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MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
                        Defined Benefit and Defined Contribution Recordkeeping

                                    Investment Service Operations System

               Internal Control Elements


               Control Environment

               The following is an organization chart of the Company as of September 30, 2020:



                                          Policyowners              Investment          General
                                         (with right to vote)       Committee            Auditor



                                                                                         Chief
                                        Board of Directors             Audit           Complianc
                                                                    Committee
                                                                                        e Officer

                                                                                         Chief
                                       President, Chairman             Other           Enterprise
                                            and CEO                 Committees
                                                                                      Risk Officer


                                      Massachusetts Mutual
                                          Life Insurance
                                            Company


                       MassMutual         Other Lines of                    Enterprise
                        DB & DC             Business        Subsidiaries   Technology &
                     Recordkeeping                                          Experience
                      & Investment
                       Operations


               The  control  environment  reflects  the  tone  of  control  consciousness  set  by  an  independent Board  of
               Directors and the President/Chairman/Chief Executive Officer. It is the foundation of all other aspects of
               internal  control.  The  Board  of  Directors  provides  oversight  for  MassMutual activities,  including  the
               Investment and Audit Committees of the Company. The Investment Committee exercises supervision and
               control of company investments and related financial matters, approves company investment policies and
               guidelines and reviews company investment strategies and investment performance. The Audit Committee
               is made aware of significant changes to the Company’s policies and practices with respect to accounting,
               financial controls, and financial reporting, including those within MassMutual.
               The Company has formal hiring practices that are designed to confirm that new associates are qualified for
               their job responsibilities. For each position, minimum education and experience requirements are identified
               and HR policy requires satisfactory completion of reference, drug, background and certain criminal checks.
               Training of personnel is accomplished through supervised on-the-job training  and external and internal
               training courses. An MassMutual employee Onboarding program has been established for new hires and
               tenured employees to provide a strong foundation for acquiring business knowledge through education. In
               addition, formal new hire curriculums are in place for key customer facing roles in the organization including
               the  Participant  Call  Centers,  Account  Management,  Recordkeeping,  Relationship  Management,  New
               Business, Sales and Education Specialists. The new hire curriculums include standard formal training along

                MassMutual Defined Benefit and Defined                    Description of the System Provided by
                Contribution Investment Service Operations                                       MassMutual
                System
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