Combination 5% Roll-up and Highest Anniversary Value Death Benefit

Available during accumulation phase. Upon death of owner or annuitant, benefit will be greatest of - 1) total purchase payments adjusted for withdrawal, 2) unadjusted contract value, 3) highest anniversary value, or 4) roll-up value. Initially highest anniversary value is equal to unadjusted contract value, thereafter on any contract anniversary equal to greater of - 1) previous highest anniversary value, or 2) unadjusted contract value on each anniversary prior to target date adjusted for withdrawals and subsequent payments made since that date. Initially roll-up value is equal to unadjusted contract value, thereafter increased daily by roll-up value (5% annually) and purchase payments made, prior to target date. If withdrawals are less than 5% of initial roll-up value Issuer will reduce benefit base by dollar amount; if withdrawals are in excess of 5% of initial roll-up value, excess portion of withdrawal will reduce benefit base in same proportion. Target Date is later of - 1) contract anniversary following owner's 80th birthday, or 2) 5th contract anniversary. Owner must participate in Asset Allocation Program.