COLUMBIA THREADNEEDLE INVESTMENTS  GLOBAL PERSONAL ACCOUNT DEALING AND   CODE OF ETHICS       Policy Type Global Policy  Last Review Date December 2021  Applicable Global  Regulatory Authorities  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  MAS guidelines on Risk Management Practices-Internal  Controls  MAS Guidelines on Individual Accountability and Conduct  Code of Conduct for Persons licensed by the Securities and  Futures Commission  Section 13 of the Bank Holding Company Act known as the  “Volcker Rule”  JFSA “Comprehensive Guideline for Supervision of Financial  Instruments Business Operators, etc.”  Japan Investment Advisors Association self-regulation   Related Policies  See Appendix C-Other Policies Applicable to Covered  Persons  Applicability and Scope  All Covered Persons and certain household members,  trusteeships and executorships of Covered Persons. 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.           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  Global Asset Management Entities1  (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.   • To ensure that investment advice is suitable to the client’s investment objectives, needs and  circumstances.     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.           • 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.           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, including employees of Columbia Wanger  Asset Management (CWAM) and Lionstone.  • 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)
 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.           Disclosure of Brokerage Accounts  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 all confirmations of securities  transactions and of all monthly, quarterly and annual account statements.  In order to comply with  regulatory expectations concerning the monitoring of trading activity within Covered Persons’ accounts,  there are requirements on where brokerage accounts may be maintained for the trading of certain types  of securities.   Please refer to Appendix H – Limited Choice Policy for specific information by region.    Notification of Brokerage Accounts  Covered Persons must immediately report any 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).  North America employees – any brokerage account outside of Limited Choice brokers (as listed in  Appendix H) 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.   UK/APAC employees – Employees are required to authorize the electronic feeds between the approved  brokers listed in Appendix H and Columbia Threadneedle Investments.   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; in North America preclearance is good only for the day it is granted, in EMEA/APAC  preclearance is good for the day granted and until the end of the following business day. If a Covered  Person does not effect 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  effect 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, Exchange Traded Funds (“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.
 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.           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  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.   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.   Initial Public Offerings (“IPOs”) and Limited Offerings/Private Placements:   • Equity IPOs in North America are prohibited including direct purchased programs.    • Covered Persons are required to obtain pre-clearance approval to purchase IPOs or Limited  Offerings/Private Placements, including additions to existing holdings but excluding capital calls for  previously approved commitments.   • Such approval will only be granted when 1) it is determined that the investment in a private fund (if  a proprietary private fund) meets the applicable banking regulatory requirements2 and 2) 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.     2 The review of applicability of banking requirements will occur during the subscription process.
 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.             Cryptocurrency3:   Transactions:  Transactions in cryptocurrency, such as Bitcoin, Ethereum, Lite Coin etc., do not require  reporting. However, transactions in any publicly traded cryptocurrency tracker instrument, such as  Grayscale’s Bitcoin Investment Trust (“GBTC”), require pre-clearance approval, must be held and traded  at an approved broker (See Appendix H).    Accounts:  Cryptocurrency accounts are not reportable and must be at firms that offer ONLY  cryptocurrency investments.  Accounts at firms that also offer brokerage options are prohibited.  Initial Coin Offerings (“ICOs”): Participation in ICOs is prohibited.  Participation in Investment Clubs:   No Covered Person may participate in private investment clubs or other similar groups.   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.  Columbia Wanger Asset Management (CWAM) Specific Trading Restrictions:  No CWAM Covered Person shall purchase any Reportable Security that is owned by a CWAM Client  Account (excluding ETFs).                3 Personal Trade Compliance continues to monitor the evolving digital assets/cryptocurrency space and the impact on  Covered Persons under the Policy.  These requirements may change if regulatory guidance or rules should be provided.   All Covered Persons are encouraged to contact Personal Trade Compliance prior to transacting in any form of digital  assets/cryptocurrency to ensure compliance with the latest regulatory and firm guidance/requirements.
 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.             Additional Trading Restrictions for Investment Personnel  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 (and other Designated Covered Persons) 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:  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.
 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.           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.           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.   MAS Guidelines on Individual Accountability and Conduct – the Board and senior management should  ensure that a framework is in place to address the standards of conduct expected of all employees. This  includes fair dealing (treating customers fairly) and management of conflicts of interest.  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.
 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.           2.2. 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.   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’s 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.           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.)   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 (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 or other entities listed in  Appendix B.   Reportable Security “Reportable Security” includes all corporate securities, options on securities, warrants,  rights, ETFs and municipal securities.    “Reportable Security” excludes:  direct obligations of the United States government; bankers’ acceptances,  bank certificates of deposit, commercial paper and high quality short-term debt instruments, including  repurchase agreements; insurance company general accounts (short-term cash equivalent options of a  variable life insurance policy); shares of a money market fund or other short-term income or short-term  bond funds; shares of any open-end mutual fund, including any shares of a Reportable Fund; and futures  and options on futures.
 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.           APPENDIX B-ENTITIIES THAT HAVE ADOPTED POLICY  Ameriprise Certificate Company (ACC)  Columbia Cent CLO Advisers, LLC (CCCA)  Columbia Management Investment Advisers, LLC (CMIA)  Columbia Management Investment Distributors, Inc. (CMID)  Columbia Management Investment Services, Corp.(CMIS)  Columbia Wanger Asset Management, LLC (CWAM)  Lionstone Partners, LLC (Lionstone)  The Threadneedle group of companies*  * The Threadneedle group of companies comprises those companies whose holding company is TAM UK  International Holdings Limited and Ameriprise Asset Management Holdings Singapore (PTE.) Limited.
 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.           APPENDIX C – OTHER POLICIES APPLICABLE TO  COVERED PERSONS  Ameriprise Financial Global Code of Conduct  Ameriprise Handling Whistleblower Claims Policy  Ameriprise Limited Choice Policy  CTI NA Policy - Privacy and Information Security and Identity Theft Prevention Program  Global Policy – Inside Information  Global Policy - Portfolio Holdings Disclosure 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.           APPENDIX D –RESOURCES  Compliance Resources  Send email to Personal.Trading@ampf.com  or call Personal Trading - 612-671-5196   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  Protect https://protect- advice.org.uk/advice-line/p  020 3117 2520    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.           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 ETFs, Closed End Funds and  publicly traded crypto-related securities, except those listed below:    • Ameriprise Financial Stock4 (only)   • Annuities and Life Insurance (where there is no specific investment exposure)   • Bank products (checking/savings, CDs, etc.)   • Currencies   • Digital assets/cryptocurrencies  • 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 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:  • Ameriprise Financial Stock  • 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)     4 Other rules, including blackout and holding periods, still apply and there can be no speculative trading in Ameriprise  Financial Stock.
 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.           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.” 5  The following is the list of Covered Funds as of December 2021:  • All Columbia Mutual Funds (both retail and variable), including Columbia Acorn Funds, Wanger Funds,  and Multi-Manager Funds offered through Ameriprise Financial advisory programs  • All Columbia ETFs  • All Columbia Threadneedle – EMEA and Asia Funds  • Columbia Seligman Premium Technology Growth Fund, Inc.  • Tri-Continental Corporation  • BMO Disciplined International Fund, Mid-Cap Value Fund, Small-Cap Value Fund, Mid-Cap Growth  Fund, Dividend Income Fund, Large Cap Value Fund, Low Volatility Equity Fund, Large Cap Growth  Fund, Small-Cap Growth Fund     Third-Party Funds Sub Advised by CMIA:  • Destinations Large Cap Equity Fund  • NVIT Columbia Overseas Value Fund  • Pathway Large Cap Equity Fund  • SA Columbia Focused Value Portfolio  • VALIC Company I Capital Appreciation Fund  • VY Columbia Contrarian Core Portfolio  • VY Columbia Small Cap Value II Portfolio    5 Under the Volcker Rule, certain employee investments/holdings in proprietary funds may need to be reviewed to  ensure that the holdings meet banking exclusions and exemptions requirements.  Employees identified as “senior  executive officers or directors” may need to provide holdings data for these funds on an ad hoc basis for analysis by the  GCO.
 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.           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 Policy should not deal 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.           APPENDIX H-LIMITED CHOICE POLICY  In order to comply with regulators expectations concerning the monitoring of trading activity within  Covered Person accounts, Ameriprise Financial and Columbia Threadneedle Investments maintain 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 in  Section 1.2 of Policy.  Securities subject to the Limited Choice Policy must be held, and trading must be conducted, through  one of these brokers.  Due to global availability of certain brokers and electronic feeds from those  brokers, each region has specific requirements that must be followed for that region:  • Ameriprise/Columbia Threadneedle North America - Ameriprise Financial Brokerage, Charles  Schwab, Merrill Lynch   • Columbia Threadneedle UK – Barclays, Hargreaves Lansdown, Interactive Brokers (Charles  Schwab and Merrill Lynch – restricted to U.S based accounts only)  • Columbia Threadneedle EMEA, excluding UK -.  Employees of Columbia Threadneedle EMEA must  report their broker accounts on PTA prior to trading and provide contract notes to Personal Trade  Compliance as soon as practicable following execution of their trade.    • Columbia Threadneedle APAC - Singapore employees are encouraged to use UOB and Interactive  because they do provide electronic feeds.  Employees of Columbia Threadneedle APAC must report  their broker accounts on PTA prior to trading and provide contract notes (if not on an electronic feed)  to Personal Trade Compliance as soon as practicable following execution of their trade.      If you maintain a brokerage account outside of the approved 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 for  your region.  See Notification of Brokerage Accounts in Section 1.2 of Policy.  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 with all other requirements in Policy).  Covered Persons must comply with the Limited Choice Policy requirements within 30 days of becoming a  Covered Person.