The following terms and conditions govern your use of this website, www.LombardPortal.com (the “Site”). Your use of the Site and Content (defined below) constitutes your acceptance of these terms and conditions. If you do not agree with these terms and conditions, you should immediately cease use of the Site and Content. The Site presents information and content that is owned by Axcelus Financial Life Assurance Company, its subsidiaries and affiliates ("Axcelus") or provided to Axcelus by third party investment management organizations. When used in these Terms and Conditions, "we" and "our" mean Axcelus and "you" and "your" refers to any individual, company, or legal entity that accesses or otherwise uses the Site.

Certain information on the Site relates to investment funds that Axcelus includes in its variable products from time to time (each a “Fund”). Much of the information about Funds provided on the Site has been provided to Axcelus by persons responsible for the sponsorship, operation, administration, and investment management activities of such Funds or their representatives (collectively “Fund Managers”). Information provided to Axcelus by Fund Managers is not audited by Axcelus nor has Axcelus independently verified the accuracy or completeness of the information provided by Fund Managers. By agreeing to these Terms and Conditions, you agree to waive any claim against Axcelus arising out of or related to the accuracy or completeness of Content of the Site.

The Site is a research site containing, among other information, information on Funds that are exempt from registration under the Securities Act of 1933 pursuant to Regulation D promulgated thereunder. The Site allows investment professionals, including without limitation independent insurance agents, wealth planners, registered representatives of broker-dealers which are members of the Financial Industry Regulatory Authority, Inc. (“FINRA”), and associated persons of investment advisers registered with the U.S. Securities and Exchange Commission (the “SEC”) and other legal and professional advisors to review information on privately-offered funds. The Funds described on the Site are not offered or sold through the Site and no interests in any such fund may be acquired through the Site.

Axcelus maintains this Site and other Axcelus websites describing Axcelus products and services. These Terms of Use apply only to your use of the Site and Content, and they do not apply to your use of any other Axcelus website or products or services otherwise offered by Axcelus. We may have established or will establish additional or different terms and conditions for certain products and services. In many instances, our products or services involve sophisticated financial instruments or investments that are regulated by governmental authorities. You agree to review all applicable terms and conditions relating to Axcelus's products and services. In the event of any conflict between the terms and conditions on the Site and such additional terms and conditions, the additional terms and conditions govern and control. If you are an insurance professional with whom Axcelus has entered into a selling, agency or similar agreement, your relationship with Axcelus is also governed by those other agreements, as applicable. In the event of any conflict between the terms and conditions on the Site and such policy or account agreements, your policy and account agreements govern and control.

The Content on the Site is for convenience and information purposes only. You should consult your financial and legal advisors, and independently verify all Content provided through the Site before you make decisions. Nothing on the Site constitutes an offer to sell or buy any product. Nothing on the Site should be construed as rendering tax, legal, investment, or accounting advice. The posting of any product offering documents or any other information on the Site is not a recommendation or opinion for you to buy or sell any product or participate in any transaction.

All of the information and content on the Site, including, but not limited to, all text, analyses, reports, articles, graphics, software applications, trademarks, service marks and trade dress ("Content") is owned by Axcelus or provided to Axcelus by third party investment management organizations. The Content is protected worldwide by applicable intellectual property laws. You may make and use printouts of the Content for your personal, non-commercial use only, provided that the printouts retain all copyright, trademark, and other proprietary notices. Axcelus reserves the right to terminate at any time your right to make personal copies of Content. You may not copy, transmit, distribute, modify, publicly perform, reuse, sell or display any of the Content for any public or commercial purpose except with the prior written consent of Axcelus or the owners of the materials, which they may issue in their sole discretion. You may not use the Content in any other website or in a network computer environment, including framing the Content within another website. Except for the limited use rights expressly provided in this paragraph, all rights in Content are reserved. All other trademarks, service marks, trade names, logos and icons are the trademarks of Axcelus Financial Life Assurance Company or third parties where indicated. Other materials on the Site are a copyright of or proprietary to Axcelus Financial Life Assurance Company or used under permission of the owner thereof. Except when included in any authorized printouts of the Content, you are not authorized to make any other use of Axcelus's marks, including, but not limited to, as metatags or in any other fashion that may create a false or misleading impression of affiliation or sponsorship with or by Axcelus.

All information obtained from the Site, other than (i) information that was known to you prior to the disclosure to you and (ii) information that is in the public domain at the time of disclosure to you, is confidential in nature and may not be shared by any you with any other party or used for any purpose other than evaluation the merits of an investment opportunity listed on the Site (such information, “Confidential Information”); provided that, (a) you may share Confidential Information obtained from the Site with its legal, tax or other professional advisors to the extent that such advisors have been notified of the confidentiality of the nature of the information obtained from this Site and (b) upon any request of a governmental, supervisory or regulatory body, you shall be permitted to disclose Confidential Information to such governmental or regulatory body (a “Permitted Disclosure”); provided that, to the extent permitted, you provides notice of such request and disclosure Axcelus Financial. You acknowledge that Axcelus Financial will be irreparably harmed if the confidentiality obligations hereunder are not specifically enforced and that Axcelus Financial would not have an adequate remedy at law in the event of an actual or threatened violation by you of its confidentiality obligations hereunder. Therefore, you agree and consent that, except in the context of a Permitted Disclosure, Axcelus Financial shall be entitled to seek an injunction or any appropriate decree of specific performance for any actual or threatened violation or breaches by you, without the posting of any bond, and such other relief as may be just and proper, including the right to recover all losses or damages suffered by Axcelus Financial resulting from any such breach or threatened breach. You are responsible for maintaining the confidentiality of your username and password used to access the Site and for restricting access to your computer, and you agree to accept responsibility for all activities that occur under your account or password. You may not assign, otherwise transfer or disclose your username, password, account or any information obtained from the Site to any other person or entity. You acknowledge that Axcelus Financial is not responsible for third party access to your account that results from theft or misappropriation of your account. Axcelus Financial reserves the right to refuse or cancel service, terminate accounts, or remove or edit content in our sole discretion.

Axcelus does not accept or consider unsolicited ideas, proposals or suggestions (collectively, “Ideas”), or materials concerning the Idea (“Materials”) including without limitation Ideas for new or improved products, processes or technologies, product enhancements, advertising and marketing campaigns, promotions or new product names. Please do not send any Ideas or Materials. The purpose of this policy is to avoid any potential misunderstanding or dispute when Axcelus’s products or marketing efforts might seem similar to Ideas or Materials submitted to Axcelus. If, despite our request not to send us your Ideas or Materials, you still do, then regardless of what your communication states, the following terms shall apply to your submission: TERMS OF SUBMISSION: You agree that: (a) your submission does not create any contract, whether implied or express, between you and Axcelus, (b) your Ideas and Materials, and all intellectual property associated therewith, will automatically become the property of Axcelus, without compensation to you, (c) Axcelus can use the Ideas and Materials for any purpose, in any way, and without attribution or compensation to you, and (d) any information you provide will be considered non-confidential.

Links from this site, if any, to a non-Axcelus site may be provided for the user's convenience only. Axcelus does not control or review these third-party sites nor does the provision of a link imply any endorsement of or association with such non-Axcelus sites. Your linking to any websites from the Site is at your own risk. Subject to the terms of applicable service or other agreements, we will remove any link from the Site upon request from the owner of the linked website.

Not all of the products or services described on the Site are available in all areas of the United States and you may not be eligible for them. We reserve the right to determine eligibility.

We strive to provide accurate and up-to-date material on the Site. However, we make no warranties or representations as to the accuracy or timeliness of the Content. Your use of the Site and Content is at your own risk. Content may become inaccurate as a result of developments after its publication on the Site. Axcelus assumes no responsibility to keep Content current or to correct inaccuracies or errors in Content. The Content on the Site and the operation of it are provided "as is" and for informational purposes only, and Axcelus disclaims all representations or warranties of any kind, either express or implied, including warranties of merchantability, fitness for particular purpose, title, non-infringement, accuracy, completeness, and timeliness. Certain jurisdictions may not permit certain disclaimers of warranties. In such case, we disclaim warranties to the fullest extent permitted by the applicable law.

Axcelus does not warrant that the website will operate error free or is free from viruses, worms, Trojan horses, or other destructive or harmful code. Axcelus assumes no liability or responsibility for any damages to you, your computer, or other property due to your access to, use of, or downloading of Content. If you download or copy Content from the Site, you are responsible for taking all reasonable precautions necessary to ensure the security and integrity of your computer and systems, including employing current virus protection software.

In no event shall Axcelus or any other party involved in creating, producing, or delivering the Site or Content on Axcelus's behalf be liable for any direct, incidental, special, consequential, indirect, lost profits, loss of business or data, or punitive damages arising out of your access to, or use of, or inability to access or use, the Site or any Content, or the performance of any product on the Site.

All information, other than information prepared by third party investment management organizations, is the property of Axcelus. Axcelus is free to use any ideas, concepts, know-how, or techniques that you may submit to Axcelus through the Site for any purpose, including, but not limited to, improving our services. We are not subject to any obligations of confidentiality regarding any submitted information except as set forth in any additional terms and conditions relating to specific products or services, or as otherwise specifically agreed or required by law.

Axcelus reserves the right to change the Content on the Site and these Terms and Conditions from time to time at any time without prior notice. The changes may include superseding terms and conditions or specific notices. YOU SHOULD REVIEW THESE TERMS AND CONDITIONS FROM TIME TO TIME TO BE AWARE OF ANY CHANGES THAT ARE MADE. Your continued use of the Site constitutes your acceptance of any change or update, all of which shall become controlling when posted.

The Site does not intend to market any Axcelus products or services to children under thirteen (13) years of age. Axcelus does not knowingly gather or solicit data from children under thirteen (13) years of age through the Site for marketing purposes. By using the Site you represent that you are not under thirteen (13) years of age. You can learn more about children's privacy and the Children's Online Privacy Protection Act (COPPA) at the Federal Trade Commission's website at http://www.ftc.gov.

These Terms and Conditions shall be governed by, and construed in accordance with, the laws of the United States and the Commonwealth of Pennsylvania, without giving effect to conflict of law principles thereof.

The services and products described and information provided through the Site are directed to and are intended to be made available only to persons in the United States and are not intended for distribution to, or use by, any person in any other country or any jurisdiction where such distribution or use would be contrary to law or regulation or that would subject Axcelus to any registration requirement within such jurisdiction or country. Persons who access the Site do so on their own initiative, and are responsible for compliance with applicable local laws and regulations. Software and other materials from the Site may be subject to export controls imposed by the United States and may not be downloaded or otherwise exported to any country or anyone prohibited by law. Axcelus prohibits your downloading or exporting of software or other material from the Site in violation of U.S. Export Laws and the laws of your resident country. By downloading software or other material from the Site, you represent and warrant that you are able to do so in full compliance with the laws of the United States and your resident country.

Axcelus reserves the right in its sole discretion to terminate or restrict your use of all or any part of the website, without notice, for any or no reason, and without liability to you or anyone else. The Terms and Conditions relating to Ownership and Use of Content, Indemnification, Limitation of Liability, Warranty Disclaimer, Limitation of Liability, and Governing law shall survive any termination.