Disclosures

DB Foresight X-Asset 10

The Trailhead Fixed Indexed Annuity (FIA) and HighLine FIA (the “Products”) are not sponsored, endorsed, sold or promoted by Deutsche Bank AG or any subsidiary or affiliate of Deutsche Bank AG, Deutsche Bank AG, London Branch or any platform operated by Deutsche Bank AG or any subsidiary or affiliate of Deutsche Bank AG. The DB Foresight X-Asset 10 Index (the “DB Index”) is the exclusive property of Deutsche Bank AG. “Deutsche Bank” and “Deutsche Bank AG”, “Deutsche Bank Global Markets”, “DB Investment Solutions” and “Deutsche Bank AG, London Branch” and “DB Foresight X-Asset 10 IndexTM” are service marks of Deutsche Bank AG; "QuantumStreet AI" is a service mark of EquBot Inc. DBA QuantumStreet AI, and have been licensed for use for certain purposes by Axonic Insurance Services LLC. Neither Deutsche Bank AG, Deutsche Bank AG, London Branch, any affiliate of Deutsche Bank AG nor any other party involved in, or related to, making or compiling the DB Index (each a “DB Group Company”) makes any = representation or warranty, express or implied, concerning the DB Index, the Products, the advisability of investing in the Products or in securities generally or as to the results obtained from the use of the DB Index. Other than to the extent required under any applicable law, regulation, principles or guidance, no DB Group Company has any obligation to take the needs of Axonic Insurance Services LLC, the sponsor of the Products, its clients, any distributor of the Products or any holder of the Products into consideration in determining, composing or calculating the DB Index. Neither Deutsche Bank AG, Deutsche Bank AG, London Branch nor any platform operated by Deutsche Bank AG or any subsidiary or affiliate of Deutsche Bank AG sells, solicits, negotiates or effects, and does not aid any other person or entity in selling, soliciting, negotiating or effecting, the Product or any other insurance policy or annuity contract. No member of the DB Group is under any obligation to initiate or continue the calculation, publication and dissemination of the DB Index No DB Group Company is responsible for or has participated in the determination of the timing of, prices at, quantities or valuation of the Products. No DB Group Company has any obligation or liability in connection with the issuance, distribution, administration, marketing or trading of the Products or use of the DB Index in relation to the Products. In addition, no DB Group Company has independently verified the information contained herein. No DB Group Company is responsible for the issue or content included in this Product Disclosure Statement. Accordingly, no representation, warranty or undertaking, express or implied, is made and no responsibility or liability is accepted by such entity as to the accuracy or completeness of the information contained herein.

ALTHOUGH DEUTSCHE BANK AG WILL OBTAIN INFORMATION FOR INCLUSION IN OR FOR USE IN THE CALCULATION OF THE DB INDEX FROM SOURCES WHICH IT CONSIDERS RELIABLE, NO DB GROUP COMPANY WILL INDEPENDENTLY VERIFY SUCH INFORMATION. NO DB GROUP COMPANY WARRANTS OR GUARANTEES THE ACCURACY AND/OR THE COMPLETENESS OF THE DB INDEX OR THE PRODUCT OR ANY DATA INCLUDED THEREIN AND SHALL HAVE NO LIABILITY FOR ANY ERRORS, OMISSIONS, OR INTERRUPTIONS THEREIN AND IS UNDER NO OBLIGATION TO ADVISE ANY PERSON OF ANY ERRORS, OMISSIONS OR INTERRUPTIONS. NO DB GROUP COMPANY MAKES ANY WARRANTY, EXPRESS OR IMPLIED, AS TO RESULTS OR RETURNS TO BE OBTAINED BY INSERT NAME OF LICENSEE] FROM THE USE OF THE DB INDEX OR ANY DATA INCLUDED THEREIN OR FROM INVESTING IN THE PRODUCTS. NO DB GROUP COMPANY MAKES ANY EXPRESS OR IMPLIED WARRANTIES, AND EXPRESSLY DISCLAIMS ALL WARRANTIES, OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE WITH RESPECT TO THE DB INDEX OR ANY DATA INCLUDED THEREIN OR IN THE PRODUCT. WITHOUT LIMITING ANY OF THE FOREGOING, IN NO EVENT SHALL A DB GROUP COMPANY HAVE ANY LIABILITY (WHETHER IN NEGLIGENCE OR OTHERWISE) FOR DIRECT, INDIRECT, PUNITIVE, SPECIAL, CONSEQUENTIAL OR ANY OTHER DAMAGES OR LOSSES (INCLUDING LOST PROFITS) IN CONNECTION WITH THE DB INDEX OR THE PRODUCTS, EVEN IF NOTIFIED OF THE POSSIBILITY THEREOF.

DB is acting solely as licensor of the DB Index and that neither DB nor any DB Group Company is acting as an investment advisor or broker-dealer in connection with providing the DB Index, and that no inclusion (or removal) of a security or other asset in the DB Index constitutes a recommendation to buy, sell or hold such security or asset, nor does it constitute investment advice. Axonic Insurance Services LLC has made its own independent decision to use the DB Index (based on its own judgement or the advice of its advisers), is not relying on any communication or other advice from any DB Group Company in connection with the use of the DB Index and understands and is capable of assuming the risks of using the DB Index. The returns of the DB Index do not represent the results of actual trading of the investible assets or securities underlying the DB Index. Deutsche Bank Index Quant, an independent research unit of DB (“DBIQ”), maintains and calculates the DB Index, but does not manage actual assets that notionally comprise the DB Index. The calculation of the DB Index and DB Index returns may deviate from the stated methodology.

DB Index returns do not reflect payment of any sales charges, fees or taxes an investor using the index may be required to pay to purchase or sell the assets notionally underlying the index if such licensee were to directly hold such assets. The imposition of these fees, charges or taxes may cause the performance of a basket of the underlying assets to be different than the performance of the DB Index for Axonic Insurance Services LLC and investors. Past performance of the DB Index is not an indication or guarantee of future results of the DB Index. Where specified in the description of DB Index, the rebalancing and/or recomposition of the DB Index is performed by an independent third party index allocator, EquBot Inc. DBA QuantumStreet AI (“Index Allocator”), in accordance with its proprietary strategy. The performance of the DB Index is, therefore, reliant upon the allocation of the DB Index by the Index Allocator. Axonic Insurance Services LLC and investors in the Products should make their own decision as to the effect of the initial composition and the possible effect of any future rebalancing and/or reconstitution of the DB Index by the Index Allocator. Further information about the Index Allocator can be found at https://quantumstreetai.com/ (a third party website). If the appointment of the Index Allocator is terminated, Axonic Insurance Services LLC and the investors in the Products should note that the DB Index will no longer be rebalanced and/or reconstituted, which may adversely affect the Products. The Index Allocator may use artificial intelligence (“AI”) algorithms to determine rebalancing and/or recomposition of the DB Index. AI algorithms can analyze large amounts of traditional and alternative data sources in order to detect patterns and make predictions, which may be difficult to explain. The data on which an algorithm is trained impacts its outputs and may have bias effects. AI algorithms can learn and adapt without human intervention. This means that the outputs of AI algorithms in any given scenario may change over time, and potentially adversely impacting the DB Index. Using AI algorithms to determine allocations may result in lower returns than would otherwise be the case. The Index Allocator uses and relies on proprietary and non-proprietary AI algorithms, tools and processes. In the event that the Index Allocator is unable to renew any relevant licences or changes third party vendors, this may materially affect the determination of allocations and the performance of the DB Index.

NO ASSURANCE CAN BE GIVEN THAT THE INDEX ALLOCATOR WILL, IN PRACTICE, FOLLOW ITS STRATEGY, NOR THAT ANY SUCH STRATEGY WILL BE PROFITABLE. A STRATEGY MAY BE BASED TO SOME EXTENT ON PREVIOUS TRENDS IN THE MARKETS, BUT THERE IS NO GUARANTEE THAT SUCH TRENDS WILL BE REPEATED IN THE FUTURE. DEUTSCHE BANK AG DOES NOT AUTHORISE, ENDORSE, RATIFY OR OTHERWISE RECOMMEND THE INDEX ALLOCATOR OR THE STRATEGY OR THE SELECTIONS OF PARAMETERS BY SUCH INDEX ALLOCATOR AND ACCEPTS NO LIABILITY OR RESPONSIBILITY WHATSOEVER TO ANY PERSON (INCLUDING ANY FINANCIAL PRODUCT INVESTOR) FOR THE ACTIVITIES PERFORMED BY THE INDEX ALLOCATOR, THE SELECTIONS OF WEIGHTS, THE STRATEGY OR THE RESULTING PERFORMANCE OF THE DB INDEX. DB reserves the right to amend or adjust the methodology for calculating the DB Index from time to time in accordance with the rules governing the calculation of the DB Index and accepts no liability for any such amendment or adjustment. Neither DB or any DB Group Company are under any obligation to continue the calculation, publication or dissemination of the DB Index and accepts no liability for any suspension or interruption in the calculation thereof which is made in accordance with the rules governing the DB Index. No purchaser, seller or holder of the Products, or any other person or entity, should use or refer to any Deutsche Bank trade name, trademark or service mark to sponsor, endorse, market or promote the Products unless this statement is included in any Product Document or Marketing Material in connection therewith. Under no circumstances may any person or entity claim any affiliation with Deutsche Bank without the written permission of DB. Additionally, no content contained in the Marketing Material [(including index data, ratings, credit-related analyses and data, research, valuations, model, software or other application or output therefrom)] or any part thereof (“Content”) may be modified, reverse-engineered, reproduced or distributed in any form or by any means, or stored in a database or retrieval system, without the prior written permission of DB. The Content shall not be used for any unlawful or unauthorized purposes. By using the Product, each Axonic Insurance Services LLC and investor in the Products acknowledges and agrees that neither Deutsche Bank AG, Deutsche Bank AG, London Branch nor any subsidiary or affiliate of Deutsche Bank AG shall have any liability or responsibility to any person or entity for any loss, damages, costs, charges, expenses or other liabilities whether caused by the negligence of Deutsche Bank AG, Deutsche Bank AG, London Branch or any subsidiary or affiliate of Deutsche Bank AG or otherwise, arising in connection with the use of the Product or the DB Index or any Product Document or Marketing Material produced in connection with the Product or the DB Index.

Disclaimer by the Index Allocator

The Index Allocator is acting solely as index allocator in respect of the DB Index and is not acting as an investment adviser or broker-dealer in connection with providing its services. The Products are not sponsored, endorsed, sold or promoted by the Index Allocator. The Index Allocator does not make any representation or warranty, express or implied, concerning the Index, the Products, the advisability of investing in the Products or in securities generally or as to the results obtained from the use of the Index Allocator’s services. The Index Allocator does not take the needs of any person into consideration in providing its services. The Index Allocator does not sell, solicit, negotiate or effect, and does not aid any other person or entity in selling, soliciting, negotiating or effecting, the Products or any other insurance policy or annuity contract. The Index Allocator is not responsible for nor does it participate in the determination of the timing of, prices at, quantities or valuation of the Product. The Index Allocator does not have any obligation or liability in connection with the issuance, distribution, administration, marketing or trading of the Products or use of the DB Index in relation to the Products. In addition, the Index Allocator has not independently verified the information contained herein. The Index Allocator is not responsible for the issuance or content included in this Product Disclosure Statements. Accordingly, no representation, warranty or undertaking, express or implied, is made and no responsibility or liability is accepted by the Index Allocator as to the accuracy or completeness of the information contained herein.