, the premium shall not be refunded if it is necessary to continue coverage.

The Company reserves the right to refund the excess of any premium payment made over the maximum amount that it determines could cause an increase of the Net Amount of Risk, unless You submit evidence of insurability satisfactory to the Company and the Company chooses to accept the risk. The Company will return or refund any premium payment that it rejects.

If this Policy was not a Modified Endowment Contract (“MEC”) under the Code on the Issue Date, it could subsequently become a MEC if You make a contractual change to this Policy (such as described in section 12) or You pay a premium in excess of the Planned Periodic Premium Payment. We reserve the right to take whatever action is necessary in our judgment to prevent, if possible, this Policy from becoming a MEC, unless You have specifically indicated to us in writing that You want a MEC. We will send You a letter explaining Our action. Any such actions on Our part will apply uniformly to all Policies that are comparably affected.

4.5 Grace Period and Policy Lapse If the Net Surrender Value on a Monthly Anniversary Day is insufficient to cover the monthly deduction due on that day and the Policy is not in a No Lapse Guarantee Period, the Company will mail to the Owner and to any assignee of record at their

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Address of Record, a notice stating that the Policy will only remain in force for 61 days from the date that the notice was mailed. This 61-day period is called the “Grace Period.” If, by the end of the Grace Period, the Owner does not make sufficient premium payments to cover the monthly deduction(s) identified in the notice, then this Policy will terminate without value and all coverage under the Policy will cease. (For this purpose, We consider payments mailed to Us as being received by Us on the date they are post-marked.)

ICC21_LC1 [10]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document The notice mailed to the Owner and to any assignee of record will indicate how much in additional premium payments or loan repayments the Owner must make before the end of the Grace Period to keep the Policy in force for two Policy Months following the end of the Grace Period. Coverage under the Policy continues during the Grace Period and the Company will deduct unpaid monthly deductions when computing any Death Benefit Proceeds if the Insured dies during the Grace Period.

4.6 No Lapse Guarantee Your Policy has a No Lapse Guarantee. The No Lapse Guarantee provides that, prior to the end of the No Lapse Guarantee Expiry Date as shown in the Policy Specifications page, if Your Policy is in a No Lapse Guarantee Period, Your Policy will not enter the Grace Period, even if Your Net Surrender Value is insufficient to cover the monthly deduction. We continue to charge monthly deductions out of your Policy Value while Your Policy is kept in force by way of the No Lapse Guarantee. After the No Lapse Guarantee Expiry Date, the Policy Value may be insufficient to keep the Policy in force unless an additional payment is made at that time. If at any point Your Policy is no longer in a No Lapse Guarantee Period, Your Policy could lapse.

4.7 Reinstatement If the Policy Lapses as provided in section 4.5, the Owner may apply to reinstate it at any time within three years of Lapse but before the Maturity Date. A Policy that has been surrendered cannot be reinstated. To reinstate a Policy, the Owner must submit to the Administrative Office:

1. An application for reinstatement; 2. Evidence of insurability satisfactory to the Company; 3. Premium payments in an amount sufficient to result (along with any loan repayments) in a positive Net Surrender Value; and 4. Premium payments in an amount sufficient that the resulting Net Premium Payments equal or exceed the amount of the next three monthly deductions.

The effective date of a reinstated Policy is the next business day following approval of all of the above-listed items. Upon reinstatement of the Policy, the Company will reinstate any remaining Loan Amount. The Policy Value of a reinstated Policy is the Policy Value on the date the Policy lapsed plus the Net Premium Payments submitted with the application for reinstatement. A reinstated Policy maintains its original Policy Date and the surrender charge is determined using that Policy Date.

SECTION 5: DEATH BENEFIT AND DEATH BENEFIT PROCEEDS

5.1 The Death Benefit If the Insured dies while the Policy and any applicable riders are in force, this Policy will provide a Death Benefit to the Beneficiary. The Death Benefit will be determined under either Option A, Option B, or Option C below, whichever You have chosen and is in effect at such time. The Initial Death Benefit Option is shown on the Policy Specifications page.

Under Option A, the Death Benefit is the greater of: • the Specified Amount on the date of death; or

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document • the Policy Value on the date of death multiplied by the applicable percentage shown in the Table of Applicable Percentages in the Policy Specifications page.

Under Option B, the Death Benefit is the greater of: • the Specified Amount plus the Policy Value on the date of death; or • the Policy Value on the date of death multiplied by the applicable percentage shown in the Table of Applicable Percentages in the Policy Specifications page.

ICC21_LC1 [11]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Under Option C the Death Benefit is the greater of (a) or (b): (a) is equal to: • the Specified Amount at date of death; plus • the sum of the Premiums paid; minus • the sum of any withdrawals, and any applicable charges, taken, provided that such result is not more than the Option C Death Benefit Limit shown on the Policy Specifications page. (b) The Policy Value on the date of death multiplied by the applicable percentage shown in the Table of Applicable Percentages in the Policy Specifications page.

5.2 Death Benefit Proceeds Upon receipt of the Due Proof of Death of the Insured while the Policy is in force and claims documentation satisfactory to Us, the Company shall pay the Death Benefit Proceeds to the Beneficiary or the Contingent Beneficiary as provided in section 3.5. If no Beneficiary or Contingent Beneficiary survives the Insured, then the Company shall pay the Death Benefit Proceeds to the Owner or the Owner’s estate.

The Death Benefit Proceeds are determined as of the date of the Insured’s death and are equal to:

1. The Death Benefit; plus 2. Any death benefit under any rider to the Policy; less 3. Any Loan Amount; less 4. Any unpaid monthly deductions if the Insured dies during the Grace Period.

The Company pays the Death Benefit Proceeds in a single sum unless a Beneficiary (or a Contingent Beneficiary) elects to receive the Proceeds under the settlement option as provided in section 14. Payment of the Death Benefit Proceeds may be delayed as provided in section 13.1.

5.3 Interest on Death Benefit Proceeds The Company will pay interest on the Death Benefit Proceeds from the date of death until the date of payment. Interest will accrue at the Two Year Treasury Constant Maturity Rate as published by the Federal Reserve. The Company will pay additional interest at an annual rate of 10% starting 31 calendar days following the latest of 1, 2, or 3 below until the date the Death Benefit Proceeds are paid:

1. The date We receive Due Proof of Death at Our Administrative Office. 2. The date We receive sufficient information to determine Our liability, the extent of the liability, and the person(s) entitled to the Death Benefit Proceeds. 3. The date that legal impediments to payment of the Death Benefit Proceeds that depend on actions of parties other than the Company are removed to Our satisfaction. (Examples of such legal impediments include: (a) the establishment of guardianships and conservatorships, (b) the appointment and qualification of trustees, and (c) submission of information necessary to satisfy state and federal reporting obligations.)

SECTION 6: THE VARIABLE ACCOUNT

6.1 Variable Account

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document The Variable Account is registered with the SEC as a unit investment trust under the Investment Company Act of 1940, as amended (the “Act”). The Variable Account is also subject to the laws of the Our state of domicile.

ICC21_LC1 [12]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Although the Company owns the assets in the Variable Account, these assets are held separately from the Company’s other assets and are not part of the General Account. The assets in the Variable Account are used to support the operation of and provide the variable values and benefits for this Policy and similar policies. The portion of the assets of the Variable Account equal to the reserves and other policy liabilities of the Variable Account are not chargeable with liabilities that arise from any other business that the Company may conduct. The Company has the right to transfer to its General Account any assets of the Variable Account that are in excess of such reserves and other liabilities.

6.2 Subaccounts The Variable Account consists of Subaccounts. The income, gains and losses, realized or unrealized, from the assets allocated to a Subaccount are credited to or charged against such Subaccount, without regard to other income, gains or losses of the Company.

Each Subaccount invests exclusively in shares of a corresponding Fund. Shares of a Fund are purchased and redeemed for a Subaccount at their net asset value. Any amounts of income, dividends and gains distributed from the shares of a Fund are reinvested in additional shares of that Fund at net asset value.

The dollar amounts of values and benefits of this Policy provided by the Variable Account depend on the investment performance of the Subaccount selected by the Owner. The Company does not guarantee the investment performance of the Subaccounts. Owners bear the full investment risk for Subaccount Value in the selected Subaccounts.

6.3 Changes to the Variable Account

Where permitted by applicable law, the Company may:

1. Create new separate accounts; 2. Combine or reorganize separate accounts, including the Variable Account; 3. Remove, combine or add Subaccounts, and make the combined or added Subaccounts available for allocation of premium payment; 4. Close any or all Subaccounts to premium payments, transfers, or other additional allocations of Policy Value by existing or new Owners; 5. Add new Funds or remove existing Funds; 6. Substitute shares of a Fund for shares of a different Fund if shares are no longer available for investment or if the Company decides, in its sole discretion, that investment in a different Fund is preferable; 7. Transfer assets from one Subaccount to another or from the Variable Account to another separate account; 8. Deregister the Variable Account under the Act if such registration is no longer required; 9. Operate the Variable Account as a management investment company under the Act or in any other form permitted by law; 10. Make any changes to the Variable Account or its operations as may be required by the Act, as amended, or by other applicable laws or regulations.

The investment policy of the Variable Account will only be changed with the approval of the Insurance Commissioner in our state of domicile. The process for such approval is on file with the insurance supervisory official of the state in which this Policy has been delivered.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 6.4 Variable Policy Value Variable Policy Value reflects the investment experience and expenses of the Subaccounts to which it is allocated, any Net Premium Payments allocated to the Subaccounts, transfers of the Policy Value in or out of the Subaccounts (including transfers resulting from Policy loans or repayment of loans), any withdrawals of Variable Policy Value, and that portion of the monthly deduction attributable to the Subaccounts. There is no guaranteed minimum Variable Policy Value.

6.5 Units For each Subaccount, Net Premium Payment(s) allocated to a Subaccount or amounts of Policy Value transferred to a Subaccount are converted into Units. The number of Units credited to a Policy is determined by dividing the dollar amount directed to each Subaccount by the value of the Unit for that Subaccount for the Valuation Day as of which the Net Premium Payment(s) or transferred amount is invested in the Subaccount. Therefore, Net Premium Payments allocated to or amounts transferred to a Subaccount under a Policy increase the number of Units of that Subaccount credited to the Policy. Units are credited as of the end of the Valuation Period in which the Company receives Written Notice regarding the event or, for the Net Periodic Premium Payment, the end of the Valuation Period during which the Net Periodic Premium Payment is made.

Certain events will reduce the number of Units of a Subaccount credited to a Policy. Withdrawals, including any withdrawal processing fee or transfers, including any transfer processing fee, of Subaccount Value from a Subaccount will result in the cancellation of the appropriate number of Units of that Subaccount, as will the following: surrender of the Policy; payment of the Death Benefit Proceeds; or the deduction of the monthly deduction. Units are cancelled as of the end of the Valuation Period in which the Company receives Written Notice regarding the event or, for the monthly deduction, the end of the Valuation Period during which the monthly deduction is made. Any additions or subtractions of Units due to Net Premiums, transfers, withdrawals, loans and monthly deductions are done after the Net Investment Factor and Unit values are calculated on each Valuation Day.

6.6 Unit Value The Unit value for each Subaccount was arbitrarily set initially at $10 when that Subaccount began operations. Thereafter, the Unit value at the end of every Valuation Day is the Unit value at the end of the previous Valuation Day times the Net Investment Factor, as described below. The Subaccount Value for a Policy on any day is equal to the number of Units of that Subaccount credited to the Policy multiplied by the value of a Unit for that Subaccount on that day.

6.7 Net Investment Factor The Net Investment Factor is an index applied to measure the investment performance of Units of a Subaccount from one Valuation Period to the next. The Net Investment Factor for any Subaccount for any Valuation Period is determined by dividing 1 by 2, where:

1. is the result of: a. the Net Asset Value Per Share of the Fund held in the Subaccount, determined at the end of the current Valuation Period; plus b. the per share amount of any dividend or capital gain distributions made by the Fund held in the Subaccount, if the “ex-dividend” date occurs during the current Valuation Period; plus or minus c. a per share charge or credit for any taxes reserved for, which is determined by Us to have resulted from the operations of the Subaccount.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 2. Is the Net Asset Value Per Share of the Fund held in the Subaccount, determined at the end of the last prior Valuation Period.

ICC21_LC1 [14]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document SECTION 7: THE FIXED ACCOUNT 7.1 Fixed Account The Fixed Account is an account that earns interest at a declared rate of interest. The Guaranteed Minimum Interest Rate for the Fixed Account is shown on the Policy Specifications page.

7.2 Fixed Policy Value On each Monthly Anniversary Day, We will calculate the Fixed Policy Value in the following order: • the Fixed Policy Value on the last Monthly Anniversary Day plus one month's interest; plus • all Net Premiums allocated to the Fixed Policy Value since the last Monthly Anniversary Day plus pro rata compound interest from the date a premium is received to the date the Fixed Policy Value is determined; plus • all transfers to the Fixed Policy Value since the last Monthly Anniversary Day plus pro rata compound interest from the date the transfer is made to the date the Fixed Policy Value is determined; minus • all withdrawals (including any applicable withdrawal processing fee) or transfers out of the Fixed Policy Value (including any applicable transfer processing fee) since the last Monthly Anniversary Day plus pro rata compound interest from the date a withdrawal or transfer is made to the date the Fixed Policy Value is determined; minus • the monthly deduction for the following month. On any day other than a Monthly Anniversary Day, the Fixed Policy Value will be equal to: • the Fixed Policy Value on the last Monthly Anniversary Day plus pro rata compound interest from the last Monthly Anniversary Day to the date the Fixed Policy Value is determined; plus • all Net Premiums received since the last Monthly Anniversary Day plus pro rata compound interest from the date a premium is received to the date the Fixed Policy Value is determined; plus • all transfers to the Fixed Policy Value since the last Monthly Anniversary Day plus pro rata compound interest from the date the transfer is made to the date the Fixed Policy Value is determined; minus • all withdrawals (including any applicable withdrawal processing fee) or transfers out of the Fixed Policy Value (including any applicable transfer processing fee) taken since the last Monthly Anniversary Day plus pro rata compound interest from the date a withdrawal or transfer is made to the date the Fixed Policy Value is determined.

7.3 Interest Credited The Company guarantees that it will credit interest on Fixed Policy Value at an effective annual rate of not less than the Guaranteed Minimum Interest Rate shown on the Policy Specifications page. In its discretion, the Company may credit interest at rates higher than the Guaranteed Minimum Interest Rate.

Any interest credited in excess of the Guaranteed Minimum Interest Rate will be credited no less than annually, and is nonforfeitable, except indirectly due to surrender charges.

SECTION 8: FEES AND CHARGES

8.1 Determination and Redetermination of Fees and Charges The Company may, in its sole discretion, charge less than the guaranteed maximum fees or charges shown on the Policy Specifications page with regard to the fees and charges identified in this section 8. Any fees and charges enumerated in this section 8 may result in a profit to the Company.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document In the determination and redetermination of any fees or charges described in this section 8, the Company, in its sole discretion, may consider factors including, but not limited to, (a) Policy duration, (b) the sex, Attained Age, Issue Age and Risk Class of the Insured, (c) its expectations as to future mortality experience, (d) its expectations as to future Policy persistency experience, (e) taxes, (f) capital and reserve requirements, (g) investment earnings, (h) other expenses, and (i) Company profit objectives. The Company reviews fees and charges on an ongoing basis based on its expectations as to factors (a) – (i) and other factors in its sole discretion.

In addition, changes in fees or charges are made on a uniform basis for Insureds of the same class as defined by sex, Attained Age, Issue Age, Risk Class, Specified Amount, and Policy duration.

This section 8.1 does not apply to the surrender charge, which is a guaranteed charge, described in section 8.8 below.

8.2 Monthly Deduction The monthly deduction is a charge made by the Company as of the Policy Date and every Monthly Anniversary Day thereafter until the Maturity Date by reducing Subaccount Values (i.e., liquidating Units) and any Fixed Policy Value either in the proportion that each Subaccount Value and any Fixed Policy Value bears to Policy Value (less Loan Account Value), or as directed by the Owner. The monthly deduction consists of: (a) the monthly administrative charge, (b) the monthly expense charge, (c) the monthly cost of insurance charge, (d) the monthly Variable Policy Value Charge, and (e) the cost of any applicable riders. The guaranteed maximum amounts of these charges are shown on the Policy Specifications page.

8.3 Monthly Administrative Charge The Company assesses a monthly administrative charge expressed in dollars. The guaranteed maximum monthly administrative charge is shown on the Policy Specifications page .

8.4 Monthly Expense Charge The Company assesses a monthly expense charge that is expressed as dollars per $1,000 of Initial Specified Amount. This charge covers the Company’s costs for sales, administration, capital, taxes, and a variety of other expenses. The guaranteed maximum monthly expense charge is shown on the Policy Specifications page. If the Specified Amount decreases, the monthly expense charge will not reflect the change in the Specified Amount. If the Specified Amount increases, Your Policy will incur an additional monthly expense charge based upon the Specified Amount increase and the insured’s Attained Age at that time.

8.5 Monthly Cost of Insurance Charge The Company assesses a monthly cost of insurance charge expressed in dollars. The monthly cost of insurance charge is computed by dividing the Net Amount at Risk by $1,000 and multiplying the result by the cost of insurance rate. The cost of insurance rates will never be greater than those rates shown in the table of guaranteed maximum cost of insurance rates on the Policy Specifications page.

8.6 Monthly Variable Policy Value Charge The Company assesses a monthly charge from Variable Policy Value expressed in dollars. The Company may choose to use revenue from this charge to cover a variety of different types of expenses, including sales expenses. The maximum monthly Variable Policy Value charge is shown on the Policy Specifications page.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 8.7 Premium Charge The Company deducts a charge from each premium payment received. The guaranteed maximum premium charge is shown on the Policy Specifications page. This charge covers some of the Company’s cost for sales expenses and any Policy-related state and federal tax liabilities.

8.8 Surrender Charge If the Owner surrenders the Policy, the Company deducts a surrender charge as shown on the Policy Specifications page. The surrender charge reduces the amount otherwise paid to the Owner upon surrender. It is also a function of a Policy’s Initial Specified Amount. The surrender charge is reinstated in the event that the Policy is reinstated.

8.9 Transfer Processing Fee A transfer processing fee may be charged for transfers during each Policy Year in excess of Maximum Transfers per Policy Year without charge shown on the Policy Specifications page. The amount of this fee is shown on the Policy Specifications page. For the purposes of assessing the transfer processing fee, each Written Notice or call to Our telephone transfer facility requesting a transfer is considered to be one transfer, regardless of the number of Subaccounts affected by the transfer. The transfer processing fee is deducted from the amount being transferred.

8.10 Withdrawals Processing Fee The Company reserves the right to assess a fee for processing each withdrawal. If the Company assesses a withdrawal processing fee for each withdrawal, the amount of this fee will be shown on the Policy Specifications page.

SECTION 9: ALLOCATIONS AND TRANSFERS

9.1 Allocation of Net Premium Payments Net Premium Payments are allocated among and between the Subaccounts and the Fixed Account as of the date that they are received at the Administrative Office according to the Owner’s allocation instruction in the application or in a subsequent Written Notice or call to Our telephone transfer facility. Allocation instructions must be in whole percentages. The Company reserves the right to establish additional limitations on premium payment allocations.

The Company allocates Net Premium Payments it receives during the Cancellation Period (including the Initial Premium Payment) to the Fixed Account. At the end of the Cancellation Period, the Net Premium Payment plus credited interest minus any monthly deduction is reallocated to each Subaccount or the Fixed Account selected by the Owner based on that the Owner’s allocation instructions.

9.2 Transfer Privilege While the Insured is still living and the Policy is in force, the Owner may, by Written Notice or by Our telephone transfer facility, transfer all or part of any Subaccount Value to another Subaccount(s) or to the Fixed Account, or transfer all or part of the Fixed Policy Value to any Subaccount(s), subject to the following restrictions and the additional restrictions in section 9.3 below:

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 1. The minimum transfer amount is shown in the Policy Specification page (or, the entire Subaccount Value or Fixed Policy Value, if less);

ICC21_LC1 [18]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 2. The maximum transfer request that would reduce any Subaccount Value or the Fixed Policy Value below an amount equal to the minimum transfer amount is treated as a transfer request for the entire Subaccount Value or Fixed Policy Value; and 3. The Company may restrict transfers between Subaccounts to the extent necessary to comply with restrictions imposed by Funds or by Company policies and procedures to prevent disruptive trading in Fund shares.

9.3 Restrictions on Transfers from the Fixed Account Transfers of Fixed Policy Value from the Fixed Account within any Policy Year after the first Policy Year may not exceed the greater of:

1. 25% of Fixed Policy Value measured on the preceding Policy Anniversary; or 2. The amount of Fixed Policy Value transferred from the Fixed Account during the preceding Policy Year.

SECTION 10: SURRENDER AND WITHDRAWALS

10.1 Surrender At any time while the Insured is still living and the Policy is in force, the Owner may, by Written Notice, surrender it for its Net Surrender Value. A surrender is effective as of the date on which a Written Notice requesting surrender is received at the Administrative Office. If the Owner surrenders the Policy during the surrender charge period, the Company will deduct a surrender charge as shown on the Policy Specifications page and described in section 8.8 above. Once the Policy is surrendered, all coverage and other benefits under it cease and it cannot be reinstated.

10.2 Withdrawals After the first Policy Year, while the Insured is still living and the Policy is in force prior to the Maturity Date, an Owner may, by Written Notice, withdraw any part of the Surrender Value of the Policy, subject to certain conditions. A withdrawal is effective as of the date on which a Written Notice requesting withdrawal is received at the Administrative Office. As of that date, Policy Value is reduced by the amount of the withdrawal plus any applicable withdrawal processing fee.

If the Death Benefit Option is Option A, the Company may reduce the Specified Amount. The Specified Amount reduction will be determined as follows, and shall never be less than zero:

A. The withdrawal minus the greater of (zero or {(1) –(2)}) divided by (3), where these equal: (1) The Policy Value immediately prior to the withdrawal multiplied by the applicable percentage shown in the Table of Applicable Percentages in the Policy Specifications page; (2) The Specified Amount immediately prior to the withdrawal; and (3) The applicable percentage shown in the Table of Applicable Percentages in the Policy Specifications page.

If the Policy Death Benefit option is B or C, then withdrawals do not reduce the Specified Amount. Unless otherwise indicated in the Written Notice, amounts withdrawn and withdrawal processing fees deducted in connection with withdrawals are taken from Subaccount Values and Fixed Policy Value based on the current allocation of monthly deductions. Where this is not possible, withdrawals are taken from Subaccount Values and Fixed Policy Value based on the proportion that each Subaccount Value and the Fixed Policy Value bear to Policy Value (less Loan Account

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Value). If the Owner requests a decrease in Specified Amount as of the same date as a withdrawal, the withdrawal is processed after the decrease in Specified Amount.

ICC21_LC1 [19]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Notwithstanding the foregoing, the Company reserves the right to reject a withdrawal request if the request would cause the Specified Amount to be reduced below the minimum Specified Amount shown on the Policy Specifications page. Likewise, the Company reserves the right to reject a withdrawal request if the request would cause the Policy to fail to qualify as a life insurance contract under the Code or regulations or rulings thereunder, as interpreted by the Company.

SECTION 11: LOANS

11.1 Borrowing Privilege At any time while the Insured is still living and the Policy is in force, the Owner may, by Written Notice, borrow money from the Company using the Policy as the sole security for the loan provided that (a) a written loan agreement is signed by the Owner and any irrevocable beneficiary, and (b) the Owner makes a satisfactory assignment of the Policy to the Company. The minimum and maximum amounts that an Owner may borrow are shown on the Policy Specifications page.

The Company reserves the right to defer the payment of any loan for six months after application for the loan is received by the Company except for any loan made to pay premiums due to the Company.

11.2 Interest Charged on Borrowed Amounts The Company charges interest on amounts borrowed by the Owner. The fixed interest rate is set at the time of the loan and is fixed for the life of the loan. The fixed interest rate charged will not exceed the Policy Loan Annual Interest Rate shown on the Policy Specifications page.

Interest is charged in advance and is due from the Owner on each Policy Anniversary for the next Policy Year. If the Owner does not pay such interest when due, the amount of the interest is added to the outstanding Loan Amount. Thus, unpaid interest is charged interest during the ensuing Policy Year.

11.3 Collateral for Loans When the Company makes a loan to the Owner, it transfers to the Loan Account an amount of Policy Value sufficient to secure the loan out of the Subaccounts and the Fixed Account. The Owner may specify how this transferred Policy Value is allocated from among the Subaccount Values and the Fixed Policy Value. If an Owner does not specify the allocation, the Company deducts the amount of the loan from the Subaccount Value(s) and the Fixed Account in the same proportion as the Company takes monthly deductions. If that is not possible, then the Company makes the allocation based on the proportion that each Subaccount Value and the Fixed Policy Value bear to the Policy Value (less Loan Account Value) as of the date that the transfer is made.

If unpaid interest is due from an Owner on a Policy Anniversary, Policy Value in the amount of the interest also is transferred to the Loan Account as of that Anniversary and is added to the Loan Amount. The Policy Value transferred in connection with unpaid interest is allocated on the same basis as other Policy Value transferred by the Company to Loan Account.

Loan Account Value is recalculated when:

1. Interest is added to the Loan Amount; 2. A loan repayment is made;

11.4 Interest Credited to the Loan Account The Company credits Loan Account Value with interest at an effective annual rate of not less than the Guaranteed Minimum Interest Rate for Loan Collateral shown on the Policy Specifications page. On each Policy Anniversary, interest earned on Loan Account Value since the preceding Anniversary is transferred

ICC21_LC1 [20]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document to the applicable Subaccount(s) and the Fixed Account. Unless the Owner specifies otherwise, such transfers are allocated in the same manner as transfers of collateral to the Loan Account.

11.5 Lapse Due to Outstanding Loans

If Loan Account Value exceeds Surrender Value, then the Owner must either make a loan repayment or a premium payment sufficient to raise the Surrender Value or lower the Loan Account Value so that Surrender Value exceeds the Loan Account Value. The Company will send the Owner and any assignee of record a notice indicating the amount that must be paid and stating that the Policy will only remain in force for 61 days (the Grace Period) from the date that the notice was mailed. If the Grace Period expires without the payment being made, then the Policy Lapses as provided in section 4.5. 11.6 Repayment of Loans The Owner may repay a loan or repay any part of a loan at any time while the Insured is still living and the Policy is in force. Upon repayment of any part of a loan, Loan Account Value in an amount equal to the payment is transferred to the Subaccounts and the Fixed Account as of the date that the payment is received at the Administrative Office. Unless the Owner specifies otherwise, the amount transferred is allocated among or between the Subaccounts and the Fixed Account according to the Owner’s allocation instruction for Net Premium Payments in effect at that time.

SECTION 12: POLICY CHANGES

12.1 Policy Changes You may make the changes in sections 12.2 – 12.5 below to this Policy after the first Policy Anniversary by sending Us a request by Written Notice. Policy changes can be made only while the Insured is living and the Policy is in force. We will send You an endorsement to Your Policy reflecting these changes when a change occurs and, if applicable, a new Table of Surrender Charges and Monthly Expense Charges. We reserve the right to refuse to make any change that We determine would cause this Policy to fail to qualify as life insurance under applicable tax law. Policy changes may have other tax consequences. You should consult a tax professional before making Policy changes.

12.2 Increase in Specified Amount For an increase in Specified Amount You must submit a new application requesting a Specified Amount increase. We reserve the right to require evidence of insurability satisfactory to Us. The minimum amount of the Specified Amount increase is shown on the Policy Specifications page. We will offer such increase up to the maximum Issue Age for Your Risk Class. The effective date of any increase will be the Monthly Anniversary Day following the date We approve the application. For this additional amount of Specified Amount there will be a new surrender charge period, new monthly expense charges and new cost of insurance rates will be charged. Surrender charges and monthly expense charges will be based upon Your Attained Age. See sections 8.2 and 8.8. We will send You an endorsement to Your Policy reflecting these changes, and a new Table of Surrender Charges.

A new two-year period of contestability will begin for the amount of the increase in Specified Amount.

12.3 Decrease in Specified Amount After the first Policy Anniversary, while the Insured is still living and the Policy is in force, the Owner may by Written Notice, request a decrease in the Specified Amount. The decrease in Specified Amount must not be in an amount so large that it would decrease the total Specified Amount below the Minimum Specified Amount shown on the Policy Specifications page.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document The Specified Amount will not be decreased if doing so would cause Net Surrender Value to fall below zero. No surrender charges will be assessed or reduced on any approved Specified Amount decrease. For any Specified Amount decreases, decreases are taken against the most recent increases first, “last in, first out”.

ICC21_LC1 [21]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document No decrease in Specified Amount is permitted during the Grace Period. Any decrease becomes effective on the Monthly Anniversary Day on or next following the date that the Company approves the request for the decrease. A decrease in Specified Amount will change the guideline premiums and You may change Your Planned Premium Payment amount. After a decrease in Specified Amount, the Company will send the Owner a supplemental Policy Specifications page showing the effective date of the decrease, the monthly cost of insurance rate after the decrease and any changes to premium payment information from the previous or original Policy Specifications page.

The Company reserves the right to limit decreases in Specified Amount to one per Policy Year.

12.4 Change in Death Benefit Option While the Insured is still living and the Policy is in force prior to the Maturity Date, the Owner may by Written Notice, request a change from one Death Benefit Option to another. Not all Death Benefit Option changes are allowed and some may require evidence of insurability. Any Change in Death Benefit Option becomes effective on the Monthly Anniversary Day on or next following the date that the Company approves the request. A surrender charge will not apply to, or be reduced by, a change in Death Benefit Option even if the Policy’s Specified Amount decreases.

If You ask Us to change from Option A to Option B, We will decrease the Specified Amount by the amount of Your Policy Value on the date of change. We reserve the right to decline to make such change if it would reduce the Specified Amount below the Minimum Specified Amount as shown in the Policy Specification page, for which We would then issue this Policy under Our rules.

If You ask Us to change from Option B to Option A, We will increase the Specified Amount by the amount of Your Policy Value on the date of change.

If You ask Us to change from Option C to Option A, We will increase the Specified Amount by an amount equal to, as of the date of the change: 1. the sum of the Premiums paid; minus 2. the sum of any withdrawals taken.

If this amount is negative, the Specified Amount will not be decreased. The Specified Amount will not be increased above the amount shown in the Policy Specifications page as the "Option C Death Benefit Limit."

If You ask Us to change from Option C to Option B, We will adjust the Specified Amount by an amount (which may be positive or negative) equal to, as of the date of the change: 1. the change to the Specified Amount for a Death Benefit Option change from Option C to Option A; minus 2. the amount of Your Policy Value.

We reserve the right to decline to make such change from Option C to Option B if it would reduce the Specified Amount below the Minimum Specified Amount as shown in the Policy Specification page, for which We would then issue this Policy under Our rules.

Changes to Option C from either Option A or Option B are not permitted.

12.5 Change in Risk Class Changes to the Insured’s Risk Class may be requested prior to reaching the maximum Issue Age of that new Risk Class. We will require a Written Request to change the Risk Class and evidence of insurability

ICC21_LC1 [22]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document satisfactory to Us. Only one request to change the Insured’s Risk Class may be made in a Policy Year. The effective date of any change in Risk Class will be the Monthly Anniversary Day following the date We approve the application. The current monthly cost of insurance rates and the guaranteed maximum cost of insurance rates will change to the new Risk Class, but the monthly expense charge and surrender charges will not change. The Table of Applicable Percentages in the Policy Specifications page may change. See sections 8.2, 8.5, and 8.8. We will send You an endorsement to Your Policy and an updated Policy Specification reflecting the changes. SECTION 13: PAYMENTS

13.1 Payment of Benefits The Company pays the amounts of any surrender, withdrawals, or Death Benefit Proceeds involving Variable Policy Value within seven business days after receipt of all applicable Written Notices and/or Due Proofs of Death. However, the Company can postpone such payments if:

1. The New York Stock Exchange is closed, other than customary weekend and holiday closing, or trading on the exchange is restricted as determined by the SEC; or 2. The SEC permits, by an order, the postponement for the protection of Owners; or 3. The SEC determines that an emergency exists that would make the disposal of securities held in the Variable Account or the determination of their value not reasonably practicable.

If a recent check or draft has been submitted, the Company has the right to defer payment of surrenders, withdrawals, Death Benefit Proceeds, or payments under the settlement option until such check or draft has been honored.

The Company has the right to defer payment of any surrender, withdrawal, or transfer of Fixed Policy Value for up to six months from the date of receipt of Your Written Notice. If the Company delays a transfer of Fixed Policy Value, it shall notify the Owner of the date as of which the transfer will be effective, the reason for the delay and the transferred amount. If the Company becomes aware of the death of an Insured, it may, prior to receipt of Due Proof of Death, transfer all Variable Policy Value to the Fixed Account until We receive Due Proof of Death and claims documentation satisfactory to Us. In this event, interest on the Death Benefit Proceeds will be paid as provided in section 5.3.

SECTION 14: SETTLEMENT OPTION

14.1 Payment of Benefits or Values The Company pays Owners or Beneficiaries (or Contingent Beneficiaries), as appropriate, the amount of any surrender, withdrawal or Death Benefit Proceeds in a single sum unless the Owner has, by Written Notice, selected the settlement option described below. If the amount being paid by the Company is less than $5,000, however, payment is only made in a single sum. In addition, if the Owner or Beneficiary (or Contingent Beneficiary) receiving payment is an executor, administrator, trustee, or not a natural person, payment is made in a single sum unless the Company specifically consents to payment under the settlement option.

Owners may elect the settlement option for payment of the Death Benefit Proceeds in lieu of a single sum, at any time while the Insured is still living while the Policy is in force. If no election is made by the Owner before the Insured’s death, then, upon the Insured’s death, the Beneficiary (or Contingent Beneficiary) may elect the settlement option before the Death Benefit Proceeds are paid. The Owner may elect to receive the Net Surrender Value of a Policy or the amount of a

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document withdrawal in the form of the settlement option at any time before the payment of the Net Surrender Value or withdrawal. For the purposes of this section 14 (and section 3.4), “Payee” means the Owner (or Contingent Owner) or Beneficiary (or Contingent Beneficiary), as appropriate.

ICC21_LC1 [23]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Any annuity benefits at the time of their commencement will not be less than those that would be provided by the application of the proceeds to purchase a single consideration immediate annuity contract at purchase rates offered by the Company at the time to the same class of annuitants whether the annuity benefits are payable in fixed or variable amounts or both, if the Company offers a single consideration annuity contract at the time to the same class of annuitants.

14.2 Frequency of Payments Payments may be made every 1 year, 6 months, 3 months, or every month. The Payee must specify the payment frequency when selecting the settlement option. If payment under the option would be less than $100.00, the Company will adjust the frequency of payments so that each payment is at least $100.00.

14.3 First Payment Depending on the payment frequency selected, the first payment under the settlement option is made as of 1 year, 6 months, 3 months, or 1 month from the date of the Insured’s death. Depending on the payment frequency selected and subject to section 13 of this Policy, the first payment under the settlement option is made as of 1 year, 6 months, 3 months, or 1 month from the effective date of any surrender or withdrawal.

14.4 Betterment of Rates If, under the settlement option, the Company’s regular annuity purchase rates on the date of the Insured’s death or the effective date of any surrender or withdrawal are more favorable than those upon which the settlement option is based, the Company shall compute payments using the regular annuity rates. The Company will furnish information about the regular annuity rates upon request.

14.5 Death of Payee Unless instructed otherwise at the time that the settlement option is selected, at the death of the Payee, the Company pays any remaining payments under the settlement option in a single sum to the Payee’s estate.

14.6 Additional Interest Earnings The Company may, in its sole discretion, pay interest at rates in excess of the rates guaranteed in the settlement option.

14.7 Settlement Option, Payments for a Specified Period The Company pays the Death Benefit Proceeds (or the Surrender Value of the amount of a withdrawal) in equal payments for the number of years specified when the settlement option is selected. The amount of each settlement payment for each $1,000 applied under this option is shown in the table below. If the Payee dies before the expiration of the specified number of years, the Company pays the value of the remaining payments as stated in section 14.5.

TABLE OF MONTHLY PAYMENTS UNDER ALTERNATE OPTION PER $1,000 OF PROCEEDS

Alternate Option Payments for a Fixed Period

Years Amount Years Amount Years Amount 1 83.72 11 8.00 21 4.40 2 42.07 12 7.37 22 4.22

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 3 28.18 13 6.83 23 4.05 4 21.24 14 6.38 24 3.90 5 17.08 15 5.98 25 3.77 6 14.30 16 5.63 26 3.64

ICC21_LC1 [24]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 7 12.32 17 5.33 27 3.52 8 10.83 18 5.06 28 3.41 9 9.68 19 4.81 29 3.31 10 8.75 20 4.60 30 3.21

ICC21_LC1 [25]

Symetra Life Insurance Company, Variable Insurance Products Fund, Variable Insurance Products Fund II And Variable Insurance Products Fund III Variable Insurance Products Fund IV, and Variable Insurance Products Fund V and Fidelity Distributors Company LLC hereby amend the Participation Agreement (“Agreement”) dated February 25, 2007, as amended, by doing the following:

1. Schedule A. Schedule A of the Agreement is hereby deleted in its entirety and replaced with the attached Schedule A:

2. Except as modified and amended hereby, the Agreement is hereby ratified and confirmed in full force and effect in accordance with its terms.

IN WITNESS WHEREOF, the parties have hereto affixed their respective authorized signatures, intending that this Amendment be effective as of the 13th day of May, 2021.

SYMETRA LIFE INSURANCE COMPANY

By: Name: Jon S. Stenberg Title: Executive Vice President

VARIABLE INSURANCE PRODUCTS FUND VARIABLE INSURANCE PRODUCTS FUND II VARIABLE INSURANCE PRODUCTS FUND III VARIABLE INSURANCE PRODUCTS FUND IV VARIABLE INSURANCE PRODUCTS FUND V

By: ______Name:______Title: Authorized Signatory

FIDELITY DISTRIBUTORS COMPANY LLC

By: Name: ______Title: ______

SEPARATE ACCOUNTS AND ASSOCIATED CONTRACTS

Name of Separate Account and Policy Form Numbers of Contracts Date Established by Board of Directors Funded By Separate Account

Symetra Separate Account SL Premier Accumulation Life November 6, 1986 Enhanced Accumulation Life Symetra Complete Symetra Complete Advisor Accumulator Variable Universal Life

Symetra Separate Account C Spinnaker September 14, 1993 Spinnaker Advisor Spinnaker Choice Focus Retirement Passport GVA Mainsail

Symetra Resource Variable Account B Spinnaker Plus February 6, 1986 Resource B Symetra True Variable Annuity

Unregistered Accounts

Symetra Separate Account D Symetra GVA

Symetra Separate Account VL VCOLI July 29, 2008

Symetra Separate Account A Resource A

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Symetra Life Insurance Company [Mail to: PO Box 34690 | Seattle, WA 98124-1690 Overnight to: 777 108th Avenue NE, Suite 1200 | Bellevue, WA 98004-5135 Phone 1-800-796-3872 ]

SURRENDER VALUE ENHANCEMENT RIDER

This Rider (“Rider”) becomes a part of the Policy to which it is attached (“the Policy”). All terms of the Policy that do not conflict with this Rider’s terms apply to this Rider. If there is a conflict between the terms of this Rider and the terms of the Policy, the terms of this Rider shall prevail. There is a one-time charge for this Rider and it has no Policy Value or Loan Amount.

Rider Benefit This Rider increases the Net Surrender Value of the Policy to which it is attached by replacing the Surrender Charges in the Policy with an alternate set of Surrender Charges which is shown on the Policy Specifications page.

Rider Charge There is a one-time rider charge taken as part of the Monthly Deduction on the Issue Date of the Policy to which this Rider is attached. The Surrender Value Enhancement Charge is shown on the Policy Specifications page. This charge once assessed is not refundable.

Reinstatement If the Policy to which this Rider is attached is reinstated, this Rider may be reinstated.

Termination This Rider will terminate on the date the Policy terminates or the date you choose to terminate the rider but the Surrender Charge Schedule shown in the Your Policy will remain in effect.

Effective Date This Rider is effective on the Issue Date or the effective date of Reinstatement of the Policy to which it is attached.

Symetra Life Insurance Company

[ ]

[David S Goldstein] [Secretary]

Symetra® is a registered service mark of Symetra Life Insurance Company.

ICC17_LE4 Page 1 of 1

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Symetra Life Insurance Company [Mail to: PO Box 34690 | Seattle, WA 98124-1690 Overnight to: 777 108th Avenue NE, Suite 1200 | Bellevue, WA 98004-5135 Phone 1-800-796-3872 ]

OVERLOAN LAPSE PROTECTION RIDER

This Overloan Lapse Protection Rider (“Rider”) is a part of the Policy to which it is attached (“Policy”). In the event of a conflict between the terms of this Rider and the terms of the Policy, the terms of this Rider shall prevail.

This Rider is effective on the Issue Date or the effective date of Reinstatement of the Policy to which it is attached.

Rider Benefit This Rider, if exercised, (1) prevents the Policy from lapsing when the Surrender Value, less the Loan Amount, is not sufficient to cover the monthly deduction due to loan indebtedness, and (2) causes the Policy to automatically become paid- up life insurance. This Rider is only available on policies which utilize the Guideline Premium Test for Life Insurance and are not considered by the Code to be Modified Endowment Contracts at its Time of Exercise (as defined below).

Exercising this Rider may have tax consequences; please consult a qualified tax professional for more details.

There is a one-time charge for exercising this Rider that will be deducted from Your Policy Value at the Time of Exercise. This Rider has no associated Policy Value or Loan Amount of its own.

Requirements to Exercise this Rider We will notify You on the first Monthly Anniversary Day following the date that the requirements listed below have been met. • The Policy is in force and has reached the fifteenth Policy Anniversary; • The Insured has reached an Attained Age of at least 75; • The Policy Death Benefit Option is Option A; • The Policy Value multiplied by the applicable percentage shown in the Table of Applicable Percentages in the Policy Specifications page exceeds the Specified Amount; and • The Loan Amount exceeds the lesser of the following values: ◦ 93% of the current Policy Value; or ◦ (100% less the Rider Exercise Charge Rate stated in the Rider Specifications page) of the current Policy Value.

Once You receive the notification that the requirements listed above have been met, You have the option of requesting that this Rider be exercised. If You wish to exercise this Rider, You must submit to Our Administrative Office a Written Notice of Your request to exercise this Rider. If the above requirements have been met and You do not choose to exercise this Rider, You may exercise this Rider at a later date as long as you submit Written Notice before the end of the grace period, provided that the Policy remains in force and the above requirements are met at the Time of Exercise.

We will send you written notice at least thirty-one days before the end of the Policy’s grace period that, if applicable,

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document this Rider may be exercised. If You wish to exercise this Rider, You must submit Written Notice to Us before the end of the grace period. If You receive the written notice from Us less than thirty-one days before the end of the grace period, and You wish to exercise the benefit, You must submit Written Notice to Us within thirty days after receiving the notice.

Operation of the Policy upon Exercising this Rider Provided You still meet the eligibility requirements above, on the Monthly Anniversary Day following the receipt of Your Written Notice to exercise this Rider and all of the requirements to exercise this Rider have been met to our satisfaction (the “Time of Exercise”), this Rider shall be considered exercised and the following terms and conditions will apply: • The charge for this Rider will be deducted from the Policy Value as described in the Rider Cost section below; • Any Variable Policy Value will be transferred to the Fixed Account and will grow at the Guaranteed Minimum Interest Rate shown on the Policy Specifications page; • No further transfers out of the Fixed Account will be permitted;

ICC21_LE3 [Page 1 of 2] [VUL]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document • The Loan Amount and the Loan Account Value will grow at the Guaranteed Minimum Interest Rate shown on the Policy Specifications page; • No monthly deductions or additional charges will be taken from the Policy Value; • No further loans or withdrawals will be allowed; • No further premium payments or loan repayments will be allowed; • No Specified Amount or Death Benefit Option changes will be allowed; • The Death Benefit Proceeds will continue to be defined per the terms of the Policy, but will never be less than $5,000; and • The Policy provisions that otherwise could cause the Policy to lapse will no longer apply, so that the Policy will be in paid-up status.

You will be notified of the changes to the Policy.

Rider Cost There is no charge for this Rider unless the Owner exercises it. If this Rider is exercised, the one-time Rider charge is equal to (1) multiplied by (2), where: (1) Is the Policy Value; and (2) Is the Rider Exercise Charge Rate stated in the Rider Specifications page.

If the Policy Value minus the Loan Amount is not sufficient to cover the charge for this Rider, a loan repayment sufficient to cover the charge for this Rider will be required in order to exercise this Rider.

Termination This Rider terminates on the earlier of the following dates: 1. The date the Policy becomes a Modified Endowment Contract as specified in the Code; 2. The date the Policy terminates; or 3. The date You terminate this Rider by Written Notice to us any time prior to the Time of Exercise of this Rider. Such termination will be effective the Monthly Anniversary Day on or next following Our receipt of Your request. In order to terminate this Rider, We have the right to require return of the Policy and this Rider for endorsement.

Termination of this Rider will not affect any claim for an Accelerated Death Benefit made while this Rider was in effect.

Once exercised, this Rider cannot be terminated.

Reinstatement If the Policy and this Rider have terminated for any reason, other than Your request to surrender the Policy or Your request to terminate this Rider, this Rider may be reinstated under the same terms as the reinstatement of the Policy.

Neither the IRS nor the courts have ruled on the tax consequences of exercising the Overloan Lapse Protection Rider. It is possible that the IRS or a court could assert that the Policy has been effectively terminated and that the outstanding loan balance should be treated as a distribution, all or a portion of which could be taxable when the Rider is exercised. In addition, this Overloan Protection Rider may not be appropriate for Your particular circumstances. Consult with a tax professional regarding the risks associated with exercising this Rider.

Symetra Life Insurance Company

ICC21_LE3 [Page 2 of 2] [VUL]

[Symetra® is a registered service mark of Symetra Life Insurance Company.]

WAIVER OF MONTHLY DEDUCTIONS RIDER

This Waiver of Monthly Deductions Rider (“Rider”) is a part of the Policy to which it is attached (“Policy”). In the event of a conflict between the terms of this Rider and the terms of the Policy, the terms of this Rider shall prevail.

This Rider is effective on the Issue Date or the effective date of reinstatement of the Policy to which it is attached.

Rider Benefit When a claim under this Rider has been approved, We will waive monthly deductions for the Policy while the Insured is Totally Disabled. The requirements to make a claim under this Rider are described below.

Any waiver of monthly deductions does not guarantee that the Policy will remain in force. If the requirements of any type of no lapse guarantee provision have not been met, the Policy may terminate as described in the Policy. This Rider has no associated Policy Value, Surrender Value or Loan Amount of its own.

Key Definitions • Total Disability or Totally Disabled: The Insured’s inability, due to bodily injury or disease, to perform substantially all of the duties of an occupation, subject to the following: ◦ During the first full 24 months of total disability, the Insured is unable to perform the substantial and material duties of the Insured’s regular occupation due to sickness or bodily injury; and ◦ After the first 24 months of total disability, the Insured, due to sickness or bodily injury, is unable to perform any of the substantial and material duties of the Insured’s occupation or any other occupation for which the Insured is reasonably suited by education, training, or experience. • Notwithstanding anything to the contrary above, if any of the following occur, the requirement of Total Disability will be met: • Total and permanent loss of the sight of both eyes; or • Total and permanent loss of use of both hands or both feet.

Proof of Total Disability In order to waive monthly deductions under this Rider, the following requirements must be met:

• Total Disability must continue for a consecutive period of six (6) months before We will approve a claim under this Rider. • Total Disability must occur while this Rider is in force. • We must receive Written Notice of proof of Total Disability in a form acceptable to us while the Insured is alive and Totally Disabled in the timeframe described below. Provided, however, the failure to provide Written Notice in the timeline described below will not invalidate the claim if the Owner can demonstrate that Written Notice was given as soon as reasonably possible. • not later than one year after Total Disability began; and

We will not waive any monthly deductions due more than one year before receipt of proof of Total Disability.

Proof of Continued Total Disability Before waiving any monthly deductions, We must receive Written Notice proving that the Total Disability has met all required conditions, including: • Total Disability began prior to Attained Age 65; and • Total Disability has existed, continuously, for at least 6 months.

During the first (24) months after We approved the claim for Total Disability, We will not require proof of continued Total Disability, more than once every 30 days. After (24) months, proof of continued Total Disability will not be required more often than once every 12 months. If the required proof is not provided, We will consider the Insured no longer Totally Disabled and no further monthly deductions will be waived. We also may require that the Insured ICC21_LE1 [Symetra® is a registered service mark of Symetra Life Insurance Company.]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document be examined once every 12 months by one of our medical examiners as part of any proof; any such examination will be at Our expense.

Exclusions No monthly deductions will be waived under the Policy if Total Disability results from any of the following:

• Total Disability caused or contributed to by any attempt at suicide, or intentionally self-inflicted injury, while sane or insane; • Total Disability caused or contributed to by active participation in a riot, insurrection or terrorist activity; • Total Disability caused or contributed to by committing or attempting to commit a felony; • Total Disability caused or materially contributed to by voluntary intake or use by any means of: • Any drug, unless prescribed or administered by a physician and taken in accordance with the physician’s instructions; or • Poison, gas or fumes, unless a direct result of an occupational accident; • Total Disability occurring before Attained Age 5; • Total Disability caused or contributed to by intoxication as defined by the jurisdiction where the disability occurred; • Total Disability caused or materially contributed to by participation in an illegal occupation or activity; or • Total Disability caused or contributed to by any condition disclosed in the application and explicitly excluded in a form attached to the Policy.

Operation of the Policy While Monthly Deductions Are Being Waived Any monthly deductions which become due before We approve a claim made under this Rider will be deducted from the Policy Value, as described in the Policy. After We approve a claim made under this Rider, we will credit to the Policy Value any monthly deductions that became due after Total Disability began.

Monthly Deductions waived by Us will not be deducted from any Death Benefit paid.

While monthly deductions are being waived under this Rider, the following Policy Changes will no longer be allowed: • Increases in the Specified Amount • Accelerations of Specified Amount for any other Rider purposes • Changes in the Death Benefit Option • Additions of any riders All other benefits included under the Policy and its other riders shall continue in force, subject to the investment performance of any separate account included as part of the Policy Value.

Time Period for Waiving Deductions • If Total Disability begins before Attained Age 60: ◦ We will waive monthly deductions due while Total Disability continues. ◦ If the Insured continues to be Totally Disabled to the Policy Anniversary following the Insured attained age 65, We will waive all further monthly deductions due for the Insured under the Policy. • If Total Disability begins on or after the Policy Anniversary following the Insured’s Attained Age 60 but before Attained Age 65: ◦ We will waive monthly deductions due during such Total Disability until the later of: ▪ Attained Age 65; or ▪ Expiry of 2 years from the beginning of such Total Disability (if this 2-year period extends beyond Attained Age 65).

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Premiums We will accept premium payments under the Policy while monthly deductions are being waived under this Rider.

If Total Disability occurs during a Grace Period, additional premium payments will be required to cover all outstanding deductions to avoid a lapse of the Policy before We approve a claim made under this Rider.

Rider Charge The charge for this Rider is calculated on each Monthly Anniversary Day, and will equal to (1) multiplied by (2), where: 1. The factor(s) shown on the Rider Specifications page; and 2. Sum of the Policy’s monthly deductions.

ICC21_LE1 [Symetra® is a registered service mark of Symetra Life Insurance Company.]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document The Rider Charges will cease upon: • Policy termination • Rider termination • Date of Death of Insured

Incontestability When permitted by law in the jurisdiction in which this Rider is delivered, in the absence of fraud in the procurement of the Rider and the Policy, and in the absence of the occurrence of Total Disability, the Company will not bring any legal action to contest the validity of this Rider after this Rider has been in force during the lifetime of the Insured for two years from the Issue Date or, if reinstated, for two years from the date of reinstatement.

Termination This Rider will terminate on the earliest of any of the following: • Insured’s Attained Age 65; however, this will not affect eligibility if Total Disability occurred before Attained Age 65; • Surrender of the Policy; • Lapse of the Policy; • Continuation of the Policy as extended-term or paid-up insurance under the nonforfeiture provisions of the Policy or other riders; • Increase in Specified Amount; • Monthly Anniversary Day which follows our receipt of Written Notice to terminate this Rider; • Termination of the Policy; or • Insufficiency of the Policy Value to allow monthly deductions in accordance with the provisions of this Rider or the Policy.

Symetra Life Insurance Company

[] [Jacqueline Veneziani ] [Secretary]

ICC21_LE1 [Symetra® is a registered service mark of Symetra Life Insurance Company.]

SUPPLEMENTAL PROTECTION RIDER

This Rider (“Rider”) becomes a part of the policy to which it is attached (“the Policy”). All terms of the Policy that do not conflict with this Rider’s terms apply to this Rider. If there is a conflict between the terms of this Rider and the terms of the Policy, the terms of this Rider shall prevail. This Rider has no Policy Value or Loan Amount.

Rider Benefit This Rider provides an amount of supplemental coverage on the Insured under the Policy as long as the Policy is in force and this Rider has not been terminated. The Specified Amount of the Policy to which this Rider is attached is increased by the Rider Specified Amount for purposes of defining Death Benefit of the Policy. We will pay the Rider Specified Amount to your beneficiary(ies) when we receive satisfactory proof of death as defined in the Policy. This Rider has no Policy Value of its own, but it affects the Policy Value because the charges for the Rider are deducted from the Policy Value.

Insured As used in this Rider, the Insured means the individual covered under the Policy as shown in the Policy Specifications page.

Rider Benefit as an Additional Amount of Coverage For purposes of defining the Death Benefit, the Net Amount at Risk, and Premium Payment limitations and qualification as life insurance under the Code, the Specified Amount of the Policy is increased by the Rider Specified Amount.

Decrease in Rider Specified Amount You may decrease the Rider Specified Amount, subject to the provisions in the Policy. The Rider is treated in the same manner as a Specified Amount Increase that occurs when the Initial Specified Amount is set for purposes of last-in first-out processing of Specified Amount Decreases under the Policy.

Increase in Rider Specified Amount Increases in the Rider Specified Amount are not permitted.

Monthly Deduction for this Rider On each Monthly Anniversary Day We will make a monthly deduction for the Rider Cost of Insurance. The Net Amount at Risk attributable to the Rider Specified Amount is based on the same “last-in first-out” processing used for Increases in Specified Amount.

The monthly cost of insurance charge for the Rider Specified Amount is computed by dividing the Rider Net Amount at Risk by $1,000 and multiplying the result by the Cost of Insurance rates described below.

Cost of Insurance Rates

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document The Maximum Monthly Cost of Insurance rates for this Rider are the same as for the Policy, and are shown on the Policy Specifications page. We may charge less than the maximum monthly Cost of Insurance rates. In setting monthly cost of insurance rates, the Company may consider factors including, but not limited to, (a) Policy Year, (b) the sex, Attained Age, Issue Age and Risk Class of the Insured, (c) its expectations as to future mortality experience, (d) taxes, (e) capital and reserve requirements, (f) investment earnings, and (g) other expenses. The Company reviews monthly cost of insurance rates on an ongoing basis based on its expectations as to factors (a) – (g) and other factors. In addition, changes in Cost of Insurance rates are made on a uniform basis for Insureds of the same class as defined by sex, Attained Age, Issue Age, Risk Class and Policy Year. The Cost of Insurance rates are never greater than those rates shown in the Maximum Monthly Cost of Insurance Rates on the Policy Specifications page.

[IUL]

ICC17_LE6 Page 1 of 2

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Minimum Monthly Premium The Minimum Monthly Premium for the Policy that is used for the No Lapse Guarantee will be increased by the addition of this Rider. The increase will be included in the Minimum Monthly Premium shown on the Policy Specifications page.

Conversion This Rider is not convertible.

Reinstatement If the Policy to which this Rider is attached is reinstated, this Rider may be reinstated.

Incontestability When permitted by law in the jurisdiction in which the Rider is delivered, in the absence of fraud in the procurement of the Rider, the Company will not bring any legal action to contest the validity of this Rider after the Rider has been in force during the lifetime of the Insured for two years from the Issue Date or, if reinstated, for two years from the date of reinstatement.

Suicide Exclusion If the Insured commits suicide, while sane or insane, within two years of the Issue Date or effective date of any reinstatement of this Rider, the Company’s liability is limited to an amount equal to the premium payments made less any Loan Amount and less any withdrawals. The Company will pay this amount to the Beneficiary in a single sum.

Termination This Rider will terminate the date the Policy terminates, the date that a Decrease in Specified Amount is made on the Policy which results in the Rider Specified Amount being decreased to zero or by request of the Owner. Should the Owner request that the Rider be terminated, any previous increases in Specified Amount will first be decreased to zero.

Effective Date This Rider is effective on the Issue Date or the effective date of reinstatement of the Policy to which it is attached.

Symetra Life Insurance Company

[ ]

[David S Goldstein] [Secretary]

Symetra® is a registered service mark of Symetra Life Insurance Company.

ICC17_LE6 Page 2 of 2 [IUL]

Proposed Insured Name: ______Symetra Policy # (if available): ______Proposed Owner Name (if other than the Insured): ______

Section 2 - Allocation Instructions (Allocations must total 100% [and be in whole numbers.]): Important Note: • These instructions shall apply until later changed by the Policy Owner. If these allocations are not the same as those used in the sales illustration, please contact the financial professional to request a revised illustration. • The maximum number of Investment Options that may be selected is [16]. • The initial Net Premium Payment is held in the Fixed Account until the end of the Cancellation Period. Upon completion of the Cancellation Period, the initial Net Premium Payment will be allocated according to the instructions below. These instructions will apply to all subsequent Net Premium Payments until Symetra Life Insurance Company (“Symetra”) is instructed otherwise. • If the proposed Owner wishes to have monthly deductions taken from certain Subaccounts, please indicate that below. • [If the proposed Owner wishes to elect Dollar Cost Averaging (DCA), please complete the allocation instructions below and elect DCA in Section 3.] • [If the proposed Owner wishes to elect Automatic Rebalancing, please complete the allocation instructions below and elect Automatic Rebalancing in Section 3.]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Investment Options % to Allocate for initial % to Allocate Net Premium Payments for monthly and subsequent Net deductions Premium Payments [American Funds IS® Growth Fund - Class 1] % % [American Funds IS® Growth-Income Fund - Class 1] % % [American Funds IS® New World Fund - Class 1] % % [American Funds IS® US Govt/AAA-Rated Securities Fund - Class 1] % % [BlackRock High Yield V.I. Fund - Class I] % % [Calvert VP Russell 2000 Small Cap Index] % % [Columbia VP Small Cap Value (Class 1)] % % [DFA VA Short-Term Fixed Portfolio] % % [DFA VA US Large Value Portfolio] % % [DFA VA US Targeted Value Portfolio] % % [DFA VIT Inflation-Protected Securities Portfolio] % % [Fidelity® VIP Contrafund Portfolio - Initial Class] % % [Fidelity® VIP Extended Market index Portfolio - Initial Class] % % [Fidelity® VIP Financial Services Portfolio - Initial Class] % % [Fidelity® VIP Index 500 Portfolio - Initial Class] % % [Fidelity VIP Utilities - Initial Class] % %

[Subtotal = ] [XXX%] [XXX%] Investment Options (continued) % to Allocate for initial % to Allocate Net Premium Payments for monthly and subsequent Net deductions Premium Payments [Fidelity® VIP Technology Portfolio - Initial Class] % % [Franklin Income Fund - Class 1] % %

[Symetra® [and [Marketing Name®]] [is a egisr tered service mark][are registered service marks] of Symetra Life Insurance Company. [[Marketing NameSM] is a service mark of Symetra Life Insurance Company.]] ICC21_LA1 [BARCODE] [1]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document [Franklin Rising Dividends Securities Fund Class 1] % % [Goldman Sachs VIT Government Money Market - Institutional Shares] % % [Janus Henderson VIT Flexible Bond Portfolio -Institutional Shares] % % [Janus Henderson VIT Mid Cap Value Portfolio - Institutional Shares] % % [JPMorgan Insurance Trust Mid Cap Value Portfolio - Class 1] % % [MFS® VIT Mid Cap Growth Series - Initial Class] % % [MFS® VIT New Discovery Series - Initial Class] % % [PIMCO VIT Emerging Markets Bond Portfolio - Institutional Class] % % [Vanguard VIF Balanced Portfolio] % % [Vanguard VIF Capital Growth Portfolio] % % [Vanguard VIF Conservative Allocation Portfolio] % % [Vanguard VIF Diversified Value] % % [Vanguard VIF Equity Income Portfolio] % % [Vanguard VIF High Yield Bond Portfolio] % % [Vanguard VIF International Portfolio] % % [Vanguard VIF Mid-Cap Index Portfolio] % % [Vanguard VIF Real Estate Index Portfolio] % % [Vanguard VIF Short Term Investment Grade Portfolio] % % [Vanguard VIF Small Company Growth Portfolio] % % [Vanguard VIF Total Bond Market Index] % % [Vanguard VIF Total International Stock Market Index Portfolio] % % [Vanguard VIF Total Stock Market Index Portfolio] % % [Fixed Account [(not available to receive DCA transfers)]] % % [Page 2 Subtotal = ] [XXX%] [XXX%] [Page 1 Subtotal = ] [XXX%] [XXX%]

Total = 100% 100%

[Section 3 – Special Programs: [A. Dollar Cost Averaging (DCA) – This optional program is designed to achieve a potentially lower average cost per Subaccount Unit over time. It does not ensure an investment gain or protect against a loss. • When DCA is elected, 100% of the initial Net Premium Payment (and, if applicable, subsequent Net Premium Payments) will be allocated to the Fixed Account until DCA transfers take place. • DCA transfers to the Investment Options selected in Section 2 are based on the frequency and amount of each DCA transfer indicated below. The Fixed Account may not be selected to receive DCA transfers. • DCA transfers will occur on the Monthly Anniversary Day and will continue until Symetra is instructed to stop or all money has been transferred out of the Fixed Account, whichever is earlier. • The first DCA transfer will take place on the first Monthly Anniversary Day after the Policy’s Cancellation Period has concluded. DCA transfers do not count toward the maximum number of transfers allowed on the Policy and no transfer fees or any policy limitations related to the Fixed Account will apply. Check one:

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document • Yes, I elect the DCA program for my initial Net Premium Payment only. • Yes, I elect the DCA program for my initial Net Premium Payment and subsequent Net Premium Payments.

Amount of each DCA Transfer Transfer Frequency (check one) [$XXX.XX] • [Monthly] [Quarterly]

]

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document [B. Automatic Rebalancing –The investment performance of the Investment Options chosen may cause the percentage invested in each Investment Option to change from the initial Net Premium Payment allocations. By electing to enroll in Automatic Rebalancing, the proposed Owner authorizes Symetra to automatically rebalance the Policy Value to match the allocations selected in Section 2 above at the frequency selected below. • Automatic rebalancing is not available if you elected DCA above. • This automatic rebalancing activity will occur on the Monthly Anniversary Day based on the frequency selected below. • Automatic Rebalancing does not count toward the maximum number of transfers allowed on the Policy and no transfer fees will apply. • Yes, I elect to enroll in the Automatic Rebalancing program.

Please rebalance my account in the following frequency (check one): • [Monthly] • [Quarterly] • [Semi-Annual] • [Annual]]

Section [4] – Authorizations & Acknowledgements:

[A. Transfer Authorization: The elections in Section 4A below pertain to the authorization to transfer among available Investment Options and/or to change the allocation percentages for subsequent Net Premium Payments. • I hereby authorize Symetra to accept instructions, either by telephone transfer facility or online, from me or any party authorized in this section below, to transfer funds among available Investment Options and/or to change the allocation percentages for subsequent Net Premium Payments. For instructions submitted online, if available, I or my financial professional will be required to log in with certain identifying information, such as password or personal identification information. This authorization will remain in effect until Symetra receives revocation via Written Notice from me. [I authorize the following individuals to, either by telephone transfer facility or online, transfer funds among available Investment Options and/or to change the allocation percentages for subsequent Net Premium Payments on my behalf as described in this section above. (Check all that apply. If no option is selected, the authorization will be limited to me as Owner and, if applicable, the Joint Owner): • [My financial professional or a member of their staff] • [The following third-party(ies): Authorized third-party name(s): ______] [Relationship to the Owner(s): Spouse Child Other (specify): ______]]]

[B. Electronic Delivery – To enroll, the Symetra Customer Electronic Consent and Disclosure Agreement must be completed: • Yes, I elect to enroll in electronic delivery and have completed the Symetra Customer Electronic Consent and Disclosure Agreement.] C.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document [Symetra® [and [Marketing Name®]] [is a egisr tered service mark][are registered service marks] of Symetra Life Insurance Company. [[Marketing NameSM] is a service mark of Symetra Life Insurance Company.]] ICC21_LA1 [BARCODE] [3]

a. I have received a current prospectus or summary prospectus (and any • Yes prospectus supplements), as well as prospectuses or summary • No prospectuses for the underlying funds I have selected, for the applicable Policy.

a. I understand the Death Benefit and other values provided by this Policy, • Yes when based on the investment performance of the Variable Account, may • No increase or decrease daily as a function of the investment performance of the Subaccounts I have selected and are not guaranteed as to the dollar amount.

a. I understand the duration of the Death Benefit may increase or decrease • Yes depending on the investment performance of the Variable Account in which • No the Policy is allocated.

a. This Policy meets my insurance objectives and anticipated financial needs. • Yes • No

By affixing my signature below, I affirm that the responses I provided above are true.

Agreement & Signature(s)

Proposed Owner: The undersigned hereby agree(s) that Individual Life Insurance Application Supplemental Application (Supplement) shall be part of the Life Insurance Application and made part of the Policy, if issued. I have read the completed Supplement and Life Insurance Application, or have had then read to me, and agree that all of the information contained herein is true and complete to the best of my knowledge. I understand I am applying for a variable life insurance and that my Policy Value may increase or decrease depending on the investment performance of the Investment Options I have chosen. Symetra has the right to add, remove, or limit Subaccount options, and interest rates, provided they do not go below the minimums shown in the Policy. I understand that any values shown, other than guaranteed minimum values, are not guarantees, promises or warranties.

FRAUD WARNING: Any person who knowingly presents a false statement in an application for insurance may be guilty of a criminal offense and subject to penalties under state law.

Signatures (Must be completed in entirety to process the application) Proposed Signed at [City, State] Date [DD/MM/YYYY] Owner Signature

Proposed Owner Name Printed

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Financial Professional: This Application is being submitted after an examination of the interests of the proposed Owner and an assessment of the stated goals of the proposed Owner. I have discussed this product with the proposed Owner and have not made any statements which contradict the disclosure materials provided to them. I have not made any promises or guarantees about the future values of any non-guaranteed elements. I have provided the proposed Owner with the required product and fund prospectus documents.

Financial Professional Signature Date [DD/MM/YYYY]

[BGA/Firm Name] [Office Address]

[Phone Number] [Email Address]

[Registered Principal Section: I have reviewed the Application, Supplements and Variable Coverage Details and find the transaction suitable.

Registered Principal Signature Date [DD/MM/YYYY]

Registered Principal Full Legal Name printed

] [Symetra® [and [Marketing Name®]] [is a egisr tered service mark][are registered service marks] of Symetra Life Insurance Company. [[Marketing NameSM] is a service mark of Symetra Life Insurance Company.]] ICC21_LA1 [BARCODE] [5]

by and among

DFA INVESTMENT DIMENSIONS GROUP INC.,

DIMENSIONAL FUND ADVISORS LP,

DFA SECURITIES LLC

and

SYMETRA LIFE INSURANCE COMPANY

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document THIS AGREEMENT, made and entered into this ____ day of _____ 2012, by and among Symetra Life Insurance Company (“Company”), on its own behalf and on behalf of segregated asset accounts of the Company that may be established from time to time (individually, an “Account” and collectively, the “Accounts”); DFA Investment Dimensions Group Inc. (“Fund”); the Fund’s investment adviser, Dimensional Fund Advisors LP (“Adviser”); and DFA Securities LLC (“DFAS”) (individually, a “Party” and collectively, the “Parties”).

The Company, the Fund, the Adviser and DFAS, intending to be legally bound, hereby agree as follows:

1. Sales of Shares/Procedures

1.1 Shares of the respective portfolios (“Portfolios”) of the Fund listed on Schedule 1.1 hereto, as amended from time to time by the Parties, shall be sold by the Fund through its agent DFAS, and purchased by the Company for the appropriate subaccount of each Account, at the net asset value next computed after receipt by the Fund or its designee of each order of the Accounts, in accordance with the provisions of this Agreement, the then current prospectus(es) of the Portfolios, and the variable contracts that use the Portfolios as an underlying investment medium (“Contracts”).

1.1(a) Transmission of Instructions For each Portfolio and for each Account maintained by the Company with such Portfolio, the Company shall transmit, or cause its designated agent(s) to transmit, to National Securities Clearing Corporation (“NSCC”) (which shall forward the information to the transfer agent of the Fund), no more than 10 aggregate purchase orders as follows:

(i) 5 purchase orders for the Accounts expressed in dollars (sent via NSCC’s DCC&S System); and

(ii) 5 purchase orders for the Accounts expressed in shares (sent via NSCC’s DCC&S System);

and no more than 10 aggregate redemption orders as follows:

(i) 5 redemption orders for the Accounts expressed in dollars (sent via NSCC’s DCC&S System); and

(ii) 5 redemption orders for the Accounts expressed in shares (sent via NSCC’s DCC&S System);

each of which reflects the aggregated effect of all purchases and all redemptions of shares of the Portfolios in such categories, based upon instructions from each Account (collectively, “Instructions”) received

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document prior to the Close of Trading on a given Business Day (“Trade Date”). “Close of Trading” shall mean 4:00 p.m. Eastern Time on a Business Day or such other time as the net asset value of a Portfolio is calculated, as disclosed in the then current prospectus(es) of the Portfolios. “Business Day” shall mean, unless otherwise noted in this Agreement, any day on which the New York Stock Exchange (the “NYSE”) is open for trading and on which a Portfolio calculates its net asset value pursuant to the rules of the Securities and Exchange Commission (“SEC”). “Business Day,” for the purposes of this Section 1.1(a), shall also include any day on which the NSCC’s DCC&S System is open to transmit and settle orders, even if the NYSE is closed for trading on such day.

On any given Business Day, the Company shall accept Instructions in proper form from an Account up to the Close of Trading, but in no event shall the Company accept Instructions that have been received by the Company after the Close of Trading on such Business Day. Instructions received in proper form by the Company after the Close of Trading on any Business Day shall be treated as if accepted on the next following Business Day. Each transmission of Instructions by the Company will constitute a representation that all purchase and redemption orders from the Accounts were received by the Company prior to 4:00 p.m. Eastern Time or the close of the NYSE, whichever is earlier, on the Business Day on which the purchase or redemption orders are transmitted, in accordance with Rule 22c1 under the Investment Company Act of 1940, as amended (the “1940 Act”).

1.1(b) Transmission Deadlines for the Accounts The transmission of orders for the Accounts will be accepted by the Fund only if provided through NSCC’s DCC&S System in the file delivered to the Fund or its transfer agent prior to 6:30 a.m. Eastern Time (currently NSCC Cycle 8) on the next Business Day following the Trade Date. Any information delivered to the Fund after such 6:30 a.m. Eastern Time file is received will be rejected by the Fund or its transfer agent, subject to the Fund’s sole discretion to accept any trade.

In the event that NSCC systems are not functioning on a given Business Day, the Company or its designate agent(s) may transmit Instructions to the Fund, its transfer agent or as otherwise directed by the Fund or the Adviser via facsimile by 8:00 a.m. Eastern Time on the next Business Day following the Trade Date; provided however, the Company will notify the Fund and the Adviser prior to transmitting Instructions via facsimile. However, this paragraph will not be applicable to Instructions which have already been entered via NSCC but not received by the Fund or its transfer agent. The Company or its designated agent(s) must notify the Fund of the existence of any such Instructions, and the Fund and its transfer agent

2 15458_2

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document will use commercially reasonable efforts to process those Instructions in a mutually satisfactory manner. Notwithstanding the foregoing, on a limited basis, the Company may transmit instructions until 9:00 a.m. Eastern Time via NSCC Cycles 9 through 12 on the next Business Day following the Trade Date for corrections to Instructions already submitted for contingency purposes.

1.1(c) Settlement Aggregated purchase and net redemption transactions shall be settled in accordance with NSCC rules and procedures. “Business Day,” for the purposes of this Section 1.1(c), shall also include any day on which the NSCC’s DCC&S System is open to transmit and settle orders, even if the NYSE is closed for trading on such day.

In the event that NSCC systems are not functioning on a given Business Day (1) for net purchase Instructions, the Company shall, or cause its designated agent(s) to, wire payment, or arrange for payment to be wired by the Company’s designated bank, in immediately available funds, to the Portfolio’s custodial account at the Fund’s custodian; and (2) for net redemption Instructions, the Fund or its transfer agent shall wire payment, or arrange for payment to be wired, in immediately available funds, to an account designated by the Company in writing. Wires from the Company must be received no later than the close of the Federal Reserve Wire Transfer System on the next day on which the Federal Reserve Wire Transfer System is open.

In the event that the total redemption order for any one Business Day shall exceed dollar limits set for a Portfolio by the Fund, such Portfolio shall have the option of (i) settling the redemption on the second Business Day following trade date through the NSCC’s money settlement process, (ii) settling the redemption outside of Fund/SERV, if necessary as determined in the discretion of the Fund, at any time within seven (7) days after receipt of the redemption order, in accordance with provisions of the 1940 Act, or (iii) in any other manner provided for in the Portfolio’s then current prospectus(es) and statement of additional information.

Nothing herein shall prevent the Fund, on behalf of a Portfolio, from delaying or suspending the right of purchase or redemption in accordance with the provisions of the 1940 Act and the rules thereunder. The Fund will not bear any responsibility whatsoever for the proper disbursement or crediting of redemption proceeds; the Company alone will be responsible for such action.

1.1(d) Errors The Company shall be solely responsible for the accuracy of any Instruction transmitted to the Fund or its transfer agent via NSCC systems or otherwise, and the transmission of such Instruction shall constitute the Company’s representation to the Fund that the Instruction is accurate,

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document complete and duly authorized by the Accounts that are purchasing or redeeming shares of the Portfolio. The Company shall assume responsibility for any loss to the Fund, the Portfolios or their transfer agent caused by a cancellation or correction made subsequent to the date as of which an Instruction has been placed, and the Company will immediately pay such loss to the Adviser, the Fund or such Portfolio(s) upon notification.

Each Party shall notify the other Parties of any errors or omissions in any information and interruptions in or delay or unavailability of, the means of transmittal of any such information as promptly as possible. The Company agrees to maintain reasonable errors and omissions insurance coverage commensurate with the Company’s responsibilities under this Agreement.

In the event of an error in the computation of a Portfolio’s net asset value per share, the Fund will follow its then current policy adopted for the sale and distribution of shares of the Portfolio regarding appropriate error correction standards. Any gain to the Company or an Account attributable to the incorrect calculation or reporting of a Portfolio’s daily net asset value shall be immediately returned to the Portfolio. The Company agrees to make commercially reasonable efforts to recover from the Account(s) any material losses incurred by the Adviser, the Fund or the Portfolios as a result of the foregoing.

The Company shall maintain a record of the total number of shares of the Portfolios which are so purchased, based on information provided by the Fund or its designee to the Company, and shall reconcile with the Fund on a periodic basis the number of shares of each Portfolio attributable to each Account. If an order to purchase shares of a Portfolio must be canceled due to nonpayment, the Company will be responsible for any loss incurred by the Fund or the Portfolio arising out of such cancellation. To recover any such loss, the Fund and the Portfolios reserve the right to redeem shares of the affected Portfolio(s) held in the name of the Company or a corresponding subaccount of the applicable Account.

1.2 The Fund will redeem the shares of the Portfolios when requested on behalf of the Company or the corresponding subaccount of the applicable Account at the net asset value next computed after receipt by the Fund or its designee of each request for redemption, in accordance with the provisions of this Agreement, the then current prospectus(es) of the Portfolios, the statement of additional information of the Fund and the Contracts; provided, however, if any conflicts exist among any such documents, then the terms of the Fund’s current prospectus(es) describing the Portfolios and the statement of additional information describing the Portfolios shall control.

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Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document The Company shall apply any net redemption proceeds received by it in accordance with the applicable Contracts. The Company shall not process or effect any redemptions with respect to shares of any Portfolio after receipt by the Company of notification of suspension of the determination of the net asset value of such Portfolio. The Board of Directors of the Fund (“Directors”) may refuse to sell shares of any Portfolio to any person, including the Company with respect to the Accounts, or suspend or terminate the offering of shares of such Portfolio, if such action is required by law or by regulatory authorities having jurisdiction, or is deemed by the Directors, in their sole discretion, acting in good faith and in light of the Directors’ duties under federal and any applicable state laws, necessary in the best interests of shareholders of the Portfolio.

1.3 The Company agrees to purchase and redeem the shares of each Portfolio in accordance with the provisions of this Agreement and the then current prospectus(es) of the Portfolios. Except as necessary to implement transactions initiated by Contract holders, or as otherwise may be required by applicable U.S. federal laws or regulations with respect to maintaining the Contracts’ status under the Internal Revenue Code of 1986, as amended from time to time and any successor provisions thereto (the “Code”), the Company shall not redeem shares of the Portfolios attributable to the Contracts.

1.4 Issuance and transfer of shares of the Portfolios will be by book-entry only. Stock certificates will not be issued to the Company or to the applicable Accounts. Shares purchased from the Fund will be recorded in appropriate book-entry titles for the Accounts by the Fund or its designee.

1.5 The Company will receive pricing and dividend rate and capital gain distribution rate information and payments through the NSCC System. The Company hereby elects to receive all such dividends and distributions as are payable on shares of a Portfolio in additional shares of that Portfolio. The Fund shall notify the Company or its delegates of the number of shares of the Portfolios so issued as payment of such dividends and distributions.

The Company shall maintain a record of the number of shares of the Portfolios held by the Accounts on behalf of each Contract holder, and the Company shall maintain appropriate records of Contract holder information.

The Company shall investigate all inquiries from Contract holders relating to their interests in the Accounts and the Portfolios, and shall respond to all communications from Contract holders and other persons having an interest in the Contracts relating to the Company’s duties hereunder, in such form of correspondence as the Company, the Fund and the Adviser may mutually agree.

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2.1 The Fund agrees that the terms on which shares of the Portfolios are offered to the Accounts will not be materially altered without at least sixty (60) days’ prior written notice to the Company during any period when the Accounts own shares of the Portfolios.

2.2 If and to the extent required by applicable law or by the terms of the Contracts, the Company shall:

(i) solicit voting instructions from the Contract holders;

(ii) vote the shares of the Portfolios held by the Accounts in accordance with instructions received from the Contract holders; and

(iii) vote the shares of the Portfolios held by the Accounts for which no timely instructions have been received from the Contract holders in the same proportion as shares of such Portfolio for which instructions have been received,

if and to the extent that (i) the SEC continues to interpret the 1940 Act to require pass-through voting privileges for variable contract holders, and (ii) such interpretation is deemed applicable to the Contracts. The Company reserves the right to vote Portfolio shares held in any segregated asset account in its own right, to the extent permitted by applicable law. The Company will calculate voting privileges in a manner consistent with other separate accounts investing in the Portfolios and in accordance with applicable law. The Company agrees to hold the Fund, the Portfolios, the Adviser and DFAS harmless from and against any liability that may arise as a result of the Company’s voting Portfolio shares held in any segregated account in its own right.

2.3 The Fund, on behalf of the Portfolios, will comply with all provisions of the 1940 Act requiring voting by shareholders, and in particular, the Fund, at its option, will either provide for annual or special meetings or comply with Section 16(c) of the 1940 Act, as well as with Sections 16(a) and, if and when applicable, 16(b) of the 1940 Act and the rules thereunder. Further, the Fund will act in accordance with the SEC’s interpretation of the requirements of Section 16(a) of the 1940 Act with respect to periodic elections of directors and with whatever rules the SEC may promulgate with respect thereto.

3. Representations and Warranties

3.1 The Company represents and warrants that it is an insurance company within the meaning of Section 816(a) of the Code, duly organized and in good standing under applicable law, and that it has legally and validly established each Account prior to any issuance or sale thereof as a segregated asset account under applicable

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3.2 The Company represents and warrants that the Contracts are or will be registered under the Securities Act of 1933, as amended (the “1933 Act”) (or exempt from such registration requirements).

3.3 The Company represents and warrants that it has or will have registered each Account as a unit investment trust, in accordance with the provisions of the 1940 Act or each such Account is, and will continue to be, exempt from registration under section 3(c) of the 1940 Act, to serve as a segregated investment account for the Contracts.

3.4 The Company represents that the Contracts are currently treated as variable life insurance endowment or annuity contracts under applicable provisions of the Code, and that the Company will maintain such treatment and that the Company will notify the Adviser and the Fund promptly upon having a reasonable basis for believing that the Contracts have ceased to be so treated or that the Contracts might not be so treated in the future.

3.5 This Agreement has been duly authorized, executed and delivered by the Company, and is a valid and legally binding contract enforceable in accordance with its terms. No consent, approval, authorization or order of any court or governmental authority is required for the consummation by the Company of the transactions contemplated by this Agreement. The execution and delivery of this Agreement did not, and the consummation of the transactions contemplated by this Agreement will not, violate the Company’s organizational documents or Bylaws, or any resolution, agreement or arrangement to which the Company is a party or by which the Company is bound.

3.6 The Company and the Accounts are duly authorized to acquire shares of the Portfolios as contemplated by the terms of this Agreement. The Company will cooperate with the Fund in providing information as provided in Schedule 3.6 hereto and will assist the Fund in preventing possible market timing and other trading activities in violation of the Fund’s policies and procedures, including without limitation restricting or prohibiting further purchases or exchanges of Fund shares as provided in Schedule 3.6 hereto.

3.7 There are no material legal, administrative or other proceedings pending or, to the Company’s knowledge, threatened against the Company or its property or assets that could result in liability on its part. The Company knows of no facts that

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Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document might form the basis for the institution of such proceedings. Neither the Company nor the Accounts are parties to or subject to the provisions of any order, decree or judgment of any court or governmental body that materially and adversely affects its or their business or its or their ability to consummate the transactions herein contemplated.

3.8 Except as noted below, the disclosure contained in the applicable offering documents for the Accounts does not contain any untrue statements of a material fact or omit to state any material fact required to be stated therein or necessary to make the statements therein not misleading, and such disclosure meets all legal requirements of applicable federal and state laws and regulations. The Company represents and warrants that all current and future offering documents with respect to the Accounts and other materials that mention the Company, the Fund, the Portfolios, DFAS or the Adviser shall meet the requirements described in the first sentence of this subparagraph; provided, however, that the Company shall not be responsible for any disclosure that is provided to it in the Fund’s current prospectus(es) describing the Portfolios or the Fund’s registration statement as filed with the SEC.

3.9 The Fund represents and warrants that it is lawfully established and validly existing under the laws of the State of Maryland. The Fund represents that its operations are and shall at all times remain in material compliance with the laws of the State of Maryland to the extent required to perform this Agreement.

3.10 The Fund represents and warrants that the shares of the Portfolios sold pursuant to this Agreement are registered under the 1933 Act, and duly authorized for issuance; that the Fund shall amend its registration statement for the Portfolios under the 1933 Act and the 1940 Act, from time to time, as required in order to effect the continuous offering of the shares of the Portfolios; that the Fund will sell such shares in compliance with all applicable federal and state laws; and that the Fund is and will remain registered under, and complies and will comply in all material respects with, the 1940 Act. The Fund shall register and qualify the shares of the Portfolios for sale in accordance with the laws of the various states only if, and to the extent, deemed advisable by the Fund or DFAS.

3.11 The Fund represents and warrants that the Portfolios will take reasonable steps to satisfy (or as to Portfolios that have not yet commenced business, will invest the money received from the sale of Portfolio shares so as to satisfy) the diversification requirements of Section 817(h) of the Code and the Treasury Regulations promulgated thereunder, and that the Fund will take all reasonable steps to ensure that the Portfolios continue to satisfy such requirements. The Fund agrees to notify the Company upon having a reasonable basis for believing that any Portfolio has ceased to satisfy such diversification requirements.

3.12 The Fund represents and warrants that the Portfolios qualify (or as to Portfolios that have not yet commenced business, will qualify) as regulated investment

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document companies under Subchapter M of the Code, and that the Fund will take all reasonable steps to maintain such qualification, subject to the reservation of the right of the Directors of the Fund to not maintain the qualification of a Portfolio as a regulated investment company if the Directors determine this course of action to be beneficial to shareholders. The Fund agrees to notify the Company upon having a reasonable basis for believing that any Portfolio has ceased to so qualify or upon the Directors taking any such action.

3.13 DFAS represents and warrants that it is and will remain a member in good standing of the Financial Industry Regulatory Authority, Inc. (“FINRA”), and is and will be duly registered as a broker- dealer with the SEC under the Securities Exchange Act of 1934, as amended (the “1934 Act”). DFAS represents that its operations are, and shall at all times remain, in material compliance with the laws of the State of Delaware to the extent required to perform this Agreement. DFAS further represents and warrants that it will sell and distribute the shares of the Portfolios in accordance with any applicable state laws and federal securities laws, including without limitation, the 1933 Act, the 1934 Act, and the 1940 Act.

3.14 The Parties represent and warrant to each other that all of their directors, officers, employees, investment advisers, and other individuals/entities dealing with the money and/or securities of the Portfolios are and shall continue to be at all times covered by a blanket fidelity bond or similar coverage for the benefit of the Fund in an amount not less than the amount required by the applicable rules of the FINRA and the federal securities laws, including the 1940 Act, as applicable. The aforesaid bond shall include coverage for larceny and embezzlement and shall be issued by a reputable bonding company. The Parties agree to make all reasonable efforts to assure that such bond or another bond containing these provisions is continuously in effect, and each agrees to notify promptly the other Parties in the event that such coverage no longer applies.

3.15 The Parties agree to limit, and not facilitate, a Contract holder’s participation in the Fund’s investment process in contravention of the following, which the Parties represent and warrant to each other to be true: (1) there is not, and there will not be, any arrangement, plan, contract or agreement between the Adviser (or a subadviser) and a Contract holder regarding the availability of the Fund as an Account under the Contract, or the specific assets to be held by the Fund or a fund that the Fund may invest its assets; (2) other than a Contract holder's ability to allocate Contract premiums and transfer amounts in the Company’s Account to and from the Company’s Account corresponding to the Fund, all investment decisions concerning the Fund will be made by the Adviser, any subadviser(s) and the Fund's Board of Directors in their sole and absolute discretion; (3) the percentage of the Fund's assets invested in a particular fund will not be fixed in advance of any Contract holder's investment and will be subject to change by the Adviser or a subadviser at any time without notice; (4) a Contract holder cannot,

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Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document and will not be able to, direct the Fund's investment in any particular asset or recommend a particular investment or investment strategy; (5) there is not, and will not be, any agreement or plan between the Adviser or a subadviser and a Contract holder regarding a particular investment of the Fund; (6) a Contract holder cannot, and will not be able to, communicate directly or indirectly with the Adviser or a subadviser concerning the selection, quality or rate of return on any specific investment or group of investments held by the Fund; (7) a Contract holder does not have, and will not have, any current knowledge of the Fund's specific assets other than as may be required to be presented in periodic reports to the Fund’s shareholders; (8) a Contract holder does not have, and will not have, any legal, equitable, direct or indirect ownership interest in any of the assets of the Fund; and (9) a Contract holder only has, and only will have, a contractual claim against the insurance company offering the Contract to receive cash from the insurance company under the terms of his or her Contract.

4. Sales Material and Information

4.1 The Company shall promptly provide the Fund with copies of any Contract holder complaints respecting the Contracts that relate to the Fund or to the Portfolios.

4.2 Except with the written consent of the Adviser, the Fund or DFAS, as appropriate, the Company shall not make any oral or written material representations concerning the Adviser, DFAS, the Fund or the Portfolios, other than the information or representations contained in: (a) a registration statement or prospectus for the Fund, as amended or supplemented from time to time; (b) published reports or statements of the Fund which are in the public domain or are approved by the Fund; or (c) sales literature or other promotional material of the Fund.

Notwithstanding the foregoing, this provision shall not be interpreted to prevent the Company from providing information about the Adviser, DFAS and the Fund or this Agreement to their Directors, regulators, accountants, legal counsel or otherwise in the ordinary course of their business.

4.3 Except with the written consent of the Company, the Adviser, DFAS, or the Fund shall not make any material representations concerning the Company, other than the information or representations contained in:

(a) a registration statement or offering memoranda for the Contracts, as amended or supplemented from time to time;

(b) published reports or statements of the Contracts or the Accounts which are in the public domain or are approved by the Company; or

Notwithstanding the foregoing, this provision shall not be interpreted to prevent the Adviser, DFAS and the Fund from providing information about the Company or this Agreement to their Directors, regulators, accountants, legal counsel or otherwise in the ordinary course of their business.

4.4 No Party shall use any other Party’s names, logos, trademarks or service marks, whether registered or unregistered, without the prior written consent of such Party.

4.5 Upon request, the Fund will provide to the Company at least one complete copy of all registration statements, prospectuses, (including any current summary prospectus, if applicable, as such term is defined in Rule 498), statements of additional information, reports, proxy statements, sales literature and other promotional materials, applications for exemptions, requests for no-action letters, and all amendments to any of the above, that relate to the Portfolios or their shares, in final form as filed with the SEC. Notwithstanding the foregoing, the Fund shall provide such documentation (including a final copy of the amended prospectus(es) of the Portfolios as set in type (including an 8 1/2” x 11” size camera-ready stat) at the Fund’s expense) and other assistance as is reasonably necessary in order for the Company once each year, at the Company’s expense, to print and provide to the contract owners the current prospectus(es) for the Portfolios.

4.6 Upon request, the Company will provide to the Fund at least one complete copy of all offering materials describing the Fund, the Portfolios and the Contracts, including application and investment election forms, sample illustrations, reports, solicitations for voting instructions, sales literature and any other promotional materials, applications for exemptions, requests for no-action letters, and all amendments to any of the above, that relate to the Contracts and each Account. In the event any such documents are required to be filed with any regulatory authority or body, the Company shall provide such materials in final form as filed with such regulatory authority or body. The Company represents and warrants that the Contracts, registration statements, offering memoranda and any other filing in connection therewith with respect to the Accounts will not materially deviate from the form of such documents provided to the Fund.

4.7 For purposes of this Section 4, the phrase “sales literature or other promotional material” shall be construed in accordance with all applicable securities laws and regulations.

4.8 To the extent required by applicable law, including the administrative requirements of regulatory authorities, or as mutually agreed between the Company and DFAS, the Company reserves the right to modify any of the Contracts in any respect whatsoever. The Company reserves the right, in its sole

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Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document discretion, to suspend the sale of any Contract, in whole or in part, or to accept or reject any application for the sale of a Contract. The Company agrees to notify the other Parties promptly upon the occurrence of any event that the Company believes might necessitate a material modification or suspension.

4.9 The Parties agree to review the arrangements set forth herein from time to time for possible changes and will make their personnel reasonably available for this purpose.

5. Fees and Expenses

5.1 The Fund shall bear the cost of registration and qualification of the shares of the Portfolios; preparation and filing of the Portfolios’ prospectus(es) and the Fund’s registration statement, proxy materials and reports relating to the Portfolios, including prospectuses, statements of additional information, and proxy materials for the Portfolios, as required by applicable state and federal law; preparation of all other statements and notices relating to the Portfolios required by any federal or state law; payment of all applicable fees, including, without limitation, all fees due under Rule 24f2 of the 1940 Act relating to the Portfolios; and all taxes on the issuance or transfer of the Portfolios’ shares.

5.2 The Company shall assure that the Contracts are registered under the 1933 Act, (or are properly exempt from such registration requirements) and that each Account is registered as a unit investment trust in accordance with the 1940 Act (or are properly exempt from such registration requirements). The Company shall bear the expenses for the costs of preparation and filing of the Company’s prospectus and registration statement with respect to the Contracts; preparation of all other statements and notices relating to each Account or Contracts required by any federal or state law; all expenses for the solicitation and sale of the Contracts, including all costs of printing and distributing all copies of advertisements, prospectuses, statements of additional information, proxy materials and reports to Contract holders and prospective purchasers of the Contracts, as required by applicable state and federal law; payment of all applicable fees and taxes relating to the Contracts; all costs of drafting, filing and obtaining approvals of the Contracts in the various states under applicable insurance laws; and all other costs associated with ongoing compliance with all such laws and its obligations hereunder.

6. Indemnification

6.1 Indemnification by the Company

6.1(a) The Company agrees to indemnify, defend and hold harmless the Fund, the Portfolios, DFAS and the Adviser, and each of their directors and officers (as applicable), and each person, if any, who controls any of them within the meaning of Section 15 of the 1933 Act (collectively, the

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document “Indemnified Parties” for purposes of this Section 6.1) against any and all losses, claims, damages, liabilities (including amounts paid in settlement with the written consent of the Company) or litigation (including legal and other expenses) (except in all cases, excluding consequential or special damages), to which the Indemnified Parties may become subject under any statute, regulation, at common law or otherwise, and:

(i) arise out of or are based upon any untrue statements or alleged untrue statements of any material fact contained in the registration statement, offering memoranda or sales literature for the Contracts (or any amendment or supplement to any of the foregoing), or arise out of or are based upon the omission or the alleged omission to state therein a material fact required to be stated therein or necessary to make the statements therein not misleading, provided that this Section 6.1(a) shall not apply as to any Indemnified Party if such statement or omission or such alleged statement or omission was made in reliance upon and in conformity with information furnished to the Company by or on behalf of the Fund for use in the registration statement or offering memoranda for the Contracts (or any amendment or supplement) or otherwise for use in connection with the sale of the Contracts or the shares of the Portfolios;

(ii) arise out of, or as a result of, statements or representations or wrongful conduct of the Company or persons under its control, with respect to the sale or distribution of the Contracts or the shares of the Portfolios;

(iii) arise out of any untrue statement or alleged untrue statement of a material fact contained in a registration statement, prospectus, or sales literature covering the Fund and the Portfolios or any amendment thereof or supplement thereto, or the omission or alleged omission to state therein a material fact required to be stated therein, or necessary to make the statements therein not misleading, if such a statement or omission was made in reliance upon information furnished to the Fund by or on behalf of the Company;

(iv) arise out of, or as a result of, any failure by the Company or persons under its control to provide the services and furnish the materials contemplated under the terms of this Agreement; or

(v) arise out of, or result from, any material breach of any representation and/or warranty made by the Company or persons under its control in this Agreement or arise out of or result from

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Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document any other material breach of this Agreement by the Company or persons under its control;

as limited by and in accordance with the provisions of Sections 6.1(b) and 6.1(c) hereof.

6.1(b) The Company shall not be liable under this indemnification provision with respect to any losses, claims, damages, liabilities or litigation to which an Indemnified Party would otherwise be subject by reason of such Indemnified Party’s willful misfeasance, bad faith, or gross negligence in the performance of such Indemnified Party’s duties or by reason of such Indemnified Party’s reckless disregard of obligations or duties under this Agreement or to the Fund, whichever is applicable, or to the extent of such Indemnified Party’s gross negligence.

6.1(c) The Company shall not be liable under this indemnification provision with respect to any claim made against an Indemnified Party unless such Indemnified Party shall have notified the Company in writing within a reasonable time after the summons or other first legal process giving information of the nature of the claim shall have been served upon such Indemnified Party (or after such Indemnified Party shall have received notice of such service on any designated agent), but failure to notify the Company of any such claim shall not relieve the Company from any liability which it may have to the Indemnified Party otherwise than on account of this indemnification provision. In case any such action is brought against the Indemnified Parties, the Company shall be entitled to participate, at its own expense, in the defense of such action, provided that it gives written notice of such intention to the Indemnified Parties. The Company also shall be entitled to assume and to control the defense thereof. After notice from the Company to such Party of the Company’s election to assume the defense thereof, the Indemnified Party shall bear the fees and expenses of any additional counsel retained by it, and the Company will not be liable to such Party under this Agreement for any legal or other expenses subsequently incurred by such Party independently in connection with the defense thereof other than reasonable costs of investigation.

6.1(d) The Indemnified Parties will promptly notify the Company of the commencement of any litigation or proceedings against them in connection with the issuance or sale of the shares of the Portfolios or the Contracts or the operation of the Portfolios.

6.2 Indemnification by DFAS

6.2(a) DFAS agrees to indemnify, defend and hold harmless the Company and each of its directors and officers and each person, if any, who controls the

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Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Company within the meaning of Section 15 of the 1933 Act (collectively, the “Indemnified Parties” for purposes of this Section 6.2) against any and all losses, claims, damages, liabilities (including amounts paid in settlement with the written consent of the Fund or DFAS) or litigation (including legal and other expenses) (except in all cases, excluding consequential or special damages) to which the Indemnified Parties may become subject under any statute, regulation, at common law or otherwise, and:

(i) arise out of or are based upon any untrue statement or alleged untrue statement of any material fact contained in the registration statement or current prospectus(es) or sales literature of the Fund and the Portfolios (or any amendment or supplement to any of the foregoing), or arise out of or are based upon the omission or the alleged omission to state therein a material fact required to be stated therein or necessary to make the statements therein not misleading, provided that this Section 6.2(a) shall not apply as to any Indemnified Party if such statement or omission or such alleged statement or omission was made in reliance upon and in conformity with information furnished to the Fund by or on behalf of the Company for use in the registration statement or prospectus(es) for the Portfolios or in sales literature (or any amendment or supplement) or otherwise for use in connection with the sale of the shares of the Portfolios;

(ii) arise out of, or as a result of, statements or representations or wrongful conduct of DFAS or the Fund or persons under their control, with respect to the sale or distribution of the shares of the Portfolios (it is understood that the persons who are involved in the sale or distribution of the Contracts are not under the control of DFAS, the Adviser or the Fund);

(iii) arise out of any untrue statement or alleged untrue statement of a material fact contained in a registration statement, offering memoranda or sales literature covering the Contracts, or any amendment thereof or supplement thereto, or the omission or alleged omission to state therein a material fact required to be stated therein, or necessary to make the statements therein not misleading, if such statement or omission was made in reliance upon information furnished to the Company by or on behalf of the Fund;

(iv) arise out of, or as a result of, any failure by DFAS, the Fund or persons under their control to provide the services and furnish the materials contemplated under the terms of this Agreement; or

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Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (v) arise out of or result from any material breach of any representation and/or warranty made by DFAS, the Fund or persons under their control in this Agreement or arise out of or result from any other material breach of this Agreement by DFAS, the Fund or persons under their control;

as limited by and in accordance with the provisions of Sections 6.2(b) and 6.2(c) hereof.

6.2(b) DFAS shall not be liable under this indemnification provision with respect to any losses, claims, damages, liabilities or litigation to which an Indemnified Party would otherwise be subject by reason of such Indemnified Party’s willful misfeasance, bad faith, or gross negligence in the performance of such Indemnified Party’s duties or by reason of such Indemnified Party’s reckless disregard of obligations and duties under this Agreement or to the Company or the Accounts, whichever is applicable, or to the extent of such Indemnified Party’s gross negligence.

6.2(c) DFAS shall not be liable under this indemnification provision with respect to any claim made against an Indemnified Party unless such Indemnified Party shall have notified DFAS in writing within a reasonable time after the summons or other first legal process giving information of the nature of the claim shall have been served upon such Indemnified Party (or after such Indemnified Party shall have received notice of such service on any designated agent), but failure to notify DFAS of any such claim shall not relieve DFAS from any liability which it may have to the Indemnified Party otherwise than on account of this indemnification provision. In case any such action is brought against the Indemnified Parties, DFAS will be entitled to participate, at its own expense, in the defense thereof, provided that it gives written notice of such intention to the Indemnified Parties. DFAS also shall be entitled to assume and to control the defense thereof. After notice from DFAS to such Party of DFAS’s election to assume the defense thereof, the Indemnified Party shall bear the fees and expenses of any additional counsel retained by it, and DFAS will not be liable to such party under this Agreement for any legal or other expenses subsequently incurred by such Party independently in connection with the defense thereof other than reasonable costs of investigation.

6.2(d) The Indemnified Parties will promptly notify DFAS of the commencement of any litigation or proceedings against them in connection with the issuance or sale of the Contracts or the operation of the Accounts.

6.3 Indemnification by the Adviser

6.3(a) The Adviser agrees to indemnify and hold harmless the Company and each of its directors and officers and each person, if any, who controls the

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Company within the meaning of Section 15 of the 1933 Act (collectively, the “Indemnified Parties” for purposes of this Section 6.3) against any and all losses, claims, damages, liabilities (including amounts paid in settlement with the written consent of the Fund or the Adviser) or litigation (including legal and other expenses) (except in all cases, excluding consequential or special damages) to which the Indemnified Parties may become subject under any statute, regulation, at common law or otherwise, and:

(i) arise out of or based upon any untrue statement or alleged untrue statement of any material fact contained in the registration statement or current prospectus(es) or sales literature of the Fund and the Portfolios (or any amendment or supplement to any of the foregoing), or arise out of or are based upon the omission or the alleged omission to state therein a material fact required to be stated therein or necessary to make the statements therein not misleading, provided that this Section 6.3(a) shall not apply as to any Indemnified Party if such statement or omission or such alleged statement or omission was made in reliance upon and in conformity with information furnished to the Fund or the Adviser by or on behalf of the Company for use in the registration statement or prospectus(es) for the Portfolios or in sales literature (or any amendment or supplement) or otherwise for use in connection with the sale of the shares of the Portfolios;

(ii) arise out of, or as a result of, statement or representations or wrongful conduct of DFAS, the Fund or the Adviser or persons under their control, with respect to the sale or distribution of the shares of the Portfolios (it is understood that the persons who are involved in the sale or distribution of the Contracts are not under the control of DFAS, the Adviser or the Fund);

(iv) arise out of, or as a result of, any failure by DFAS, the Adviser, the Fund or persons under their control to provide the services and

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(v) arise out of or result from any material breach of any representation and/or warranty made by DFAS, the Fund, the Adviser or persons under their control in this Agreement or arise out of or result from any other material breach of this Agreement by DFAS, the Adviser, the Fund or persons under their control;

as limited by and in accordance with the provisions of Sections 6.3(b) and 6.3(c) hereof.

6.3(b) The Adviser shall not be liable under this indemnification provision with respect to any losses, claims, damages, liabilities or litigation to which an Indemnified Party would otherwise be subject by reason of such Indemnified Party’s willful misfeasance, bad faith, or gross negligence in the performance of such Indemnified Party’s duties or by reason of such Indemnified Party’s reckless disregard of obligations and duties under this Agreement or to the Company or the Accounts, whichever is applicable, or to the extent of such Indemnified Party’s gross negligence.

6.3(c) The Adviser shall not be liable under this indemnification provision with respect to any claim made against an Indemnified Party unless such Indemnified Party shall have notified the Fund or the Adviser in writing within a reasonable time after the summons or other first legal process giving information of the nature of the claim shall have been served upon such Indemnified Party (or after such Indemnified Party shall have received notice of such service on any designated agent), but failure to notify the Fund or the Adviser of any such claim shall not relieve the Adviser from any liability which it may have to the Indemnified Party otherwise than on account of this indemnification provision. In case any such action is brought against the Indemnified Parties, the Adviser will be entitled to participate, at its own expense, in the defense thereof, provided that it gives written notice of such intention to the Indemnified Parties. The Adviser also shall be entitled to assume and to control the defense thereof. After notice from the Adviser to such Party of the Adviser’s election to assume the defense thereof, the Indemnified Party shall bear the fees and expenses of any additional counsel retained by it, and the Adviser will not be liable to such Party under this Agreement for any legal or other expenses subsequently incurred by such Party independently in connection with the defense thereof, other than reasonable costs of investigation.

6.3(d) The Indemnified Parties will promptly notify the Fund or the Adviser of the commencement of any litigation or proceedings against them in

18 15458_2

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document connection with the issuance or sale of the Contracts or the operation of the Accounts.

7. Potential Conflicts

7.1 The Directors will monitor the Fund for the existence of any material irreconcilable conflict between the interests of the contract owners of all separate accounts investing in the Portfolios. An irreconcilable material conflict may arise for a variety of reasons, including: (a) an action by any state insurance regulatory authority; (b) a change in applicable insurance (including federal, state or other jurisdiction), tax, or securities laws or regulations, or a public ruling, private letter ruling, no-action or interpretive letter, or any similar action by insurance, tax or securities regulatory authorities; (c) an administrative or judicial decision in any relevant proceeding; (d) the manner in which the investments of any Portfolio are being managed; (e) a difference in voting instructions given by variable annuity contract and variable life insurance contract owners; or (f) a decision by an insurer to disregard the voting instructions of contract owners. The Directors shall promptly inform the Company if they determine that an irreconcilable material conflict exists and the implications thereof.

7.2 The Company will report any potential or existing conflicts of which it is aware to the Directors and, on an annual basis, shall provide the Fund with written notification that the Company is not aware of any conflict, if such is the case. The Company will assist the Directors in carrying out their responsibilities under any applicable provisions of the federal securities laws and/or any exemptive orders granted by the SEC, including the order obtained by the Fund from the SEC, dated March 12, 2002 (File No. 81212760) (“Exemptive Order”), by providing the Directors with all information reasonably necessary for the Directors to consider any issues raised. This includes, but is not limited to, an obligation by the Company to inform the Directors whenever Contract holder voting instructions are disregarded.

The Company acknowledges that: (i) the Company’s disregard of voting instructions may conflict with the majority of Contract holders’ voting instructions; and (ii) the Company’s action could preclude a majority vote approving a proposed change or could represent a minority view. If the Company’s judgment represents a minority position or would preclude a majority vote, then the Company may be required, at the Fund’s election, to withdraw the Accounts’ investment in the Portfolios. Other than possible decline in the value of an Account due to fluctuations in the net asset value of the Portfolios, no charge or penalty will be imposed as a result of such withdrawal.

7.3 If it is determined by a majority of the Directors, or a majority of its disinterested Directors, that a material irreconcilable conflict exists, the Company shall, at its expense and to the extent reasonably practicable (as determined by a majority of disinterested Directors), take whatever steps are necessary to remedy or eliminate

19 15458_2

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document the irreconcilable material conflict, up to and including: (1) withdrawing the assets allocable to some or all of the Accounts from any Portfolio and reinvesting such assets in a different investment medium, including (but not limited to) another Portfolio of the Fund, or submitting the question whether such segregation should be implemented to a vote of all affected Contract holders and, as appropriate, segregating the assets of any appropriate group that votes in favor of such segregation, or offering to the affected Contract holders the option of making such a change; and (2) establishing a new registered management investment company or managed separate account.

7.4 If a material irreconcilable conflict arises because a particular state insurance regulator’s decision applicable to the Company conflicts with the majority of other insurance regulators, then the Company will withdraw the affected Account’s investment in the Portfolio(s) and terminate this Agreement with respect to such Account within six (6) months after the Directors inform the Company in writing that the Directors have determined that such decision has created an irreconcilable material conflict; provided, however, that such withdrawal and termination shall be limited to the extent required by the foregoing material irreconcilable conflict as determined by a majority of the disinterested Directors. Until the end of the foregoing six (6) month period, DFAS and the Fund shall continue to accept and implement orders by the Company for the purchase (and redemption) of shares of the Portfolios.

7.5 For purposes of Sections 7.3 through 7.5 of this Agreement, a majority of the disinterested Directors shall determine whether any proposed action adequately remedies any irreconcilable material conflict. The Company shall not be required by Section 7.3 to establish a new funding medium for the Contracts if an offer to do so has been declined by vote of a majority of Contract holders materially adversely affected by the irreconcilable material conflict. In the event that the Directors determine that any proposed action does not adequately remedy any irreconcilable material conflict, then the Company will withdraw an Account’s investment in the Portfolios and terminate this Agreement within six (6) months after the Directors inform the Company in writing of the foregoing determination; provided, however, that such withdrawal and termination shall be limited to the extent required by any such material irreconcilable conflict.

7.6 If and to the extent that Rule 6e2 and Rule 6e3(T) are amended, or Rule 6e3 is adopted, to provide exemptive relief from any provision of the 1940 Act or the rules promulgated thereunder with respect to mixed or shared funding (as defined in any Exemptive Order) on terms and conditions materially different from those contained in any Exemptive Order, then (a) the Fund and/or the Company, as appropriate, shall take such steps as may be necessary to comply with Rules 6e2 and 6e3 (T), as amended, and Rule 6e3, as adopted, to the extent such rules are applicable; and (b) Sections 7.1, 7.2, 7.3 and 7.4 of this Agreement shall continue in effect only to the extent that terms and conditions

20 15458_2

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document substantially identical to such Sections are contained in such Rule(s) as so amended or adopted by the SEC.

8. Term and Termination

a. This Agreement may be terminated by any Party with or without cause on thirty (30) days’ advance written notice.

8.2 Notwithstanding any other provision of this Agreement, DFAS, the Adviser or the Fund may terminate this Agreement for cause on not less than thirty (30) days’ prior written notice to the Company, unless the Company has cured such cause within thirty (30) days of receiving such notice, for any material breach by the Company of any representation, warranty, covenant or obligation hereunder.

8.3 Notwithstanding any other provision of this Agreement, the Company may terminate this Agreement for cause on not less than thirty (30) days’ prior written notice to DFAS, the Adviser and the Fund, unless DFAS, the Adviser or the Fund, as appropriate, has cured such cause within thirty (30) days of receiving such notice, for any material breach by DFAS, the Adviser or the Fund of any representation, warranty, covenant or obligation hereunder.

8.4 Notwithstanding any other provision of this Agreement, the Company may terminate this Agreement by written notice to the Fund and DFAS with respect to any Portfolio based upon the Company’s determination that shares of such Portfolio are not reasonably available to meet the requirements of the Contracts.

8.5 Notwithstanding any other provision of this Agreement, the Company may terminate this Agreement by written notice to the Fund, the Adviser and DFAS with respect to any Portfolio in the event such Portfolio’s shares are not registered, issued or sold in accordance with applicable state and/or federal law, or such law precludes the use of such shares as the underlying investment media of the Contracts issued or to be issued by the Company.

8.6 Notwithstanding any other provision of this Agreement, the Company may terminate this Agreement by written notice to the Fund, the Adviser and DFAS with respect to any Portfolio in the event that such Portfolio ceases to qualify as a “regulated investment company” under Subchapter M of the Code, or if the Company reasonably believes that any such Portfolio may fail to so qualify.

8.7 Notwithstanding any other provision of this Agreement, the Company may terminate this Agreement by written notice to the Fund, the Adviser and DFAS with respect to any Portfolio in the event that such Portfolio fails to satisfy the diversification requirements of Section 817 of the Code and the Treasury regulations promulgated thereunder.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 8.8 Notwithstanding any other provision of this Agreement, the Fund, the Adviser or DFAS may terminate this Agreement by written notice to the Company, if any one or all shall determine, in their sole judgment, exercised in good faith, that the Company has suffered a material adverse change in its business, operations, financial condition or prospects since the date of this Agreement or is the subject of material adverse publicity.

8.9 Notwithstanding any other provision of this Agreement, the Company may terminate this Agreement by written notice to the Fund, the Adviser and DFAS, if the Company shall determine, in its sole judgment, exercised in good faith, that any of the Fund, the Portfolios, the Adviser or DFAS has suffered a material adverse change in its business, operations, financial condition or prospects since the date of this Agreement or is the subject of material adverse publicity.

8.10 Notwithstanding any other provision of this Agreement, any Party may terminate this Agreement for cause on not less than thirty (30) days’ prior written notice to all other Parties, unless any of the other Parties has cured such cause within thirty (30) days of receiving such notice, for any one of the following reasons:

(a) change in control of any Party or such Party’s ultimate controlling person; however, a change in the name of the Party will not constitute a change in control;

(b) a material change in, or other material revision to, the Contracts or the prospectus(es) of the Portfolios, which material change or revision is not acceptable to any of the other Parties; or

(c) any action taken by federal, state or other regulatory authorities of competent jurisdiction which, in the reasonable judgment of any of the Parties, either (i) materially and adversely alters the terms, advantages and/or benefits of the Contracts to current or prospective purchasers; or (ii) materially or adversely alters the terms or conditions of such Party’s participation in the subject matter of this Agreement.

8.11 Notwithstanding the termination of this Agreement, each Party shall continue for so long as any Contracts remain outstanding to perform such of its duties hereunder as are necessary to ensure the continued tax status thereof and the payment of benefits thereunder, with respect to a Portfolio and the corresponding subaccount of each Account.

9. Notices

Any notice shall be deemed sufficiently given when sent by registered or certified mail, or via facsimile, to the other Parties at the address of such Parties set forth below or at such other address as such Parties may from time to time specify in writing to the other Parties.

22 15458_2

Catherine L. Newell, Esq. Vice President and Secretary DFA Investment Dimensions Group Inc. 6300 Bee Cave Road, Building One Austin, TX 78746

If to the Adviser:

Catherine L. Newell, Esq. Vice President and Secretary Dimensional Fund Advisors Inc. 6300 Bee Cave Road, Building One Austin, TX 78746

If to DFAS:

Catherine L. Newell, Esq. Vice President and Secretary DFA Securities LLC 6300 Bee Cave Road, Building One Austin, TX 78746

If to the Company:

Symetra Life Insurance Company 777 108th Ave NE, Suite 1200 Legal Dept. SC-11 Attn: Legal Counsel Bellevue, WA 98004

10. Miscellaneous

10.1 The captions in this Agreement are included for convenience of reference only and in no way affect the construction or effect of any provisions hereof.

10.2 If any portion of this Agreement shall be held or made invalid by a court decision, statute, rule or otherwise, the remainder of the Agreement shall not be affected thereby.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 10.3 This Agreement may be executed simultaneously in two or more counterparts, each of which taken together shall constitute one and the same instrument.

23 15458_2

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 10.4 Each Party shall cooperate with each other Party and all appropriate governmental authorities (including, without limitation, the SEC, FINRA, and any applicable insurance, securities or other regulator of competent jurisdiction), and shall permit such authorities reasonable access to its books and records as required by applicable law in connection with any investigation or inquiry relating to this Agreement.

10.5 Each Party hereto grants to the other Parties the right to audit its records relating to the terms and conditions of this Agreement upon reasonable notice during reasonable business hours in order to confirm compliance with this Agreement.

10.6 The rights, remedies and obligations contained in this Agreement are cumulative and are in addition to any and all rights, remedies and obligations, at law or in equity, which the Parties hereto are entitled to under state and federal laws.

10.7 Subject to the requirements of legal process and regulatory authority, the Fund, the Adviser and DFAS shall treat as confidential the names and addresses of the owners of the Contracts and all information reasonably identified as confidential in writing by the Company hereto and, except as permitted by this Agreement, shall not disclose, disseminate or utilize such names and addresses and other confidential information without the express written consent of the Company until such time as it may come into the public domain.

10.8 This Agreement or any of the rights and obligations hereunder may not be assigned by any Party without the prior written consent of all Parties hereto.

10.9 In any dispute arising hereunder, each Party waives its right to demand a trial by jury and hereby consents to a bench trial of all such disputes. j. The terms of this Agreement shall be construed and the provisions hereof interpreted under and in accordance with the laws of the State of Texas, without regard to the conflicts of law principles thereof; provided, however, that all performances rendered hereunder shall be subject to compliance with all applicable state and federal laws and regulations.

To the extent they are applicable, this Agreement shall be subject to the provisions of the 1933 Act, the 1934 Act, and the 1940 Act, and the rules and regulations and interpretations thereunder, including such exemptions from those statutes, rules and regulations as the SEC may grant, and any applicable FINRA regulations or interpretations, and the terms hereof shall be interpreted and construed in accordance therewith.

24 15458_2

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document IN WITNESS WHEREOF, each of the Parties hereto has caused this Agreement to be duly executed as of the date first set forth above.

Company:

SYMETRA LIFE INSURANCE COMPANY

By: Name: Daniel R. Guilbert Title: Executive Vice President

Fund:

DFA INVESTMENT DIMENSIONS GROUP INC.

By: Name: Title:

Adviser:

DIMENSIONAL FUND ADVISORS LP By: Dimensional Holdings Inc., general partner

By: Name: Title:

DFAS:

DFA SECURITIES LLC

By: Name: Title:

VA U.S. Targeted Value Portfolio

VA U.S. Large Value Portfolio

VA International Value Portfolio

VA International Small Portfolio

VA Short-Term Fixed Portfolio VA Global Bond Portfolio

Symetra Participation Agreement.docx3

1. Agreement to Provide Information. The Company (hereafter, an "Intermediary") agrees to provide the Fund, upon written request, the taxpayer identification number (“TIN”), the Individual/International Taxpayer Identification Number ("ITIN")1, or other government-issued identifier ("GII"), if known, of any or all Contract holders or shareholder(s) of the account (together, "Shareholder(s)") and the amount, date, name or other identifier of any investment professional(s) associated with the Shareholder(s) or account (if known), and transaction type (purchase, redemption, transfer, or exchange) of every purchase, redemption, transfer, or exchange of Fund shares (“Shares”) held through an account maintained by the Intermediary during the period covered by the request.

a.. Period Covered by Request. Requests must set forth a specific period, generally not to exceed 90 days from the date of the request, for which transaction information is sought. Fund or its designee may request transaction information older than 90 days from the date of the request as it deems necessary to investigate compliance with policies established by the Fund for the purpose of eliminating or reducing any dilution of the value of the outstanding shares issued by the Fund or if the Funds or Dimensional believe that any combination of trading activity in Shareholder accounts is potentially disruptive to a Fund.

b.. Form and Timing of Response.

i... Intermediary agrees to provide, promptly but in any event not later than five (5) business days, or as otherwise agreed to by the parties, after receipt of a request of the Fund or its designee, the requested information specified in Section 1. If requested by the Fund or its designee, Intermediary agrees to use its best efforts to determine promptly whether any specific person about whom it has received the identification and transaction information specified in Section 1 is itself a financial intermediary (“indirect intermediary”) and, upon further request of the Fund or its designee, promptly either (i) provide (or arrange to have provided) the information set forth in Section 1 for those shareholders who hold an account with an indirect intermediary, or (ii) if directed by the Fund restrict or prohibit the indirect intermediary from purchasing, in nominee name on behalf of other persons, securities issued by the Fund. Intermediary additionally agrees to inform the Fund whether it plans to perform (i) or (ii). For purposes of this provision, an “indirect intermediary” has the same meaning as in SEC Rule 22c-2 under the 1940 Act.

11 According to the IRS’ website, the ITIN refers to the Individual Taxpayer Identification number, which is a nine-digit number that always begins with the number 9 and has a 7 or 8 in the fourth digit, example 9XX-7X-XXXX.. The IRS issues ITINs to individuals who are required to have a U.S. taxpayer identification number but who do not have, and are not eligible to obtain a Social Security Number (SSN) from the Social Security Administration (SSA). SEC Rule 22c-2 inadvertently refers to the ITIN as the International Taxpayer Identification Number

Symetra Participation Agreement.docx3

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document ii... Responses required by this paragraph must be communicated in writing and in a format mutually agreed upon by the parties.

iii... To the extent practicable, the format for any transaction information provided to the Fund should be consistent with the NSCC Standardized Data Reporting Format.

c.. Limitations on Use of Information. The Fund agrees not to use the information received from the Intermediary for the Fund’s use in external solicitation or marketing to shareholders without the prior written consent of the Intermediary. The Fund is permitted to use the information received from the Intermediary for the Fund’s internal purposes, including monitoring compliance with the Fund’s internal policies, procedures and practices. The Fund agrees to keep any non-public information furnished by the Intermediary confidential consistent with the Fund's then current privacy policy, except as necessary to comply with federal, state, or local laws, rules, or other applicable legal requirements.

3. Agreement to Restrict Trading. Intermediary agrees to execute written instructions from the Fund to restrict or prohibit further purchases or exchanges of Shares by a Shareholder that has been identified by the Fund as having engaged in transactions in the Fund’s Shares (directly or indirectly through the Intermediary’s account) that violate policies established by the Fund for the purpose of eliminating or reducing any dilution of the value of the outstanding Shares issued by the Fund.

a.. Form of Instructions. Instructions to restrict or prohibit trading must include the TIN, ITIN, or GII, if known, and the specific restriction(s) to be executed. If the TIN, ITIN, or GII is not known, the instructions must include an equivalent identifying number of the Shareholder(s) or account(s) or other agreed upon information to which the instruction relates.

b.. Timing of Response. Intermediary agrees to execute instructions from the Fund to restrict or prohibit trading as soon as reasonably practicable, but not later than five (5) business days after receipt of the instructions by the Intermediary.

c.. Confirmation by Intermediary. Intermediary must provide written confirmation to the Fund that instructions have been executed. Intermediary agrees to provide confirmation as soon as reasonably practicable, but not later than ten (10) business days after the instructions have been executed.

4. Definitions. For purposes of this Schedule 3.6:

a.. The term “Fund” includes the Fund’s principal underwriter and transfer agent. The term not does include any “excepted funds” as defined in SEC Rule 22c-2(b) under the 1940 Act.2

22 As defined in SEC Rule 22c-2(b), the term “excepted fund” means any: (1) money market fund; (2) fund that issues securities that are listed on a national exchange; and (3) fund that affirmatively permits short-term trading of its securities, if its prospectus clearly and prominently discloses that the fund permits short-term trading of its securities and that such trading may result in additional costs for the fund

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document b.. The term “Shares” means the interests of Shareholders corresponding to the redeemable securities of record issued by the Fund under the 1940 Act that are held by the Intermediary.

c.. The term “Shareholder” means the beneficial owner of Shares, whether the Shares are held directly or by the Intermediary in nominee name; except:

i... with respect to retirement plan recordkeepers, the term “Shareholder” means the Plan participant notwithstanding that the Plan may be deemed to be the beneficial owner of Shares; and

ii... with respect to insurance companies, the term “Shareholder” means the holder of interests in a variable annuity or variable life insurance contract issued by the Intermediary.

d.. The term “written” includes electronic writings and facsimile transmissions.

e.. The term “Intermediary” shall mean a “financial intermediary” as defined in SEC Rule 22c-2.3

f.. The term “purchase” does not include the automatic reinvestment of dividends.

g.. The term “promptly” as used in Section 1.2 shall mean as soon as practicable but in no event later than 10 business days from the Intermediary’s receipt of the request for information from the Fund or its designee.

33 “Financial intermediary” is defined in SEC Rule 22c-2(c)(1) as: “(i) any broker, dealer, bank, or other entity that holds securities of record issued by the fund, in nominee name; (ii) a unit investment trust or fund that invests in the fund in reliance on section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)); and (iii) in the case of a participant-directed employee benefit plan that owns the securities issued by the fund, a retirement plan’s administrator under section 3(16)(A) of the Employee Retirement Income Security Act of 1974 (29 U.S.C. 1002(16)(A)) or any entity that maintains the plan’s participant records.

29 15458_2

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document AMENDMENT 2 TO PARTICIPATION AGREEMENT BY AND BETWEEN GOLDMAN SACHS VARIABLE INSURANCE TRUST, GOLDMAN, SACHS & CO. AMENDMENT 2 TO PARTICIPATION AGREEMENT BY AND BETWEEN GOLDMAN SACHS VARIABLE INSURANCE TRUST, GOLDMAN, SACHS & CO. AND SYMETRA LIFE INSURANCE COMPANY

This Amendment 2 to the Participation Agreement dated November 20, 2014 (the “Amendment”), is made and entered into this 20th day of November 2014 by and between GOLDMAN SACHS VARIABLE INSURANCE TRUST, a statutory trust formed under the laws of Delaware (the “Trust”), GOLDMAN, SACHS & CO., a New York limited partnership (the “Distributor”), and SYMETRA LIFE INSURANCE COMPANY, a Washington life insurance company (the “Company”), on its own behalf and on behalf of each separate account of the Company referred to herein.

WITNESSETH:

WHEREAS, the Trust, the Distributor and the Company entered into a Participation Agreement on September 28, 2009, as amended (the “2009 Agreement”); and

WHEREAS, the Trust, the Distributor and the Company wish to amend Schedule 1A and 1B of the 2009 Agreement; and

WHEREAS, Article XI of the 2009 Agreement provides that the 2009 Agreement may be amended by written agreement signed by all of the parties.

NOW, THEREFORE, in consideration of the mutual covenants herein contained, which consideration is full and complete, the Trust, the Distributor and the Company hereby agree as follows:

1. Schedule 1 of the 2009 Agreement is hereby deleted in its entirety and replaced with the attached Schedule 1.

** SIGNATURE PAGE FOLLOWS **

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document IN WITNESS WHEREOF, each of the parties hereto has caused this Amendment to be executed in its name and behalf by its duly authorized officer on the date specified below.

GOLDMAN SACHS VARIABLE INSURANCE TRUST (Trust)

Date:______By:______Name: Title:

GOLDMAN, SACHS & CO. (Distributor)

Date:______By:______Name: Title:

SYMETRA LIFE INSURANCE COMPANY (Company)

Date:______By:______Name: Daniel R. Guilbert Title: Executive Vice President

Schedule 1A

Separate Accounts of the Company Registered Under the 1940 Act as Unit Investment Trusts

The following separate accounts of the Company are subject to the Agreement:

Name of Account Date Established by Board of SEC 1940 Act Registration Type of Product Supported by Directors of the Company Number Account

Separate Account C September 14, 1993 811-08052 Individual and Group Variable Annuities

Resource Variable Account B February 6 1986 811-4716 Individual and Group Variable Annuities

VCOLI/VCOLIX July 29, 2008 Unregistered Variable Corporate Owned Life Insurance

Schedule 1B

Variable Annuity Contracts and Variable Life Insurance Contracts Registered Under the Securities Act of 1933

The following Contracts are subject to the Agreement:

Retirement Passport All series of Goldman Sachs 333-158141 Group Variable Annuity Variable Insurance Trust - Institutional and Service Shares Symetra True Variable Annuity All series of Goldman Sachs 333-178461 Individual Variable Annuity Variable Insurance Trust - Institutional and Service Shares VCOLI/VCOLIX All series of Goldman Sachs unregistered Private Placement - VCOLI Variable Insurance Trust - Institutional and Service Shares

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document AMENDMENT TO PARTICIPATION AGREEMENT BY AND BETWEEN GOLDMAN SACHS VARIABLE INSURANCE TRUST, GOLDMAN, SACHS & CO. AND SYMETRA LIFE INSURANCE COMPANY

This Amendment to the Participation Agreement dated September 28, 2009 (the “Amendment”), is made and entered into this __ day of March 2014 by and between GOLDMAN SACHS VARIABLE INSURANCE TRUST, a statutory trust formed under the laws of Delaware (the “Trust”), GOLDMAN, SACHS & CO., a New York limited partnership (the “Distributor”), and SYMETRA LIFE INSURANCE COMPANY, a Washington life insurance company (the “Company”), on its own behalf and on behalf of each separate account of the Company referred to herein.

WITNESSETH:

WHEREAS, the Trust, the Distributor and the Company entered into a Participation Agreement on September 28, 2009 (the “2009 Agreement”); and

WHEREAS, the Trust, the Distributor and the Company wish to amend Schedule 1A of the 2009 Agreement; and

WHEREAS, Article XI of the 2009 Agreement provides that the 2009 Agreement may be amended by written agreement signed by all of the parties.

NOW, THEREFORE, in consideration of the mutual covenants herein contained, which consideration is full and complete, the Trust, the Distributor and the Company hereby agree as follows:

1. Amendment of the 2009 Agreement. The 2009 Agreement is amended as set forth below.

2. Amendments to Schedules.

Schedule 1 of the 2009 Agreement is hereby deleted in its entirety and replaced with the attached Schedule 1.

***SIGNATURE PAGE FOLLOWS***

GOLDMAN SACHS VARIABLE INSURANCE TRUST (Trust)

Date: ______By: ______Name: Title:

GOLDMAN, SACHS & CO. (Distributor)

Date: ______By: ______Name: Title:

SYMETRA LIFE INSURANCE COMPANY (Company)

Date: ______By: ______Name: Daniel R. Guilbert Title: Executive Vice President

Schedule 1A

Separate Accounts of the Company Registered Under the 1940 Act as Unit Investment Trusts

The following separate accounts of the Company are subject to the Agreement:

Name of Account Date Established by Board of SEC 1940 Act Registration Type of Product Supported by Directors of the Company Number Account

Separate Account C September 14, 1993 811-08052 Individual and Group Variable Annuities

Resource Variable Account B February 6 1986 811-4716 Individual and Group Variable Annuities

Schedule 1B

Variable Annuity Contracts and Variable Life Insurance Contracts Registered Under the Securities Act of 1933

The following Contracts are subject to the Agreement:

Name of Contract Available Funds 1933 Act Registration Number Type of Product

THIS AGREEMENT, made and entered into this __ day of September, 2009 by and between GOLDMAN SACHS VARIABLE INSURANCE TRUST, statutory trust formed under the laws of Delaware (the “Trust”), GOLDMAN, SACHS & CO., a New York limited partnership (the “Distributor”), and SYMETRA LIFE INSURANCE COMPANY, a Washington life insurance company (the “Company”), on its own behalf and on behalf of each separate account of the Company identified herein.

WHEREAS, the Trust engages in business as an open-end management investment company of the series-type mutual fund offering shares of beneficial interest (the “Trust shares”) consisting of one or more separate series (“Series”) of shares, each such Series representing an interest in a particular investment portfolio of securities and other assets (a “Fund”), and which Series is subdivided into various classes (“Classes”) with each such Class supporting a distinct charge and expense arrangement; and

WHEREAS, the Trust was established for the purpose of serving as an investment vehicle for life insurance company separate accounts supporting variable annuity contracts and variable life insurance policies to be offered by insurance companies and may also be utilized by qualified retirement plans; and

WHEREAS, an order of the Securities and Exchange Commission dated February 2, 1998, (File No. 812-10794) grants certain separate accounts supporting variable life insurance policies, their life insurance company depositors, and their principal underwriters, exemptions from Sections 9(a), 13(a), 15(a) and 15(b) of the Investment Company Act of 1940, and from Rules 6e-2(b)(15) and 6e-3(T)(b)(15) thereunder, to the extent necessary for such separate accounts to purchase and hold Trust shares at the same time that such shares are sold to or held by separate accounts of affiliated and unaffiliated insurance companies supporting either variable annuity contracts or variable life insurance policies, or both, or by qualified pension and retirement plans (the “SEC Order”); and

WHEREAS, the Distributor has the exclusive right to distribute Trust shares to qualifying investors; and

WHEREAS, the Company desires that the Trust serve as an investment vehicle for a certain separate account(s) of the Company and the Distributor desires to sell shares of certain Series and/or Class(es) to such separate account(s);

NOW, THEREFORE, in consideration of their mutual promises, the Trust, the Distributor and the Company agree as follows:

ARTICLE I Additional Definitions

1.1. “Accounts” -- the separate accounts of the Company described more specifically in Schedules 1A, 2A and 3A to this Agreement.

1.2. “Business Day”—each day that the Trust is open for business as provided in the Trust’s Prospectus.

1.3. “Code”—the Internal Revenue Code of 1986, as amended, and any successor thereto.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 1.4. “Contracts”—the class or classes of variable annuity contracts and/or variable life insurance policies issued by the Company and described more specifically on Schedules 1B, 2B, or 3B to this Agreement.

1.5. “Contract Owners”—the owners of the Contracts, as distinguished from all Product Owners.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 1.6. “Participating Account”—a separate account investing all or a portion of its assets in the Trust, including the Accounts.

1.7. “Participating Insurance Company”—any insurance company with a Participating Account, including the Company.

1.8. “Participating Plan”—any qualified retirement plan investing in the Trust.

1.9. “Participating Investor”—any Participating Account, Participating Insurance Company or Participating Plan, including the Accounts and the Company.

1.10. “Products”—variable annuity contracts and variable life insurance policies supported by Participating Accounts, including the Contracts.

1.11. “Product Owners”—owners of Products, including Contract Owners.

1.12. “Trust Board”—the board of trustees of the Trust.

1.13. “Registration Statement”—with respect to the Trust shares or a class of Contracts, the registration statement filed with the SEC to register such securities under the 1933 Act, or the most recently filed amendment thereto, in either case in the form in which it was declared or became effective. The Contracts’ Registration Statement for each class of Contracts is described more specifically on Schedule 1B to this Agreement. The Trust’s Registration Statement is filed on Form N-1A (File No. 333-35883).

1.14. “1940 Act Registration Statement”—with respect to the Trust or the Schedule 1 Accounts, the registration statement filed with the SEC to register such person as an investment company under the 1940 Act, or the most recently filed amendment thereto. The Schedule 1 Accounts’ 1940 Act Registration Statements are described more specifically on Schedule 1A to this Agreement. The Trust’s 1940 Act Registration Statement is filed on Form N-1A (File No. 811-08361).

1.15. “Prospectus”—with respect to shares of a Series (or Class) of the Trust or a class of Contracts, each version of the definitive prospectus or supplement thereto filed with the SEC pursuant to Rule 497 under the 1933 Act. With respect to any provision of this Agreement requiring a party to take action in accordance with a Prospectus, such reference thereto shall be deemed to be to the version for the applicable Series, Class or Contracts last so filed prior to the taking of such action. For purposes of Article IX, the term “Prospectus” shall include any statement of additional information incorporated therein.

1.16. “Schedule 1 Accounts”—Accounts registered under the 1940 Act as unit investment trusts and listed on Schedule 1A.

1.17. “Schedule 2 Accounts”—Accounts excluded from the definition of an investment company as provided for by Section 3(c)(11) of the 1940 Act and listed on Schedule 2A.

1.18. “Schedule 3 Accounts”—Accounts excluded from the definition of an investment company as provided for by Section 3(c)(1) or Section 3(c)(7) of the 1940 Act and listed on Schedule 3A.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 1.19. “Schedule 1 Contracts”—Contracts through which interests in Schedule 1 Accounts are offered and issued, which interests are registered as securities under the 1933 Act.

1.20. “Schedule 2 Contracts”—Contracts through which interests in Schedule 2 Accounts are offered and issued to trustees of qualified pension and profit-sharing plans and certain government plans identified in Section 3(a)(2) of the 1933 Act (which interests are not registered as securities in reliance upon Section 3(a)(2) of the 1933 Act).

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 1.21. “Schedule 3 Contracts”—Contracts through which interests in Schedule 3 Accounts are offered and issued to “accredited investors”, as that term is defined in Regulation D under the 1933 Act, or other investors permitted by Regulation D (which interests are not registered as securities in reliance upon Regulation D).

1.22. “Statement of Additional Information”—with respect to the shares of the Trust or a class of Contracts, each version of the definitive statement of additional information or supplement thereto filed with the SEC pursuant to Rule 497 under the 1933 Act. With respect to any provision of this Agreement requiring a party to take action in accordance with a Statement of Additional Information, such reference thereto shall be deemed to be the last version so filed prior to the taking of such action. 1.23. “SEC”—the Securities and Exchange Commission.

1.24. “NASD”—The National Association of Securities Dealers, Inc.

1.25. “1933 Act”—the Securities Exchange Act of 1933, as amended.

1.26. “1940 Act”—the Investment Company Act of 1940, as amended.

ARTICLE II Sale of Trust Shares

2.1. Availability of Shares

(a) The Trust has granted to the Distributor exclusive authority to distribute the Trust shares and to select which Series or Classes of Trust shares shall be made available to Participating Investors. Pursuant to such authority, and subject to Article X hereof, the Distributor shall make available to the Company for purchase on behalf of the Accounts, shares of the Series and Classes listed on Schedules 1B, 2B, and 3B to this Agreement, such purchases to be effected at net asset value in accordance with Section 2.3 of this Agreement. The Distributor shall make such Series and Classes available to the Company in accordance with the terms and provisions of this Agreement until: (i) this Agreement is terminated pursuant to Article X, or (ii) the Distributor suspends or terminates the offering of shares of such Series or Classes in the circumstances described in Article X.

(b) Notwithstanding clause (a) of this Section 2.1, Series or Classes of Trust shares in existence now or in the future will be made available to the Company only as the Distributor may so provide, subject to the Distributor’s rights set forth in Article X to suspend or terminate the offering of shares of any Series or Class or to terminate this Agreement.

(c) The parties acknowledge and agree that: (i) the Trust may revoke the Distributor’s authority pursuant to the terms and conditions of its distribution agreement with the Distributor, and (ii) the Trust reserves the right in its sole discretion to refuse to accept a request for the purchase of Trust shares. 2.2. Redemptions. The Trust shall redeem, at the Company’s request, any full or fractional Trust shares held by the Company on behalf of the Account, such redemptions to be effected at net asset value in accordance with Section 2.3 of this Agreement. Not¬with¬standing the foregoing: (a) the Company shall not redeem Trust shares attributable to Contract Owners except in the circumstances permitted in Article X of this Agreement, and (b) the Trust may delay redemption of

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Trust shares of any Series or Class to the extent permitted by the 1940 Act, any rules, regulations or orders thereunder, or the Prospectus for such Series or Class.

2.3. Purchase and Redemption Procedures

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (a) The Trust hereby appoints the Company as an agent of the Trust for the limited purpose of receiving purchase and redemption requests on behalf of the Schedule 1 Accounts (but not on behalf of the Schedule 2 Accounts, Schedule 3 Accounts, or the Company’s general account) for shares of those Series or Classes made available hereunder, based on transactions in Account Units of the Schedule 1 Accounts under the Schedule 1 Contracts. Receipt of any such requests (or effectuation of such transaction or processing) on any Business Day by the Company as such limited agent of the Trust prior to the Trust’s close of business as defined from time to time in the applicable Prospectus for such Series or Class (which as of the date of execution of this Agreement is the close of regular trading on the New York Stock Exchange (normally 4:00 p.m. New York Time)) shall constitute receipt by the Trust on that Business Day, provided that the Trust receives actual and sufficient notice of such request by 9:00 a.m. New York Time on the next following Business Day. Such notice may be communicated by telephone to the office or person designated for such notice by the Trust and shall be confirmed by facsimile.

(b) The Company shall pay for shares of each Series or Class on the same day that it provides actual notice to the Trust of a purchase request for such shares. Payment for Series or Class shares shall be made in federal funds transmitted to the Trust by wire by 12:00 p.m. New York Time on the day the Trust receives actual notice of the purchase request for Series or Class shares (unless the Trust determines and so advises the Company that sufficient proceeds are available from redemption of shares of other Series or Classes effected pursuant to redemption requests tendered by the Company on behalf of the Account). In no event may proceeds from the redemption of shares requested pursuant to an order received by the Company after the Trust’s close of business on any Business Day be applied to the payment for shares for which a purchase order was received prior to the Trust’s close of business on the same day. If the issuance of Trust shares is canceled because federal funds are not timely received, the Company shall indemnify the respective Fund and Distributor with respect to all costs, expenses and losses relating thereto. Upon the Trust’s receipt of federal funds so wired, such funds shall cease to be the responsibility of the Company and shall become the responsibility of the Trust. If federal funds are not received on time, such funds will be invested, and Trust shares purchased thereby will be issued, as soon as practicable after actual receipt of such funds but in any event not on the same day that the purchase order was received.

(c) Payment for Trust shares redeemed by the Accounts or the Company shall be made in federal funds transmitted by wire to the Company or any other person properly designated in writing by the Company, such funds normally to be transmitted by 6:00 p.m. New York Time on the next Business Day after the Trust receives actual notice of the redemption order for such shares (unless redemption proceeds are to be applied to the purchase of Trust shares of other Series or Classes in accordance with Section 2.3(b) of this Agreement), except that the Trust reserves the right to redeem trust shares in assets other than cash and to delay payment of redemption proceeds to the extent permitted by the 1940 Act and any rules or regulations thereunder, or the applicable Prospectus. The Trust shall not bear any responsibility whatsoever for the proper disbursement or crediting of redemption proceeds by the Company or the Accounts; the Company alone shall be responsible for such action.

(d) Any purchase or redemption request for Trust shares held or to be held by the Company’s general account, shall be effected at the net asset value per share next determined after the Trust’s actual receipt of such request, provided that, in the case of a purchase request, payment for Trust shares so requested is received by the Trust in federal funds prior to close of business for determination of such value, as defined from time to time in the Prospectus for such Series or Class.

(e) Prior to the first purchase of any Trust shares hereunder, the Company and the Trust shall provide each other with all information necessary to effect wire transmissions of federal funds to the other party and all other designated persons pursuant to such protocols and security procedures as the parties may agree upon. Should such information change

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document thereafter, the Trust and the Company, as applicable, shall notify the other in writing of such changes, observing the same protocols and security procedures, at least three Business Days in advance of when such change is to take effect. The Company and the Trust

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document shall observe customary procedures to protect the confidentiality and security of such information. For any breach of confidentiality or security, the Distributor shall be liable to the Company.

(f) The procedures set forth herein are subject to any additional terms set forth in the applicable Prospectus for the Series or Class or by the requirements of applicable law.

2.4. Net Asset Value. The Trust shall use its best efforts to inform the Company of the net asset value per share for each Series or Class available to the Company as soon as reasonably practicable after the net asset value per share for such Series or Class is calculated. The Trust shall calculate such net asset values in accordance with the Prospectus for such Series or Class.

2.5. Dividends and Distributions. The Trust shall furnish notice to the Company as soon as reasonably practicable of any income dividends or capital gain distributions payable on any Series or Class shares. The Company, on its behalf and on behalf of the Accounts, hereby elects to receive all such dividends and distributions as are payable on any Series or Class shares in the form of additional shares of that Series or Class. The Company reserves the right, on its behalf and on behalf of the Accounts, to revoke this election and to receive all such dividends and capital gain distributions in cash; to be effective, such revocation must be made in writing and received by the Trust at least [ten] Business Days prior to a dividend or distribution date. The Trust shall notify the Company promptly of the number of Series or Class shares so issued as payment of such dividends and distributions.

2.6. Book Entry. Issuance and transfer of Trust shares shall be by book entry only. Stock certificates will not be issued to the Company or the Accounts. Purchase and redemption orders for Trust shares shall be recorded in an appropriate ledger for each Account.

2.7. Pricing Errors. Any material errors in the calculation of the net asset value of a Fund, the net asset value per share of any Series or Class of Trust shares, dividends or capital gain information shall be reported to the Company immediately upon discovery. An error shall be deemed “material” based on a reasonable interpretation of the SEC’s position and policy with regard to materiality, as it may be modified from time to time. The Distributor, and its affiliates shall indemnify the Company for losses arising as a direct result of the Distributor or its affiliates’ error in the calculation of the net asset value of a Fund or the net asset value per share of any Series or Class of Trust shares. Neither the Trust, any Fund, the Distributor, nor any of their affiliates shall be liable for any information provided to the Company pursuant to this Agreement, which information is based on incorrect information supplied by or on behalf of the Company or any other Participating Company to the Trust or the Distributor.

2.8. Limits on Purchasers. The Distributor and the Trust shall sell Trust shares only to insurance companies and their separate accounts and to persons or plans (“Qualified Persons”) that qualify to purchase shares of the Trust under Section 817(h) of the Code and the regulations thereunder without impairing the ability of the Accounts to consider the portfolio investments of the Trust as constituting investments of the Accounts for the purpose of satisfying the diversification requirements of Section 817(h). The Company hereby represents and warrants that it and the Accounts are Qualified Persons. The Distributor and the Trust shall not sell Trust shares to any insurance company or separate account unless an agreement complying with Article VIII of this Agreement is in effect to govern such sales. The Distributor and the Trust shall not sell more than 10% of any Series of Trust shares to any Participating Plan unless an agreement is in effect between the Distributor, the Trust and the trustee (or other fiduciary) of the Plan containing provisions substantially the same as those in

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Article VIII of this Agreement. The Distributor and the Trust shall not sell Trust shares to any Participating Plan unless a written acknowledgment of the foregoing condition is received from the trustee (or other fiduciary) of the Plan.

2.9. Disruptive Trading.

(a) The Trust has adopted policies designed to prevent frequent purchases and redemptions of any Series of Trust shares in quantities great enough to: (i) disrupt orderly management of the corresponding

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Fund’s investment portfolio, or (ii) dilute the value of the outstanding Trust shares of that Series (“Disruptive Trading Policies”). These policies are disclosed in the Trust’s prospectus. From time to time, the Trust and the Distributor implement procedures reasonably designed to enforce the Trust’s Disruptive Trading Policies and shall provide a written description of such procedures (and revisions thereto) to the Company. As a procedure in furtherance of its Disruptive Trading Policies, the Trust may assess fees, to be paid by one or more Accounts or by the Company, upon redemption of one or more Series or Classes of Trust shares within certain stated time periods after such shares have been purchased.

(b) The Company agrees to develop, adopt and maintain policies regarding transactions in Account units reasonably designed to complement the Trust’s Disruptive Trading Policies and, from time to time, to implement procedures regarding transactions in Account units reasonably designed to effectuate the Trust’s procedures for preventing disruptive trading in Trust shares. In particular, in the event that the Trust or the Distributor has identified a particular Contract Owner as having engaged in transactions in Account units that directly or indirectly violate the Trust’s Disruptive Trading Policies, the Company agrees, at the written request of the Trust or the Distributor, to restrict or prohibit further transactions in Account units by that Contract Owner which could result in additional purchases and redemptions of a specified Series and/or Class of Trust shares in violation of the Trust’s Disruptive Trading Policies.

(c) In furtherance of Section 2.9(b), the Trust and the Distributor may, from time to time, investigate purchases and redemptions of any Series or Class of Trust shares by the Company on behalf of the Accounts that appears to violate, or has the potential to violate, the Trust’s Disruptive Trading Policies. When requested by the Trust or the Distributor in writing, the Company agrees to provide the following with respect to purchases and redemptions of a specific Series and/or Class of Trust shares over a designated period.

• the identity of the Contract Owner or Contract Owners whose transactions in Account units underlies the Trust share purchases and redemptions being investigated, • the amounts and dates of transactions in Account units during the designated period representing an indirect investment in the Series and/or Class of Trust shares being investigated, and • the identity of any investment professional known by the Company to be associated with the Contract Owner or Contract Owners.

The Company agrees to provide the foregoing information that is on its books and records promptly. If the requested information is not on its books and records, it agrees to make reasonable efforts to:

• promptly obtain the requested information, or • if requested by the Trust or the Distributor restrict or prohibit further transactions in Account units by that Contract Owner which could result in additional purchases and redemptions of a specified Series and/or Class of Trust shares.

ARTICLE III Representations and Warranties

3.1. Company. The Company represents and warrants that: (a) it is an insur¬ance company duly organized and in good standing under the laws of the jurisdiction of its organization, (b) it has legally and validly established each Account as a segregated asset account under applicable state law to serve as segregated investment accounts for the Contracts, (c) each Schedule 1 Account is duly registered as a unit investment trust under the 1940 Act and each such Account’s 1940 Act Registration Statement has been filed with the SEC in accordance with the 1940 Act, (d) the Schedule 2 Accounts and

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Schedule 3 Accounts each qualify for the exclusions on which they rely for not registering as investment companies under the 1940 Act, (e) it has registered, or will register, all Schedule 1 Contracts offered and sold pursuant to this Agreement under the 1933 Act and has effective Registration Statements for that purpose, (f) it will offer and sell the Contracts in compliance in all material respects with all applicable federal and state laws and regulations, including, but not limited to, state insurance law and federal

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document securities law suitability requirements, (g) the Contracts have been filed, qualified and/or approved for sale, as applicable, under the insurance laws and regulations of the states in which the Contracts will be offered, (h) sales of the Schedule 2 Contracts and Schedule 3 Contracts properly qualify for exemptions on which the Company relies in not registering such Contracts, or interests in the Account through which each is issued, under the 1933 Act, (i) its activities and those of its employees in promoting the sale and distribution of the Contracts and effecting Contract Owner transactions in Account units have not caused, and will not cause, the Company to be deemed a broker-dealer, (j) orders it places for the purchase and redemption of Trust shares pursuant to Article 2.3 of this Agreement are the net result of transactions in units issued by an Account, instructions for which are received by the Company prior to the Trust’s close of business as defined from time to time in the applicable Prospectus for such Series or Class (which as of the date of execution of this Agreement is the close of regular trading on the New York Stock Exchange (normally 4:00 p.m. New York Time)), (k) as long as this Agreement remains in effect, it shall remain in continuous compliance with Article 6.3, Article 6.4 and Article 6.5 of this Agreement and (l) it will notify the Distributor and the Trust promptly if for any reason it is unable to perform its obligations under this Agreement.

3.2. Trust. The Trust represents and warrants that: (a) it is a statutory trust duly organized and validly existing under Delaware law, (b) it is duly registered under the 1940 Act as an open-end management investment company and has filed a 1940 Act Registration Statement with the SEC in accordance with the provisions of the 1940 Act, (c) Trust shares issued pursuant to this Agreement have been, or will be, duly authorized and validly issued in accordance with applicable law, (d) it will offer and sell Trust shares pursuant to this Agreement in compliance in all material respects with all applicable federal and state laws and regulations, (e) it has registered, or will register, all Trust shares offered and sold pursuant to this Agreement under the 1933 Act and has an effective Registration Statement for that purpose, (f) as long as this Agreement remains in effect, it shall remain in continuous compliance with Article 6.1 and Article 6.2 of this Agreement, and (g) the Trust’s Board, a majority of whom are not interested persons of the Trust, have formulated and approved the plan under Rule 12b-1 (“Rule 12b-1 Plan”) to finance distribution expenses.

3.3. Distributor. The Distributor represents and warrants that: (a) it is a limited partnership duly organized and in good standing under New York law, and (b) it is registered as a broker-dealer under federal and applicable state securities laws and is a member of the NASD.

3.4. Legal Authority. Each party represents and warrants that the execution and delivery of this Agreement and the consummation of the transactions contemplated herein have been duly authorized by all necessary corporate, partnership or trust action, as applicable, by such party, and, when so executed and delivered, this Agreement will be the valid and binding obligation of such party enforceable in accordance with its terms.

3.5. Bonding Requirement. Each party represents and warrants that all of its directors, officers, partners and employees dealing with the money and/or securities of the Trust are and shall continue to be at all times covered by a blanket fidelity bond or similar coverage for the benefit of the Trust in an amount not less than the amount required by the applicable rules of the NASD and the federal securities laws. The aforesaid bond shall include coverage for larceny and embezzlement and shall be issued by a reputable bonding company. All parties shall make all reasonable efforts to see that this bond or another bond containing these provisions is always in effect, shall provide evidence thereof promptly to any other party upon written request therefor, and shall notify the other parties promptly in the event that such coverage no longer applies.

ARTICLE IV Regulatory Requirements

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 4.1. Trust Filings. The Trust shall amend the Trust’s Registration Statement from time to time and maintain its effectiveness as required in order to effect the continuous offering of Trust shares in

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document compliance with applicable law. Notwithstanding the foregoing, the Trust shall register and qualify Trust shares for sale in accordance with the laws of various states if, and to the extent, deemed advisable by the Trust or the Distributor. The Trust shall amend its 1940 Act Registration Statement as required by the 1940 Act to maintain its registration under the 1940 Act for as long as Trust shares are outstanding. The Trust shall file Form 24F-2 and pay 1933 Act registration fees for all Series and Classes of Trust shares as required by Rule 24f-2 under the 1940 Act. The Trust shall comply in all material respects with the 1940 Act.

4.2. Account Filings. The Company shall amend the Registration Statement for each Schedule 1 Contract from time to time and maintain its effectiveness as required in order to effect the continuous offering of such Contracts in compliance with applicable law for as long as purchase payments are made under such Contracts. Notwithstanding the foregoing, the Company: (a) may permit the effectiveness of a Schedule 1 Contract’s Registration Statement expire if the Company has supplied the Trust with an SEC “no-action” letter or opinion of counsel satisfactory to the Trust’s counsel to the effect that maintaining such Registration Statement on a current basis is no longer required, and (b) shall register and qualify the Contracts for sale in accordance with the securities laws of the various states only if, and to the extent, it considers such registration and qualification necessary. The Company shall amend each Schedule 1 Account’s 1940 Act Registration Statement as required by the 1940 Act to maintain the Account’s registration under the 1940 Act for as long as the Schedule 1 Contracts issued through that Account are in force. With regard to each Schedule 1 Account, the Company shall comply in all material respects with the 1940 Act.

The Company shall be responsible for filing all Contract forms, applications, marketing materials and other documents relating to the Contracts and/or the Accounts with state insurance commissions, as required or customary, and shall use its best efforts: (a) to obtain any and all approvals thereof, under applicable state insurance law, of each state or other jurisdiction in which Contracts are or may be offered for sale, and (b) to keep such approvals in effect for so long as the Contracts are outstanding.

4.3 Delivery of Prospectuses by the Company. The Company shall deliver (or arrange for delivery of) an appropriate Prospectus to each prospective Contract Owner describing in all material respects the terms and features of the Contract being offered. The Company also shall deliver (or arrange for delivery of) a Prospectus for each Fund that a prospective Contract Owner identifies on his or her application as an intended investment option under a Contract or to which a Contract Owner allocates premium payments to or transfers Contract value. The Company shall deliver (or arrange for delivery of) such Prospectuses at the times required by applicable provisions of the 1933 Act and rules or regulations thereunder.

4.4. Voting of Trust Shares. The extent required by applicable law, whenever the Trust shall have a meeting of holders of any Series or Class of Trust shares, the Company shall:

• solicit voting instructions from Contract Owners

• vote Trust shares held in each Account at such shareholder meetings in accordance with instructions received from Contract Owners, and

• vote Trust shares held in each Account for which it has not received timely instructions in the same proportion as it votes the applicable Series or Class of Trust shares for which it has received timely instructions.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Except with respect to matters as to which the Company has the right in connection with Schedule 1 Contracts under Rule 6e-2 or Rule 6e-3(T) under the 1940 Act, to vote Trust shares without regard to voting instructions from Contract Owners, neither the Company nor any of its affiliates will recommend action in connection with, or oppose or interfere with, the actions of the Trust Board to hold shareholder

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document meetings for the purpose of obtaining approval or disapproval from shareholders (and, indirectly, from Contract Owners) of matters put before the shareholders.

As required by the conditions attaching to the SEC Order, the Company shall remain responsible for ensuring that it calculates voting instructions and votes Trust shares at shareholder meetings in a manner consistent with other Participating Investors. The Trust will notify the Company of any changes to the SEC Order, the conditions attaching thereto, or to any interpretation of the Order or conditions.

4.5. State Insurance Law Restrictions. The Company acknowledges and agrees that it is the responsibility of the Company and other Participating Insurance Companies to determine investment restrictions and any other restrictions, limitations or requirements under state insurance law applicable to any Fund or the Trust or the Distributor, and that neither the Trust nor the Distributor shall bear any responsibility to the Company, other Participating Insurance Companies or any Product Owners for any such determination or the correctness of such determination. The Company shall inform the Trust of any investment restrictions imposed by state insurance law that the Company determines may become applicable to the Trust or a Fund from time to time as a result of the Accounts’ investment therein. Upon receipt of any such information from the Company or any other Participating Insurance Company, the Trust shall determine whether it is in the best interests of shareholders to comply with any such restrictions. If the Trust determines that it is not in the best interests of shareholders (which, for this purpose, shall mean Product Owners) to comply with a restriction determined to be applicable by the Company, the Trust shall so inform the Company, and the Trust and the Company shall discuss alternative accommodations in the circumstances. If the Trust determines that it is in the best interests of shareholders to comply with such restrictions, the Trust and the Company shall amend Schedule 4 to this Agreement to reflect such restrictions, subject to obtaining any required shareholder approval thereof.

4.6. Interpretation of Law. Under no circumstances will the Trust, the Distributor or any of their affiliates (excluding Participating Investors) be held responsible or liable in any respect for any statements or representations made by them or their legal advisers to the Company or any Contract Owner concerning the applicability of any federal or state laws, regulations or other authorities to the activities contemplated by this Agreement.

Under no circumstances will the Company or any of its affiliates be held responsible or liable in any respect for any statements or representations made by them or their legal advisers to the Trust, the Distributor or any of their affiliates (excluding Participating Investors) concerning the applicability of any federal or state laws, regulations or other authorities to the activities contemplated by this Agreement.

4.7. Disclosure. The Trust’s prospectus shall state that the statement of additional information for the Trust is available from either the Distributor or the Trust. The Trust hereby notifies the Company that it is appropriate to include in Contract Prospectuses, disclosure of the potential risks of mixed and shared funding.

4.8. Drafts of Filings. The Trust and the Company shall provide to each other copies of draft versions of any Registration Statements, Prospectuses, Statements of Additional Information, periodic and other shareholder or Contract Owner reports, proxy statements, solicitations for voting instructions, applications for exemptions, requests for no-action letters, and all amendments or supplements to any of the above, prepared by or on behalf of either of them and that mentions the other party by name. Such drafts shall be provided to the other party sufficiently in advance of filing such materials with regulatory authorities in order to allow such other party a reasonable opportunity to review the materials.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 4.9. Copies of Filings. Upon request, the Trust and the Company shall provide to each other at least one complete copy of all Registration Statements, Prospectuses, Statements of Additional Information, periodic and other shareholder or Contract Owner reports, proxy statements, solicitations of voting instructions, applications for exemptions, requests for “no-action” letters, and all amendments or supplements to any of the above, that relate to the Trust, the Contracts or the Accounts, as the case may

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document be, promptly after the filing by or on behalf of each such party of such document with the SEC or other regulatory authorities (it being understood that this provision is not intended to require the Trust to provide to the Company copies of any such documents prepared, filed or used by Participating Investors other than the Company and the Accounts). If the Trust, Distributor or any of their affiliates are named in the filing(s), the Company shall send the filing(s) to the contacts listed in Article XII.

4.10. Regulatory Responses. Upon request, each party shall promptly provide to all other parties copies of responses to no-action requests, notices, orders and other rulings received by such party with respect to any filing covered by Section 4.9 of this Agreement. If the Trust, Distributor or any of their affiliates are named in the regulatory response(s), the Company shall send the regulatory response(s) to the contacts listed in Article XII.

4.11. Complaints and Proceedings

(a) The Trust and/or the Distributor shall immediately notify the Company of: (i) the issuance by any court or regulatory body of any stop order, cease and desist order, or other similar order (but not including an order of a regulatory body exempting or approving a proposed transaction or arrangement) with respect to the Trust’s Registration Statement or the Prospectus of any Series or Class, (ii) any request by the SEC for any amendment to the Trust’s Registration Statement or the Prospectus of any Series or Class, (iii) the initiation of any proceedings for that purpose or for any other purposes relating to the registration or offering of the Trust shares, or (iv) any other action or circumstances that may prevent the lawful offer or sale of Trust shares or any Class or Series in any state or jurisdiction, including, without limitation, any circumstance in which (A) such shares are not registered and, in all material respects, issued and sold in accordance with applicable state and federal law or (B) such law precludes the use of such shares as an underlying investment medium for the Contracts. The Trust will make every reasonable effort to prevent the issuance of any such stop order, cease and desist order or similar order and, if any such order is issued, to obtain the lifting thereof at the earliest possible time.

(b) The Company shall immediately notify the Trust and the Distributor of: (i) the issuance by any court or regulatory body of any stop order, cease and desist order, or other similar order (but not including an order of a regulatory body exempting or approving a proposed transaction or arrangement) with respect to the Contracts’ Registration Statement or the Contracts’ Prospectus, (ii) any request by the SEC for any amendment to the Contracts’ Registration Statement or Prospectus, (iii) the initiation of any proceedings for that purpose or for any other purposes relating to the registration or offering of the Contracts, or (iv) any other action or circumstances that may prevent the lawful offer or sale of the Contracts or any class of Contracts in any state or jurisdiction, including, without limitation, any circumstance in which such Contracts are not registered, qualified and approved, and, in all material respects, issued and sold in accordance with applicable state and federal laws. The Company will make every reasonable effort to prevent the issuance of any such stop order, cease and desist order or similar order and, if any such order is issued, to obtain the lifting thereof at the earliest possible time.

(c) Each party shall immediately notify the other parties when it receives notice, or otherwise becomes aware of, the commencement of any litigation or proceeding against such party or a person affiliated therewith in connection with the issuance or sale of Trust shares or the Contracts if such litigation or proceeding involves a Fund or a Contract in which the Fund is offered.

(d) The Company shall provide to the Trust and the Distributor any complaints it has received from Contract Owners pertaining to the Trust or a Fund, and the Trust and Distributor shall each provide to the Company any complaints it has received from Contract Owners relating to the Contracts.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 4.12. Cooperation. Each party hereto shall cooperate with the other parties and all appropriate government authorities (including without limitation the SEC, the NASD and state securities and insurance regulators) and shall permit such authorities reasonable access to its books and records in connection with any investigation or inquiry by any such authority relating to this Agreement or the

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document transactions contemplated hereby. However, such access shall not extend to attorney-client privileged information.

ARTICLE V Sale, Administration and Servicing of the Contracts

5.1. Sale of the Contracts. The Company shall be fully responsible as to the Trust and the Distributor for the sale and marketing of the Contracts. The Company shall provide Contracts, the Contracts’ and Trust’s Prospectuses, Contracts’ and Trust’s Statements of Additional Information, and all amendments or supplements to any of the foregoing to Contract Owners and prospective Contract Owners, all in accordance with federal and state laws. Without limiting the generality of the foregoing, the Company shall: (1) enter into and enforce agreements with affiliated and unaffiliated parties to, and (2) adopt and implement written compliance policies and procedures reasonably designed to, ensure that:

• all persons offering or selling the Contracts are duly licensed and registered under applicable insurance and securities laws,

• all individuals offering or selling the Contracts are duly appointed agents of the Company and are registered representatives of a NASD member broker-dealer,

• each sale of a Contract satisfies applicable suitability requirements under insurance and securities laws and regulations, including without limitation the rules of the NASD,

• persons offering or selling the Contracts disclose to prospective Contract Owners remuneration each expects to receive in connection with sales of the Contracts and any conflicts of interest arising therefrom as required by applicable law, and

• persons offering or selling the Contracts do not intend to engage in Account unit transactions that would violate the Company’s or the Trust’s Disruptive Trading Policies.

5.2. Anti-Money Laundering. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: • it will have agreements with broker dealers that as part of processing an application for a Contract, the broker dealer will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract,

• it will have agreements with broker dealers that as part of its ongoing compliance with the USA Patriot Act, the broker dealer will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons,

• as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons,

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons,

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document • it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non- cooperating countries or jurisdictions published by the Financial Action Task Force, and

• if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust.

The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

5.3. Administration and Servicing of the Contracts. The Company shall be fully responsible for the underwriting, issuance, service and administration of the Contracts and for the administration of the Account, including, without limitation, the calculation of performance information for the Contracts, the timely payment of Contract Owner redemption requests and processing of Contract transactions, and the maintenance of a service center, such functions to be performed in all respects at a level commensurate with those standards prevailing in the variable insurance industry. The Company shall provide to Contract Owners all Trust reports, solicitations for voting instructions including any related Trust proxy solicitation materials, and updated Trust Prospectuses as required under the federal securities laws.

5.4. Customer Complaints. The Company shall promptly address all complaints from Contract Owners and resolve such complaints consistent with high ethical standards and principles of ethical conduct.

5.5. Trust Prospectuses and Reports. In order to enable the Company to fulfill its obligations under this Agreement and the federal securities laws, the Trust shall provide the Company with a copy, in camera-ready form or form otherwise suitable for printing or duplication of: (a) the Trust’s Prospectus for the Series and Classes listed on Schedules 1B, 2B, and 3B and any supplement thereto; (b) any Trust proxy soliciting material for such Series or Classes; and (c) any Trust periodic shareholder reports. The Trust and the Company may agree upon alternate arrangements, but in all cases, the Trust reserves the right to approve the printing of any such material. The Trust shall make available to the Company on the Trust’s website each Statement of Additional Information and supplement thereto. The Trust shall provide the Company at least 10 days advance written notice when any such material shall become available, provided, however, that in the case of a supplement, the Trust shall provide the Company notice reasonable in the circumstances, it being understood that circumstances surrounding such supplement may not allow for advance notice. The Company may not alter any material so provided by the Trust or the Distributor (including, without limitation, presenting or delivering such material in a different medium such as electronic mail or attachments thereto) without the prior written consent of the Distributor.

5.6. Trust Advertising Material. Neither the Company or any person directly or indirectly authorized by the Company (including, without limitation, underwriters, distributors, and sellers of the Contracts) shall use any piece of advertising, sales literature or other promotional material in which the Trust, the Distributor, or an affiliate of either is named, except with the prior written consent of the Trust or the Distributor. The Trust or the Distributor shall respond to any request for written consent on a prompt and timely basis, but failure to respond shall not relieve the Company of the obligation to obtain the prior written consent of the Trust or the Distributor. After receiving the Trust’s or Distributor’s consent to the use of any such

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document material, no further changes may be made without obtaining the Trust’s or Distributor’s consent to such changes. The Trust or Distributor may at any time in its sole discretion revoke such written consent, and upon notification of such revocation, the Company shall no longer use the material

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document subject to such revocation. The Company shall not be responsible for filing any materials with the FINRA as applicable.

5.7. Contracts Advertising Material. The Trust and the Distributor shall not use any piece of advertising or sales literature or other promotional material in which the Company, an Account or a Contract is named, except with the prior written consent of the Company. The Trust or the Distributor shall furnish to the Company each such piece of advertising, sales literature or other promotional material at least ten (10) days prior to its use. The Company shall respond to any request for written consent on a prompt and timely basis, but failure to respond shall not relieve the Trust or the Distributor of the obligation to obtain the prior written consent of the Company. After receiving the Company’s consent to the use of any such material, no further changes may be made by the Trust or Distributor without obtaining the Company’s consent to such changes. The Company may at any time in its sole discretion revoke any written consent, and upon notification of such revocation, neither the Trust nor the Distributor shall use the material subject to such revocation. The Trust and the Distributor shall not be responsible for filing any such materials with the NASD as applicable.

5.8. Trade Names. No party shall use any other party’s names, logos, trademarks or service marks, whether registered or unregistered, without the prior written consent of such other party, or after written consent therefor has been revoked. The Company shall not use in advertising, publicity or otherwise the name of the Trust, Distributor, or any of their affiliates nor any trade name, trademark, trade device, service mark, symbol or any abbreviation, contraction or simulation thereof of the Trust, Distributor, or their affiliates without the prior written consent of the Trust or the Distributor in each instance.

5.9. Representations by Company. Except with the prior written consent of the Trust, the Company shall not give any information or make any representations or statements about the Trust or the Funds nor shall it authorize or allow any other person to do so except information or representations contained in the Trust’s Registration Statement or the Trust’s Prospectuses or in reports or proxy statements for the Trust, or in advertisements, sales literature or other promotional material approved in writing by the Trust or its designee in accordance with this Article V, or in published reports or statements of the Trust in the public domain.

The Company agrees to ensure that advertisements, sales literature or other promotional material for the Contracts prepared by the Company or its affiliates will be consistent with every law, rule, and regulation of any regulatory agency or self-regulatory agency that applies to the Contracts or to the sale of the Contracts, including, but not limited to, NASD Conduct Rule 2210 and IM-2210-1, IM-2210-2 and IM-2210-3 thereunder.

The Company has adopted and implemented, or shall adopt and implement, written compliance procedures reasonably designed to ensure that information concerning the Trust, the Distributor, or any of their affiliates which is intended for use by brokers or agents selling the Contracts (i.e., information that is not intended for distribution to Contract Owners or prospective Contract Owners) is so used. Neither the Trust, the Distributor, nor any of their affiliates shall be liable for any losses, damages, or expenses relating to the improper use of such “broker only” materials by agents of the Company or its affiliates who are unaffiliated with the Trust or the Distributor. The parties agree that this Section 5.9 is not intended to designate nor otherwise imply that the Company is an underwriter or distributor of the Trust’s shares.

5.10. Representations by Trust. Except with the prior written consent of the Company, the Trust shall not give any information or make any representations on behalf of the Company or concerning the Company, the Accounts or the Contracts other than the information or representations contained in the appropriate Contract Registration Statement or Contract Prospectus or in published reports of the Company or the Accounts which are in the public domain or in

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document advertisements, sales literature or other promotional material approved in writing by the Company in accordance with this Article V.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document The Trust agrees to ensure that advertisements, sales literature or other promotional material for the Trust prepared by the Distributor or its affiliates in connection with the sale of the Contracts will be consistent with every law, rule, and Regulation of any regulatory agency or self regulatory agency that applies to the Trust or to the sale of Trust shares, including, but not limited to, NASD Conduct Rule 2210 and IM-2210-1, IM-2210-2 and IM-2210-3 thereunder.

The Trust or the Distributor shall mark information produced by or on behalf of the Trust which is intended for use by brokers or agents selling the Contracts (i.e., information that is not intended for distribution to Contract Owners or prospective Contract Owners) “FOR BROKER USE ONLY,” and neither the Company nor any of its affiliates shall be liable for any losses, damages, or expenses arising on account of the use by brokers of such information with third parties in the event that it is not so marked.

5.11. Advertising. For purposes of this Article V, the phrase “advertising, sales literature or other promotional material” includes, but is not limited to, any material constituting sales literature or advertising under the NASD Conduct rules, the 1940 Act or the 1933 Act. Such material includes, without limitation, the following materials for prospective Contract Owners, existing Contract Owners, wholesalers and other broker-dealers, rating or ranking agencies, or the press:

• advertisements (such as material published, or designed for use in, a newspaper, magazine, or other periodical, radio, television, telephone or tape recording, videotape display, signs or billboards, motion pictures, websites, or other public media),

• sales literature (i.e., any written communication distributed or made generally available to customers or the public, including brochures, circulars, research reports, market letters, form letters, seminar texts, reprints or excerpts of any other advertisement, sales literature, electronic mail, or published article),

• educational or training materials or other communications distributed or made generally available to some or all agents or employees, and

• registration statements, prospectuses, statements of additional information, shareholder reports, and proxy materials.

ARTICLE VI Compliance with Code

6.1. Section 817(h). The Trust will at all times invest money from the Contracts in such a manner as to ensure that the Contracts will be treated as variable contracts the Code and regulations thereunder. Without limiting the scope of the foregoing, the Trust shall ensure that each Fund will comply with Section 817(h) of the Code and Treasury Regulation 1.817-5 thereunder, relating to the diversification requirements for variable annuity, endowment, or life insurance contracts, and any amendments or other modifications to such Section and Regulation or successors thereto. The Trust shall notify the Company immediately upon having a reasonable basis for believing that a Fund has failed to so comply or that it might not comply in the future.

6.2. Subchapter M. The Trust shall maintain the qualification of each Fund as a regulated investment company (under Subchapter M or any successor or similar provision), and the Trust shall notify the Company immediately upon having a reasonable basis for believing that a Fund has ceased to so qualify or that it might not so qualify in the future.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 6.3. Contracts. The Company shall ensure that at the time each Contract is issued it is treated as a life insurance, endowment, or annuity contract under applicable provisions of the Code, and that as long as the Accounts hold shares of the Trust the Company shall maintain such treatment for each outstanding Contract. The Company shall notify the Trust and the Distributor immediately upon having any basis for

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document believing that the Contracts will not be treated as life insurance, endowment, or annuity contracts under applicable provisions of the Code.

6.4 Regulation 1.817-5(f). The Company shall ensure that no Fund fails to remain eligible for “look-through” treatment under Treasury Regulation 1.817-5(f) by reason of a current or future failure of the Company, the Accounts or the Contracts to comply with any applicable requirements of the Code or Treasury Regulations. The Company shall notify the Trust and the Distributor immediately upon having any basis for believing that the failure of the Company, the Accounts or the Contracts to comply with any applicable requirements of the Code or Treasury Regulations could render a Fund ineligible, or jeopardize a Fund’s eligibility, for “look-through” treatment under Treasury Regulation 1.817-5(f). In the event of such a failure, the Company shall take all necessary steps to cure any such failure, including, if necessary, obtaining a waiver or closing agreement with respect to such failure from the U.S. Internal Revenue Service at the Company’s expense.

6.5 Modified Endowment Contracts. The Company shall ensure that any Prospectus offering a variable life insurance Contract in circumstances where it is reasonably probable that such Contract would be a “modified endowment contract,” as that term is defined in Section 7702A of the Internal Revenue Code, will identify such Contract as a modified endowment contract.

ARTICLE VII Expenses

7.1. Expenses. All expenses incident to each party’s performance under this Agreement (including expenses expressly assumed by such party pursuant to this Agreement) shall be paid by such party to the extent permitted by law.

7.2. Trust Expenses. Expenses incident to the Trust’s performance of its duties and obligations under this Agreement include, but are not limited to, the costs of:

(a) registration and qualification of the Trust shares under the federal securities laws;

(b) preparation and filing with the SEC of the Trust’s Prospectuses, Trust’s Statement of Additional Information, Trust’s Registration Statement, Trust proxy materials and shareholder reports, and preparation of a “camera-ready” copy of the foregoing;

(d) printing of all proxy materials, shareholder reports, prospectuses and other documents required to be provided by the Trust to its existing shareholders, and providing sufficient copies of the same to the Company for distribution to Contract Owners currently invested in the Trust; provided, however, that if the Company prints copies of the Trust’s prospectus (or portions thereof) as part of a larger document containing prospectuses of other investment companies, the Trust shall bear the expense only of its share of the cost of printing the document (for this purpose, the Trust’s share shall be the percentage of the total cost of the document represented by the ratio that the number of pages of the Trust’s prospectus bears to the total number of pages);

(e) all taxes on the issuance or transfer of Trust shares;

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (f) payment of all applicable fees relating to the Trust, including, without limitation, all fees due under Rule 24f-2 in connection with sales of Trust shares to qualified retirement plans, custodial, auditing, transfer agent and advisory fees, fees for insurance coverage and Trustees’ fees;

(g) any expenses permitted to be paid or assumed by the Trust pursuant to a Rule 12b-1 under the 1940 Act; and

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (h) solicitation of voting instructions, including distribution of Trust proxy materials to Contract Owners.

7.3. Company Expenses. Expenses incident to the Company’s performance of its duties and obligations under this Agreement include, but are not limited to, the costs of:

(a) registration and qualification of the Schedule 1 Contracts under the federal securities laws;

(b) preparation Contract Prospectuses, and filing with the SEC of the Prospectuses and Registration Statements for Schedule 1 Contracts;

(c) the sale, marketing and distribution of the Contracts, including printing and dissemination of Contract Prospectuses to current and prospective Contract owners [and of the Trust’s Prospectuses to prospective Contract Owners] as well as compensation for Contract sales;

(d) administration of the Contracts;

(e) payment of all applicable fees relating to Accounts and the Contracts;

(f) preparation, printing and dissemination of all statements and notices to Contract Owners required by any federal or state insurance law other than those paid for by the Trust; and

(g) preparation, printing and dissemination of all marketing materials for the Contracts and Trust except where other arrangements are made in advance.

7.4. Other Expenses and Payments. The Trust and the Distributor shall pay no fee or other compensation to the Company under this Agreement. Each party, however, shall, in accordance with the allocation of expenses specified in this Agreement, reimburse other parties for expenses paid by such other parties, but allocated to it. In addition, nothing herein shall prevent the parties from otherwise agreeing to perform, and arranging for appropriate compensation for, other services relating to the Trust, the Distributor, the Company or the Accounts. Notwithstanding the foregoing, pursuant to the distribution plan adopted by the Trust under Rule 12b-1 under the 1940 Act, and as contemplated by Article 3.2(g) of this Agreement, the Trust or any Series or Class thereof may pay the Distributor, and the Distributor may pay the principal underwriter or distributor of one or more classes of Contracts, for activities primarily intended to result in the sale of Trust shares to the Accounts through which such Contracts are issued. Likewise, if the Trust or any Series or Class adopts and implements a shareholder service plan pursuant to Rule 12b-1 under the 1940 Act, or otherwise, then the Trust or the appropriate Series or Class may pay the Distributor and the Distributor may pay the principal underwriter or distributor of one or more classes of Contracts, or the Company, for activities related to personal service and/or maintenance of Contract Owner accounts, as permitted by such plan.

ARTICLE VIII Potential Conflicts

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 8.1. SEC Order. The parties to this Agreement acknowledge that the Trust has obtained the SEC Order granting exemptions from various provisions of the 1940 Act and the rules thereunder to Participant Accounts supporting variable life insurance policies to the extent necessary to permit them to hold Trust shares when Trust share also are sold to and held by variable annuity and variable life insurance separate accounts of both affiliated and unaffiliated Participating Insurance Companies and other Qualified Persons (as defined in Section 2.8 hereof). The SEC Order is conditioned upon the Trust and each Participating Insurance Company complying with conditions and undertakings substantially as provided in this Article VIII. The Trust will not enter into a participation agreement with any other Participating Insurance

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document Company unless it imposes the same conditions and undertakings on that company as are imposed on the Company pursuant to this Article VIII.

8.2. Company Monitoring Requirements. The Company will monitor its operations and those of the Trust for the purpose of identifying any material irreconcilable conflicts or potential material irreconcilable conflicts between or among the interests of Participating Plans, Product Owners of variable life insurance policies and Product Owners of variable annuity contracts. 8.3. Company Reporting Requirements. The Company shall report any conflicts or potential conflicts to the Trust Board and will provide the Trust Board, at least annually, with all information reasonably necessary for the Trust Board to consider any issues raised by such existing or potential conflicts or by the conditions and undertakings required by the Exemptive Order. The Company also shall assist the Trust Board in carrying out its obligations including, but not limited to: (a) informing the Trust Board whenever it disregards Contract Owner voting instructions with respect to variable life insurance policies, and (b) providing such other information and reports as the Trust Board may reasonably request. The Company will carry out these obligations with a view only to the interests of Contract Owners.

8.4. Trust Board Monitoring and Determination. The Trust Board shall monitor the Trust for the existence of any material irreconcilable conflicts between or among the interests of Participating Plans, Product Owners of variable life insurance policies and Product Owners of variable annuity contracts and determine what action, if any, should be taken in response to those conflicts. A majority vote of Trustees who are not interested persons of the Trust as defined in the 1940 Act (the “disinterested trustees”) shall represent a conclusive determination as to the existence of a material irreconcilable conflict between or among the interests of Product Owners and Participating Plans and as to whether any proposed action adequately remedies any material irreconcilable conflict. The Trust Board shall give prompt written notice to the Company and Participating Plan of any such determination. Minutes of the meetings of the Trust Board, or other appropriate records of the Trust, shall record all reports received by the Board regarding such conflicts and all actions taken by the Board in response.

8.5. Undertaking to Resolve Conflict. In the event that a material irreconcilable conflict of interest arises between Product Owners of variable life insurance policies or Product Owners of variable annuity contracts and Participating Plans, the Company will, at its own expense, take whatever action is necessary to remedy such conflict as it adversely affects Contract Owners up to and including: (1) establishing a new registered management investment company, and (2) withdrawing assets from the Trust attributable to reserves for the Contracts subject to the conflict and reinvesting such assets in a different investment medium (including another Fund) or submitting the question of whether such withdrawal should be implemented to a vote of all affected Contract Owners, and, as appropriate, segregating the assets supporting the Contracts of any group of such owners that votes in favor of such withdrawal, or offering to such owners the option of making such a change. The Company will carry out the responsibility to take the foregoing action with a view only to the interests of Contract Owners.

8.6. Withdrawal. If a material irreconcilable conflict arises because of the Company’s decision to disregard the voting instructions of Contract Owners of variable life insurance policies and that decision represents a minority position or would preclude a majority vote at any Fund shareholder meeting, then, if Trust Board so requests, the Company will redeem the shares of the Trust to which the disregarded voting instructions relate [and terminate this Agreement with respect to the Account through which such Contracts were issued]. No charge or penalty, however, will be imposed in connection with such a redemption.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 8.7. Expenses Associated with Remedial Action. In no event shall the Trust be required to bear the expense of establishing a new funding medium for any Contract. The Company shall not be required by this Article VIII to establish a new funding medium for any Contract if an offer to do so has been declined by vote of a majority of the Contract Owners materially adversely affected by the irreconcilable material conflict.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document 8.8. Successor Rules. If and to the extent that Rule 6e-2 and Rule 6e-3(T) are amended, or Rule 6e-3 is adopted, to provide exemptive relief from any provisions of the 1940 Act or the rules promulgated thereunder with respect to mixed and shared funding on terms and conditions materially different from those contained in the SEC Order, then: (a) the Trust and/ or the Company, as appropriate, shall take such steps as may be necessary to comply with Rules 6e-2 and 6e-3(T), as amended, or Rule 6e-3, as adopted, as applicable, to the extent such rules are applicable, and (b) Sections 8.2 through 8.7 of this Agreement shall continue in effect only to the extent that terms and conditions substantially identical to such Sections are contained in such Rule(s) as so amended or adopted.

ARTICLE IX Indemnification

9.1. Indemnification by the Company. The Company hereby agrees to, and shall, indemnify and hold harmless the Trust, the Distributor and each person who controls or is affiliated with the Trust or the Distributor within the meaning of such terms under the 1933 Act or 1940 Act (but not any Participating Insurance Companies or Qualified Persons) and any officer, trustee, partner, director, employee or agent of the foregoing, against any and all losses, claims, damages or liabilities, joint or several (including any investigative, legal and other expenses reasonably incurred in connection with, and any amounts paid in settlement of, any action, suit or proceeding or any claim asserted), to which they or any of them may become subject under any statute or regulation, at common law or otherwise, insofar as such losses, claims, damages, expenses or liabilities:

(a) arise out of or are based upon any untrue statement of any material fact or alleged untrue statement of material fact contained in the Contracts Registration Statement, Contracts Prospectus, sales literature or other promotional material for the Contracts or the Contracts themselves (or any amendment or supplement to any of the foregoing), or arise out of or are based upon the omission to state therein a material fact required to be stated therein or necessary to make the statements therein not misleading in light of the circumstances in which they were made; provided that this obligation to indemnify shall not apply if such statement or omission was made in reliance upon and in conformity with information furnished in writing to the Company by the Trust or the Distributor for use in the Contracts Registration Statement, Contracts Prospectus or in the Contracts or sales literature or promotional material for the Contracts (or any amendment or supplement to any of the foregoing) or otherwise for use in connection with the sale of the Contracts or Trust shares; or

(b) arise out of any untrue statement or alleged untrue statement of a material fact contained in the Trust Registration Statement, any Prospectus for Series or Classes or sales literature or other promotional material of the Trust (or any amendment or supplement to any of the foregoing), or the omission to state therein a material fact required to be stated therein or necessary to make the statements therein not misleading in light of the circumstances in which they were made, if such statement or omission was made in reliance upon and in conformity with information furnished to the Trust or Distributor in writing by or on behalf of the Company; or

(c) arise out of or are based upon any wrongful conduct of, or violation of federal or state law by, the Company or persons under its control or subject to its authorization, including without limitation, any broker-dealers or agents authorized to sell the Contracts, with respect to the sale, marketing or distribution of the Contracts or Trust shares, including, without limitation, any impermissible use of broker-only material, unsuitable or improper sales of the Contracts or unauthorized representations about the Contracts or the Trust; or

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (d) arise as a result of any failure by the Company or persons under its control (or subject to its authorization) to provide services, furnish materials or make payments as required under this Agreement; or

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (e) arise out of any material breach by the Company or persons under its control (or subject to its authorization) of this Agreement; or

(f) any breach of any warranties contained in Article III hereof, any failure to transmit a request for redemption or purchase of Trust shares or payment therefore on a timely basis in accordance with the procedures set forth in Article II, or any unauthorized use of the names or trade names of the Trust or the Distributor.

This indemnification is in addition to any liability that the Company may otherwise have; provided, however, that no party shall be entitled to indemnification if such loss, claim, damage, expense or liability is caused by the wilful misfeasance, bad faith, gross negligence or reckless disregard of duty by the party seeking indemnification.

9.2. Indemnification by the Trust. The Trust hereby agrees to, and shall, indemnify and hold harmless the Company and each person who controls or is affiliated with the Company within the meaning of such terms under the 1933 Act or 1940 Act and any officer, director, employee or agent of the foregoing, against any and all losses, claims, damages or liabilities, joint or several (including any investigative, legal and other expenses reasonably incurred in connection with, and any amounts paid in settlement of, any action, suit or proceeding or any claim asserted), to which they or any of them may become subject under any statute or regulation, at common law or otherwise, insofar as such losses, claims, damages, expenses or liabilities:

(a) arise out of or are based upon any untrue statement of any material fact or alleged untrue statement of material fact contained in the Trust Registration Statement, any Prospectus for Series or Classes or sales literature or other promotional material of the Trust (or any amendment or supplement to any of the foregoing), or arise out of or are based upon the omission to state therein a material fact required to be stated therein or necessary to make the statements therein not misleading in light of the circumstances in which they were made; provided that this obligation to indemnify shall not apply if such statement or omission was made in reliance upon and in conformity with information furnished in writing by the Company to the Trust or the Distributor for use in the Trust Registration Statement, Trust Prospectus or sales literature or promotional material for the Trust (or any amendment or supplement to any of the foregoing) or otherwise for use in connection with the sale of the Contracts or Trust shares; or

(b) arise out of any untrue statement of a material fact or alleged untrue statement of material fact contained in the Contracts Registration Statement, Contracts Prospectus or sales literature or other promotional material for the Contracts (or any amendment or supplement to any of the foregoing), or the omission to state therein a material fact required to be stated therein or necessary to make the statements therein not misleading in light of the circumstances in which they were made, if such statement or omission was made in reliance upon information furnished in writing by the Trust to the Company; or

(c) arise out of or are based upon wrongful conduct of the Trust or its Trustees or officers with respect to the sale of Trust shares; or

(d) arise as a result of any failure by the Trust to provide services, furnish materials or make payments as required under the terms of this Agreement; or

(e) arise out of any material breach by the Trust of this Agreement (including any breach of Section 6.1 of this Agreement and any warranties contained in Article III hereof); or

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (f) arise out of any unauthorized use of the names or trade names of the Company. it being understood that in no way shall the Trust be liable to the Company with respect to any violation of insurance law, compliance with which is a responsibility of the Company under this Agreement or

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document otherwise or as to which the Company failed to inform the Trust in accordance with Section 4.5 hereof. This indemnification is in addition to any liability that the Trust may otherwise have; provided, however, that no party shall be entitled to indemnification if such loss, claim, damage or liability is caused by the willful misfeasance, bad faith, gross negligence or reckless disregard of duty by the party seeking indemnification.

9.3. Indemnification by the Distributor. The Distributor hereby agrees to, and shall, indemnify and hold harmless the Company and each person who controls or is affiliated with the Company within the meaning of such terms under the 1933 Act or 1940 Act and any officer, director, employee or agent of the foregoing, against any and all losses, claims, damages or liabilities, joint or several (including any investigative, legal and other expenses reasonably incurred in connection with, and any amounts paid in settlement of, any action, suit or proceeding or any claim asserted), to which they or any of them may become subject under any statute or regulation, at common law or otherwise, insofar as such losses, claims, damages, expenses or liabilities:

(a) arise out of or are based upon any untrue statement of any material fact or alleged untrue statement of material fact contained in the Trust Registration Statement, any Prospectus for Series or Classes or sales literature or other promotional material of the Trust (or any amendment or supplement to any of the foregoing), or arise out of or are based upon the omission to state therein a material fact required to be stated therein or necessary to make the statements therein not misleading in light of the circumstances in which they were made; provided that this obligation to indemnify shall not apply if such statement or omission was made in reliance upon and in conformity with information furnished in writing by the Company to the Trust or Distributor for use in the Trust Registration Statement, Trust Prospectus or sales literature or promotional material for the Trust (or any amendment or supplement to any of the foregoing) or otherwise for use in connection with the sale of the Contracts or Trust shares; or

(c) arise out of or are based upon wrongful conduct of the Distributor or persons under its control with respect to the sale of Trust shares; or

(d) arise as a result of any failure by the Distributor or persons under its control to provide services, furnish materials or make payments as required under the terms of this Agreement; or

(e) arise out of any material breach by the Distributor or persons under its control of this Agreement (including any breach of Section 6.1 of this Agreement and any warranties contained in Article III hereof); it being understood that in no way shall the Distributor be liable to the Company with respect to any violation of insurance law, compliance with which is a responsibility of the Company under this Agreement or otherwise or as to which the Company failed to inform the Distributor in accordance with Section 4.5 hereof. This indemnification is in addition to any liability that the Distributor may otherwise have; provided, however, that no party shall be entitled to indemnification if such

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document loss, claim, damage or liability is caused by the willful misfeasance, bad faith, gross negligence or reckless disregard of duty by the party seeking indemnification.

9.4. Rule of Construction. It is the parties’ intention that, in the event of an occurrence for which the Trust has agreed to indemnify the Company, the Company shall seek indemnification from the Trust only

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document in circumstances in which the Trust is entitled to seek indemnification from a third party with respect to the same event or cause thereof.

9.5. Indemnification Procedures. After receipt by a party entitled to indemnification (“indemnified party”) under this Article IX of notice of the commencement of any action, if a claim in respect thereof is to be made by the indemnified party against any person obligated to provide indemnification under this Article IX (“indemnifying party”), such indemnified party will notify the indemnifying party in writing of the commencement thereof as soon as practicable thereafter, provided that the omission to so notify the indemnifying party will not relieve it from any liability under this Article IX, except to the extent that the omission results in a failure of actual notice to the indemnifying party and such indemnifying party is damaged solely as a result of the failure to give such notice. The indemnifying party, upon the request of the indemnified party, shall retain counsel reasonably satisfactory to the indemnified party to represent the indemnified party and any others the indemnifying party may designate in such proceeding and shall pay the reasonable fees and disbursements of such counsel related to such proceeding. In any such proceeding, any indemnified party shall have the right to retain its own counsel, but the fees and expenses of such counsel shall be at the expense of such indemnified party unless (i) the indemnifying party and the indemnified party shall have mutually agreed to the retention of such counsel or (ii) the named parties to any such proceeding (including any impleaded parties) include both the indemnifying party and the indemnified party and representation of both parties by the same counsel would be inappropriate due to actual or potential differing interests between them. The indemnifying party shall not be liable for any settlement of any proceeding effected without its written consent but if settled with such consent or if there be a final judgment for the plaintiff, the indemnifying party agrees to indemnify the indemnified party from and against any loss or liability by reason of such settlement or judgment.

A successor by law of the parties to this Agreement shall be entitled to the benefits of the indemnification contained in this Article IX. The indemnification provisions contained in this Article IX shall survive any termination of this Agreement.

ARTICLE X Relationship of the Parties; Termination

10.1. Relationship of Parties. The Company is to be an independent contractor vis-a-vis the Trust, the Distributor, or any of their affiliates for all purposes hereunder and will have no authority to act for or represent any of them (except to the limited extent the Company acts as agent of the Trust pursuant to Section 2.3(a) of this Agreement). In addition, no officer or employee of the Company will be deemed to be an employee or agent of the Trust, Distributor, or any of their affiliates. The Company will not act as an “underwriter” or “distributor” of the Trust, as those terms variously are used in the 1940 Act, the 1933 Act, and rules and regulations promulgated thereunder. Likewise, the Company is not a “transfer agent” of the Trust as that term is used in the 1934 Act and rules and regulations thereunder. Consistent with the foregoing, the Company is not a “service provider” to the Trust as that term is defined in Rule 38a-1 under the 1940 Act.

10.2. Non-Exclusivity and Non-Interference. The parties hereto acknowledge that the arrangement contemplated by this Agreement is not exclusive; the Trust shares may be sold to other insurance companies and investors (subject to Section 2.8 hereof) and the cash value of the Contracts may be invested in other investment companies, provided, however, that until this Agreement is terminated pursuant to this Article X:

(a) the Company shall promote the Trust and the Funds made available hereunder on the same basis as other funding vehicles available under the Contracts;

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (b) the Company shall not, without prior notice to the Distributor (unless otherwise required by applicable law), take any action to operate the Account as a management investment company under the 1940 Act;

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (c) the Company shall not, without the prior written consent of the Distributor (unless otherwise required by applicable law), solicit, induce or encourage Contract Owners to change or modify the Trust to change the Trust’s distributor or investment adviser, to transfer or withdraw Contract Values allocated to a Fund, or to exchange their Contracts for contracts not allowing for investment in the Trust;

(d) the Company shall not substitute another investment company for one or more Funds without providing written notice to the Distributor at least 60 days in advance of effecting any such substitution; and

(e) the Company shall not withdraw the Account’s investment in the Trust or a Fund of the Trust except as necessary to facilitate Contract Owner requests and routine Contract processing.

10.3. Termination of Agreement. This Agreement shall not terminate until: (a) the Trust is dissolved, liquidated, or merged into another entity, or (b) as to any Fund that has been made available hereunder, the Account no longer invests in that Fund and the Company has confirmed in writing to the Distributor, if so requested by the Distributor, that it no longer intends to invest in such Fund. However, certain obligations of, or restrictions on, the parties to this Agreement may terminate as provided in Sections 10.4 through 10.6 and the Company may be required to redeem Trust shares pursuant to Section 10.7 or in the circumstances contemplated by Article VIII. Article IX and Sections 5.7 and 10.8 shall survive any termination of this Agreement.

10.4. Termination of Offering of Trust Shares. The obligation of the Trust and the Distributor to make Trust shares available to the Company for purchase pursuant to Article II of this Agreement shall terminate at the option of the Distributor upon written notice to the Company as provided below:

(a) upon institution of formal proceedings against the Company, or the Distributor’s reasonable determination that institution of such proceedings is being considered by the NASD, the SEC, the insurance commission of any state or any other regulatory body regarding the Company’s duties under this Agreement or related to the sale of the Contracts, the operation of the Account, the administration of the Contracts or the purchase of Trust shares, or an expected or anticipated ruling, judgment or outcome which would, in the Distributor’s reasonable judgment exercised in good faith, materially impair the Company’s or Trust’s ability to meet and perform the Company’s or Trust’s obligations and duties hereunder, such termination effective upon 15 days prior written notice;

(b) in the event any of the Contracts are not registered, issued or sold in accordance with applicable federal and/or state law, such termination effective immediately upon receipt of written notice;

(c) if the Distributor shall determine, in its sole judgment exercised in good faith, that either (1) the Company shall have suffered a material adverse change in its business or financial condition or (2) the Company shall have been the subject of material adverse publicity which is likely to have a material adverse impact upon the business and operations of either the Trust or the Distributor, such termination effective upon 30 days prior written notice;

(d) if the Distributor suspends or terminates the offering of Trust shares of any Series or Class to all Participating Investors or only designated Participating Investors, if such action is required by law or by regulatory authorities having jurisdiction or if, in the sole discretion of the Distributor acting in good faith, suspension or termination is necessary in the best interests of the share¬holders of any Series or Class (it being understood that “shareholders” for this purpose shall

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document mean Product Owners), such notice effective immediately upon receipt of written notice, it being understood that a lack of Participating Investor interest in a Series or Class may be grounds for a suspension or termination as to such Series or Class and that a suspension or termination shall apply only to the specified Series or Class;

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (e) upon the Company’s assignment of this Agreement (including, without limitation, any transfer of the Contracts or the Account to another insurance company pursuant to an assumption reinsurance agreement) unless the Trust consents thereto, such termination effective upon 30 days prior written notice;

(f) if the Company is in material breach of any provision of this Agreement, which breach has not been cured to the satisfaction of the Trust within 10 days after written notice of such breach has been delivered to the Company, such termination effective upon expiration of such 10-day period; or

(g) upon the determination of the Trust’s Board to dissolve, liquidate or merge the Trust as contemplated by Section 10.3(a), upon termination of the Agreement pursuant to Section 10.3(b), or upon notice from the Company pursuant to Section 10.5 or 10.6, such termination pursuant hereto to be effective upon 15 days prior written notice.

Except in the case of an option exercised under clause (b), (d) or (g), the obligations shall terminate only as to new Contracts and the Distributor shall continue to make Trust shares available to the extent necessary to permit owners of Contracts in effect on the effective date of such termination (hereinafter referred to as “Existing Contracts”) to reallocate investments in the Trust, redeem investments in the Trust and/or invest in the Trust upon the making of additional purchase payments under the Existing Contracts.

10.5. Termination of Investment in a Fund. The Company may elect to cease investing in a Fund, or withdraw its investment or the Account’s investment in a Fund, subject to compliance with applicable law, upon written notice to the Trust within 15 days of the occurrence of any of the following events (unless provided otherwise below):

(a) if the Trust informs the Company pursuant to Section 4.4 that it will not cause such Fund to comply with investment restrictions as requested by the Company and the Trust and the Company are unable to agree upon any reasonable alternative accommodations;

(b) if shares in such Fund are not reasonably available to meet the requirements of the Contracts as determined by the Company (including any non-availability as a result of notice given by the Distributor pursuant to Section 10.4(d)), and the Distributor, after receiving written notice from the Company of such non-availability, fails to make available, within 10 days after receipt of such notice, a sufficient number of shares in such Fund or an alternate Fund to meet the requirements of the Contracts; or

(c) if such Fund fails to meet the diversification requirements specified in Section 817(h) of the Code and any regulations thereunder and the Trust, upon written request, fails to provide reasonable assurance that it will take action to cure or correct such failure;

Such termination shall apply only as to the affected Fund and shall not apply to any other Fund in which the Company or the Account invests.

10.6. Termination of Investment by the Company. The Company may elect to cease investing in all Series or Classes of the Trust made available hereunder, or withdraw its investment or the Accounts’ investment in the Trust, subject to compliance with applicable law, upon written notice to the Trust within 15 days of the occurrence of any of the following events (unless provided otherwise below):

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (a) upon institution of formal proceedings against the Trust or the Distributor (but only with regard to the Trust) by the NASD, the SEC or any state securities or insurance commission or any other regulatory body;

(b) if, with respect to the Trust or a Fund, the Trust or the Fund ceases to qualify as a regulated investment company under Subchapter M of the Code, as defined therein, or any successor or similar provision, or if the Company reasonably believes that the Trust may fail to so qualify, and the Trust, upon

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document written request, fails to provide reasonable assurance that it will take action to cure or correct such failure within 30 days; or

(c) if the Trust or Distributor is in material breach of a provision of this Agreement, which breach has not been cured to the satisfaction of the Company within 10 days after written notice of such breach has been delivered to the Trust or the Distributor, as the case may be.

Notwithstanding the foregoing, the Company may elect to cease promoting the Trust as an investment option under any newly issued Contract at its sole discretion.

10.7. Company Required to Redeem. The parties understand and acknowledge that it is essential for compliance with Section 817(h) of the Code that the Contracts qualify as annuity contracts or life insurance policies, as applicable, under the Code. Accordingly, if any of the Contracts cease to qualify as annuity contracts or life insurance policies, as applicable, under the Code, or if the Trust reasonably believes that any such Contracts may fail to so qualify, the Trust shall have the right to require the Company to redeem Trust shares attributable to such Contracts upon notice to the Company and the Company shall so redeem such Trust shares in order to ensure that the Trust complies with the provisions of Section 817(h) of the Code applicable to ownership of Trust shares. Notice to the Company shall specify the period of time the Company has to redeem the Trust shares or to make other arrangements satisfactory to the Trust and its counsel, such period of time to be determined with reference to the requirements of Section 817(h) of the Code. In addition, the Company may be required to redeem Trust shares pursuant to action taken or request made by the Trust Board in accordance with the Exemptive Order described in Article VIII or any conditions or undertakings set forth or referenced therein, or other SEC rule, regulation or order that may be adopted after the date hereof. The Company agrees to redeem shares in the circumstances described herein and to comply with applicable terms and provisions. Also, in the event that the Distributor suspends or terminates the offering of a Series or Class pursuant to Section 10.4(d) of this Agreement, the Company, upon request by the Distributor, will cooperate in taking appropriate action to withdraw the Account’s investment in the respective Fund.

10.8. Confidentiality. The parties agree that the names, addresses, and other information relating to the Contract owners or participants or prospects for the sale of the Contracts developed by Company are the exclusive property of the Company and may not be used by Distributor or the Funds without the written consent of the Company except for carrying out the terms of this Agreement or as otherwise provided for in this Agreement and any amendments thereto. Each party to this Agreement agrees to maintain the confidentiality of all information (including personal financial information of the customers of either party, and/or information regarding the business and affairs of the other party) received from the other party pursuant to this Agreement. Each party agrees not to use any such information for any purpose, or disclose any such information to any person, except as permitted or required by applicable laws, rules and regulations, including the Gramm- Leach-Bliley Act and any regulations promulgated thereunder.

ARTICLE XI Applicability to New Accounts and New Contracts

The parties to this Agreement may amend the schedules to this Agreement from time to time to reflect, as appropriate, changes in or relating to the Contracts, any Series or Class, additions of new classes of Contracts to be issued by the Company and Accounts therefor investing in the Trust. Such amendments may be made effective by executing the form of amendment included on each schedule attached hereto. The provisions of this Agreement shall be equally applicable to each such class of Contracts, Series, Class or separate account, as applicable, effective as of the date of amendment of

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document such Schedule, unless the context otherwise requires. The parties to this Agreement may amend this Agreement from time to time by written agreement signed by all of the parties.

ARTICLE XII

Any notice, request or consent to be provided pursuant to this Agreement is to be made in writing and shall be given:

If to the Trust:

Peter V. Bonanno Secretary Goldman Sachs Variable Insurance Trust One New York Plaza 37th Floor New York, NY 10004

If to the Distributor:

Sara Cunningham Goldman Sachs & Co. 32 Old Slip 31st Floor New York, NY 10005

If to the Company: Legal Department Symetra Life Insurance Company 777 108th Ave NE, Suite 1200 Legal SC-11 Bellevue, WA 98004 or at such other address as such party may from time to time specify in writing to the other party. Each such notice, request or consent to a party shall be sent by registered or certified United States mail with return receipt requested or by overnight delivery with a nationally recognized courier, and shall be effective upon receipt. Notices pursuant to the provisions of Article II may be sent by facsimile to the person designated in writing for such notices.

ARTICLE XIII Miscellaneous

13.1. Interpretation. This Agreement shall be construed and the provi¬sions hereof interpreted under and in accordance with the laws of the state of Delaware, without giving effect to the principles of conflicts of laws, subject to the following rules:

(a) This Agreement shall be subject to the provisions of the 1933 Act, 1940 Act and Securities Exchange Act of 1934, as amended, and the rules, regulations and rulings thereunder, including such exemptions from those statutes, rules, and regulations as the SEC may grant, and the terms hereof shall be limited, interpreted and construed in accordance therewith.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (b) The captions in this Agreement are included for convenience of reference only and in no way define or delineate any of the provisions hereof or otherwise affect their construction or effect.

(c) If any provision of this Agreement shall be held or made invalid by a court decision, statute, rule or otherwise, the remainder of the Agreement shall not be affected thereby.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document (d) The rights, remedies and obligations contained in this Agreement are cumulative and are in addition to any and all rights, remedies and obligations, at law or in equity, which the parties hereto are entitled to under state and federal laws.

13.2. Counterparts. This Agreement may be executed simultaneously in two or more counterparts, each of which together shall constitute one and the same instrument.

13.3. No Assignment. Neither this Agreement nor any of the rights and obligations hereunder may be assigned by the Company, the Distributor or the Trust without the prior written consent of the other parties.

13.4. Declaration of Trust. A copy of the Declaration of Trust of the Trust is on file with the Secretary of State of the state of Delaware, and notice is hereby given that this instrument is executed on behalf of the Trustees of the Trust as trustees, and is not binding upon any of the Trustees, officers or shareholders of the Trust individually, but binding only upon the assets and property of the Trust. No Series of the Trust shall be liable for the obligations of any other Series of the Trust.

IN WITNESS WHEREOF, each of the parties hereto has caused this Agreement to be executed in its name and behalf by its duly authorized officer on the date specified below.

GOLDMAN SACHS VARIABLE INSURANCE TRUST (Trust)

Date: ______By: ______Name: Title:

GOLDMAN, SACHS & CO. (Distributor)

Date: ______By: ______Name: Title:

SYMETRA LIFE INSURANCE COMPANY (Company)

Date: ______By: ______Name: Linda C. Mahaffey Title: Vice President

Schedule 1A

Separate Accounts of the Company Registered Under the 1940 Act as Unit Investment Trusts

The following separate accounts of the Company are subject to the Agreement:

Name of Account Date Established by Board of SEC 1940 Act Registration Type of Product Supported by Directors of the Company Number Account

Separate Account C September 14, 1993 811-08052 Individual and Group Variable Annuities

Schedule 1B

Variable Annuity Contracts and Variable Life Insurance Contracts Registered Under the Securities Act of 1933

The following Contracts are subject to the Agreement:

Name of Contract Available Funds 1933 Act Registration Number Type of Product

Retirement Passport Goldman Sachs VIT 333-158141 Group Variable Annuity Government Income Fund – Service Shares

Schedule 2A

Separate Accounts of the Company Excluded From the Definition of an Investment Company as Provided for by Section 3(c)(11) of the 1940 Act

The following separate accounts of the Company are subject to the Agreement:

Name of Account Date Established by Board of SEC 1940 Act Registration Type of Product Supported by Directors of the Company Number Account

Schedule 2B

Variable Annuity Contracts and Variable Life Insurance Contracts Not Registered Under the Securities Act of 1933 in Reliance Upon Section 3(a)(2) of the Act

The following Contracts are subject to the Agreement:

Name of Contract Available Funds 1933 Act Registration Number Type of Product

Schedule 3A

Separate Accounts of the Company Excluded From the Definition of an Investment Company as Provided for by Section 3(c)(1) or 3(c)(7) of the 1940 Act

The following separate accounts of the Company are subject to the Agreement:

Name of Account Date Established by Board of SEC 1940 Act Registration Type of Product Supported by Directors of the Company Number Account

Schedule 3B

Variable Annuity Contracts and Variable Life Insurance Contracts Not Registered Under the Securities Act of 1933 in Reliance Upon Section 4(2) of the Act and Regulation D Thereunder

The following Contracts are subject to the Agreement:

Name of Contract Available Funds 1933 Act Registration Number Type of Product

Re: Accumulator Variable Universal Life

Directors:

I have acted as counsel to Symetra Life Insurance Company (the “Company”) in connection with the filing with the Securities and Exchange Commission of the Registration Statement on Form N-6 for the Flexible Premium Adjustable Variable Life Insurance Policies (the "Policies") to be issued by the Company and its separate account, Symetra Separate Account SL. I have made such examination of the law and have examined such records and documents as in my judgment are necessary or appropriate to enable me to render the following opinion:

1. Symetra Life Insurance Company is a validly existing stock life insurance company of the state of Iowa.

2. Symetra Separate Account SL is a separate investment account of Symetra Life Insurance Company validly existing pursuant to the Iowa insurance laws and regulations thereunder.

3. All of the prescribed corporate procedures for the issuance of the Policies have been followed, and, when such Policies are issued in accordance with the prospectus contained in the Registration Statement, all state requirements relating to such Policies will have been met.

4. Upon the acceptance of the Premium Payments made by a prospective Policy Owner pursuant to a Policy issued in accordance with the Prospectus contained in the Registration Statement and upon compliance with applicable law, such Policy Owner will have a legally-issued, fully paid, non-assessable Policy.

I hereby consent to the use of this letter, or a copy hereof, as an exhibit to the Registration Statement.

Very truly yours,

/S/ Rachel Dobrow Stone

Rachel Dobrow Stone Senior Counsel

ACCUMULATOR VARIABLE UNIVERSAL LIFE

FLEXIBLE PREMIUM ADJUSTABLE VARIABLE LIFE INSURANCE POLICY Issued by SYMETRA LIFE INSURANCE COMPANY

Administrative Office: P.O. Box 34690 Seattle, WA 98124

This Summary Prospectus summarizes key features of Accumulator Variable Universal Life, a flexible premium adjustable variable life insurance policy (“Policy”). Before you invest, You should also review the prospectus for the Policy, which contains more information about the Policy’s features, benefits, and risks. You can find this document and other information about the Policy online at www.symetra.com/regulatoryreports.com. You can also obtain this information at no cost by calling 1-800-796-3872 or by sending an email request to [email protected].

You may cancel your Policy within 10 days of receiving it without paying fees or penalties (the "Cancellation Period"). Upon cancellation, You will receive a refund of the premium payments made, minus any loans. You should review the prospectus, or consult with your investment professional (all references to "investment professionals" shall by definition include registered representatives), for additional information about the specific cancellation terms that apply.

Additional general information about certain investment products, including variable life insurance, has been prepared by the Securities and Exchange Commission’s staff and is available at Investor.gov.

Copyright © 2021 www.secdatabase.com. All Rights Reserved. Please Consider the Environment Before Printing This Document TABLE OF CONTENTS Page DEFINITIONS 1 KEY INFORMATION 3 OVERVIEW OF THE POLICY 5 STANDARD DEATH BENEFIT 6 OTHER BENEFITS AVAILABLE UNDER THE POLICY 8 PREMIUMS 9 HOW YOUR POLICY CAN LAPSE 9 MAKING WITHDRAWALS: ACCESSING THE MONEY IN YOUR POLICY 10 ADDITIONAL INFORMATION ABOUT FEES 12 APPENDIX A: PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY A-1

Table of Contents Statutory Prospectus Definitions