Global Code of Conduct 
 
 
 
 
 
 
OUR VALUES 
 
                    
 
 
 
Client-focused Integrity 
always 
Excellence          Respect
    2    
 
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
From our Chairman and Chief Executive Officer 
Our clients, advisors, employees, shareholders and regulators rightfully expect us to obey 
the law and to treat them with integrity.
  
The success of  
Ameriprise depends on 
the trust and confidence  
we earn every day.  
Our actions matter. 
Ameriprise Financial has a proud, more 
than 120 year history as a successful, 
client-focused financial services firm. No 
company can thrive for over a century 
and grow as we have without a deep 
commitment to ethical behavior and 
doing what is right for our clients, 
advisors, employees and shareholders. 
Our Global Code of Conduct 
emphasizes the core ethical principles 
that must guide our behavior at all times.  
The Global Code of Conduct also 
identifies potential areas of ethical risk. 
Please read it carefully. When you see 
misconduct, report it to your leader. Ask 
your leader for help when you are unsure 
of the right thing to do. We will not take 
action against an individual who reports 
what he or she believes in good faith to be 
misconduct. Even if it turns out that no 
misconduct occurred, you will be 
protected as long as you acted in good 
faith. 
Our Board of Directors, Executive 
Leadership Team and I hold ourselves 
to the same high standards of conduct 
that we expect you to honor. For those 
who lead others, it’s your duty to set the 
right example for behavior. And it’s up to 
each of us to ensure we treat team 
members and others with dignity and 
respect. 
Our vision is to be the most respected 
and referred financial services brand. 
We can only achieve our vision if each 
of us does business the right way. 
Thank you for your commitment to the 
principles in the Code and the continued 
success of our company. 
 
 
 
JAMES M. CRACCHIOLO 
CHAIRMAN AND CHIEF EXECUTIVE 
OFFICER
    3    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
 
Contents  
 
 
• Introduction 
− This Code applies to everyone ............... 4 
• Report your concerns .................................. 6 
• Our ethical principles 
− Obey the law and guard against  
criminal activity .................................... 7 
− Do the right thing for the client .............. 9 
− Conduct business ethically ................. 11 
− Compete fairly in the marketplace ...... 13 
− Protect the company’s reputation  
and assets ......................................... 15 
− Safeguard and maintain  
accurate information .......................... 17 
− Treat everyone with dignity  
and respect ........................................ 19 
• Navigate your ethical questions ................. 21 
• Consequences for non-compliance ............ 22 
• Resources ................................................. 23
    4    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
This Code applies to everyone  
at Ameriprise Financial  
All officers, employees, financial advisors and their staff must follow this Code. 
What you need to know 
 We value ethics and integrity. •
  We maintain an environment where •
 compliance and adherence to the Code of 
Conduct is the norm. 
About the Code 
This Code is enterprise-wide and applies to 
everyone working for one of the company’s 
business areas or affiliates. Commitment to the 
ethical principles helps ensure compliance with 
the Code. 
This Code applies even if you also adhere to 
another code of ethics or conduct within your 
business area.  
For U.S. employees and employee advisors, 
compliance with the Code is a condition of 
employment. For franchise advisors and their 
staff, compliance with the Code is required by 
the franchise agreement.  
Applicable company policies 
The Code requires you to comply with the 
provisions of other policies, codes of ethics 
and other business procedures to which you 
are subject.  
You must read and comply with the policies 
and procedures that apply to you. (See Page 
23 for a partial list of company policies.) 
This Code can’t cover every situation 
No code of conduct or ethics can anticipate all 
of the circumstances that you may encounter 
during your career. If the Code doesn’t 
address a specific situation, you are still 
obligated to act in an ethical and honest 
manner. Above all, seek guidance from your 
leader, manager or one of the provided 
resources (See list of resources on Page 6) 
before you act. 
Violations of the Code 
If you violate the Code, you will be subject to 
disciplinary action, including possible 
termination of your employment or franchise 
agreement. Disciplinary action will depend on 
the circumstances and will be consistent with 
the company’s policies and procedures. (See 
consequences for non-compliance on Page 
22.) 
Waivers of the Code 
Only the Board of Directors of Ameriprise 
Financial, Inc. can grant a waiver of the Code 
of Conduct. We will promptly disclose to our 
Why ethics matter 
The culture of any company is determined 
by what its directors, officers and 
employees actually do rather than what they 
are supposed to do. It is simply about doing 
the right thing, day in and day out. 
We expect you to: 
 Comply with the Code. •
  Act with integrity.  •
  Follow all applicable laws, rules and •
 regulations. 
 Use your best judgment.  •
  Ask for guidance before you act. •
  Report ethical concerns promptly. •
  Be an example of ethical behavior for •
 your team.
    5    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
 
shareholders any waivers granted to our executive officers and directors. 
 
 
 
I’m a contractor working on a three-
 month project. Since I’m not an 
employee, does the Code apply  
to me?  
Yes. Anyone doing business on behalf 
of Ameriprise Financial, RiverSource, 
Columbia Threadneedle Investments or 
any of our other subsidiaries is held 
accountable for reading, understanding 
and following the Code and all company 
policies applicable to his or her roles 
and responsibilities. 
When we refer to “Ameriprise” or our 
“company,” we mean all majority-owned 
businesses and entities of Ameriprise 
Financial, Inc. 
 
 
I discovered that my coworker is 
violating the Code by falsifying 
financial results. Do I have to  
report this?  
Yes. You, too, will have violated the 
Code if you don’t report your concerns. 
As long as you act in good faith, you will 
be protected from retaliation. This very 
important point is covered in more detail 
in the next section.
    6    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
Report your concerns  
If you observe behavior that concerns you, or that you believe in good faith may be 
illegal or a violation of the Code, you are required to report the issue promptly. 
What you need to know 
 We respond appropriately to all allegations •
 by employees, suppliers, clients or 
contractors that the company is not 
meeting its legal, ethical or financial 
obligations. 
 We provide several reporting options for •
 anyone who suspects breaches of the 
Code, our policies or the law.  
Whistleblower claims 
Acting ethically includes reporting misconduct. 
If you don’t report the misconduct of others, 
you are not acting ethically and will be held 
accountable. It may not be easy to report 
misconduct involving a colleague or friend, but 
that is what we expect you to do. 
You should, in good faith, report an alleged 
impropriety that prevents the company from 
meeting its legal obligations or complying with 
generally accepted accounting principles. 
 A whistleblower is an individual who •
 lawfully makes any allegation of 
impropriety or discloses or provides 
information or assistance in connection 
with any governmental proceeding or 
inquiry. 
 Acting in good faith means that you have a •
 sincere belief that a reasonable person in 
the same situation with access to the same 
facts would also conclude there is a 
likelihood of misconduct. 
Non-retaliation 
We will not tolerate any retaliation against you 
if you report possible misconduct in good faith 
even if it turns out that no misconduct 
occurred. You won’t be fired, given a lower 
performance rating or demoted solely because 
you reported possible misconduct in good 
faith. Retaliating against a person who has 
reported a suspected violation is considered a 
violation of the Code.  
 All reports are investigated and your report •
 will be treated confidentially to the extent 
allowed by law and company policy.  
 If you believe you have been retaliated •
 against, promptly contact any of the 
resources listed on this page. 
 Leaders are responsible for properly •
 reporting any allegations they become 
aware of. 
 
Why ethics matter 
Your diligence allows us to correct problems 
that may involve a violation of law or pose a 
risk to health, safety or the company’s 
reputation. 
We expect you to report concerns 
promptly to your leader, manager or 
one of the following resources: 
 Employee Relations Group  •
 Service Center – ERGSC@ampf.com 
 Ethics Hotline – 1.800.963.6395  •
  Safe Call (UK) – 0800 915 1571 •
  FCA Whistleblowing (UK) –  •
 whistle@fca.gov.uk 
 Public Concern at Work (UK) –  •
 helpline@pcaw.co.uk 
 Corporate Secretary’s Office – •
 Thomas.R.Moore@ampf.com 
 General Counsel’s Organization – •
 karen.wilson.thissen@ampf.com  
 Executive Vice President, •
 Human Resources – 
Kelli.A.Hunter@ampf.com
    7    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
Obey the law and guard against criminal activity 
We comply with all laws and regulations that apply to our operations, including insider 
trading laws. 
What you need to know 
 We obey the law in our professional lives •
 just as we do in our personal lives. Being 
unaware that a law or regulation exists 
won’t excuse any violation you commit.  
 We follow the advice of our legal and •
 compliance professionals. 
 We always cooperate fully and honestly •
 with our regulatory agencies during 
examinations and inquiries. 
Comply with rules, regulations and laws 
Additional rules or regulations may apply to 
you in your home country or because of your 
specific job responsibilities. Each of us is 
responsible to know and follow the laws 
wherever we work. 
Fraud prevention 
Preventing fraud is a responsibility of everyone 
at all levels. You have a duty to be mindful of 
potential fraudulent activity and to promptly 
report anything suspicious. Fraud includes a 
wide variety of illegal acts, all characterized by 
the intent to deceive someone. Fraud can be 
committed to the detriment of the company, 
our clients, our shareholders or others, and 
can be carried out by people inside as well as 
outside of the company. 
Insider trading 
Insider trading is both illegal and unethical. 
Insider trading is the practice of buying or 
selling securities of any company, including 
Ameriprise Financial, when you are aware of 
material, non-public information about that 
company or its securities. If you are convicted 
of insider trading, you could be sentenced to 
years in prison. 
Personal trading 
Our personal trading rules, policies and 
procedures apply to everyone who is subject to 
this Code with few exceptions. These rules are 
derived from securities and investment laws, 
regulatory guidelines and other corporate 
policies. They aim to eliminate the appearance of 
conflict between the personal trading activities of 
our associates and our clients as well as the rest 
of the investing public. 
In addition to the general rules that apply 
broadly to individuals subject to the Code, 
more restrictive rules apply to certain persons 
based on their access to information and/or 
their job responsibilities. You are responsible 
for understanding the related company policies 
that apply to you.  
Why ethics matter 
Legal or regulatory violations can cost our 
shareholders millions of dollars in legal 
judgments, fines or penalties. In some 
cases, you could also face fines, the loss of 
your job and even imprisonment. The 
company often sets a higher standard than 
what the law requires, so it is important to 
understand all policies that apply to you.  
We expect you to: 
 Become familiar with the laws and •
 regulations that apply to you and your 
job, including insider trading laws, 
which apply to everyone.  
 Complete all mandatory training, •
 disclosures and other requirements 
related to your job. 
 Stay current on legal and regulatory •
 developments you need to know. 
 Report suspected insider trading, •
 market abuse or fraudulent activity 
promptly.
    8    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
 
 
I told my spouse about a 
company that Ameriprise Financial 
is considering buying. Was that 
wrong? 
Yes. First, you should not share 
confidential business information with 
anyone unless it’s necessary to do your 
job. Second, if this is material, non-
 public information and your spouse 
trades in the stock of Ameriprise or the 
other company, you both could face 
prosecution for insider trading.  
 
 
Am I subject to blackout 
periods for trading in the 
company’s stock? 
It depends on your role within the 
company. The company’s Board of 
Directors, certain executive officers and 
other designated employees are subject 
to regular quarterly blackout periods, 
during which they are prohibited from 
executing transactions in Ameriprise 
Financial securities. The blackout 
periods generally begin on Jan. 1, April 
1, July 1 and Oct. 1. The beginning date 
of each blackout period is fixed, 
regardless of whether that date happens 
to be a business day. Each blackout 
period ends two full business days after 
the public release of the last quarter’s 
earnings results. If you are subject to 
the blackout, you will receive emails 
telling you when it will begin and end.
    9    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
Do the right thing for the client 
From initial contact with prospects, through our continued service of existing individual 
or institutional client and end-client accounts, we stand behind what we say and do. 
What you need to know 
 We carefully consider the impact of our •
 decisions on clients. 
 We provide exceptional client service. •
  We are committed to making full and fair •
 disclosures. 
Full and fair disclosure 
You must make full and fair disclosure of all 
features, benefits, risks and fees of products or 
services sold or marketed to all clients and 
prospects, particularly where your interests may 
conflict with those of our clients. Full and fair 
disclosure applies to initial client communications 
as well as to subsequent recommendations.  
Your disclosures must be accurate, fair and 
balanced and presented in the proper context. 
Do not omit material facts or qualifications if 
the result would be misleading. 
Marketing, advertising and 
communications with the public  
Marketing, advertising and communications 
with the public, including clients, prospects, 
investors, analysts and the general public, 
must be truthful and accurate. You may not 
make exaggerated or misleading statements, 
regardless of whether the information is given 
directly or indirectly. You must answer all 
questions honestly and completely.  
In addition, the content must meet applicable 
regulatory and legal standards. When preparing 
advertising, marketing and communication for 
the public, you must ensure that required reviews 
and approvals are received prior to first use.  
Suitability 
Advice and products recommended must be 
suitable for each client. Always take the time to 
ensure that investment advice and products or 
services recommended are appropriate given 
a client’s age, financial situation, investment 
planning objectives and tolerance for risk. 
Also, take time to provide clients with the 
information necessary for them to fully 
understand the features, potential benefits and 
risks of the recommended product or service. 
When dealing with elderly clients, pay special 
attention to their expected financial needs and 
tolerance for risk. 
Our suitability requirements apply not only to 
initial buy, sell and hold recommendations, but 
also to subsequent recommendations in 
existing accounts. 
 
Why ethics matter 
We maintain our clients’ loyalty and improve 
their experience by acting with integrity. Our 
first priority is the success of our clients. They 
have selected us to help them reach their 
financial goals, support their children’s 
education and prepare for retirement on their 
terms. If we break that trust, our clients will 
leave us for other firms. 
We expect you to: 
 Be truthful and accurate. •
  Never mislead a client or prospect. •
  Help clients and prospects understand our •
 products and services. 
 Provide clients and prospects with all •
 information they need to make an informed 
decision about our products and services.
    10    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
 
 
 
 
My job doesn’t involve client contact. 
Recently, however, someone claiming 
to be a client was transferred to my 
number. She was upset about 
something, but I politely said I couldn’t 
help her and hung up. Was that wrong? 
Yes. In this situation, you should ask for the 
person’s name, address, telephone number 
and a brief description of the issue. After 
telling her you will find the right person to 
help her, talk to your leader about how to 
follow up. You should never try to answer a 
question if you are not qualified to do so, but 
each of us has a responsibility to do the right 
thing for our clients. 
 
We know that trust must be 
earned and are committed 
to making fair and 
accurate disclosures.
    11    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
Conduct business ethically 
We have a duty to promote the interests of the company. That means we do not use the 
company’s property or information for our own benefit or to compete with the company.
 What you need to know 
 We do not use company information and •
 property for personal gain.  
 We carefully monitor and control conflicts •
 of interest.  
 We do not give, solicit or accept gifts that •
 could influence our business judgment. 
Conflicts of interest 
You may engage in outside activities that do 
not compete or conflict with the interests of the 
company or interfere with the responsibilities of 
your job or the company’s employees. 
A conflict of interest occurs when your private 
interests interfere in any way – or even appear 
to interfere – with the interests of a client or the 
company. A conflict of interest also arises 
when you or a member of your family receives 
improper personal benefits as a result of your 
position in the company.  
You are prohibited from using your position 
with the company, or information acquired 
during your employment or relationship with 
the company, to advance your personal 
interests over the interests of clients or the 
company. 
 
Gifts or entertainment 
Generally, you may only accept gifts (including 
business-related meals or entertainment) if the 
value of the gift is not significant and the gift 
will not place you – or appear to place you – 
under any obligation to the donor.  
Before accepting a gift, you should ask 
yourself if the gift would appear significant to 
others or place you under any obligation. If the 
answer is yes, then you should not accept the 
gift. 
You may be subject to a specific policy related 
to accepting or giving gifts over a certain dollar 
value. (Please refer to policies that apply to 
you.) 
Political contributions and involvement 
We respect your right to participate in the 
political process. However, because of U.S. 
campaign finance laws, you may not:  
 Use company funds or be reimbursed for a •
 political contribution 
 Allow a candidate or campaign to use •
 company facilities or property 
 Use work time or company equipment for •
 political or campaign purposes 
 Allow your contribution of time or money to •
 appear to be made with, or reimbursed by, 
company funds 
Why ethics matter 
Employees, officers and directors owe a duty to 
the company to advance its legitimate interests. 
Your personal interests, whether winning a 
promotion or earning more compensation, are 
never more important than the best interests of 
our clients or the company. 
We expect you to: 
 Address conflicts of interest before you act. •
 If you are about to take any job action that 
may benefit you or your family, seek 
guidance before you act. 
 Avoid even the appearance of impropriety. •
  Comply with company policies related to •
 outside business activities, political 
contributions and gifts and entertainment. 
 Advisors, registered persons and −
 investment-access persons must file 
reports as required by applicable policies. 
 All other U.S. employees may report or −
 disclose to the Corporate Secretary’s 
Office using the Prior Approval and 
Disclosure form found on Inside.
    12    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
 
 
 
A client sent me a case of wine as a 
gift. I know that if I purchased the 
wine, it would be expensive. Can I 
accept this gift? 
If you are subject to a gift and 
entertainment policy, you may be required 
to decline the gift politely and return it. If 
you are a licensed person, you should 
seek advice from your registered principal 
or the Compliance Department. If you 
don’t know whether a gift policy applies to 
you, you should call the Corporate 
Secretary. Remember that you are never 
permitted to solicit a gift from a client, 
vendor or anyone else doing business 
with the company. 
 
 
Do I need to pre-clear my political 
contributions and political volunteer 
activities? 
If you are a financial advisor, you are 
subject to pre-clearance requirements. 
Otherwise, you need to refer to the 
Political Contributions policy to see if you 
are covered. Depending upon changes in 
your job or band level, you may become 
subject to pre-clearance in the future even 
if you are not covered now. Also, it's 
important to see if your current political 
contributions may affect your chances to 
apply for certain jobs in the future, due to 
the SEC’s pay-to-play rules.
    13    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
Compete fairly in the marketplace 
We believe that everyone benefits from fair, free and open markets, and we compete 
fairly in the marketplace based on the merits of our products and services.
 What you need to know 
 We must never offer, make or accept •
 unlawful payments or gifts regardless of 
local business customs.  
 We comply with all antitrust, anti-bribery, •
 anticorruption, monopoly and competition 
laws. Failure to comply can have serious 
consequences for the company and for you. 
Antitrust and competition law 
We prohibit agreements intended to limit 
competition. We expect you to avoid any 
agreement with a competitor to limit 
competition.  
 When dealing with outside companies, •
 including contractors and vendors, 
consider whether they are competing with 
Ameriprise Financial.  
 The General Counsel’s Organization is •
 available whenever you question the 
legality of a proposed activity or need 
further guidance.  
 False or misleading statements about our •
 competitors are contrary to our values and 
damage our reputation. 
 
Fair dealing 
All employees, officers and directors should deal 
fairly with our clients, investors, suppliers and 
competitors. We don’t take unfair advantage of 
anyone through manipulation, concealment, 
abuse of privileged information, misrepresentation 
of material facts or any unfair practices.  
Non-retaliation 
An individual shall not be held criminally or civilly 
liable under any Federal or State trade secret law 
for the disclosure of a trade secret that is made: 
 in confidence to a Federal, State, or local •
 government official or to an attorney solely for 
the purpose of reporting or investigating a 
suspected violation of law; or 
 in a complaint or other document filed in a •
 lawsuit or other proceeding, if such filing is 
made under seal.  
An individual who files a lawsuit for retaliation by 
an employer for reporting a suspected violation of 
law may disclose the trade secret to the attorney of 
the individual and use the trade secret information 
in the court proceeding, if the individual files any 
document containing the trade secret under seal; 
and does not disclose the trade secret, except 
pursuant to court order. 
Why ethics matter 
We operate in a highly regulated industry 
and under intense media and public 
scrutiny. Regulators and prosecutors 
recognize the importance of a strong 
ethical and compliance culture.  
We expect you to: 
 Deal fairly with clients, vendors, •
 competitors and other employees. 
 Maintain the company’s confidential or •
 proprietary information and trade 
secrets.
    14    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
 
 
 
I noticed that a contractor made a 
mistake in its invoice in our favor. 
What should I do? 
Call the contractor to discuss the invoice 
and confirm that we have been 
undercharged. If so, ask for a corrected 
invoice. That’s what we would expect if we 
made that mistake in one of our invoices. 
 
 
I’m having a business lunch with an 
official of a foreign government at an 
inexpensive restaurant. I know that he 
is an avid golfer, so I plan to give him 
a box of golf balls as a small gesture 
of appreciation for meeting with me. 
What do I need to know? 
This legal area is very complex, so seek 
advice from the General Counsel’s 
Organization before you give anything of 
value to a government official or anyone 
claiming to represent a government or a 
government-controlled entity. The United 
States Foreign Corrupt Practices Act and 
the UK Bribery Act impose severe 
penalties if you give anything of value to a 
government official. Many other countries 
are also enacting strict laws against bribery 
and corruption. In this case, even a modest 
meal and small gift can result in severe 
penalties for you and the company.
    15    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
Protect the company’s reputation and assets 
We diligently safeguard the company’s reputation, its physical and intellectual property 
and all sensitive information.
 What you need to know 
 We consider our reputation one of our •
 most valuable assets. 
 We protect our assets and use them for •
 appropriate business purposes. 
Anti-money laundering and identity theft 
The company maintains policies and 
procedures to prevent and detect money 
laundering and identity theft. Suspicious 
activity takes many forms and is hard to define 
in absolute terms; however, common 
examples of “red flags” are included in the 
company’s related policies. If you ignore or 
choose not to report suspicious activity, both 
you and the company could be considered 
willfully blind and held liable for the criminal 
activity. 
Report concerns by submitting a Report of 
Unusual Activity, which can be found on Inside 
or the AdvisorCompass® site. 
Company property 
Our company property, including equipment, 
supplies, systems and facilities, must only be 
used for valid business purposes. Theft, 
carelessness and waste have a direct impact on 
our profitability. If you suspect someone was 
involved in, or is attempting to cover up, the theft 
or misuse of company property, immediately 
report it to your local security personnel or to 
SecurityAMPF@ampf.com. 
Intellectual property 
Intellectual property is one of the most 
valuable assets of our company. Our logos 
and branding (e.g., trademarks, service marks) 
stand as a unique symbol of the quality, 
integrity and reliability that underlie all our 
products and services. Moreover, they serve to 
identify us to the world and set us apart from 
our competitors. 
The use of all logos and brand names, such as 
“Ameriprise Financial,” “RiverSource,” 
“Columbia Threadneedle Investments,” 
“Columbia Management” and “Threadneedle” 
must conform with company policy. 
We will also never knowingly infringe on the 
intellectual property rights of others. You are 
responsible for confirming that the use of any 
third-party intellectual property is approved and 
done with written permission. This includes, 
but is not limited to, computer programs, 
brands, logos and periodicals. 
Why ethics matter 
Our ability to attract and retain clients, 
advisors and employees depends on our 
reputation as an ethical, honest and law-
 abiding company. Anything that you do, 
whether at work or in your personal life, that 
damages our reputation is a serious matter. 
Be especially careful not to post or say 
anything on social media that could embarrass 
you or damage the reputation and brand we 
have worked so hard to establish. Remember 
that your obligation to comply with the Code 
doesn’t stop when you leave the office.  
We expect you to: 
 Be alert to situations or actions that may  •
 be unethical or potentially damaging to the 
company’s reputation. 
 Watch for warning signs that may signal •
 fraudulent activity and report any 
suspicious activity. 
 Use company property only for valid  •
 business purposes and with proper 
authorization.  
 Protect all company and client property  •
 and assets against theft or misuse.
    16    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
 
 
 
I hear leaders refer to 
enterprise risk management. 
What does it mean to me in my 
role? 
Like all financial services companies, we 
face various risks that could harm our 
company, clients and shareholders. We 
invest significant time and money to 
identify and manage these risks, but of 
course it’s impossible to eliminate many 
of them. Even if an event is completely 
out of our control, such as a natural 
disaster or act of terrorism, we need to 
anticipate it as much as possible and be 
able to respond effectively. Risks can 
become more serious over time and 
new risks are emerging constantly. 
Our Board of Directors and Executive 
Leadership Team are focused on risk 
management because it’s crucial to our 
continued success. We also have 
talented teams of officers and 
employees around the world who are 
devoted to risk management. To be truly 
effective in identifying, monitoring and 
managing risk, each of us must think 
and act like a risk manager.  
Regardless of your job or level of 
responsibility, we expect you to be part 
of our risk management program. Each 
of us is a risk manager.
    17    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
Safeguard and maintain accurate information 
We diligently safeguard the personal information of our clients. We believe that 
accurate recordkeeping and reporting are essential to our reputation and credibility.
 What you need to know 
 We collect, safeguard and disclose client or •
 sensitive information only in compliance with 
the law and our policies. 
Confidentiality and privacy 
We maintain the confidentiality of information 
entrusted to us by the company and our clients. 
Confidential information includes all non-public 
information that might be of use to competitors or 
harmful to the company or its clients if released. 
Only employees with a business need-to-know 
reason are allowed access to such data. Report 
privacy incidents or unauthorized access to 
sensitive information to 
Privacy.Swat.Team@ampf.com.  
Financial and business information 
Maintaining accurate and complete business and 
financial records, including financial statements 
and accounts, expense reports, time records and 
invoices, is not just the job of Accounting and 
Finance personnel. 
 Always record and classify transactions in •
 the proper accounting period and in the 
appropriate account and department.  
 Never delay or accelerate the recording of •
 revenue or expenses. 
 Always support estimates and accruals with •
 appropriate documentation based on your 
best judgment. 
 Never falsify any document or distort the true •
 nature of any transaction. 
 Never enable another person’s efforts to •
 evade taxes or subvert local currency laws.  
 Only make payments to the person or firm •
 that actually provided the goods or services. 
Records management 
We maintain appropriate books and records 
according to the law and our policies. We do not 
shred, destroy or alter documents that are 
related to any imminent or ongoing investigation, 
lawsuit, audit, examination or are required to be 
maintained for regulatory purposes. 
Signature issues and forgery  
Employees, advisors or staff may not copy, 
affix or trace a client’s signature or sign any 
document on behalf of a client, even if 
specifically asked to by the client. A signature 
is considered forged if it was signed by 
someone other than the person named, or  
that person’s legally authorized representative. 
Whenever a client signature is required, it must 
be an original signature of the client or his or 
her legally authorized representative. 
Why ethics matter 
Many data breaches and cybersecurity 
incidents are the result of employee mistakes 
or negligence. Carelessly clicking a link in an 
email or opening an attachment could result in 
a serious cybersecurity incident. You’ve 
probably read about incidents at other 
companies that have cost millions to resolve. 
You play a role in being attentive and doing 
everything you can to avoid one at Ameriprise. 
We expect you to: 
 Protect the privacy, confidentiality and •
 security of client, employee, advisor and 
company information. 
 Keep accurate business and financial •
 records. 
 Safeguard sensitive information from •
 unauthorized disclosure. 
 Report financial and other business •
 information truthfully, accurately and 
completely. 
 Maintain all business records in •
 accordance with the company’s policies 
and procedures.
    18    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
 
 
A package mailed by a client 
containing a completed 
application and a check looked 
like it had been opened. Do I 
need to tell anyone about this?  
Yes. Even if nothing appeared to be 
missing, this is still a potential breach of 
the client’s privacy. Send an email to 
Privacy.Swat.Team@ampf.com, who 
will research and identify potential risk. 
 
 
Contact your leader, registered 
principal, the Employee 
Relations Group Service 
Center at 1.877. 267.4748, the 
Ethics Hotline at 
1.800.963.6395 or Safe Call in 
the UK at 0800 915 1571 if you: 
 Believe financial information or •
 business records are not reported or 
maintained accurately and 
completely. 
 Feel pressure to report inaccurate or •
 incomplete financial or business 
information.  
 Are asked to prepare or destroy •
 documents in violation of company 
policy.
    19    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
Treat everyone with dignity and respect 
We value our people, encourage their development and reward their performance. 
What you need to know 
 We are good citizens in our communities.  •
  We make all reasonable efforts to maintain a •
 safe and healthy work environment for our 
employees and visitors. 
 We prohibit discrimination or harassment.  •
 Equal employment opportunity 
Employees, financial advisors and leaders are 
responsible for complying with the company’s 
Equal Employment Opportunity Policy, Individual 
Treatment Policy and related policies, and anti-
 discrimination and anti-harassment laws. 
Leaders have the added responsibility of 
ensuring compliance with those policies and 
laws. 
Freedom from discrimination 
We prohibit discrimination or harassment against 
any person on the grounds of race, color, 
religion, national origin, disability, age, sex, 
marital status, sexual orientation, gender identity, 
veteran status or citizenship. 
Each of us, particularly leaders, is responsible for 
creating and maintaining a work environment 
free of discrimination and harassment. 
 
 
Freedom from fear and violence in the 
workplace 
We prohibit the possession of weapons in the 
workplace or when conducting business on 
behalf of the company. You may not assist or 
permit others to possess weapons in the 
workplace. 
Importance of diversity 
We are committed to valuing and supporting 
diversity in the workplace and community. 
Employees, field members and staff represent 
many age groups, ethnicities, family structures, 
races, religions, sexual orientations, nationalities 
and mental and physical abilities.  
Non-retaliation 
We do not retaliate against or intimidate an 
individual who makes a complaint, assists in 
making a complaint or is a witness in an 
investigation. Our values and the law protect an 
individual who, in good faith, reports 
discrimination, harassment, threats of violence or 
any inappropriate behavior. 
Safety, health and the environment 
We make all reasonable efforts to provide and 
maintain a safe and healthy working environment 
for our employees and visitors.
 Why ethics matter 
We expect all persons to behave in a values-
 driven manner, which includes welcoming 
diversity and treating all people with dignity 
and respect. Discriminatory treatment and 
harassment are illegal and violate our 
company values. Therefore, we encourage 
individuals to report any violations.  
We expect you to: 
 Treat others the way you would like to  •
 be treated. 
 Be an example to the next generation  •
 of leaders. 
 Support a diverse and safe work •
 environment. 
 Notify your local or onsite security •
 personnel or local law enforcement 
immediately if you see anyone exhibiting 
threatening behavior or if there is a 
potentially dangerous situation at your 
workplace.  
 Security Services −
 1.800.455.5187 
 Safe Call (UK) −
 0800 915 1571 
 Employee Relations Group  −
 Service Center  
ERGSC@ampf.com
    20    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
 
 
 
 
A colleague in my department has 
been acting very erratically lately. 
He complains that he has been 
treated unfairly at work and talks 
about “getting even” with people. 
What should I do? 
Call Security Services or your local 
security personnel immediately and 
explain the situation. You share the 
responsibility of helping the company 
maintain a safe environment for all of 
our employees and visitors. As long as 
you act in good faith, you will not face 
any retaliation for sharing your 
concerns.
    21    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
Navigate your ethical questions 
Consider your actions carefully. Ask for guidance when you need it. 
What you need to know 
 We make decisions with integrity. •
  We expect our leaders to set an example of •
 courteous and respectful behavior toward 
their team members and others. 
Related policies 
The Code of Conduct and the related policies 
cannot, and do not attempt to, address every 
possible situation or circumstance that you 
may encounter. You are responsible for 
becoming familiar with the Code of Conduct 
and related policies, adhering to the principles 
and rules stated in them and seeking advice 
and guidance when you are uncertain as to the 
proper course of action. 
If you are a leader 
Leaders at all levels are responsible for 
continually emphasizing integrity as a standard 
of performance for all employees, 
demonstrating how employees and others 
should be treated with dignity and respect and 
creating and maintaining a work environment 
free of discrimination and harassment. 
 Leaders should always seek legal advice •
 about the laws that may apply to a 
particular situation. 
 Leaders are responsible for the health, •
 safety and welfare of their departments, 
and everyone reporting or assigned to 
them, including visitors and contractors, 
regardless of their work location. 
If you are an individual contributor 
We expect all leaders to set the right ethical 
example for the company and its employees, 
regardless of how many people they lead. But 
even if you aren’t a leader, we expect you to 
be an example of this same honest and ethical 
behavior for others on your team. Remember 
that others may model their behavior based on 
yours, especially if you have more experience 
or have been with the company for a longer 
period of time. Never make jokes about 
complying with the law, our policies and 
procedures or the Code of Conduct. Never 
belittle anyone for asking what the right thing 
to do is.  
 If someone on your team asks for your •
 advice on how to handle an ethical 
question, encourage him or her to speak 
with your leader. 
 Be supportive and remind the person that •
 we have a strict policy against retaliation 
for reports made in good faith. 
 How you behave and what you say •
 matters.  
 
We expect you to: 
 Be aware of the consequences of your •
 actions. 
 Ask for guidance when you need it. •
  Ask yourself about a potential behavior or •
 action: 
 Is it consistent with the Code and other −
 company policies? 
 Is it ethical? −
  Is it legal? −
  Am I setting a good example? −
  Will it put the company at undue risk? −
  Will it reflect poorly on the company  −
 or me? 
 Would I want to read about it in the −
 news or on social media? 
 How would I explain my actions to my −
 colleagues, friends and family?
    22    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES 
Consequences for non-compliance 
Remember that asking for guidance before you act may help you avoid disciplinary 
action for violating the Code or a law, rule or regulation. 
What you need to know 
 We will not accept ignorance or oversight as •
 excuses for behavior that violates the Code, 
related policies or any law or regulation. 
 We retain the right to determine whether •
 specific actions or behaviors violate the 
Code of Conduct.  
Violations of the Code 
Personal conduct that violates the Code 
includes, but is not limited to: 
 Willful or negligent damage to company •
 property or property of others 
 Theft or dishonesty, including falsification of •
 company records or furnishing false or 
incomplete information on expense forms, 
time records, employment applications or 
other documents related to your employment 
 Inappropriate behavior that is harmful or •
 embarrasses the company or its clients, 
including posting or transmitting offensive or 
inappropriate material on the internet or any 
social media site 
 Disruptive behavior, including •
 insubordination, willful disregard of company 
policies or procedures, disrespect toward a 
leader or member of management or failure 
to perform work as required or assigned 
 Violations of safety or health laws or •
 regulations or engaging in conduct that 
creates a safety or health hazard 
In addition, if you violate the law during the 
course of your employment you may be subject 
to criminal and civil penalties as well as payment 
of monetary damages to the company or third 
parties. 
Disciplinary action may be taken against an 
employee or advisor who: 
 Authorizes, directs, approves, participates in •
 or encourages violations of the Code 
 Deliberately fails to report or conceals •
 violations or deliberately withholds or 
misstates relevant information 
 Retaliates against any other employee •
 because he or she reported a suspected 
violation in good faith 
 Knew or should have known about a •
 violation by people under his or her 
supervision and did not promptly report it
 We expect you to: 
Talk to your leader or any of these resources 
about any situation that concerns you: 
 Your Human Resources  •
 business partner  
 Employee Relations Group Service •
 Center – 1.877.267.4748 
 General Counsel’s Organization – •
 1.612.671.3651 
 Executive Vice President, Human •
 Resources – 1.612.671.3997 
 Corporate Secretary’s Office – •
 1.612.678.0106 
 Ethics Hotline – 1.800.963.6395 •
  Personal Trading Hotline – •
 1.612.671.5196 
 Suspicious Activity Hotline – •
 1.612.671.6166 
 Safe Call (UK) – 0800 915 1571 •
  FCA Whistleblowing (UK) –  •
 whistle@fca.gov.uk 
 Public Concern at Work (UK) –  •
 helpline@pcaw.co.uk
    23    
CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |     ETHICAL PRINCIPLES     |     CONSEQUENCES FOR NON-COMPLIANCE     |     NAVIGATE YOUR ETHICAL QUESTIONS     |     RESOURCES 
 Resources 
Refer to related company policies, procedures or related resources for questions or 
additional information. 
This list contains only a portion of the policies and procedures that may apply to you or that may provide helpful guidance in your role. 
Search Inside, AdvisorCompass, Complisource or other company intranet systems for these and additional policies. 
 Ameriprise Financial Global Anti-Money •
 Laundering and Economic Sanctions Policy  
 Ameriprise Financial Personal Trading Policy •
  Ameriprise Financial Political Contributions ("Pay •
 to Play") Policy  
 Ameriprise Financial Public Appearances and •
 Interaction with the Media Policy  
 Antitrust Guidelines  •
  Client Privacy Principles  •
  Columbia Management Activities Involving •
 Outside Entities or Family Relationships Policy  
 Columbia Management Employee Registration •
 and Licensing  
 Columbia Management Firm Registration, •
 Regulatory Filings, and Disclosure Policy  
 Columbia Management Gifts, Entertainment and •
 Other Benefits Policy  
 Columbia Management International Compliance •
 Policy for Columbia Management Non-U.S. / 
Offshore Sales and Service Activities  
 Columbia Management Material Nonpublic •
 Information Policy  
 Columbia Management Political Contributions •
 Policy  
 Columbia Management Portfolio Holdings •
 Disclosure Policy  
 Columbia Management Privacy and Information •
 Security and Identity Theft Prevention Program 
 Conducting Competitive Intelligence Activities  •
  Corporate Compliance Manual  •
  Corporate Supervision Manual  •
  Dual Registration Policy  •
  Electronic Communication Acceptable Use •
 Policy 
 Enterprise Abandoned Property Policy  •
  Equal Employment Opportunity Policy •
  Facility Rules, Guidelines and Standards of •
 Use 
 Fair Labor Standards Act  •
  Gifts and Business Entertainment Policy - •
 Ameriprise Financial Services, Inc.  
 Gifts and Business Entertainment Policy - •
 American Enterprise Investment Services 
 Global Anti-Corruption Policy and Guidelines  •
  Global Asset Management Code of Ethics •
 Personal Accounts Dealing Policy  
 Handling Whistleblower Claims Policy •
  HIPAA Policies and Procedures Manual  •
  Identity Theft Prevention Policy  •
  Individual Treatment Policy •
  Intellectual Property  •
  Licensing and Registration  •
  Mandatory Training: Annual Requirements  •
  Mandatory Training: New-Hire Requirements  •
  Notification to Consolidated Regulator of Intra-•
 Group Transactions Policy  
 Outside Business Activities Policy  •
  Public Communications Policy  •
  Record and Information Management  •
  RiverSource Gifts, Entertainment and Benefits •
 Policy  
 Social Media Policy •
  Threadneedle Other Conflicts of Interest •
 Policies Applicable to Covered Persons  
 Threadneedle Market Abuse & Insider Dealing •
 Policy  
 Threadneedle Conflicts of Interest Policy  •
  Threadneedle Outside Activities & Family •
 Relationships Policy  
 Threadneedle Gifts & Corporate Hospitality •
 Policy  
 Threadneedle Treating Customers Fairly  •
  Threadneedle Whistleblowing Policy   •
  Your Guide to a Safe and Respectful •
 Workplace Policy Snapshot
 Financial Planning | Retirement | Investments | Insurance 
Ameriprise Financial, Inc. 
Corporate Secretary’s Office 
1098 Ameriprise Financial Center, Minneapolis, MN 55474 
ameriprise.com 
Revised January 2017 
© Ameriprise Financial, Inc. All rights reserved. 
Notes 
 
This document does not create a contract of employment or a contract for any specific term or condition of employment between Ameriprise 
Financial and an employee. Except as provided otherwise by the laws of a foreign jurisdiction, the relationship between Ameriprise Financial and 
an employee is at-will, meaning that either the employee or the company may terminate it at any time for any reason, with or without advance 
notice or progressive disciplinary action. The company reserves the right to make changes in or discontinue company policies, compensation 
plans, benefits and programs as it deems appropriate and these changes may be implemented even if they have not been communicated in this 
(or by change to this) document or otherwise.  
If this document refers to any company benefit program, it describes only certain highlights of the company’s benefit program. It does not 
supersede the actual provisions of the applicable plan documents, which in all cases are the final authority. The applicable plan administrator has 
the sole authority and discretion to determining your eligibility to participate in the plan, interpret the plan documents and administer of the plans.  
Ameriprise Financial takes reasonable efforts to ensure the accuracy of the contents of policy documents and in the administration of its policies 
and programs. The company does not assume responsibility for consequential damages caused by administrative or clerical errors.