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MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
                                   Defined Benefit and Defined Contribution

                                       Recordkeeping Operations System



               Internal Control Elements


               Control Environment

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



                                     Policy owners            Investment        General
                                    (with right to vote)      Committee         Auditor



                                                                                 Chief
                                                                Audit
                                   Board of Directors                          Complianc
                                                              Committee
                                                                                e Officer
                                                                                 Chief
                                  President, Chairman            Other         Enterprise
                                       and CEO                Committees         Risk
                                                                                Offi

                                    Massachusetts
                                 Mutual Life Insurance
                                       Company


                   MassMutual                                                  Enterprise
                    DB & DC          Other Lines of       Subsidiaries        Technology &
                  Recordkeeping        Business                                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 for  Executive  level  positions  only,  drug,
               background and certain criminal checks for all positions.

               Training of personnel is accomplished through supervised on-the-job training  and external and internal
               training courses. A 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 Recordkeeping Operations System                                     MassMutual
                                                             14
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