Exhibit 14(c) 
 
 
 
 
 
 
 
 
 
Global Code of Conduct 
 
 
 
 
 
 
OUR VALUES 
 
                    
 
 
 
Client-focused Integrity always Excellence          Respect
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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
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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
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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.
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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.
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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
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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.
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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 one full business day 
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.
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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.
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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.
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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.
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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.
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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.
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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. 
Protect the company’s reputation and assets
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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.
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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.
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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 
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.
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an original signature of the client or his or her legally authorized representative.  
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.
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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
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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.
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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?
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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
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 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 July 1, 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.