<PAGE>

                                                                   EXHIBIT 14(b)

                        INVESTMENT ADVISER CODE OF ETHICS
                                      FOR
                             RETAIL ACCESS PERSONS:

     -    EMPLOYEES, INCLUDING P1 & FSC ADVISORS

     -    P2 ADVISORS AND EMPLOYEES/CONTRACTORS OF P2 ADVISORS

                       AMERIPRISE FINANCIAL, INC. AND ITS
                                   AFFILIATES

                                   APRIL 2008


IA Code of Ethics for Retail Access Persons                                    1

<PAGE>

                        INVESTMENT ADVISER CODE OF ETHICS
                  AMERIPRISE FINANCIAL, INC. AND ITS AFFILIATES

<TABLE>
<S>                                                                           <C>
OVERVIEW...................................................................    3
   Required Standards of Business Conduct..................................    4
   General Policy on Accepting Gifts.......................................    5
   Fiduciary Principles....................................................    5
DEFINITIONS................................................................    7
PERSONAL TRADING RULES FRAMEWORK...........................................    8
   Applicability...........................................................    8
   General Rules...........................................................    9
   Basis for Rules.........................................................   11
REPORTING REQUIREMENTS FOR RETAIL ACCESS PERSONS...........................   12
   Securities Activities Which Must Be Reported............................   12
   How To Comply...........................................................   12
   Exceptions to Limited Choice............................................   13
   Securities Reporting for Retail Access Persons..........................   14
ADDITIONAL RULES & REPORTING REQUIREMENTS..................................   16
   Limited Offerings (Private Placement) Preclearance - Equity and Fixed
      Income...............................................................   16
   Initial Holdings Disclosure.............................................   17
   Annual Certification and Annual Holdings Disclosure.....................   17
   Quarterly Reporting and Certification...................................   17
   Investment Clubs........................................................   18
   Sanctions...............................................................   19
   Unusual Trading Activity................................................   19
RESPONSIBILITIES OF THE CHIEF COMPLIANCE OFFICER...........................   20
AMERIPRISE FINANCIAL INSIDER TRADING POLICY................................   21
   A. General..............................................................   21
   B. What is "Material Non-Public Information"?...........................   21
   C. Criminal and Civil Penalties and Regulatory Sanctions for Insider
      Trading..............................................................   23
   D. Prohibitions Regarding Misuse of Material Non-Public Information.....   24
</TABLE>

Appendix A: Initial Personal Account and Holdings Disclosure
Appendix B: Brokerage Account Notification Form
Appendix C: Limited Choice Exception Request
Appendix D: Investment Club Client Disclosure Form


IA Code of Ethics for Retail Access Persons                                    2

<PAGE>

                                    OVERVIEW

AS A CONDITION OF YOUR CONTINUED EMPLOYMENT OR ASSOCIATION WITH AMERIPRISE
FINANCIAL, INC. OR ITS AFFILIATES ("AMERIPRISE FINANCIAL"), YOU ARE REQUIRED TO
READ, UNDERSTAND, AND FULLY COMPLY WITH THIS CODE OF ETHICS. THE CODE OF ETHICS
ALSO INCORPORATES INTO ITS TERMS AND REQUIREMENTS THE PROVISIONS OF OTHER
IMPORTANT DOCUMENTS TO WHICH YOU ARE SUBJECT; NAMELY, THE AMERIPRISE FINANCIAL
CODE OF CONDUCT AND, FOR FINANCIAL ADVISORS AND THEIR EMPLOYEES, THE POLICIES
AND PROCEDURES CONTAINED IN THE REGULATORY INFORMATION CENTER.

It is your personal responsibility and accountability to avoid any conduct that
could create a conflict, or even the appearance of a conflict, with our clients'
interests, or do anything that could damage or erode the trust our clients place
in Ameriprise Financial. This is the spirit of the Code of Ethics. Every person
has the absolute obligation to comply with both the letter and the spirit of the
Code. Failure to comply with its spirit is just as much a violation as a failure
to comply with the written provisions of the Code. In this regard, you should
also be aware that it is impossible for the Code of Ethics to cover every
situation you may encounter. In situations that are not specifically covered by
the Code we must follow the spirit of the Code. If you are uncertain as to the
appropriate course of action, you should seek immediate assistance from your
leader, Personal Trade Compliance, the Chief Compliance Officer, or by calling
the Employee Relations Group Service Center at 877-267-HR4U, option 2. If the
Code of Ethics is silent on a particular matter, it does not authorize conduct
that violates the spirit of the Code.

The Code covers not only the activities you perform on a day-to-day basis, but
also your personal securities transactions as well as those of certain of your
family members and entities (such as corporations, trusts, or partnerships) that
you may be deemed to control or influence.

Appropriate sanctions will be imposed for violations of the Code of Ethics.
Sanctions may include bans on personal trading, financial penalties,
disgorgement of trading profits, suspension of employment, and/or termination of
employment or association with Ameriprise Financial. Repeat violations of the
Code will result in progressively stronger sanctions. Self-reporting a violation
of the Code will be considered in determining the appropriate sanction for the
violation.

This Code will be provided to all individuals who are subject to its terms.
AFTER YOU RECEIVE AND REVIEW THE CODE, YOU MUST CERTIFY THAT YOU HAVE RECEIVED,
READ AND UNDERSTAND THE DOCUMENT AND AGREE THAT YOU ARE SUBJECT TO IT AND WILL
COMPLY WITH IT. You are also required to provide similar certifications when the
Code is amended. On an annual basis you must certify that you have complied with
the Code during the past year and will continue to do so going forward.


IA Code of Ethics for Retail Access Persons                                    3

<PAGE>

REQUIRED STANDARDS OF BUSINESS CONDUCT

UNDER THIS CODE OF ETHICS ALL SUPERVISED PERSONS OF AMERIPRISE FINANCIAL MUST
COMPLY WITH AMERIPRISE FINANCIAL'S STANDARDS OF BUSINESS CONDUCT. THESE
STANDARDS ARE THE FOLLOWING:

     -    COMPLIANCE WITH ALL APPLICABLE LAWS AND REGULATIONS, INCLUDING THE
          FEDERAL SECURITIES LAWS AND OUR FIDUCIARY OBLIGATIONS;

     -    COMPLIANCE WITH THIS CODE OF ETHICS;

     -    COMPLIANCE WITH THE AMERIPRISE FINANCIAL CODE OF CONDUCT;

     -    COMPLIANCE WITH ALL OTHER POLICIES AND PROCEDURES APPLICABLE TO YOUR
          POSITION AND ASSIGNED RESPONSIBILITIES, INCLUDING ANY SPECIFIC GIFT
          POLICIES;

     -    FINANCIAL ADVISORS AND THEIR EMPLOYEES MUST ALSO COMPLY WITH THE
          POLICIES AND PROCEDURES CONTAINED IN THE REGULATORY INFORMATION
          CENTER.

THESE STANDARDS APPLY TO ALL INDIVIDUALS, AT ALL LEVELS OF THE ORGANIZATION.
COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS IS MANDATORY FOR EVERYONE AND IS
NOT SUBJECT TO BUSINESS PRIORITIES OR INDIVIDUAL DISCRETION. IF AT ANY TIME YOU
HAVE A QUESTION ABOUT THE LEGALITY OF A COURSE OF ACTION YOU SHOULD CONSULT WITH
THE GENERAL COUNSEL'S OFFICE BEFORE PROCEEDING.

The Investment Advisers Act of 1940 imposes a fiduciary duty on an investment
adviser to act in utmost good faith with respect to its clients, and to provide
full and fair disclosure of all material facts, particularly where the adviser's
interests may conflict with the client's. The Adviser has a duty to deal fairly
and act in the best interests of its clients at all times.

All employees and certain other associated persons of Ameriprise Financial must
also comply with the Ameriprise Financial Code of Conduct. The Code of Conduct
deals with issues covering, among other things, the acceptance of gifts, service
on the boards of public companies and other outside activities. For specific
guidance on these and other topics that may not be specifically covered by the
Code of Ethics you should refer to the Code of Conduct and the Regulatory
Information Center.

All financial advisors and their employees associated with Ameriprise Financial
must comply with the policies and procedures contained in the Regulatory
Information Center. The provisions of the Code of Ethics and the Regulatory
Information Center should not conflict. In the event the provisions of the Code
of Ethics or the Regulatory Information Center conflict or appear to conflict
with those contained in the Code of Conduct you should follow the guidance
contained in the Code of Ethics or the Regulatory Information Center. If at any
time you feel there is ambiguity as to what the appropriate course of action
should be in a particular situation you should immediately seek assistance from
the General Counsel's Office or the Compliance Department before you act.

You are also subject to compliance policies and procedures and other policies
and procedures adopted by the organization. You are responsible for being
familiar with and complying with these policies and procedures. If you are
uncertain as to these additional policies and procedures to which you are
subject, speak with your leader.

As described in greater detail below, the Code of Ethics also addresses personal
securities trading activities in an effort to detect and prevent illegal or
improper transactions.

Under this Code of Ethics you have a duty to promptly report any violation or
apparent violation of the Code of Ethics (including the Code of Conduct and the
Regulatory Information Center) to the Chief Compliance Officer or Personal Trade
Compliance. You can also report violations or


IA Code of Ethics for Retail Access Persons                                    4

<PAGE>

possible violations through the Employee Relations Group Service Center at
877-267-HR4U, option 2, or anonymously via Ethicspoint(R) at 800-963-6395. This
duty exists whether the violation or apparent violation is yours or that of
another associated person of Ameriprise Financial. All such reports will be
treated confidentially to the extent permitted by law and will be investigated
promptly and appropriately. Ameriprise Financial prohibits retaliation against
individuals who report violations or apparent violations of the Code in good
faith and will treat any such retaliation as a further violation of the Code.
However, it must be understood that associated persons of Ameriprise Financial
who violate the Code are subject to sanctions for the violation even if they
report the violation.

GENERAL POLICY ON ACCEPTING GIFTS

Instances may arise in the course of business where a person or organization
offers you a gift. When being offered a gift, you will need to determine whether
or not the gift can be accepted. The Ameriprise Financial Code of Conduct
provides general guidance. More specific information can be located within each
business entity's gift policy:

     -    Employees of Ameriprise Financial Services, Inc. (AFSI) should
          reference the company intranet site Inside for their Gifts &
          Entertainment policy

     -    Employees of American Enterprise Investment Services (AEIS) should
          reference the company intranet site Inside for their Gifts &
          Entertainment policy

WHEN RECEIVING A GIFT, IT IS IMPERATIVE TO AVOID EVEN THE APPEARANCE OF A
CONFLICT OF INTEREST, REGARDLESS OF THE VALUE OF THE GIFT. Sometimes a situation
may be unclear. If you are unsure whether to accept a gift, talk with your
leader. If your leader is unsure, or feels an exception should be made, he or
she should contact the unit's Business Unit Compliance Officer (BUCO) for
guidance. Above all, the decision should comply with the spirit of the Code of
Conduct and this Code of Ethics.


IA Code of Ethics for Retail Access Persons                                    5

<PAGE>

FIDUCIARY PRINCIPLES

The following general fiduciary principles shall govern your activities and the
interpretation and administration of these rules:

     -    The interests of our advised and sub-advised account clients
          (including Mutual Fund shareholders) must be placed first at all
          times.

     -    All personal trading transactions must be conducted consistent with
          the rules contained in this Code and in such a manner as to avoid any
          actual or potential conflict of interest or any abuse of an
          individual's position of trust and responsibility.

     -    You should never use your position with the company, or information
          acquired during your employment, in your personal trading in a manner
          that may create a conflict - or the appearance of a conflict - between
          your personal interests and the interest of the company or its
          customers and clients. If such a conflict or potential conflict
          arises, you must report it immediately to Personal Trade Compliance.

     -    Company personnel should not take inappropriate advantage of their
          positions.

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; and

     -    Functions as a manipulative practice with respect to securities.

These rules do not identify all possible conflicts of interest, and literal
compliance with each of the specific provisions of this Code of Ethics will not
shield company personnel from liability for personal trading or other conduct
that is designed to circumvent its restrictions or violates a fiduciary duty to
our clients.


IA Code of Ethics for Retail Access Persons                                    6

<PAGE>

                                   DEFINITIONS

This Investment Adviser Code of Ethics for Retail Access Persons applies to all
associated persons of Ameriprise Financial other than Investment Access Persons
or certain others who receive notice that a different Code of Ethics applies to
them.

ACCESS PERSONS: supervised persons and other persons who are employees or
associated persons of Ameriprise Financial, who have access to nonpublic
information regarding clients' purchase or sale of securities or non public
information regarding the portfolio holdings of Proprietary Funds, are involved
in making securities recommendations to clients, or who have access to
recommendations that are nonpublic.

     RETAIL ACCESS PERSONS: Access Persons who have access only to Ameriprise
     Financial retail client information.

     INVESTMENT ACCESS PERSONS: Access Persons who have access to Ameriprise
     Financial / RiverSource institutional client information. Investment Access
     Persons are also subject to rule 17j-1 under the Investment Company Act of
     1940.

BROKERAGE ACCOUNT: A Brokerage Account is an account held at a licensed
brokerage firm in which securities are bought and sold (e.g., stocks, bonds,
futures, options, Mutual Funds). This includes employer-sponsored incentive
savings plans.

COVERED MUTUAL FUNDS: Mutual Funds for which RiverSource Investments or Kenwood
Capital Management serves as an investment adviser or for which an affiliate of
RiverSource Investments or Kenwood Capital Management serves as principal
underwriter. As of January 1, 2008, Covered Mutual Funds include:

     -    RiverSource Mutual Funds (both retail and variable portfolio funds)

     -    John Hancock Funds (John Hancock Investment Services, LLC)

     -    Diversified Investors Portfolios (Diversified Investment Advisors,
          Inc.)

     -    Calvert/Ameritas Funds (Calvert Asset Management Company, Inc.)

     -    Nationwide Funds (Nationwide Fund Advisors)

INITIAL PUBLIC OFFERING (IPO): a corporation's first offering of stock to the
public. Purchases of initial public offerings are prohibited.

LIMITED OFFERINGS (PRIVATE PLACEMENTS): an offering of securities exempt from
registration due to certain exemptions such as the size of the offering and the
number of purchasers. You are not allowed to invest in Limited Offerings
(Private Placements) without preclearance - see page 16.

SUPERVISED PERSON: any partner, officer, director (or other person occupying a
similar status or performing similar functions), or an employee of an investment
adviser, or other person who provides investment advice on behalf of the
investment adviser and is subject to the supervision and control of the
investment adviser.

MUTUAL FUNDS: U.S. registered open-end investment companies the shares of which
are redeemable on any business day at the net asset value, including Mutual
Funds that underlie variable annuity and variable life insurance contracts.


IA Code of Ethics for Retail Access Persons                                    7

<PAGE>

                        PERSONAL TRADING RULES FRAMEWORK

APPLICABILITY

These rules apply to securities trading in which you have a beneficial
ownership. Beneficial ownership includes accounts held in the name of any of the
following individuals:

-    You

-    Your spouse/partner

-    Financially dependent members of your household

In addition, these rules apply to the following types of accounts 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

-    Owns an IRA

-    Participates in an investment club

-    Has another arrangement where they give advice and also have a direct or
     indirect ownership.


IA Code of Ethics for Retail Access Persons                                    8

<PAGE>

GENERAL RULES

THESE GENERAL RULES, ALONG WITH THE PROCEDURES CONTAINED IN THE REST OF THIS
DOCUMENT, MUST ALWAYS BE FOLLOWED:

     1.   No use of inside information (refer to "Ameriprise Financial Insider
          Trading Policy" on page 21).

     2.   No front-running. This involves an individual taking advantage of
          non-public information about imminent trading activity in our Mutual
          Funds or other advised accounts by trading in a security before the
          fund or advised account does. YOU ARE NOT ALLOWED TO TRADE IN A
          PARTICULAR SECURITY AHEAD OF, OR AT THE SAME TIME AS, YOUR CLIENTS'
          ACCOUNTS.

     3.   No misuse of material non-public information relating to Mutual Funds,
          including information relating to portfolio holdings or pricing.

     4.   No Access Person shall divulge to any person any client holdings, any
          recommendation made to a client, or any contemplated or completed
          securities transactions or trading strategies of a client, except as
          required in the performance of his or her duties and only to the
          extent such other person has a need to know such information to
          perform his or her duties. Disclosures of any past, current or
          contemplated client holdings must be consistent with the Portfolio
          Holdings Disclosure policy.

     5.   No market timing (short-term trading) in shares of Mutual Funds. This
          prohibition applies across all accounts in which you have a beneficial
          interest (so that you cannot buy shares of a Mutual Fund in one
          account and sell them from another account in market timing
          transactions), including the Ameriprise Financial 401(k) Plan and
          Mutual Funds underlying a variable annuity and variable life insurance
          contracts.

          This prohibition also applies to investments through pooled investment
          vehicles, such as hedge funds, that may engage in market timing. You
          are responsible for ensuring that no pooled investment vehicle in
          which you invest engages in market timing.

          If you invest in a hedge fund whose offering document does not state
          whether the hedge fund engages in market timing of Mutual Funds, you
          should obtain written assurance from the hedge fund that it does not
          engage in market timing of Mutual Funds.

     6.   No purchasing of initial public offerings.

     7.   No preferential treatment from other brokerage firms due to the
          purchaser's employment by or association with Ameriprise Financial.

     8.   No direct trades with broker/dealers' trading desks.

     9.   No non-retail relationships with broker/dealers.


IA Code of Ethics for Retail Access Persons                                    9

<PAGE>

     10.  No use of Ameriprise Financial's name (or the name of any of its
          subsidiaries) to obtain a better price from a broker who is a market
          maker in the security being traded.

     11.  No speculative trading of Ameriprise Financial stock, which is
          characterized by transactions in "put" or "call" options, or short
          sales or similar derivative transactions. Ameriprise Financial
          discourages short-term trading in its own stock. This includes
          soliciting speculative trades in Ameriprise Financial securities. You
          should not solicit or offer an opinion on Ameriprise Financial stock.
          (Subject to the Ameriprise Financial Insider Trading Policies, you are
          allowed to exercise any Ameriprise Financial stock options you have
          received as a result of your employment with the Company. Members of
          the Executive Leadership Team, however, must preclear these trades
          through the Corporate Secretary's office.)

     12.  No stopping stock. This is defined as a guarantee by a specialist that
          an order placed by a Floor Broker will be executed at the best bid or
          offer price then in the Specialist's book unless it can be executed at
          a better price within a specified period of time.

     13.  When engaging in a personal securities transaction, an Access Person
          shall always place the interests of clients first and avoid any actual
          or potential conflict of interest or abuse of his or her position.

     14.  Required forms must be filled out completely, accurately and on a
          timely basis. This includes quarter end reports. Violations of the
          Code, including late filing of periodic reports will be reported to
          Senior Management and the RiverSource Investments, LLC Funds Board of
          Directors.

     15.  Required forms must be filled out completely, accurately and on a
          timely basis. This includes annual and quarter end reports.


IA Code of Ethics for Retail Access Persons                                   10

<PAGE>

IMPORTANT:

     -    OBLIGATION TO REPORT VIOLATIONS: Any person who discovers that he or
          she or another person has violated or apparently violated these
          general rules or other provisions of this Code must promptly report
          the matter to the Chief Compliance Officer, Personal Trade Compliance
          or your leader.

     -    PERSONAL TRADING RECORDS SUBJECT TO REVIEW BY REGULATORS: The SEC and
          FINRA have the authority to review individuals' personal trading
          records. It is not unusual in the course of regulatory exams for the
          examiners to interview individuals about their trading activity or
          violations of the Code of Ethics.

     -    Even if you receive preclearance, you cannot be ensured that you have
          not violated the Code. Receiving preclearance does not exclude you
          from other personal trading rules included in this Code.

     -    The Compliance Department has the authority to review records and
          request additional information.

     -    The privacy of your reported information is extremely important and
          will be held in the utmost confidence but is subject to review and
          action by appropriate personnel such as Personal Trade Compliance
          personnel.

BASIS FOR RULES

The rules and procedures that apply to personal trading for Retail Access
Persons are derived from:

          Securities and investment laws

               -    Securities Act of 1933

               -    Securities Exchange Act of 1934

               -    Investment Company Act of 1940 (Rule 17j-1)

               -    Investment Advisers Act of 1940 (Rule 204A-1)

               -    Insider Trading and Securities Fraud Enforcement Act of 1988

          Rules, regulations and corporate policies

               -    Securities and Exchange Commission (SEC)

               -    Financial Industry Regulatory Authority (FINRA)

               -    Ameriprise Financial Insider Trading Policy

               -    Ameriprise Financial Code of Conduct

          Investment Company Institute (ICI) Guidelines to Industry on Personal
          Investing


IA Code of Ethics for Retail Access Persons                                   11

<PAGE>

                REPORTING REQUIREMENTS FOR RETAIL ACCESS PERSONS

SECURITIES ACTIVITIES WHICH MUST BE REPORTED

All personal securities trading activities (e.g., stocks, options, bonds,
Covered Fund shares), whether bought or sold, must be reported, with the
exception of such things as money market mutual funds and certificates of
deposit. See "How to Comply" section below for more information. A chart
indicating which transactions must be reported is located on pages 14-15. You
must report activity involving securities trading in which you have a BENEFICIAL
OWNERSHIP. This includes accounts held in the name of any of the following
individuals:

-    You

-    Your spouse/partner

-    Financially dependent members of your household

In addition, these rules apply to the following types of accounts 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

-    Owns an IRA

-    Participates in an investment club

-    Has another arrangement where you give advice and also have a direct or
     indirect ownership.

HOW TO COMPLY

Limited Choice Policy: Unless you have an exception approved by Personal Trade
Compliance, your personal securities must be held and trading must be conducted
through one of three brokers - Ameriprise Financial Brokerage, Charles Schwab,
or Merrill Lynch. See page 14-15 for a complete list of securities subject to
this limited choice policy.

You must report any new accounts opened by immediately completing the following
steps:

-    Complete the Brokerage Account Notification Form in Appendix B and return
     it to Personal Trade Compliance, H26/1880.

-    Notify your broker of your association with Ameriprise Financial. You are
     responsible for notifying your broker that you work for Ameriprise
     Financial, a broker/dealer, and ensuring that Personal Trade Compliance is
     provided with duplicate statements and confirmations for your account(s).

NOTE: Accounts owned solely by spouses/domestic partners and other financial
dependants of NON-LICENSED employees of P2 advisors are not required to be
transferred to one of the three limited choice brokers. THESE ACCOUNTS MUST
STILL BE REPORTED ON REQUIRED CERTIFICATION FORMS.

Accounts owned directly by non-licensed employees of P2 advisors must be held at
one of the three limited choice brokers.

NOTE FOR P2 ADVISORS, PARAPLANNERS, AFAS AND EMPLOYEES OF P2 ADVISORS: Based on
activities you or your employing P2 advisor conducts in client accounts, you may
be required to conduct all of your personal trading activity at Ameriprise
Financial.

FAILURE TO COMPLY WITH THE LIMITED CHOICE POLICY AND FAILURE TO DISCLOSE ALL
COVERED MUTUAL FUND ACCOUNTS AND APPLICABLE BROKERAGE ACCOUNTS AND SECURITIES
ARE VIOLATIONS OF THE CODE AND MAY RESULT IN A SANCTION, WHICH INCLUDES POSSIBLE
TERMINATION.


IA Code of Ethics for Retail Access Persons                                   12

<PAGE>

WHAT TYPES OF INVESTMENTS MUST BE TRANSFERRED TO OR HELD AT ONE OF THE LIMITED
CHOICE FIRMS?

-    Stocks -- common (including Ameriprise Financial), preferred, convertible
     preferred, short sales, rights, or warrants

-    Corporate bonds (including convertible and foreign)

-    State and local municipal bonds

-    Derivatives, including futures, options and index securities

-    Limited partnerships (if purchased through a Brokerage Account)

-    Unit Investment Trusts (UITs), American Depository Receipts (ADRs) and Real
     Estate Investment Trusts (REITs), Exchange Traded Funds and closed-end
     funds.

-    Managed or wrap accounts in which individual securities are held and the
     investor has the ability to exercise trading discretion

-    RiverSource Mutual Funds must be held through Ameriprise Brokerage,
     Ameriprise Financial 401(k) Plan, "at fund" (directly with the Mutual
     Fund), or underlying a variable annuity or variable life insurance contract
     from IDS Life Insurance Company or another affiliate of Ameriprise
     Financial

WHAT INVESTMENTS ARE NOT SUBJECT TO THIS LIMITED CHOICE POLICY?

Some investments are not subject to this policy, and therefore, do not need to
be transferred. You may continue to hold the following investments in accounts
at other firms:

-    Open-end Mutual Funds other than RiverSource Mutual Funds

-    Annuities

-    Certificates of Deposit, savings certificates, checking and savings
     accounts and money market accounts

-    Commercial paper

-    Dividend reinvestment plans

-    Employer sponsored incentive savings plans

-    US Government bonds (U.S. Treasury notes, bills, bonds, STRIPS, savings
     bonds)

-    Church bonds

-    Limited Offerings / Private Placements (These transactions require specific
     preclearance-see page 16)

-    Managed or wrap accounts that do not include individual securities

EXCEPTIONS TO LIMITED CHOICE

Exceptions to the limited choice policy of conducting personal trading through
one of the three authorized brokers - Ameriprise Financial Brokerage, Charles
Schwab, or Merrill Lynch - will be rare. If you believe your situation warrants
an exception, print and complete the Exception Request Form found in Appendix C.

Note that if you are granted an exception for a managed account where you have
no trading discretion, you and your broker will be required to re-certify to
this annually in order to maintain that exception.

If you are granted an exception, you are responsible for ensuring that Personal
Trade Compliance receives duplicate confirmations and statements.

An exception to the limited choice policy does not eliminate the need to comply
with the rest of this Investment Adviser Code of Ethics.


IA Code of Ethics for Retail Access Persons                                   13
<PAGE>

SECURITIES REPORTING LIST FOR RETAIL ACCESS PERSONS

<TABLE>
<CAPTION>
This chart lists which securities are subject to LIMITED CHOICE* and     IS REPORTING REQUIRED & SUBJECT TO LIMITED
must be reported on your initial and annual certification.                                CHOICE*?
--------------------------------------------------------------------     ------------------------------------------
<S>                                                                      <C>
American Depository Receipts/Shares/Units (ADRs/ADSs/ADUs)                                   Yes

Annuities - Fixed                                                                            No
(other than market value adjusted annuities)

Annuities - Variable and market value adjusted annuities                                     Yes
                                                                           Report underlying Covered Mutual Funds

American Express Stock                                                                       Yes

(Options on) American Express Stock (i.e., puts and calls)                                   Yes

American Express employee stock options (Obtained as a part of an                            Yes
incentive plan. This also includes other company employee stock option
plans)

Ameriprise Financial Stock                                                                   Yes
                                                                           Executive Leadership Team must preclear
                                                                            trades with the Corporate Secretary's
                                                                                           office

(Options on) Ameriprise Financial Stock (i.e., puts and calls)                           Prohibited

Ameriprise Financial employee stock options (obtained as a part of an                        Yes
incentive plan)**                                                          Executive Leadership Team must preclear
                                                                            trades with the Corporate Secretary's
                                                                                           office

Bonds and other debt instruments, including but not limited to:                              Yes

     -    Corporate
     -    U.S. Guaranteed or of federally sponsored enterprises
          (FHLMC, FNMA, GNMA, etc.)
     -    Municipal
     -    Closely held

Bonds and other direct debt instruments of the U.S. Government:                              No
(e.g., Treasury notes, bills, bonds or STRIPS)

Bonds - convertible                                                                          Yes

Bank certificates of deposit, Savings Certificates, checking and                             No
savings accounts and money market accounts, bankers' acceptances,
commercial paper and high quality short-term debt instruments,
including repurchase agreements.

Currency Accounts                                                                            No

Derivatives (DECS, ELKS, PRIDES, etc.)                                                       Yes

Futures:  commodity, currency, financial, or stock index                                     Yes

Index Securities  -  (e.g., S&P 500, SPDRS/SPY, Diamonds/DIA,                                Yes
Cubes/QQQ, Exchange Traded Funds,  Holders Trusts)

Life Insurance (variable)                                                                    Yes
                                                                           Report underlying Covered Mutual Funds

Limited Offerings / Private Placements - Equity and Fixed Income                             Yes
                                                                                        (see page 16)

Limited Partnerships                                                                         Yes

Managed or wrap accounts:

-    If individual securities held and investor has ability to                               Yes
     exercise trading discretion

-    If individual securities held and investor does not have ability                        Yes
     to exercise trading discretion
</TABLE>


IA Code of Ethics for Retail Access Persons                                   14

<PAGE>

<TABLE>
<CAPTION>
This chart lists which securities are subject to LIMITED CHOICE* and     IS REPORTING REQUIRED & SUBJECT TO LIMITED
must be reported on your initial and annual certification.                                CHOICE*?
--------------------------------------------------------------------     ------------------------------------------
<S>                                                                      <C>
-    If individual securities not held                                                       Yes

Money market mutual funds                                                                    No

Mutual Funds: Open-end Mutual Funds that are "Covered Mutual Funds"                          Yes
(these are Mutual Funds other than money market mutual funds that are
advised or sub-advised by RiverSource Investments or Kenwood Capital
Management or for which an affiliate of RiverSource Investments or
Kenwood Capital Management serves as principal underwriter.

As of January 1, 2008, Covered Mutual Funds include RiverSource Mutual
Funds, John Hancock Funds, Diversified Investors Portfolios,
Calvert/Ameritas Funds and Nationwide Funds.)

Mutual Funds (including money market mutual funds): Open-end mutual                          No
funds that are not "Covered Mutual Funds"

Mutal Funds: Closed-end funds                                                                Yes

Options on stocks                                                                            Yes

Options: exercise of option to buy or sell underlying stock                                  Yes

Options on futures and indices (currency, financial, or stock index)                         Yes

REITS (Real Estate Investment Trusts)                                                        Yes

Stocks: common or preferred                                                                  Yes

Stocks: convertible preferred                                                                Yes

Stocks: short sales (short sales prohibited on Ameriprise Financial                          Yes
stock)

Stocks (owned) - exchanges, swaps, mergers, tender offers                                    Yes

Stocks - public offerings (initial OR secondary)                                         Prohibited

Stocks - Rights or warrants acquired separately                                              Yes

Treasury Inflation Protected Securities (TIPS)                                               No

Unit Investment Trusts (UITs)                                                                Yes
</TABLE>

*    LIMITED CHOICE: The Limited Choice policy requires that securities subject
     to the policy in the preceding table must be held/traded at one of the
     three Limited Choice brokers--Ameriprise Brokerage, Merrill Lynch or
     Schwab.

SPECIAL NOTE FOR 401(K)S: reporting is required for any 401(k) or an
employer-sponsored incentive savings plan that holds a security that is subject
to the reporting requirements in the above table.

SPECIAL NOTE FOR AUTOMATIC INVESTMENT PLANS: you do not need to report
transactions that are made as part of a regular periodic purchase (or
withdrawal). For example: payroll deduction, bank authorizations etc.


IA Code of Ethics for Retail Access Persons                                   15

<PAGE>

                    ADDITIONAL RULES & REPORTING REQUIREMENTS

LIMITED OFFERINGS (PRIVATE PLACEMENT) PRECLEARANCE - EQUITY AND FIXED INCOME

ALL ACCESS PERSONS need to obtain approval to invest in any Limited Offerings
(private placements), i.e., a security not offered to the public. Approvals must
be obtained in writing from your immediate leader or registered principal, and
Personal Trade Compliance PRIOR to investing.

Limited Offerings include all hedge funds.

HOW TO OBTAIN APPROVAL - Write an explanation of the investment and submit the
request to your leader or registered principal. Required information you must
include in your request:

-    the nature of the investment

-    how you were solicited

-    approximate dollar amount you are planning to invest

-    whether or not the opportunity was being offered to any client accounts

-    whether the security is likely to be purchased by a client account in the
     future

In considering whether to make a request, consider whether your investment might
create a conflict with a business interest of Ameriprise Financial. See the
Ameriprise Financial Code of Conduct and the Regulatory Information Center.

HOW LIMITED OFFERINGS/PRIVATE PLACEMENTS ARE APPROVED - Your leader or
registered principal will approve or reject your request, and return the request
to you. If approval is granted, send the request via Lotus Notes message to
Private Placement Preclearance. YOU CANNOT ENTER INTO THE PROPOSED TRANSACTION
WITHOUT APPROVAL FROM PERSONAL TRADE COMPLIANCE.

Personal Trade Compliance will respond to you requesting any additional
information or further documentation needed to make a decision. Upon receipt of
all necessary documentation, Personal Trade Compliance will then confirm in
writing whether you may invest. If your preclearance request is approved, if you
are an employee Band 50 or above, you must report the investment on the
quarterly reporting form, which will be provided to you near the beginning of
each calendar quarter.

If you have questions about how the private placement approval process applies
to a transaction you are considering, PLEASE CONTACT PERSONAL TRADE COMPLIANCE
BY SENDING A LOTUS NOTES MESSAGE TO PERSONAL TRADING OR CALL THE PERSONAL TRADE
HOTLINE AT 612-671-5196 BEFORE YOU INVEST.


IA Code of Ethics for Retail Access Persons                                   16

<PAGE>

FAILURE TO COMPLETELY AND ACCURATELY DISCLOSE APPLICABLE BROKERAGE & COVERED
MUTUAL FUND ACCOUNTS, HOLDINGS AND QUARTERLY NON-BROKERAGE ACTIVITY BY THE TIME
FRAMES SPECIFIED BY PERSONAL TRADE COMPLIANCE IS A VIOLATION OF THE CODE AND MAY
RESULT IN A SANCTION, WHICH INCLUDES POSSIBLE TERMINATION.

INITIAL HOLDINGS DISCLOSURE

New Access Persons must disclose certain accounts and securities holdings in
which they have a beneficial interest, as indicated in the chart on pages 14-15
of this Code. You also must disclose all of the holdings in those accounts. All
new Investment Access Persons will receive a copy of the Code of Ethics that
applies to them and that includes an Initial Personal Account and Holdings
Disclosure form. This document must be returned to Personal Trade Compliance
H26/1880 within 10 days. An example of this form is located in Appendix A.

IF YOU MAINTAIN A BROKERAGE ACCOUNT OUTSIDE OF THE LIMITED CHOICE BROKERS
(AMERIPRISE FINANCIAL, MERRILL LYNCH, OR SCHWAB) THAT HOLDS SECURITIES SUBJECT
TO THE LIMITED CHOICE POLICY, YOU MUST TRANSFER YOUR ACCOUNT(S) TO ONE OF
LIMITED CHOICE BROKERS WITHIN 45 CALENDAR DAYS.

ANNUAL CERTIFICATION AND ANNUAL HOLDINGS DISCLOSURE

In addition to reporting requirements already outlined, every Access Person must
submit an annual certification form. If you are new to the company, you will
receive a form and instructions when you attend your orientation session. If you
do not attend this orientation session, please contact Personal Trade Compliance
at 612-671-5196 for the information.

All Access Persons must also disclose annually certain accounts and securities
holdings in which they have a beneficial interest, as indicated in the chart on
pages 15-16. Failure to disclose annual holdings by the time frames specified by
Personal Trade Compliance may result in a sanction, which includes possible
termination. Additionally, on an annual basis you must certify that you have
complied with the Code during the past year and will continue doing so going
forward.

All Access Persons will receive a form on an annual basis from Personal Trade
Compliance. You must document your account(s) certification and holdings
disclosures on this form.

QUARTERLY REPORTING AND CERTIFICATION

All access persons must disclose on a quarterly basis if they executed
securities transactions outside of a broker-dealer account or engaged in
transactions in Covered Mutual Funds as identified on the quarterly reporting
form.

Reporting forms will be available on Inside (for home office employees) and
Advisor Compass (for field members) during the certification period. Those
persons with reportable activity must return their forms to Personal Trade
Compliance by the due date given.

Employees Band 50 and above will be sent a separate form which also requires
reporting of Limited Offering (Private Placement) transactions during the
quarter.


IA Code of Ethics for Retail Access Persons                                   17

<PAGE>

INVESTMENT CLUBS

There is no prohibition against joining an investment club. However, the account
must be held at one of the limited choice brokers, Ameriprise Brokerage, Schwab
or Merrill Lynch, unless the club has been granted an exception from Personal
Trade Compliance. When FORMING OR JOINING AN INVESTMENT CLUB, provide the
following to Personal Trade Compliance:

     -    a copy of the Brokerage Account Notification Form (see Appendix B)

     -    a copy of your investment club's bylaws

     -    a list of the members in the club and an indication if any members are
          employees, independent contractors or associated persons of Ameriprise
          Financial. Please include the individual's employee, Advisor, or
          contractor identification number.

     -    the contact person for the club in case of questions

ADVISORS

YOU MAY NOT SOLICIT CLIENTS OF AMERIPRISE FINANCIAL TO BECOME INVESTMENT CLUB
MEMBERS, DUE TO POSSIBLE CONFLICTS OF INTEREST. If an existing member of your
investment club later becomes your client, you must obtain a written and signed
disclaimer from him/her immediately. A sample copy of the disclaimer is attached
in Appendix D.1, titled Investment Club Client Disclosure Form. This disclaimer
must state the investment club relationship was pre-existing and entered into
freely, and the client understands Ameriprise Financial in no way endorses,
approves, or guarantees any activity undertaken by the club. Furthermore, the
client/club members understand Ameriprise Financial has no responsibility for
the financial results due to his/her participation in the club. A completed copy
of the Client Disclosure Form must be routed to Personal Trade Compliance
immediately.


IA Code of Ethics for Retail Access Persons                                   18

<PAGE>

SANCTIONS

Sanctions will be imposed for violations of this Code or Ameriprise Financial,
SEC, or FINRA rules or policies. These sanctions are communicated via violation
letters and may vary depending on the severity of the violation, if a record of
previous violations exists and/or the violation was self-reported. Examples of
potential sanctions include (but are not limited to):

-    a written reminder about the rules (with a copy to the individual's
     manager)

-    notification to your broker to freeze your account from any buy-side
     trading. This is a typical sanction if you fail to move your account(s) to
     one of the three limited choice brokers - Ameriprise Financial Brokerage,
     Schwab, or Merrill Lynch. The account could then be used only for transfers
     and liquidations.

-    prohibition against personal trading for a specific period of time

-    forfeiture of trading profits

-    monetary fine

-    negative impact on the individual's bonus or other compensation and or
     performance rating

-    termination

A written record of each violation and sanction is maintained by Personal Trade
Compliance.

UNUSUAL TRADING ACTIVITY

The Personal Trade Committee and your department head review your personal
trading activity regularly. We may ask to review specific transactions with you
or your broker if clarification is necessary. You may also be asked to supply
Personal Trade Compliance with an explanation of your personal trade(s).
Examples of situations that may require explanation include, but are not limited
to:

-    violations of personal trading rules

-    trades in a security shortly before our Investment Department trades in the
     same security on behalf of a client

-    patterns of personal trading that are similar to your clients' trading

-    significant changes in trading volume or consistently excessive trading
     volume

-    patterns of short-term, in and out trading

-    significant positions in illiquid securities

-    a number of associated persons trading in the same security in the same
     time frame


IA Code of Ethics for Retail Access Persons                                   19

<PAGE>

      RESPONSIBILITIES OF THE CHIEF COMPLIANCE OFFICER, OR THEIR DELEGATE,
                           RELATED TO PERSONAL TRADING

PROCESS AND RESPONSIBILITY

The Chief Compliance Officer, or their delegate (i.e. Personal Trade
Compliance), has primary responsibility for enforcing the Code. The Personal
Trade Committee (PTC) reviews all alleged personal trading violations and any
sanctions applied. If the alleged violator is the Chief Compliance Officer, the
matter must also be reported to the General Counsel of the firm.

OPPORTUNITY TO RESPOND

A person charged with a violation of the Code shall have the opportunity to
appear before the person or persons enforcing the Code and to respond to all
charges, orally or in writing.

INITIAL HOLDINGS REPORT; ANNUAL HOLDINGS REPORT

The Chief Compliance Officer, or their delegate, shall review and maintain the
initial and annual holdings reports. Completion of the review shall involve such
considerations as the Chief Compliance Officer, or their delegate, deems
necessary to enforce the provisions and intent of this Code.

QUARTERLY PERSONAL TRADING REPORTS

The Chief Compliance Officer, or their delegate, shall review and maintain the
quarterly transaction reports. Completion of the review shall involve such
considerations as the Chief Compliance Officer, or their delegate deems
necessary to enforce the provisions and intent of this Code.

PRE-CLEARANCE

The Chief Compliance Officer, or their delegate, shall review and approve or
disapprove the Access Person requests to pre-clear securities transactions. Such
review shall involve such considerations as the Chief Compliance Officer, or
their delegate, deems necessary to enforce the provisions and intent of this
Code.

VIOLATIONS OR SUSPECTED VIOLATIONS

If the Chief Compliance Officer or their delegate becomes aware of a violation
or suspected violation of the Code as a result of such review, the Chief
Compliance Officer, or their delegate, shall take whatever steps deemed
necessary to enforce the provisions of the Code, including consulting with
outside counsel.

RECORD RETENTION

Records are required to be kept for seven years (a minimum of two years on
site).


IA Code of Ethics for Retail Access Persons                                   20

<PAGE>

                   AMERIPRISE FINANCIAL INSIDER TRADING POLICY

                             AMERIPRISE FINANCIAL'S
             STATEMENT OF POLICY AND PROCEDURES WITH RESPECT TO THE
               RECEIPT AND USE OF MATERIAL NON-PUBLIC INFORMATION

This statement represents the policy of Ameriprise Financial with regard to the
receipt and use of material non-public information. If you have any questions or
comments about this policy, please contact either the General Counsel's Office
(the "GCO") or the Compliance Department. For Investment Access Persons, this
policy is supplemented by the Policy and Business Procedures Regarding Insider
Trading, Restricted List and Information Walls.

A. GENERAL

Ameriprise Financial prohibits any associated person from trading on the basis
of or otherwise misusing material non-public ("inside") information. Section
10(b) of the Securities Exchange Act of 1934 (the "Exchange Act") and Rule 10b-5
make it unlawful for any person or corporate insider, while in the possession of
material non-public ("inside") information, to trade or to recommend trading in
securities, or to communicate the material non-public information to others.

In light of the above and in compliance with the requirements of Section 204A of
the Investment Advisers Act of 1940 (the "Advisers Act'), Rule 206(4)-7 enacted
thereunder and the Insider Trading & Securities Fraud Enforcement Act of 1988
(the "Enforcement Act"), Ameriprise Financial has consistently maintained the
policy that associated persons possessing material nonpublic information must
not (a) use such information to obtain profits, mitigate losses or otherwise
secure benefits for Ameriprise Financial, any of its affiliates or clients,
themselves or others, (b) engage in transactions or make recommendations on the
basis of such information, or (c) disclose such information to others.

B. WHAT IS "MATERIAL NON-PUBLIC INFORMATION"?

Generally, it includes material information about an issuer (including a
government entity) or the market for the issuer's securities that has not been
disclosed generally to the marketplace. In addition to coming from the issuer,
material non-public information can come from persons with access to the
information, including not only the issuer's officers, directors and other
employees, but also among others its auditors, investment bankers and attorneys.
Material non-public information may also be obtained by happenstance, e.g., from
social situations, business gatherings, overheard conversations, misplaced
documents and tips from insiders or other third parties.

1. Material Information. Information is "material" if its dissemination is
likely to affect the market price of any of the company's or other issuers'
securities or is likely to be considered important by reasonable investors,
including reasonable speculative investors, in determining whether to trade in
such securities. Information may or may not be material, depending on its
specificity, its magnitude, its reliability and the extent to which it differs
from information previously publicly disseminated.


IA Code of Ethics for Retail Access Persons                                   21

<PAGE>

Though there is no precise, generally accepted definition of materiality,
information is likely to be material if it relates to significant changes
affecting matters such as:

          -    Dividend or earnings expectations;

          -    Changes in previously released earnings estimates;

          -    Write-downs or write-offs of assets;

          -    Additions to reserves or bad debts or contingent liabilities;

          -    A significant increase or decrease in orders;

          -    Expansion or curtailment of company or major division operations;

          -    Proposals or agreements involving a joint venture, merger,
               acquisition, divestiture;

          -    A purchase or sale of substantial assets;

          -    New products or services;

          -    Exploratory, discovery or research development;

          -    Criminal indictments, civil litigation or government
               investigation;

          -    Disputes with major suppliers or customers;

          -    Labor disputes including strikes or lock-outs;

          -    Substantial changes in accounting methods;

          -    Debt service or liquidity problems;

          -    Extraordinary borrowings;

          -    Bankruptcy or insolvency;

          -    Extraordinary management developments;

          -    Public offerings or private sales of debt or equity securities;

          -    Calls, redemptions or purchases of the company's own stock;

          -    Issuer tender offers;

          -    Recapitalizations;

          -    Competitive developments within the marketplace.

     2. Non-public Information. Non-public information is information that has
not been made available to investors generally. It includes information received
in circumstances indicating that it is not yet in general circulation. It also
includes situations in which the recipient knows or should know that the
information could only have been provided directly or indirectly by the issuer
or its insiders. For example, personnel at Ameriprise Financial may temporarily
become insiders when an external source, such as a company or officer of a
company, entrusts material non-public information in connection with a
commercial relationship or transaction to an associated person of Ameriprise
Financial with the expectation that the information will remain confidential. In
order for non-public information to become public, it must be disseminated
through recognized channels of distribution designed to reach the securities
marketplace.

To show that material information is public, you should be able to point to some
fact verifying that the information has become generally available. For example,
disclosure in a national business and financial wire service, by a news service,
or in a publicly disseminated disclosure document would all be sufficient to
consider the information generally available. The circulation of rumors or "talk
on the street," even if accurate and widespread does not constitute the
requisite public disclosure.

Material information disclosed only to institutional investors or to a fund
analyst or a favored group of analysts generally may retain its status as
non-public information and must not be disclosed or otherwise misused.
Similarly, partial disclosure does not constitute public dissemination. As long
as any material component of the inside information has yet to be publicly
disclosed, the information is non-public and a trade based on, or sharing of
such information is prohibited.


IA Code of Ethics for Retail Access Persons                                   22

<PAGE>

     3. Information Disclosed in Breach of a Duty (Tipper and Tippee Liability).
Associated persons of Ameriprise Financial must be wary of material non-public
information disclosed in breach of a corporate insider's fiduciary duty. Even
when there is no expectation of confidentiality, you may become an insider upon
receiving material non-public information in circumstances in which you know or
should know that a corporate insider is disclosing information in breach of the
fiduciary duty he or she owes his or her company and its shareholders. Whether
the disclosure is an improper "tip" that renders the recipient a "tippee"
depends on whether the corporate insider expects to benefit personally, either
directly or indirectly, from the disclosure. In the context of an improper
disclosure by the corporate insider, the requisite "personal benefit" is not
limited to a business or future monetary gain. Rather, a prohibited personal
benefit may include a reputational benefit, an expectation of a quid pro quo
from the recipient or the recipient's employer, or an intention to benefit the
recipient or the recipient's employer by sharing the material non-public
information.

Given the potentially severe regulatory, civil and criminal sanctions to which
you, Ameriprise Financial and other associated persons of Ameriprise Financial
could be subject, if uncertain as to whether the information you possess is
material non-public information, you should immediately contact Legal or
Compliance. Pending a final determination in consultation with Legal and/or
Compliance, the information should be treated as material non-public information
that cannot otherwise be communicated to any other person or misused.

C. CRIMINAL AND CIVIL PENALTIES AND REGULATORY SANCTIONS FOR INSIDER TRADING

Penalties for misusing material non-public information are severe. Depending on
the circumstances and the adequacy of the relevant procedures, the associated
person involved, his or her supervisor, Ameriprise Financial's principals,
officers, directors and other supervisory personnel could all face substantial
regulatory, civil and criminal sanctions.

For example, associated persons of Ameriprise Financial who either trade on
inside information or become subject to tipper or tippee liability are subject
to the following penalties:

1.   A civil penalty of up to three times the profit gained or loss avoided;

2.   A criminal fine of up to $5,000,000; and

3.   A jail term of up to 20 years.

Furthermore, Ameriprise Financial and its supervisory personnel, if they fail to
take appropriate steps to prevent insider trading, are subject to the following
penalties:

1.   A civil penalty of up to $1,000,000 or, if greater, three times the profit
     gained or loss avoided as a result of the associated person's violation;
     and

2.   A criminal penalty of up to $2,500,000 for individuals and up to
     $25,000,000 for Ameriprise Financial.

Finally, violations of insider trading laws could result in civil injunctions
and a suspension or permanent bar from the securities industry. In addition to
the criminal, civil and regulatory penalties described above, any associated
person who is found to have violated these rules or who is found to have
violated a federal or state securities law or regulation related to the misuse
of material non-public information will be subject to serious sanctions by
Ameriprise Financial, including termination of employment.


IA Code of Ethics for Retail Access Persons                                   23

<PAGE>

D. PROHIBITIONS REGARDING MISUSE OF MATERIAL NON-PUBLIC INFORMATION

Listed below are certain prohibitions regarding the misuse of material
non-public information. Anyone who knows or has reason to suspect that these
prohibitions have been violated must bring such actual or potential violation to
the immediate attention of Compliance. These prohibitions are not intended to be
exhaustive, but instead are listed to provide examples of the types of
situations likely to raise significant issues with respect to the misuse of
inside information. No director, officer, principal or associated person of
Ameriprise Financial shall do any of the following:

     -    Purchase or sell or recommend or direct the purchase or sale of a
          security for any client or any client's account managed by Ameriprise
          Financial (including accounts owned by Ameriprise Financial) or for
          any other person while in possession of material non-public
          information relevant to that security.

     -    Take advantage of material non-public information to purchase or sell
          or recommend or direct the purchase or sale of any security for his or
          her own account, for any account over which he or she has a direct or
          indirect beneficial interest (including an account held by or for any
          family member or family-related trust).

     -    Subject to relevant procedures (including this Personal Trading Code
          of Ethics and the Policy and Business Procedures Regarding Restricted
          List and Information Walls), disclose material non-public information
          to any person, unless such disclosure is both authorized and necessary
          to effectively carry out the project or transaction for which
          Ameriprise Financial has been approached or engaged.

     -    Engage in tipping or recommending, whether formally, informally,
          orally or in writing, the purchase or sale of any security based on
          material non-public information relevant to that security.

     -    Give consideration to any material non-public information furnished by
          any broker-dealer when recommending the allocation of brokerage to any
          broker-dealer.

     -    Trade for his or her personal account with the expectation that an
          account managed by Ameriprise Financial will soon trade in the same
          security (otherwise known as front-running).


IA Code of Ethics for Retail Access Persons                                   24

<PAGE>

APPENDIX A: INITIAL PERSONAL ACCOUNT AND HOLDINGS DISCLOSURE

    INITIAL PERSONAL ACCOUNT AND HOLDINGS DISCLOSURE COMPLETION INSTRUCTIONS
                              RETAIL ACCESS PERSONS

BELOW ARE THE STEPS FOR COMPLETING THE INITIAL PERSONAL ACCOUNT AND HOLDINGS
DISCLOSURE ("INITIAL CERTIFICATION") FORM FOUND ON PAGES A.2 AND A.3:

1.   Write your NAME, SOCIAL SECURITY NUMBER, ID NUMBER, and ROUTING NUMBER (or
     Area Office if you are in the field) on the top portion of the form. PLEASE
     WRITE LEGIBLY.

2.   SECTION 1: Disclose accounts and investments required to be reported--see
     pages 14-15 of the Code of Ethics for a list of investments required to be
     reported. If you have no investments required to be reported, please write
     NONE in Section 1. If you have an account that only contains holdings that
     are not required to be reported (e.g., a money market), you do not need to
     report that account.

     Complete all columns/fields. Include name, account number, and type of
     ownership (Individual, Jt, IRA, Roth, Trust etc.). If securities are held
     outside of a Brokerage Account (i.e. physical stock certificate), write in
     physical certificate or where they are held in the firm name field.

3.   SECTION 2: Sign and date you form.

4.   Return pages A.2 and A.3 to Personal Trade Compliance (H26/1880) within 5
     business days. This is important due to regulatory timing obligations.

YOU MUST COMPLETE AND RETURN THIS FORM EVEN IF YOU HAVE NO ACCOUNTS OR HOLDINGS
TO DISCLOSE.

ADDITIONAL INFORMATION

-    BROKERAGE ACCOUNTS: You must disclose all Brokerage Accounts you own or in
     which you have a BENEFICIAL INTEREST (see below for definition of
     beneficial interest) that contain securities listed on page 14-15. This
     includes Ameriprise Brokerage and accounts held with any other broker.

-    COVERED MUTUAL FUNDS: You must disclose all Covered Mutual Funds held
     direct-at-fund, including variable annuities and variable life insurance.
     COVERED MUTUAL FUNDS are those Mutual Funds for which RiverSource
     Investments or Kenwood Capital Management serves as an investment adviser
     or for which an affiliate of RiverSource Investments or Kenwood Capital
     Management serves as principal underwriter. As of January 1, 2008, Covered
     Mutual Funds include the RiverSource Mutual Funds (both retail and variable
     portfolio funds), John Hancock Funds (John Hancock Investment Services,
     LLC), Diversified Investors Portfolios (Diversified Investment Advisors,
     Inc.), Calvert/Ameritas Funds (Calvert Asset Management Company, Inc.) and
     Nationwide Funds (Nationwide Fund Advisors). For a current list of Covered
     Mutual Funds, please see contact Personal Trade Compliance.

-    401(K)S: Reporting is required for any 401(k), 403(b), or
     employer-sponsored incentive savings plan only if the plan contains a
     Covered Mutual Fund or stock.

-    BENEFICIAL INTEREST: You must disclose accounts in which you have a
     beneficial interest. This includes accounts held in the name of YOU, YOUR
     SPOUSE/PARTNER, OR ANY FINANCIALLY DEPENDENT MEMBER OF YOUR HOUSEHOLD.
     Additionally, beneficial interest extends to the following types of
     accounts if you, your spouse/partner or financially dependent member of
     your household:

          -    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, as an executor of an estate after death, or through
               providing investment advice for compensation

          -    Owns an IRA

          -    Participates in an investment club

          -    Has another arrangement substantially equivalent to direct or
               indirect ownership.

          NOTE: If none of the above beneficial interest situations apply and
          you are solely the beneficiary on an account, you do not need to
          disclose that account.

FOR QUESTIONS ABOUT SECURITIES THAT YOU ARE RESPONSIBLE FOR DISCLOSING, SEE
PAGES 14-15 OF THE INVESTMENT ADVISER CODE OF ETHICS FOR RETAIL ACCESS PERSONS.


Initial Personal Account and Holdings Disclosure                    Appendix A.1
<PAGE>

              INITIAL PERSONAL ACCOUNT AND HOLDINGS DISCLOSURE FORM
                              RETAIL ACCESS PERSONS

NAME: __________________            SOCIAL SECURITY #: _______________________
ID NUMBER: _____________            ROUTING OR AREA OFFICE #: ________________

PLEASE DISCLOSE ACCOUNTS AND HOLDINGS THAT YOU OR ANY MEMBER OF YOUR HOUSEHOLD
(SPOUSE/PARTNER AND FINANCIAL DEPENDENTS) OWN. A LIST OF INVESTMENTS TO BE
DISCLOSED CAN BE FOUND ON PAGE 14-15 OF THE CODE OF ETHICS.

IF YOU OWN AN ACCOUNT THAT ONLY CONTAINS HOLDINGS THAT ARE NOT REQUIRED TO BE
REPORTED (E.G., A MONEY MARKET), YOU DO NOT NEED TO REPORT THAT ACCOUNT.

If you do not have any investments to report, please write NONE in Section 1 or
leave the section blank.

                                    SECTION 1

                             ACCOUNT/HOLDINGS DETAIL

-    Please complete all columns.

-    If submitting electronically, please initial Section 2 and send via email
     to personal.trading@ampf.com.

-    If submitting a paper copy, please sign Section 2 and send to Personal
     Trade Compliance, H26/1880.

-    PLEASE RETURN THIS FORM TO PERSONAL TRADE COMPLIANCE WITHIN 5 DAYS DUE TO
     REGULATORY TIMING OBLIGATIONS.

<TABLE>
<CAPTION>
BROKERAGE FIRM NAME OR                                               OWNERSHIP TYPE* /  SSN
INSTITUTION NAME where                                              (*INDIVIDUAL, JOINT, IRA,
securities are held. If          SECURITY DESCRIPTION:               UGMA, SPOUSAL IRA, ETC.)     QUANTITY
securities are not held in an    Name or ticker symbol   ACCOUNT   NOTE: Only input the SSN if   Shares or
account, list where held        (or CUSIP) of Security    NUMBER     different from your own       amount
-----------------------------   ----------------------   -------   ---------------------------   ---------
<S>                             <C>                      <C>       <C>                           <C>

</TABLE>

*    E.G. INDIVIDUAL, JOINT, IRA, UTMA/UGMA, SPOUSAL IRA, ETC.

IF MORE SPACE IS NEEDED, ATTACH THE ADDITIONAL INFORMATION ON A SEPARATE PAGE.
PLEASE SIGN AND DATE ANY ATTACHED SHEETS.


Initial Personal Account and Holdings Disclosure                    Appendix A.2

<PAGE>

                                    SECTION 2

By signing this document, I am certifying that:

-    The accounts listed above are the only accounts in which I have a direct or
     indirect beneficial interest at this time.

-    I understand that failure to completely disclose all of my Brokerage
     Accounts and Covered Mutual Fund accounts to Personal Trade Compliance may
     result in sanctions, which could lead to termination.

-    The securities listed above are the holdings I have at this time. I
     understand that failure to completely disclose all of my holdings to
     Personal Trade Compliance may result in sanctions, which could include
     termination.

-    If I have one or more managed accounts, I do not have trading discretion
     for the accounts.

-    I have completely filled out this certification form so a letter
     authorizing duplicate confirmations and statements can be sent to my broker
     until my accounts have been transferred to one of the three limited choice
     brokerage firms.

-    I understand that failure to completely disclose all of my security
     holdings to Personal Trade Compliance or failure to complete this form by
     the required due date may result in sanctions, which could include
     termination.

-    I will not participate in market timing of any Mutual Fund or other pooled
     vehicle.

-    If I open any new Brokerage Accounts I will notify Personal Trade
     Compliance in writing by filling out a Brokerage Account Notification form
     BEFORE THE FIRST TRADE IS CONDUCTED.

-    I HAVE READ AND UNDERSTAND THE AMERIPRISE FINANCIAL INSIDER TRADING POLICY
     AND INVESTMENT ADVISER CODE OF ETHICS DOCUMENT AND WILL ABIDE BY THEM.


-------------------------------------   --------------------
Signature                               Date

RETURN TO: PERSONAL TRADE COMPLIANCE-- H26/1880


Initial Personal Account and Holdings Disclosure                    Appendix A.3

<PAGE>

APPENDIX B: BROKERAGE ACCOUNT NOTIFICATION FORM

                   BROKERAGE ACCOUNT NOTIFICATION FORM PROCESS

On the following page is the Brokerage Account Notification Form that is
REQUIRED to be completed if you--or an immediate family member--maintains an
external Brokerage Account. The brokers other than Ameriprise Financial
Brokerage that are allowed at this time are Schwab or Merrill Lynch only.

Please be sure to:

-    Fill out the Personal Information Section.

-    Fill out the Brokerage Account Information Section.

REMINDER: PLEASE SUBMIT THIS FORM PRIOR TO ANY TRADING

If you have questions, please send a Lotus Notes message to PERSONAL TRADING or
call the Personal Trade Hotline at 612-671-5196.


Brokerage Account Notification Form                                 Appendix B.1
<PAGE>

                   ***THIS IS NOT AN ACCOUNT TRANSFER FORM AND
                    WILL NOT CAUSE YOUR SECURITIES TO MOVE***

                       BROKERAGE ACCOUNT NOTIFICATION FORM

    WHEN TO USE THIS FORM: Complete this form when opening any new Brokerage
     Account (including new accounts opened to support an account transfer).

STEP 1: COMPLETE PERSONAL INFORMATION SECTION

<TABLE>
<S>                                  <C>
ID Number (eg., E12345) / Position   / - Corporate Office - Advisor - Field Employee
Social Security Number
Field or Corporate Office Routing
</TABLE>

STEP 2: COMPLETE BROKERAGE ACCOUNT INFORMATION SECTION

<TABLE>
<CAPTION>
                                                                            BROKER DEALER (choose one)
                                                                          ------------------------------
                                                                          AMERIPRISE
                                                                           FINANCIAL   CHARLES   MERRILL
NAME ON ACCOUNT   ACCOUNT NUMBER   SOCIAL SECURITY NUMBER   OWNERSHIP *    BROKERAGE    SCHWAB    LYNCH
---------------   --------------   ----------------------   -----------   ----------   -------   -------
<S>               <C>              <C>                      <C>           <C>          <C>       <C>

</TABLE>

*    E.G. INDIVIDUAL, JOINT, IRA, UTMA/UGMA, SPOUSAL IRA, ETC.

STEP 3: SUBMIT COMPLETED FORM TO PERSONAL TRADE COMPLIANCE

A.   To submit via Interoffice mail, send to PERSONAL TRADE COMPLIANCE, H26 /
     1880.

B.   To submit via Lotus Notes message, attach completed form and send to
     PERSONAL TRADING.


Brokerage Account Notification Form                                 Appendix B.2

<PAGE>

APPENDIX C: LIMITED CHOICE EXCEPTION REQUEST

                        LIMITED CHOICE EXCEPTION REQUEST

   COMPLETE THIS FORM IF ONE OF THE SITUATIONS DESCRIBED BELOW APPLIES TO YOU
      AND YOU WISH TO REQUEST AN EXCEPTION TO THE LIMITED CHOICE POLICY OF
         CONDUCTING TRADING THROUGH ONE OF THE THREE AUTHORIZED FIRMS.

Exception Policy - The typical kinds of situations for which Personal Trade
Compliance expects exception requests include:

A.   spouse accounts where your spouse works for a broker/dealer firm that
     prohibits outside accounts (supporting documentation to include copy of
     other firm's policy)

B.   non-transferable limited partnership interests held prior to implementation
     of limited choice policy (supporting documentation to include copies of
     statements reflecting these holdings) Note: Other holdings and trading
     would remain subject to limited choice.

C.   managed accounts where, e.g., you have authorized broker to exercise
     investment discretion on your behalf and you have no discretion over what
     specific securities are traded in account (supporting documentation to
     include: power of attorney document signed by you and written
     representations from you and from broker that you have no trading
     discretion.) You will be required to re-certify annually.

SECTION 1. REQUEST FOR EXCEPTION (COMPLETED BY YOU, PLEASE PRINT)

YOUR NAME: ______________ ID NUMBER: ____________ ROUTING:_________________

- CORPORATE OFFICE   - ADVISOR   - FIELD EMPLOYEE

EXCEPTION TYPE DESCRIBED ABOVE (ALSO ATTACH SUPPORTING DOCUMENTATION):

[ ]   A

[ ]   B

[ ]   C

[ ]   Other - explain in sufficient detail on an attachment

Broker Name:                                      Account #
--------------------------------------------------------------------------------

Account Ownership (Name on Account):
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
Your Signature                  Social Security #                   Date

SECTION 2. EXCEPTION REVIEW (COMPLETED BY PERSONAL TRADE COMPLIANCE)

[ ]   Request on hold, more documentation needed - PLEASE PROVIDE:

[ ]   Request Denied

[ ]   Request Approved

--------------------------------------------------------------------------------
1st Level Approval                                         Date

--------------------------------------------------------------------------------
2nd Level Approval                                         Date

RETURN THIS FORM AND SUPPORTING DOCUMENTATION TO PERSONAL TRADE COMPLIANCE VIA
FAX AT 612-678-0150 OR INTERNAL ROUTING AT H26/1880.


Limited Choice Exception Request                                    Appendix C.1

<PAGE>

APPENDIX D: INVESTMENT CLUB CLIENT DISCLOSURE FORM

                     INVESTMENT CLUB CLIENT DISCLOSURE FORM

I was a member of the ____________________________ Investment Club before
                             (Club name)
becoming a client of Ameriprise Financial, Inc. or its affiliates. I understand
that ___________________________________ is a financial advisor with
            (Financial Advisor name)
Ameriprise Financial Services, but is not acting in his/her capacity as a
financial advisor with Ameriprise Financial Services through his/her
participation in this club.

I also understand Ameriprise Financial, Inc. and its affiliates do not endorse,
approve, or guarantee any activity undertaken by this club. Furthermore, I
understand Ameriprise Financial, Inc. and its affiliates are not responsible for
this club's investment performance, investment results, and/or any other direct
or indirect financial impact to me as a result of my participation in this club.


-------------------------------------   --------------
Client signature                        Date


-------------------------------------   --------------
Financial Advisor signature             Date

Send to PERSONAL TRADE COMPLIANCE - H26/1880.


Investment Club Client Disclosure Form                              Appendix D.1