Safeway (SWY)

ACCOUNTS AND TRUST FUNDING

4.1 Deferral Accounts.

The Committee shall establish and maintain a Deferral Account for each Participant under the Plan. Each Participant’s Deferral Account shall be further divided into separate subaccounts (“Investment Fund Subaccounts”), each of which corresponds to a investment fund elected by the Participant pursuant to Section 3.2(a). A Participant’s Deferral Account shall be credited as follows:

(a) Within five business days after each payroll date, the Committee shall credit the Investment Fund Subaccounts of the Participant’s Deferral Account with an amount equal to Compensation deferred by the Participant during each pay period in accordance with the Participant’s election under Section 3.2(a); that is, the portion of the Participant’s deferred Compensation that the Participant has elected to be deemed to be invested in a certain type of investment fund shall be credited to the Investment Fund Subaccount corresponding to that investment fund;

(b) Each Investment Fund Subaccount of a Participant’s Deferral Account shall be credited daily with earnings or losses in an amount equal to that determined by multiplying the balance credited to such Investment Fund Subaccount as of the last day of the preceding month plus contributions during the current month commencing on the date such contributions are credited to the Investment Fund Subaccount by the Interest Rate for the corresponding fund selected by the Company pursuant to Section 3.2(b).

(c) In the event that a Participant elects for a given Plan Year’s deferral of Compensation to have a Scheduled Withdrawal Date, all amounts attributed to the deferral of Compensation for such Plan Year shall be accounted for in a manner which allows separate accounting for the deferral of Compensation and investment gains and losses associated with such Plan Year’s deferral of Compensation.

4.2 Company Discretionary Contribution Account.

The Committee shall establish and maintain a Company Discretionary Contribution Account for each Participant under the Plan, which shall be credited the amount of Company Discretionary Contributions, if any, contributed to the Plan on behalf of such Participant. Each Participant’s Company Discretionary Contribution Account shall be further divided into separate Investment Fund Subaccounts corresponding to the investment fund elected by the Participant pursuant to Section 3.2(a). A Participant’s Company Discretionary Contribution Account shall be credited as follows:

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(a) The Committee shall credit the Investment Fund Subaccounts of the Participant’s Company Discretionary Contribution Account with an amount equal to the Company Discretionary Contribution Amount, if any, applicable to that Participant, that is, the proportion of the Company Discretionary Contribution Amount, if any, which the Participant elected to be deemed to be invested in a certain type of investment fund shall be credited to the corresponding Investment Fund Subaccount; and

(b) As of the last day of each month, each Investment Fund Subaccount of a Participant’s Company Discretionary Contribution Account shall be credited with earnings or losses in an amount equal to that determined by multiplying the balance credited to such Investment Fund Subaccount as of the last day of the preceding month plus contributions during the current month commencing on the date such contributions are credited to the Investment Fund Subaccount by the Interest Rate for the corresponding Fund selected by the Company pursuant to Section 3.2(b).

4.3 401(k) Excess Account.

The Committee shall establish and maintain a 401(k) Excess Account for each Participant under the Plan, for 401(k) Excess deferral made prior to January 1, 2008, which shall be credited the amount of 401(k) Excess, if any, contributed to the Plan on behalf of such Participant. Each Participant’s 401(k) Excess Account shall be further divided into separate Investment Fund Subaccounts corresponding to the investment fund elected by the Participant pursuant to Section 3.2(a). A Participant’s 401(k) Excess Account shall be credited as follows:

(a) The Committee shall credit the Investment Fund Subaccounts of the Participant’s 401(k) Excess Account with an amount equal to the 401(k) Excess, if any, applicable to that Participant, that is, the proportion of the 401(k) Excess, if any, which the Participant elected to be deemed to be invested in a certain type of investment fund shall be credited to the corresponding Investment Fund Subaccount; and

(b) As of the last day of each month, each Investment Fund Subaccount of a Participant’s 401(k) Excess Account shall be credited with earnings or losses in an amount equal to that determined by multiplying the balance credited to such Investment Fund Subaccount as of the last day of the preceding month plus contributions during the current month commencing on the date such contributions are credited to the Investment Fund Subaccount by the Interest Rate for the corresponding Fund selected by the Company pursuant to Section 3.2(b).

4.4 Trust Funding.

The Company has created the Trust to hold contributions made to this Plan. The Company shall make contributions to the Trust in accordance with the terms of the Trust.

Although the principal of the Trust and any earnings thereon shall be held separate and apart from other funds of Participating Companies and shall be used exclusively for the uses and purposes of Plan Participants and beneficiaries as set forth therein, neither the

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Participant nor their beneficiaries shall have any preferred claim on, or any beneficial ownership in, any assets of the Trust prior to the time such assets are paid to the Participants or beneficiaries as benefits and all rights created under this Plan shall be unsecured contractual rights of Plan Participants and beneficiaries against the Participating Companies. Any assets held in the Trust will be subject to the claims of the Participating Companies’ general creditors under federal and state law in the event of insolvency as defined in Section 3 of the Trust.

The assets of the Plan and Trust shall never inure to the benefit of the Company, unless otherwise provided in the Trust, and the same shall be held for the exclusive purpose of providing benefits to Participants and their beneficiaries, other than reasonable expenses of administering the Plan and Trust.

ACCOUNTS AND TRUST FUNDING

4.1 Deferral
Accounts.

The Committee shall establish and maintain a Deferral Account for each Participant under the Plan. Each
Participant’s Deferral Account shall be further divided into separate subaccounts (“Investment Fund Subaccounts”), each of which corresponds to a investment fund elected by the Participant pursuant to Section 3.2(a). A
Participant’s Deferral Account shall be credited as follows:

(a) Within five business days after each payroll date, the
Committee shall credit the Investment Fund Subaccounts of the Participant’s Deferral Account with an amount equal to Compensation deferred by the Participant during each pay period in accordance with the Participant’s election under
Section 3.2(a); that is, the portion of the Participant’s deferred Compensation that the Participant has elected to be deemed to be invested in a certain type of investment fund shall be credited to the Investment Fund Subaccount
corresponding to that investment fund;

(b) Each Investment Fund Subaccount of a Participant’s Deferral Account shall be credited
daily with earnings or losses in an amount equal to that determined by multiplying the balance credited to such Investment Fund Subaccount as of the last day of the preceding month plus contributions during the current month commencing on the date
such contributions are credited to the Investment Fund Subaccount by the Interest Rate for the corresponding fund selected by the Company pursuant to Section 3.2(b).