Exhibit 14(b)           COLUMBIA THREADNEEDLE INVESTMENTS  GLOBAL PERSONAL ACCOUNT DEALING AND   CODE OF ETHICS                                Policy Type              Global Policy    Last Review Date         December 2019                             SEC Rule 204A-1 of the Advisers Act                            SEC Rule 17j-1 of the Investment Company Act                            FCA Rule Conduct of Business Sourcebook (COBS) 11.7                            Securities and Futures Act   Applicable Global   Regulatory Authorities   MAS guidelines on Risk Management Practices-Internal                            Controls                            Code of Conduct for Persons licensed by the Securities and                            Futures Commission                                                         See Appendix C-Other Policies Applicable to Covered   Related Policies         Persons                             All Covered Persons and certain household members,   Applicability and Scope  trusteeships and executorships of Covered Persons.                                                                                         1
 1.  POLICY STATEMENT  1.1. Keys Points    Standard of Business Conduct: The conduct of personal dealings in investments by Covered Persons  (See Appendix A-Definitions for Covered Persons definition) employed by or affiliated with the Ameriprise                              1 Global Asset Management Entities  (the “Firms”) is a matter of the utmost importance to the organization,  its clients, its regulators and to employees themselves. It is essential that the Firms appropriately manage  access to privileged information concerning clients’ portfolios, the Firms’ trading intentions and trading  activities, and that the Firms discharge their duties in a way that does not harm the interests of clients, the  Firms or breach any legal or regulatory requirements. It is important that the Firms are not seen to act on  privileged information for personal gain.    Duty Owed to Clients: Various regulations applicable to the Firms impose a fiduciary duty to act in the  exclusive best interest of their clients at all times recognizing their role as a “Trusted Adviser”. A number  of specific obligations flow from the duty that is owed to clients, including:    •  To act solely in the best interests of clients at all times.   •  To make full and fair disclosure of all material facts, particularly where the Firms’ interests may conflict     with those of its clients.   •  To act in a manner which satisfies the fiduciary duty owed to clients.   •  To refrain from favouring the interest of a particular client over the interests of another client.   •  To keep all information about clients (including former clients) confidential, including the client’s     identity, client’s securities holdings information, and other non-public information.   •  To exercise a high degree of care to ensure that adequate and accurate representations and other     information is presented appropriately.     In connection with providing investment management services to clients, this includes prohibiting any  activity which directly or indirectly:    •  Defrauds a client in any manner.   •  Misleads a client, including any statement that omits material facts.   •  Operates or would operate as a fraud or deceit on a client.   •  Functions as a manipulative practice with respect to a client.   •  Functions as a manipulative practice with respect to securities.      Specifically, the fiduciary duty owed to clients means the following outcomes must be achieved:    •  To have a reasonable, independent basis for investment advice.                                      1 See Appendix B-Entities That Have Adopted Policy  This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                        2
 •  To ensure that investment advice is suitable to the client’s investment objectives, needs and     circumstances.   •  To refrain from effecting Personal Securities Transactions inconsistent with clients’ interests.   •  To obtain best execution for clients’ securities transactions.     Conflicts of Interest: All Covered Persons must be vigilant in terms of identifying circumstances that may  present a conflict of interest. A conflict of interest is any situation that presents an incentive to act other  than in the best interest of a client or without objectivity. A conflict of interest may arise, for example, when  a Covered Person engages in a transaction that potentially favors:    •  The Firms’ interests over a client’s interest   •  The interest of a Covered Person over a client’s interest   •  One client’s interest over another client’s interest    In addition to this Ameriprise Global Asset Management Personal Account Dealing and Code of Ethics  Policy (“Policy”), the Firms have adopted various policies designed to prevent, or otherwise manage,  conflicts of interest in contexts outside of personal trading.  To effectively manage conflicts of interest, all  Covered Persons must seek to prevent conflicts of interest, including the appearance of a conflict.    The requirements set forth in this Policy do not identify all possible conflicts of interest that may arise in  relation to personal transactions. Employees are encouraged to seek assistance from their local  Compliance resources (see Appendix D-Resources) whenever they have any questions concerning  obligations under the Policy, including conflicts of interest situations or concerns.      Additional Standards of Conduct and Regulatory Requirements: Covered Persons must comply with  other policies adopted by the individual Ameriprise Global Asset Management Entities that are intended to  promote fair and ethical standards of business conduct and comply with related regulatory requirements,  including the Ameriprise Financial Global Code of Conduct. (See Appendix C-Other Policies Applicable to  Covered Persons).                        This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                        3
 1.2. Specific Policy Requirements    This Policy applies to all Covered Persons and certain household members, Trusteeships and   Executorships of Covered Persons. Covered Persons include:   •  All Columbia Threadneedle employees and contractors.  •  Any other individual with a specific role (including working on a project) which compels Covered Person     status due to access to proprietary information (e.g., holdings/transactions), such as the member of a     staff group that provides ongoing audit, technology, finance, compliance, or legal support to Firms.   •  Any other persons that may be deemed appropriate by Compliance.       Covered Securities Transactions/Accounts: This Policy governs a Covered Person’s personal   securities transactions as well as those securities transactions in which a Covered Person is deemed to   have a direct or indirect Beneficial Ownership (see Appendix A-Definitions for Beneficial Ownership   definition) and over which a Covered Person exercises direct or indirect influence or control (“Affiliated   Accounts”). An account generally is covered by this Policy if it is:     • In the Covered Person’s name    • In the name of the Covered Person’s spouse/partner and/or any financially dependent members of the     Covered Person’s household,    • Of a partnership in which the Covered Person or a member of his/her immediate family is a partner with     direct or indirect investment discretion    • Of a trust in which the Covered Person (or a member of his/her immediate family) is a beneficiary and     a trustee with direct or indirect investment discretion    • Of a closely held corporation in which the Covered Person or a member of his/her immediate family     holds shares and have direct or indirect investment discretion    It is the responsibility of the Covered Person to seek advice in the event that it is not clear whether certain   personal securities transactions are covered by this Policy.    Material Nonpublic Information: A Covered Person who is in possession of material nonpublic   information (often referred to as “Inside Information”) about securities or financial instruments is prohibited   from buying, selling, recommending or trading such securities or financial instruments. In addition, a   Covered Person must not communicate or disclose such information to others who may misuse it. Material   nonpublic information may include nonpublic information about a pooled investment vehicle (e.g., UCITS,   open-end and closed-end mutual funds, and private funds) that are advised or sub-advised by the Firm.   The Firms each have adopted specific policies that address these prohibitions, and set forth specific   protocols for handling material nonpublic information (see Appendix C-Other Policies Applicable to   Covered Persons)     Brokerage Accounts at Designated Broker-Dealers (Limited Choice): Covered Persons must promptly   disclose their brokerage accounts to their Firm’s Compliance group and ensure that each broker-dealer   with which he/she maintains an account sends to the Compliance group, as soon as practicable, copies of    This document is current as of the last review date but subject to change thereafter.    Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle    group of companies.                                                                                         4
 all confirmations of his/her securities transactions and of all monthly, quarterly and annual account  statements.    North America employees must receive approval from Personal Trading Compliance prior to opening any  new brokerage account outside of the Limited Choice Policy2 in order to comply with FINRA Rule 3210.  Limited Choice accounts must be disclosed on PTA ahead of any trading.     EMEA/APAC employees must receive approval from Personal Trading Compliance prior to opening any  new brokerage account outside the Limited Choice Policy. Limited Choice accounts must be disclosed on  PTA ahead of any trading and the feed from a Limited Choice Broker must be authorized by the employee  prior to trading.        Personal Trading Restrictions   Prohibition on “Front Running”:  Covered Persons are prohibited from engaging in a Personal Securities  Transaction that involves the purchase or sale of a Reportable Security when such Covered Person has  knowledge that such security (1) is being considered for purchase or sale by a client account or (2) is being  purchased or sold by a client account.    Prior Approval (Pre-Clearance) of Personal Security Transactions: Covered Persons must obtain  approval – often referred to as pre-clearance - from Compliance prior to effecting a securities trade in most  categories of investments. This pre-clearance requirement extends to securities transactions in all  accounts for which the Covered Person has Beneficial Ownership (see Appendix A-Definitions). If the  Covered Person receives pre-clearance approval, it is valid only for the duration of the locally defined  approval period; if a Covered Person does not affect the pre-cleared personal trade(s) within that locally  approved time period, the Covered Person must request and obtain pre-clearance for the proposed  personal trade(s) again before the trade(s) are effected. If the Covered Person does not receive pre- clearance approval, he/she must not affect the requested Personal Securities Transaction (but may  request approval on a subsequent day).    Covered Persons are required to obtain such pre-clearance approval for the majority of investments (e.g.  stocks, bonds, ETFs, closed-end funds). Please refer to Appendix E-Individual Security Requirements  which identifies those categories of investments to which pre-clearance is or is not applicable. Please note:  pre-clearance requests must be entered during your designated local timeframes.     Private Placements/Limited Offerings: Investments in private placement offerings require approval by the  Compliance group (e.g., private placements, non-exchange traded REITs, hedge funds, fixed income new  issues, unlisted structured products, non-charity crowdfunding, etc.).  If approved, the approval is good for  90 days.    Gifts and Charitable Donations: Approval is not necessary for a gift of securities to a Non-Profit  Organization, but Compliance should be notified in advance and the Short-Term and 14-day Blackout rules                                     2 See Appendix H for details on the Limited Choice Policy  This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                        5
 do not apply. For gifting securities to a For-Profit Organization, individual, trust or other person or entity  (other than a Non-Profit Organization), the pre-clearance requirement and 14-day Blackout rule do apply  if you are purchasing the securities you intend to give. If the securities are already owned, the transfer of  securities does not require pre-clearance.  If you receive a gift of securities, you must update your holdings  on PTA and no pre-clearance is required.         Short-Term Trading Prohibition (30 Day Holding Period)    Individual Securities at a Profit: Covered Persons are prohibited from engaging in short-term trading of  Reportable Securities. This means that Covered Persons may not buy (or add to their existing position),  then sell the same securities (or equivalent) within 30 calendar days if the trade would result in a gain.  Covered Persons must wait until calendar day 31 (Trade Date + 30) to trade out of a position at a profit  within the same account.    When calculating the 30-day holding period, the average cost method within the last 30 calendar days  must be used.    Covered Funds and other Pooled Investment Vehicles: A Covered Person is prohibited from short term  trading in any Covered Fund (e.g., mutual fund, SICAV, OEIC, or other pooled investment vehicle, see  Appendix F-Covered Funds List) held for less than 30 calendar days, or a longer time if specified in the  Covered Fund’s prospectus or similar disclosure document. Covered Persons are prohibited from  engaging in market timing (short-term trading) in shares of any pooled investment vehicles and must  comply with the holding period policy established by any prospectus.    Transactions exempted from short-term trading prohibitions: Money market fund investments, automated  investments and withdrawal programs, and Dividend Reinvestments are not subject to the 30-day holding  period.    EMEA and APAC employees: Columbia Threadneedle provides discounts on investments to EMEA and  APAC employees in certain of its products but operates a holding period of a minimum 60 working days in  order to qualify for those discounts. Please refer to the Columbia Threadneedle –EMEA and Asia  Compensation & Benefits intranet site for information.   Initial Public Offerings (“IPOs”) and Limited Offerings: Covered Persons require pre-clearance  approval to purchase Initial Public Offerings (“IPOs”) or Limited Offerings, including additions to existing  holdings but excluding capital calls for previously approved commitments. Such approval will only be  granted when it is established that there is no conflict or appearance of a conflict with any Client or other  possible impropriety (such as where the Security in the Limited Offering is appropriate for purchase by a  Client, or when his/her participation in the Limited Offering is suggested by a person who has a business  relationship with any such Company or expects to establish such a relationship). The 30-day holding period  also applies to IPOs.    Participation in Investment Clubs: No Covered Person may participate in private investment clubs or  other similar groups.    This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                        6
 Derivatives: Covered Persons are strongly discouraged from investing in any form of derivative that could  give rise to an open ended, unlimited liability. Most derivative trading is subject to pre-clearance  requirements, option trading guidelines and the Short-Term Trading Prohibition. (See Appendix G- Options/Short Trading Guidelines).      Frequent and Unusual Trading Activity: Compliance monitors patterns of personal trading activity and  may require additional information from a Covered Person with respect to a specific trade or series of  transactions. In addition, frequent personal trading activity is strongly discouraged. Although each situation  is case specific, we generally review trading amounts over 25 trades per quarter for further analysis, which  could result in corrective measures.   Additional Trading Restrictions for Investment Employees    Rules Applicable to Portfolio Managers and other Designated Covered Persons:   14 Day Blackout Period: Portfolio Managers (and other Covered Persons specifically identified by  Compliance) are not permitted to transact in any security that is purchased or sold in a client account 7  calendar days before and 7 calendar days after a client account they manage trades in that same (or  equivalent) security. This means a Portfolio Manager must wait until calendar day 8 to trade the security.  Application of this rule may be applied broader based on team function and location.    Because it is a Portfolio Manager’s responsibility to put his/her client’s interests ahead of his/her own,  he/she may not delay taking appropriate action for a client account in order to avoid potential adverse  consequences in his/her personal account. In certain limited instances, Compliance, at their discretion,  may determine that a trade should be deemed to have not caused a black out violation (e.g., unexpected  significant client redemption or inflow triggering a sale or purchase in all securities held in the client  portfolio).    Rules Applicable to Research Analysts:    Centralised Research Analysts (those who publish research for the use by Columbia Threadneedle) are  prohibited from engaging in a personal securities transaction that involves securities issued by issuers on  their Coverage List at the security (not issuer) level. This restriction includes securities convertible into,  options on, and derivatives of, such securities.    Embedded Research Analysts-should the analyst have access to place an order within a fund they will be  subject to the same blackout period as a Portfolio Manager (see above).    Rules Applicable to Trading Personnel:    3 Day Blackout Period: Traders are not permitted to transact in any security that is purchased or sold in a  client account 3 calendar days after the client transaction. This means a Trader must wait until calendar  day 4 to trade the security. Application of this rule may be adjusted based on team function and location.   Rules applicable to Ameriprise Shares:   This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                        7
 All employees at band level 50 and above are subject to a blackout period of trading Ameriprise shares.  The blackout occurs on the first calendar day of January, April, July, and October and lasts until one full  trading day after the Ameriprise earnings for the preceding quarter are publicly released. During this period  employees are restricted from trading any Ameriprise shares. All applicable employees will receive emails  notifying of the start and end date of the blackout.   1.3. Reporting Requirements    Initial Holdings Report and Certification: Upon becoming a Covered Person under this Policy, one must  disclose all securities holdings (as indicated in Appendix E-Individual Securities Requirements) in which  they have Beneficial Ownership (as defined in Appendix A-Definitions).  All brokerage accounts must be  disclosed.    All Covered Persons are notified of this requirement and are provided with a copy of this Policy when they  first become subject to the Policy. This initial certification must be completed within 10 calendar days of  becoming a Covered Person. This information must be current as of the date no more than 45 days prior  to the date the person becomes a Covered Person.    Annual Certification: Covered Persons are also required to complete an annual accounts and holdings  certification. This certification allows the Covered Person to validate the Brokerage Accounts and certain  securities holdings in which they have Beneficial Ownership (as defined in Appendix A-Definitions).  Covered Persons also certify that they have received, read and understand the Policy. This information  must be current as of a date no more than 45 days prior to the date the report was submitted.    Quarterly Certification: On a quarterly basis, Covered Persons must also certify to securities transactions  outside of a previously reported and approved Brokerage Account. The quarterly certification must be  completed within 30 calendar days of the last day of the quarter.    1.4. Confidentiality    All reports and other documents and information supplied by or on behalf of any Covered Person in  accordance with the requirements of this Policy will be treated as confidential, but are subject to review as  provided herein and in the procedures by Legal, Compliance and other involved departments of the Firms,  by Personal Trading, senior management, by representatives relevant regulatory authority of the asset  management business’ regulatory or self-regulatory authority, or otherwise as required by law, regulation,  or court order.   1.5. Personal Data   The collection and use of personal data for employees and clients located in EMEA by firms is subject to  regulation to ensure the protection of data subjects; the firm sets out the general principles for handling  personal data that must be followed by all staff within the EMEA Personal Data Policy. The firm has put  in place comprehensive but proportionate governance measures to minimise the risk of breaches and  uphold the protection of personal data. The relevant measures have been documented within this Policy.     This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                        8
 2.  ADMINISTRATIVE REQUIREMENTS  2.1. Summary of Legal and Regulatory Requirements    Regulatory rules require registered investment advisers and investment companies to adopt a code of  ethics to; protect the firm’s clients, set forth standards of conduct, comply with applicable federal securities  laws and address personal trading. SEC Rule 204A-1 under the Advisers Act (“Rule 204A-1”) requires  each registered investment adviser to adopt a code of ethics that sets out standards of conduct expected  of advisory personnel, safeguards material nonpublic information about client transactions and requires  advisers’ “access persons” to report their personal securities transactions, including transactions in any  mutual fund managed by the adviser.   Rule 17j-1 makes it unlawful for any affiliated person of a fund or any affiliated person of its investment  adviser or principal underwriter to engage in certain enumerated types of misconduct in connection with  the purchase or sale by such person of a security held or to be acquired by the fund. Each fund and its  investment adviser and principal underwriter are required to adopt a written code of ethics containing  provisions reasonably necessary to prevent the specified types of misconduct, and to use reasonable  diligence and institute procedures reasonably necessary to prevent violations of the code.   FCA Rule COBS 11.7 requires a firm that conducts designated investment business to establish,  implement and maintain adequate arrangements aimed at preventing certain activities (entering into  certain personal transactions or advising anyone else to do so, or disclosing any non-public information)  of any relevant person that may give rise to a conflict of interest, or who has access to inside information   as defined in the Market Abuse Regulation3 or to other confidential information relating to clients or  transactions with or for clients by virtue of an activity carried out by him on behalf of the firm.   MAS Guidelines on Risk Management Practices – Internal Controls state that an institution should have  adequate policies, procedures and controls to address conflict of interest situations. It should require  employees to disclose such conflicts on a timely basis. These cases should be escalated to either the  Board or senior management, and disclosed to customers where relevant.    Code of Conduct for Persons licensed by or registered with the Securities and Futures Commission – A  licensed person should have a policy which has been communicated to employees in writing on whether  employees are permitted to deal or trade for their own accounts. Transactions of employees’ accounts and  related accounts should be reported to and actively monitored and procedures maintained to detect  irregularities and ensure that the handling by the licensed or registered person of these transactions or  orders is not prejudicial to the interests of their clients.    2.2. Roles and Responsibilities/Supervision   At least annually, each Chief Compliance Officer/Compliance Executive of the Ameriprise Global Asset  Management Entities must review the adequacy of this Policy and the policies and procedures herein  referenced.     This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                        9
 2.3. Escalation for Non-Compliance   The Firms have various resources for Covered Persons to raise compliance issues and concerns on a  confidential basis (refer to Appendix D-Resources for a list of Compliance resources). In general, a  Covered Person should first discuss a compliance issue with their supervisor, department head, Chief  Compliance Officer, Compliance Executive, or other resource listed on Appendix D-Resources. In the  event that a Covered Person does not feel comfortable discussing compliance issues through these  channels, the employee may anonymously report suspected violations of law or company policy by  contacting their local resources (refer to Appendix D-Resources). Employees are encouraged to report  these questionable practices so that the Firms have an opportunity to address and resolve these issues  before they become more significant regulatory or legal issues.   Violations/Breaches of this Policy are taken seriously and may result in disciplinary actions and/or  sanctions. Disciplinary actions could be up to and including termination of employment and sanctions will  vary depending on local requirements or the circumstances (e.g., depending on the severity of the violation,  if a record of previous violations exists, etc.).   2.4. Monitoring/Oversight  Compliance is responsible for the daily monitoring of employee personal trading and applicable accounts  through the usage of personal trading assistant.     Escalation of matters are provided to appropriate local governance committee.    2.5. Disclosure   Columbia Threadneedle must provide information that is material about it business practices to clients  and/or regulatory agencies, including information about any conflicts of interests and the policies to  address such conflicts.  Practices related to this Policy are publicly disclosed in accordance to local rules  and regulations.   2.6. Recordkeeping  Each respective Compliance group is primarily responsible for maintaining records created with respect to  this Policy and the procedures adopted to implement it.  All records must be maintained for five years after  the end of the fiscal year in which the documents were later of creation or last use, the first two years in an  easily accessible place.                This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                       10
 APPENDIX A-DEFINITIONS   Beneficial Owner of an account or a security includes any person who, directly or indirectly, has or shares  voting or investment power. For the purposes of the Code of Ethics, a beneficial owner includes accounts  held in the name of: you, your spouse/partner and/or any financially dependent members of your household  (while this normally applies to dependent children, adult children living with older parents are also included)    In addition, you also have Beneficial Ownership if any of the individuals listed above:    • Is a trustee or custodian for an account (e.g., for a child or parent)   • Exercises discretion over an account via a power of attorney arrangement or as an executor of an estate    after death   • Has another arrangement where they give advice and also have a direct or indirect ownership (e.g.    treasurer of an outside organization).      Brokerage Account: A Brokerage Account is an account held at a licensed brokerage firm in which  securities on the Securities Reporting List are bought and sold (e.g., stocks, bonds, futures, options,  Covered Funds). This includes employer-sponsored incentive savings plans.    Closed-End Funds: A closed-end fund is a publicly traded investment company that raises a fixed amount  of capital through an Initial Public Offering (IPO). The fund is then structured, listed and traded like a stock  on a stock exchange.    Covered Funds: Closed-End Funds, ETFs and Open-Ended Funds for which a Columbia Threadneedle  entity serves as an investment adviser or for which an affiliate of Columbia Management Investment  Advisers, LLC serves as principal underwriter are considered “Covered Funds.”    Covered Persons includes all Columbia Threadneedle employees and contractors, any other individual  with a specific role (including working on a project) which compels Covered Person status due to access  to proprietary information (e.g., holdings/transactions), such as the member of a staff group that provides  ongoing audit, technology, finance, compliance, or legal support to Firms, and any other persons that may  be deemed appropriate by Compliance.    Private Funds: Private investment funds sponsored and managed by CMIA.     This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                       11
 APPENDIX B-ENTITIIES THAT HAVE ADOPTED POLICY   Columbia Management Investment Advisers, LLC   Columbia Management Investment Distributors, Inc.   Columbia Management Investment Services, Corp.  Lionstone Partners, LLC   Threadneedle Asset Management Holdings SARL (TAMHS)   Threadneedle Asset Management Ltd.   Threadneedle Asset Management Limited (TAML)   Threadneedle International Limited   Threadneedle International Investment GmbH   Threadneedle International Limited (TINTL)   Threadneedle Investment Services Limited (TISL)   Threadneedle Investments Singapore (Pte) Limited (TIS)   Threadneedle Management Luxembourg SA. (TMLUX)   Threadneedle Management Services Limited   Threadneedle Navigator ISA Manager Limited (TNIML)   Threadneedle Pensions Limited (TPEN)   Threadneedle Portfolio Services Hong Kong Limited, Korea Representative Office   Threadneedle Portfolio Services Hong Kong Limited (TPSHKL)   Threadneedle Portfolio Services Limited (TPSL)   Threadneedle Unit Trust Manager Limited (TUTML)  It should be noted that Columbia Management includes Wanger Acorn trading data to also cover non-  CWAM employees under one consolidated Code.    This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                       12
 APPENDIX C – OTHER POLICIES APPLICABLE TO  COVERED PERSONS   Ameriprise Financial Global Code of Conduct   Ameriprise Handling Whistleblower Claims Policy   Ameriprise Limited Choice Policy   Global Policy – Inside Information   Columbia Management Portfolio Holdings Disclosure Policy    Columbia Management Privacy Policy   Global Policy - Gifts and Entertainment    Global Policy – Political Contributions   Global Policy – Outside Activities and Family Relationships   Threadneedle Other Conflicts of Interest Policies Applicable to Covered Persons:    Threadneedle Market Abuse & Insider Dealing Policy   Threadneedle Conflicts of Interest Policy   Threadneedle Treating Customers Fairly   Threadneedle Whistleblowing Policy    This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                       13
 APPENDIX D –RESOURCES  Compliance Resources   Personal Trading - 612-671-5196 or send email to Personal.Trading@ampf.com   Columbia Threadneedle EMEA and Asia Personal Trading  personalaccountdealing@columbiathreadneedle.com    Contact the Compliance Team if you are ever at doubt as to your obligations under this Policy.   Whistleblowing   Ameriprise Financial provides a dedicated resource through NAVEX Global (formerly known as  Ethicspoint) (800-963-6395), a comprehensive and confidential reporting service for U.S. employees to  report suspected fraud, abuse or other misconduct.      EMEA employees, in accordance with the EMEA/APAC Whistleblowing Policy, may contact the following  for reporting, investigating and remedying any wrongdoing in the workplace.         Reporting Option            Contact Email            Contact Number (+44)        Safecall                                             0800 915 1571        FCA whistleblowing line     whistle@fca.gov.uk       020 7066 9200        Public Concern at Work      helpline@pcaw.co.uk      020 7404 6609      APAC employees, in accordance with the EMEA/APAC Whistleblowing Policy, may contact the Head of  HR APAC, the Head of Legal or Compliance or Safecall (number noted above) for reporting,  investigating and remedying any wrongdoing in the workplace.     This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                       14
 APPENDIX E-INDIVIDUAL SECURITIES REQUIREMENTS  Pre-clearance Requirements      All securities held in brokerage accounts (including 401K Alight Financial self-directed brokerage accounts)  are subject to prior approval (“pre-clearance”) under the Policy, including Exchange Traded Funds (“ETFs”)  and Closed End Funds, except those listed below:     •  Ameriprise Financial Stock (other rules - blackout, holding periods still apply, no speculative trading)   •  Annuities and Life Insurance (where there is no specific investment exposure)   •  Bank products (checking/savings, CDs, etc.)   •  Currencies   •  Debt securities issued by any government   •  Dividend Reinvestment Plans (DRIPS)   •  Futures   •  Money Market Funds   •  Non Investment derivatives – sporting bets only   •  Open-End Mutual Funds   •  Columbia Threadneedle - EMEA and APAC Products*   •  Unit Investment Trusts (UITs)   *Pre-clearance only required by FPDC/SPC members (applicable to EMEA only).   Reporting Requirements       Brokerage accounts   All brokerage accounts, including the Alight 401(k) self-directed accounts, must be reported to Personal  Trade Compliance through the PTA system.  This reporting requirement applies even if the holdings in the  account do not require reporting (See Holdings below).     Holdings   The following securities do not require reporting:   •  Annuities (report only Covered Funds listed in Appendix F)   •  Bank products (checking/savings, CDs etc.)   •  Currencies   •  Debt securities issued by any government   •  529 plans   •  Money Market Funds   •  Open-End Mutual Funds (report only Covered Funds listed in Appendix F)                   This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                       15
 APPENDIX F-COVERED FUNDS LIST   The Global Asset Management Personal Account Dealing and Code of Ethics Policy (“Policy”) speaks to  certain rules concerning activity within Covered Funds. Closed-End Funds, ETFs and Mutual Funds for  which Columbia Management Investment Advisers, LLC serves as an investment adviser or for which an  affiliate of Columbia Management Investment Advisers, LLC serves as principal underwriter are considered  “Covered Funds.”   The following is the list of Covered Funds as of December 2019:  •  All Columbia Mutual Funds (both retail and variable), including Columbia Acorn Funds, Wanger Funds,     Active Portfolios® and CMG Ultra Short-Term Bond Fund  •  All Columbia Exchange-Traded Funds (ETFs)   •  All Columbia Threadneedle – EMEA and Asia Funds  •  Columbia Seligman Premium Technology Growth Fund, Inc.  •  Tri-Continental Corporation     Third-Party Funds Sub Advised by CMIA:  •  Pathway Large Cap Equity Fund  •  Destinations Large Cap Equity Fund  •  SA Columbia Focused Value Portfolio  •   SA Columbia Technology Portfolio  •  VALIC Company I Large Cap Core Fund  •  VY Columbia Contrarian Core Portfolio  •  VY Columbia Small Cap Value II Portfolio  •  Guardian Integrated Research VIP FUND    This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                       16
 APPENDIX G-OPTIONS/SHORT TRADING GUIDELINES  Short Trading-General Guidelines  Shorting individual securities is prohibited.  Shorting broad-based market securities (ETFs) is permitted.    Options Trading-General Guidelines   All persons subject to the Global Asset Management Personal Account Dealing and Code of Ethics Policy  (“Policy”) are strongly discouraged from dealing in any form of derivative that could give rise to an open  ended, unlimited liability.  All Covered Persons must obtain pre-clearance via PTA prior to placing an options trade.    Short term trading at a profit is prohibited under the code.  Covered Persons may not trade options that  will result in a gain if held less than 30 days.  Covered Persons must wait trade date plus 30 days before  closing the position at a profit.      Acceptable Transactions   •  Options that have an expiration greater than 30 days and  •  Out of the money option contracts  •  In the money option contracts only if there is an underlying position held greater than 30 days   Prohibited Transactions   •  Options that have an expiration within 30 days  •  In the money option contracts – unless there is a sufficient underlying position held greater than 30     days (100 shares per contract)  •  Buying and selling options contracts at a profit held less than 30 days   Key Reminders   Covered Persons are required to preclear the option ticker symbol (please use the new option symbology)  and not the underlying ticker.  Covered Persons are responsible for calculating the 30-day holding period (Trade date + 30 days), you  must use the average cost method (PTA does not calculate the 30-day holding period).  Receiving pre-clearance does not exclude you from other personal trading rules included in the Policy.     This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                       17
 APPENDIX H-LIMITED CHOICE POLICY   In order to comply with regulators expectations concerning the monitoring of trading activity within  Covered Person accounts, Ameriprise Financial maintains a “limited choice” brokerage policy which  dictates where certain types of securities must be held and traded.    The types of securities that are subject to the Limited Choice Policy are specified in Appendix E-  Individual Securities Requirements.  Securities not subject to the Limited Choice Policy may be held in  brokerage accounts and must meet certain requirements.  See Notification of Brokerage Accounts.  Securities subject to the Limited Choice Policy must be held, and trading must be conducted, through  one of these brokers:  •  Ameriprise/Columbia Threadneedle North America - Ameriprise Financial Brokerage, Charles     Schwab, Merrill Lynch   •  Columbia Threadneedle EMEA and Asia – Barclays, Hargreaves Lansdowne, Equiniti, Interactive     Brokers, UOB Kay Hian, DBS Bank of Singapore, (Charles Schwab and Merrill Lynch – restricted to     U.S based accounts only)    If you maintain a brokerage account outside of the limited choice brokers that holds securities subject to  the Limited Choice policy, you have the following options:  1. You may transfer the subject holdings to a like-ownership account at one of the approved brokers.      See Notification of Brokerage Accounts  2. You may liquidate the subject holdings (subject to the requirements in the Policy) and either hold the     proceeds as cash or reinvest in non-subject securities.  3. You may apply for an exception.  Contact Personal Trading for more information about what may be     an allowable exception and what steps need to be taken to request an exception.   An exception     does not make you exempt from complying will all other requirements in Policy).  Covered Persons must comply with the Limited Choice Policy requirements within 30 days of becoming a  Covered Person.    Notification of Brokerage Accounts  Covered Persons must immediately report any new brokerage accounts opened by completing the  following steps:  •  Add the account to the PTA system using the “Add Brokerage Account” functionality.    •  Notify your broker of your association with Ameriprise Financial or Columbia Threadneedle. You are     responsible for notifying your broker that you are affiliated with or employed by a broker/dealer and     ensuring that Personal Trade Compliance is provided with duplicate statements and confirmations for     your account(s).    This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                       18
 North America employees – any brokerage account outside of Limited Choice brokers (for example, a  brokerage account holding mutual funds only) must be approved by Personal Trade Compliance prior  to establishing the account in order to comply with FINRA rule 3210.   EMEA/APAC employees – Employees are required to authorize the electronic feeds between the limited  brokers and Columbia Threadneedle Investments.     This document is current as of the last review date but subject to change thereafter.   Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle   group of companies.                                                                                       19