Exhibit 14(c)    Global Code of Conduct                                                                          OUR VALUES                                                                           Client-focused      Integrity always      Excellence           Respect
 Exhibit 14(c)       CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                  From our Chairman and Chief Executive Officer                 Our clients, advisors, employees, shareholders and regulators rightfully expect us to obey                 the law and to treat them with integrity.                                        Ameriprise Financial has a proud, more than Our Board of Directors, Executive                                       120 year history as a successful, client- Leadership Team and I hold ourselves to the  The success of                       focused financial services firm. No company same high standards of conduct that we  Ameriprise depends on                can thrive for over a century and grow as expect you to honor. For those who lead  the trust and confidence             we have without a deep commitment to others, it’s your duty to set the right                                       ethical behavior and doing what is right for example for behavior. And it’s up to each of  we earn every day.                   our clients, advisors, employees and us to ensure we treat team members and  Our actions matter.                  shareholders. Our Global Code of Conduct others with dignity and respect.                                       emphasizes the core ethical principles that                                                                            Our vision is to be the most respected and                                       must guide our behavior at all times.  referred financial services brand. We can                                       The Global Code of Conduct also identifies only achieve our vision if each of us does                                       potential areas of ethical risk. Please read it business the right way. Thank you for your                                       carefully. When you see misconduct, report it commitment to the principles in the Code                                       to your leader. Ask your leader for help when and the continued success of our company.                                       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                                                                                  JAMES M. CRACCHIOLO                                       misconduct occurred, you will be protected as CHAIRMAN AND CHIEF EXECUTIVE OFFICER                                      long as you acted in good faith.                                                                                                                                                                                                                      2
 Exhibit 14(c)       CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES   Contents             •  Introduction     −  This Code applies to everyone ........4                                                 •  Report your concerns .........................6  •  Our ethical principles     −  Obey the law and guard against         criminal activity ............................7     −  Do the right thing for the client ......9     −  Conduct business ethically ........... 11     −  Compete fairly in the marketplace 13     −  Protect the company’s reputation         and assets ................................. 15     −  Safeguard and maintain         accurate information .................. 17     −  Treat everyone with dignity         and respect ............................... 19   •  Navigate your ethical questions ........ 21  •  Consequences for non-compliance .... 22  •  Resources ....................................... 23                                                                                                                                                                                                                        3
 Exhibit 14(c)             CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                           This Code applies to everyone                            at Ameriprise Financial                            All officers, employees, financial advisors and their staff must follow this Code.    Why ethics matter                          What you need to know                      You must read and comply with the policies and                                                                                        procedures that apply to you. (See Page 23 for a  The culture of any company is determined by • We value ethics and integrity.          partial list of company policies.)  what its directors, officers and employees                                             •  We maintain an environment where  actually do rather than what they are supposed                                        This Code can’t cover every situation                                                compliance and adherence to the Code of  to do. It is simply about doing the right thing,                                                Conduct is the norm.                    No code of conduct or ethics can anticipate all of  day in and day out.                                                                   the circumstances that you may encounter during                                             About the Code                             your career. If the Code doesn’t address a specific  We expect you to:                          This Code is enterprise-wide and applies to situation, you are still obligated to act in an ethical                                                                                        and honest manner. Above all, seek guidance from  •   Comply with the Code.                  everyone working for one of the company’s                                             business areas or affiliates. Commitment to the your leader, manager or one of the provided  •   Act with integrity, due skill, care and ethical principles helps ensure compliance with the resources (See list of resources on Page 6) before      diligence                              Code.                                      you act.  •   Follow all applicable laws, rules and  This Code applies even if you also adhere to Violations of the Code      regulations.                                             another code of ethics or conduct within your If you violate the Code, you will be subject to  •   Be open and cooperative with our       business area.                             disciplinary action, including possible termination      regulators                             For U.S. employees and employee advisors,  of your employment or franchise agreement.  •   Use your best judgment.                compliance with the Code is a condition of Disciplinary action will depend on the                                             employment. For franchise advisors and their staff, circumstances and will be consistent with the     •   Ask for guidance before you act.       compliance with the Code is required by the company’s policies and procedures. (See  •   Report ethical concerns promptly.      franchise agreement.                       consequences for non-compliance on Page 22.)  •   Be an example of ethical behavior for your Applicable company policies            Waivers of the Code      team.                                  The Code requires you to comply with the   Only the Board of Directors of Ameriprise  •   Pay due regard to the interests of our provisions of other policies, codes of ethics and Financial, Inc. can grant a waiver of the Code of      clients and treat them fairly.         other business procedures to which you are Conduct. We will promptly disclose to our                                                                                        shareholders any waivers granted to our executive                                             subject.   •   Observe proper standards of market                                                officers and directors.      conduct.                                                                                                                                                                                                                                                         4
 Exhibit 14(c)        CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                   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.                                                                                                                                                                                                                                                                              5
 Exhibit 14(c)              CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                            Report your concerns                           If you observe behavior that concerns you, or that you believe in good faith may be                           illegal or a violation of the Code, you are required to report the issue promptly.    Why ethics matter                          What you need to know                          the same situation with access to the same                                                                                            facts would also conclude there is a likelihood  Your diligence allows us to correct problems that • We respond appropriately to all allegations by of misconduct.  may involve a violation of law or pose a risk to employees, suppliers, clients or contractors health, safety or the company’s reputation.   that the company is not meeting its legal, Non-retaliation                                                ethical or financial obligations.       We will not tolerate any retaliation against you if  We expect you to report concerns           •  We provide several reporting options for you report possible misconduct in good faith even  promptly to your leader, manager or one       anyone who suspects breaches of the Code, if it turns out that no misconduct occurred. You  of the following resources:                   our policies or the law.                won’t be fired, given a lower performance rating or                                                                                        demoted solely because you reported possible  •  Employee Relations Group                Whistleblower claims                       misconduct in good faith. Retaliating against a     Service Center – ERGSC@ampf.com         Acting ethically includes reporting misconduct. If person who has reported a suspected violation is  •  Ethics Hotline – 1.800.963.6395         you don’t report the misconduct of others, you are considered a violation of the Code.                                              not acting ethically and will be held accountable. It  •  Safe Call (UK) – 0800 915 1571                                                     •   All reports are investigated, and your report                                            may not be easy to report misconduct involving a will be treated confidentially to the extent                                            colleague or friend, but that is what we expect you  •  FCA Whistleblowing (UK) –                                                              allowed by law and company policy.    whistle@fca.gov.uk                      to do.                                                                                        •   If you believe you have been retaliated •  Public Concern at Work (UK) –           You should, in good faith, report an alleged   against, promptly contact any of the resources    helpline@pcaw.co.uk                     impropriety that prevents the company from     listed on this page.                                            meeting its legal obligations or complying with  •  Corporate Secretary’s Office –                                             generally accepted accounting principles.  •   Leaders are responsible for properly reporting    Thomas.R.Moore@ampf.com                                                                any allegations they become aware of. •  General Counsel’s Organization –        •  A whistleblower is an individual who lawfully                                               makes any allegation of impropriety or    Karen.Wilson.Thissen@ampf.com                                               discloses or provides information or assistance  •  Executive Vice President,                  in connection with any governmental    Human Resources –                          proceeding or inquiry.    Kelli.A.Hunter@ampf.com                                            •  Acting in good faith means that you have a                                               sincere belief that a reasonable person in                                                                                                                                                                                                                                                      6
 Exhibit 14(c)              CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                            Obey the law and guard against criminal activity                            We comply with all laws and regulations that apply to our operations, including insider                            trading laws.                                                What you need to know                      Insider trading  Why ethics matter                                              •  We obey the law in our professional lives just Insider trading is both illegal and unethical. Insider  Legal or regulatory violations can cost our                                                 as we do in our personal lives. Being unaware trading is the practice of buying or selling securities  shareholders millions of dollars in legal                                                 that a law or regulation exists won’t excuse of any company, including Ameriprise Financial,  judgments, fines or penalties. In some cases,                                                 any violation you commit.               when you are aware of material, non-public  you could also face fines, the loss of your job                                        information about that company or its securities. If  and even imprisonment. The company often    •  We follow the advice of our legal and   you are convicted of insider trading, you could be  sets a higher standard than what the law       compliance professionals.               sentenced to years in prison.  requires, so it is important to understand all                                              •  We always cooperate fully and honestly with Personal trading  policies that apply to you.                    our regulatory agencies during examinations                                                 and inquiries.                          Our personal trading rules, policies and procedures  We expect you to:                                                                      apply to everyone who is subject to this Code with                                              Comply with rules, regulations and laws                                                                                         few exceptions. These rules are derived from  •  Become familiar with the laws and                                                                                         securities and investment laws, regulatory guidelines     regulations that apply to you and your job, Additional rules or regulations may apply to you in                                              your home country or because of your specific job and other corporate policies. They aim to eliminate     including insider trading laws, which apply                                              responsibilities. Each of us is responsible to know the appearance of conflict between the personal     to everyone.                                               and follow the laws wherever we work.      trading activities of our associates and our clients as  •  Complete all mandatory training,                                                    well as the rest of the investing public.     disclosures and other requirements related Fraud prevention                                                                                         In addition to the general rules that apply broadly     to your job.                             Preventing fraud is a responsibility of everyone at to individuals subject to the Code, more restrictive  •  Stay current on legal and regulatory     all levels. You have a duty to be mindful of rules apply to certain persons based on their     developments you need to know.           potential fraudulent activity and to promptly access to information and/or their job                                              report anything suspicious. Fraud includes a wide responsibilities. You are responsible for  •  Report suspected insider trading, market                                              variety of illegal acts, all characterized by the understanding the related company policies that     abuse or fraudulent activity promptly.                                              intent to deceive someone. Fraud can be    apply to you.                                                                      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.                                                                                                                                                                                                                                                                                                          7
 Exhibit 14(c)         CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES    I told my spouse about a company that  Ameriprise Financial  is considering  buying. Was that wrong?  Yes. First, you should not share confidential  business information with anyone unless  it’s necessary to do your job. Second, if this  is material, non-public information and your  spouse trades in the stock of Ameriprise or  the other company, you both could face  prosecution for insider trading.     Am I subject to blackout periods for  trading in the company’s stock?  It depends on your role within the  company. The company’s Board of  Directors, certain executive officers and  other designated employees are subject to  regular quarterly blackout periods, during  which they are prohibited from executing  transactions in Ameriprise Financial  securities. The blackout periods generally  begin on Jan. 1, April 1, July 1 and Oct. 1.  The beginning date of each blackout period  is fixed, regardless of whether that date  happens to be a business day. Each  blackout period ends 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.                                                                                                                                                                                                                                             8
 Exhibit 14(c)               CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                             Do the right thing for the client                             From initial contact with prospects, through our continued service of existing individual                             or institutional client and end-client accounts, we stand behind what we say and do.                                                  What you need to know                       In addition, the content must meet applicable  Why ethics matter                                                                         regulatory and legal standards. When preparing                                                •  We carefully consider the impact of our  advertising, marketing and communication for the  We maintain our clients’ loyalty and improve their decisions on clients.                  public, you must ensure that required reviews and  experience by acting with integrity. Our first                                                                                            approvals are received prior to first use.   priority is the success of our clients. They have • We provide exceptional client service.  selected us to help them reach their financial • We are committed to making full and fair Suitability  goals, support their children’s education and    disclosures.                             Advice and products recommended must be  prepare for retirement on their terms. If we break                                                Full and fair disclosure                    suitable for each client. Always take the time to  that trust, our clients will leave us for other firms.                                    ensure that investment advice and products or                                                You must make full and fair disclosure of all features, services recommended are appropriate given a                                                benefits, risks and fees of products or services sold or  We expect you to:                                                                         client’s age, financial situation, investment                                                marketed to all clients and prospects, particularly                                                                                            planning objectives and tolerance for risk. Also,  •   Be truthful and accurate.                 where your interests may conflict with those of our                                                                                            take time to provide clients with the information  •   Never mislead a client or prospect.       clients. Full and fair disclosure applies to initial client necessary for them to fully understand the                                                communications as well as to subsequent                                                                                            features, potential benefits and risks of the  •   Help clients and prospects understand our recommendations.       products and services.                                                                recommended product or service. When dealing                                                Your disclosures must be accurate, fair and with elderly clients, pay special attention to their  •   Provide clients and prospects with all    balanced and presented in the proper context. Do expected financial needs and tolerance for risk.      information they need to make an informed not omit material facts or qualifications if the      decision about our products and services.                                             Our suitability requirements apply not only to                                                result would be misleading.                 initial buy, sell and hold recommendations, but                                                Marketing, advertising and communications with also to subsequent recommendations in existing                                                the public                                  accounts.                                                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.                                                                                                                                                                                                                                                             9
 Exhibit 14(c)         CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES    My job doesn’t involve client contact.  Recently, however, someone claiming  to be a  client was transferred to my number. She  was upset about something, but I politely  said I couldn’t help her and hung up. Was  that wrong?  Yes. In this situation, you should ask for the  person’s name, address, telephone number and  a brief description of the issue. After telling her  you will find the right person to help her, talk to  your leader about how to follow up. You should  never try to answer a question if you are not  qualified to do so, but each of us has a  responsibility to do the right thing for our  clients.   We know that trust must be  earned and are committed  to making fair and  accurate disclosures.                                                                                                                                                                                                                                              10
 Exhibit 14(c)               CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                             Conduct business ethically                             We have a duty to promote the interests of the company. That means we do not use the                             company’s property or information for our own benefit or to compete with the company.                                                What you need to know                      You are prohibited from using your position with  Why ethics matter                                                                       the company, or information acquired during your                                               •  We do not use company information and   employment or relationship with the company, to  Employees, officers and directors owe a duty to the                                                  property for personal gain.             advance your personal interests over the interests  company to advance its legitimate interests. Your                                                                                          of clients or the company.  personal interests, whether winning a promotion or • We carefully monitor and control conflicts of  earning more compensation, are never more       interest.                               Gifts or entertainment  important than the best interests of our clients or                                               •  We do not give, solicit or accept gifts that Generally, you may only accept gifts (including  the company.                                                   could influence our business judgment.  business-related meals or entertainment) if the                                               Conflicts of interest                      value of the gift is not significant and the gift will                                                                                          not place you – or appear to place you – under any  We expect you to:                            You may engage in an outside activity if it does not                                                                                          obligation to the donor. Before accepting a gift,                                               compete or conflict with the interests of the  •  Address conflicts of interest before you take                                        you should ask yourself if the gift would appear                                               company or interfere with the responsibilities of     any job action or engage in an outside business                                      significant to others or place you under any     activity that may benefit you or your family. your job or the company’s employees. A conflict of obligation. If the answer is yes, then you should                                               interest occurs when your private interests     This applies to everyone, regardless of whether                                      not accept the gift.     you are a registered person               interfere in any way – or even appear to interfere –                                               with the interests of a client or the company. A You may be subject to a specific policy related to     •  Avoid even the appearance of impropriety. conflict of interest also arises when you or a accepting or giving gifts over a certain dollar value.  •  Comply with company policies related to   member of your family receives improper personal (Please refer to policies that apply to you.)                                               benefits as a result of your position in the     outside business activities, political                                               Political contributions and involvement     contributions and gifts and entertainment. company.                                                                                           We respect your right to participate in the political     −  Advisors, registered persons and investment- You must be especially sensitive to potential                                                                                          process. However, because of U.S. campaign        access persons must file reports as required by conflicts of interest when you are considering        applicable policies.                                                              finance laws, you may not: use company funds or                                               engaging in consulting or other outside activities be reimbursed for a political contribution; allow a     −  All persons subject to the Code and located in that involve the skills and knowledge you use in candidate or campaign to use company facilities or        the U.S. must seek guidance from the   your job. Simply reporting or disclosing an activity                                                                                          property; use work time or company equipment        Corporate Secretary about potential conflicts of                                               without first resolving possible conflicts of interest for political or campaign purposes; or allow your        interest, whether involving gifts, vendor may result in a violation of the Code.        relationships, outside business activities, or                                    contribution of time or money to appear to be        other circumstances.                                                              made with, or reimbursed by, company funds     −                                                                                                                                                                                                                                                     11
 Exhibit 14(c)         CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES    A client sent me a case of wine as a gift.  I know that if I purchased the wine,   it would be expensive. Can I accept   this gift?  If you are subject to a gift and entertainment  policy, you may be required to decline the gift  politely and return it. If you are a licensed  person, you should seek advice from your  registered principal or the Compliance  Department. If you don’t know whether a gift  policy applies to you, you should call the  Corporate Secretary. Remember that you are  never permitted to solicit a gift from a client,  vendor or anyone else doing business with the  company.    Do I need to pre-clear my political  contributions and political volunteer  activities?  If you are a financial advisor, you are subject  to pre-clearance requirements. Otherwise,  you need to refer to the Political  Contributions policy to see if you are covered.  Depending upon changes in your job or band  level, you may become subject to pre- clearance in the future even if you are not  covered now. Also, it's important to see if  your current political contributions may affect  your chances to apply for certain jobs in the  future, due to the SEC’s pay-to-play rules.                                                                                                                                                                                                                                            12
 Exhibit 14(c)              CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                            Compete fairly in the marketplace                            We believe that everyone benefits from fair, free and open markets, and we compete                            fairly in the marketplace based on the merits of our products and services.                                               What you need to know                      All employees, officers and directors should deal fairly                                                                                         with our clients, investors, suppliers and competitors.  Why ethics matter                           •  We must never offer, make or accept unlawful We don’t take unfair advantage of anyone through                                                 payments or gifts regardless of local business manipulation, concealment, abuse of privileged  We operate in a highly regulated industry and                                                 customs.                                information, misrepresentation of material facts or  under intense media and public scrutiny.                                                                                         any unfair practices.   Regulators and prosecutors recognize the    •  We comply with all antitrust, anti-bribery,  importance of a strong ethical and compliance  anticorruption, monopoly and competition laws. Non-retaliation  culture.                                       Failure to comply can have serious consequences                                                 for the company and for you.            An individual shall not be held criminally or civilly liable                                                                                         under any Federal or State trade secret law for the                                              Antitrust and competition law  We expect you to:                                                                      disclosure of a trade secret that is made:                                              We prohibit agreements intended to limit                                                                                         •   in confidence to a Federal, State, or local  •   Deal fairly with clients, vendors,      competition. We expect you to avoid any      competitors and other employees.                                                       government official or to an attorney solely for the                                              agreement with a competitor to limit competition.  purpose of reporting or investigating a suspected     •   Maintain the company’s confidential     •  When dealing with outside companies,        violation of law; or      or proprietary information and             including contractors and vendors, consider      trade secrets.                                                                     •   in a complaint or other document filed in a lawsuit                                                 whether they are competing with Ameriprise  or other proceeding, if such filing is made under                                                 Financial.                                  seal.                                               •  The General Counsel’s Organization is                                                                                         An individual who files a lawsuit for retaliation by an                                                 available whenever you question the legality employer for reporting a suspected violation of law                                                 of a proposed activity or need further  may disclose the trade secret to the attorney of the                                                 guidance.                               individual and use the trade secret information in the                                              •  False or misleading statements about our court proceeding, if the individual files any document                                                 competitors are contrary to our values and containing the trade secret under seal; and does not                                                 damage our reputation.                  disclose the trade secret, except pursuant to court                                                                                         order.                                                                                                                                          Fair dealing                                                                                                                                                                                                                                                         13
 Exhibit 14(c)         CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES    I noticed that a contractor made a   mistake in its invoice in our favor. What  should I do?  Call the contractor to discuss the invoice and  confirm that we have been undercharged. If  so, ask for a corrected invoice. That’s what we  would expect if we made that mistake in one  of our invoices.    I’m having a business lunch with an official  of a foreign government at an inexpensive  restaurant. I know that he is an avid golfer,  so I plan to give him a box of golf balls as a  small gesture of appreciation for meeting  with me. What do I need to know?  This legal area is very complex, so seek advice  from the General Counsel’s Organization  before you give anything of value to a  government official or anyone claiming to  represent a government or a government- controlled entity. The United States Foreign  Corrupt Practices Act and the UK Bribery Act  impose severe penalties if you give anything of  value to a government official. Many other  countries are also enacting strict laws against  bribery and corruption. In this case, even a  modest meal and small gift can result in severe  penalties for you and the company.                                                                                                                                                                                                                                             14
 Exhibit 14(c)                CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                              Protect the company’s reputation and assets                              We diligently safeguard the company’s reputation, its physical and intellectual property                              and all sensitive information.                                                 What you need to know                      Intellectual property  Why ethics matter                             •  We consider our reputation one of our most Intellectual property is one of the most valuable                                                                                           assets of our company. Our logos and branding  Our ability to attract and retain clients, advisors valuable assets.                                                                                           (e.g., trademarks, service marks) stand as a unique  and employees depends on our reputation as an •  We protect our assets and use them for  ethical, honest and law-abiding company.                                                 symbol of the quality, integrity and reliability that                                                   appropriate business purposes.          underlie all our products and services. Moreover,  Anything that you do, whether at work or in your                                                                                           they serve to identify us to the world and set us  personal life, that damages our reputation is a Anti-money laundering and identity theft                                                                                           apart from our competitors.  serious matter. Be especially careful not to post or The company maintains policies and procedures to  say anything on social media that could embarrass prevent and detect money laundering and identity The use of all logos and brand names, such as  you or damage the reputation and brand we have theft. Suspicious activity takes many forms and is “Ameriprise Financial,” “RiverSource,” “Columbia  worked so hard to establish. Remember that your hard to define in absolute terms; however, Threadneedle Investments,” “Columbia  obligation to comply with the Code doesn’t stop common examples of “red flags” are included in Management” and “Threadneedle” must conform  when you leave the office.                    the company’s related policies. If you ignore or with company policy.                                                choose not to report suspicious activity, both you We will also never knowingly infringe on the  We expect you to:                             and the company could be considered willfully intellectual property rights of others. You are                                                blind and held liable for the criminal activity. responsible for confirming that the use of any     •   Be alert to situations or actions that may  Report concerns by submitting a Report of Unusual third-party intellectual property is approved and      be unethical or potentially damaging to the                                                Activity, which can be found on Inside or the done with written permission. This includes, but is      company’s reputation.                     AdvisorCompass® site.                      not limited to, computer programs, brands, logos  •   Watch for warning signs that may signal                                              and periodicals.                                                Company property      fraudulent activity and report any suspicious      activity.                                 Our company property, including equipment,                                                supplies, systems and facilities, must only be used for  •   Use company property only for valid                                                 valid business purposes. Theft, carelessness and      business purposes and with proper                                                waste have a direct impact on our profitability. If you      authorization.                            suspect someone was involved in, or is attempting to  •   Protect all company and client property   cover up, the theft or misuse of company property,      and assets against theft or misuse.       immediately report it to your local security personnel                                                or to SecurityAMPF@ampf.com.                                                                                                                                                                                                                                                               15
 Exhibit 14(c)        CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                  I hear leaders refer to enterprise  risk management. What does it                                                     mean to me in my role?  Like all financial services companies, we  face various risks that could harm our  company, clients and shareholders. We  invest significant time and money to  identify and manage these risks, but of  course it’s impossible to eliminate many of  them. Even if an event is completely out of  our control, such as a natural disaster or act  of terrorism, we need to anticipate it as  much as possible and be able to respond  effectively. Risks can become more serious  over time and new risks are emerging  constantly.  Our Board of Directors and Executive  Leadership Team are focused on risk  management because it’s crucial to our  continued success. We also have talented  teams of officers and employees around the  world who are devoted to risk  management. To be truly effective in  identifying, monitoring and managing risk,  each of us must think and act like a risk  manager.   Regardless of your job or level of  responsibility, we expect you to be part of  our risk management program. Each of us is  a risk manager.                                                                                                                                                                                                                                                                            16
 Exhibit 14(c)               CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                             Safeguard and maintain accurate information                             We diligently safeguard the personal information of our clients. We believe that                             accurate recordkeeping and reporting are essential to our reputation and credibility.                                                What you need to know                      •   Always support estimates and accruals with  Why ethics matter                                                                           appropriate documentation based on your best                                               •  We collect, safeguard and disclose client or  Many data breaches and cybersecurity incidents                                              judgment.                                                  sensitive information only in compliance with the  are the result of employee mistakes or negligence.                                                  law and our policies.                   •   Never falsify any document or distort the true  Carelessly clicking a link in an email or opening an                                        nature of any transaction.  attachment could result in a serious cybersecurity Confidentiality and privacy  incident. You’ve probably read about incidents at                                       •   Never enable another person’s efforts to evade                                               We maintain the confidentiality of information taxes or subvert local currency laws.   other companies that have cost millions to   entrusted to us by the company and our clients.  resolve. You play a role in being attentive and Confidential information includes all non-public • Only make payments to the person or firm that  doing everything you can to avoid one at     information that might be of use to competitors or actually provided the goods or services.  Ameriprise.                                               harmful to the company or its clients if released. Only Records management                                               employees with a business need-to-know reason are                                                                                          We maintain appropriate books and records  We expect you to:                            allowed access to such data. Report privacy incidents or                                               unauthorized access to sensitive information to according to the law and our policies. We do not  •  Protect the privacy, confidentiality and  Privacy.Swat.Team@ampf.com.                shred, destroy or alter documents that are related to     security of client, employee, advisor and                                            any imminent or ongoing investigation, lawsuit, audit,     company information.                      Financial and business information         examination or are required to be maintained for                                                                                          regulatory purposes.  •  Keep accurate business and financial records. Maintaining accurate and complete business and                                               financial records, including financial statements and Signature issues and forgery   •  Safeguard sensitive information from      accounts, expense reports, time records and invoices,     unauthorized disclosure.                  is not just the job of Accounting and Finance Employees, advisors or staff may not copy, affix or                                                                                          trace a client’s signature or sign any document on  •  Report financial and other business       personnel.                                                                                          behalf of a client, even if specifically asked to by     information truthfully, accurately and                                               •  Always record and classify transactions in the the client. A signature is considered forged if it was     completely.                                  proper accounting period and in the appropriate signed by someone other than the person named,  •  Maintain all business records in accordance  account and department.                 or      with the company’s policies and procedures. • Never delay or accelerate the recording of that person’s legally authorized representative.                                                  revenue or expenses.                    Whenever a client signature is required, it must be                                                                                          an original signature of the client or his or her                                                                                          legally authorized representative.                                                                                                                                                                                                                                                            17
 Exhibit 14(c)        CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES       A package mailed by a client  containing a completed application                                                     and a check looked like it had been  opened. Do I need to tell anyone  about this?   Yes. Even if nothing appeared to be missing,  this is still a potential breach of the client’s  privacy. Send an email to  Privacy.Swat.Team@ampf.com, who will  research and identify potential risk.                 Contact your leader, registered  principal, the Employee Relations  Group Service Center at 1.877.  267.4748,  the Ethics Hotline at  1.800.963.6395  or Safe Call in the  UK at 0800  915 1571 if you:  •  Believe financial information or     business records are not reported or     maintained accurately and completely.  •  Feel pressure to report inaccurate or     incomplete financial or business     information.   •  Are asked to prepare or destroy     documents in violation of company     policy.                                                                                                                                                                                                                                             18
 Exhibit 14(c)              CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                                                        Treat everyone with dignity and respect                            We value our people, encourage their development and reward their performance.   Why ethics matter   We expect all persons to behave in a values- What you need to know                       driven manner, which includes welcoming  diversity and treating all people with dignity and • We are good citizens in our communities.    respect. Discriminatory treatment and                                              •  We make all reasonable efforts to maintain a Freedom from fear and violence in the workplace  harassment are illegal and violate our company                                                 safe and healthy work environment for our  values. Therefore, we encourage individuals to                                         We prohibit the possession of weapons in the  report any violations.                         employees and visitors.                 workplace or when conducting business on behalf of                                              •  We prohibit discrimination or harassment.  the company. You may not assist or permit others to                                                                                         possess weapons in the workplace.  We expect you to:                           Equal employment opportunity                                                                                         Importance of diversity  • Treat others the way you would like to    Employees, financial advisors and leaders are    be treated.                               responsible for complying with the company’s Equal We are committed to valuing and supporting  • Be an example to the next generation      Employment Opportunity Policy, Individual Treatment diversity in the workplace and community.    of leaders.                               Policy and related policies, and anti-discrimination Employees, field members and staff represent many                                              and anti-harassment laws. Leaders have the added age groups, ethnicities, family structures, races,  • Support a diverse and safe work           responsibility of ensuring compliance with those religions, sexual orientations, nationalities and mental    environment.                              policies and laws.                         and physical abilities.   • Notify your local or onsite security personnel or Freedom from discrimination        Non-retaliation    local law enforcement immediately if you see    anyone exhibiting threatening behavior or if We prohibit discrimination or harassment against any We do not retaliate against or intimidate an    there is a potentially dangerous situation at person on the grounds of race, color, religion, individual who makes a complaint, assists in making a    your workplace.                           national origin, disability, age, sex, marital status, complaint or is a witness in an investigation. Our                                              sexual orientation, gender identity, veteran status or values and the law protect an individual who, in good    −  Security Services                      citizenship.                               faith, reports discrimination, harassment, threats of       1.800.455.5187                                                                    violence or any inappropriate behavior.                                              Each of us, particularly leaders, is responsible for    −  Safe Call (UK)                         creating and maintaining a work environment free of Safety, health and the environment       0800 915 1571                          discrimination and harassment.         −  Employee Relations Group                      Service Center        ERGSC@ampf.com                                                                                                                                                                                                                                    19
 Exhibit 14(c)        CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES   We make all reasonable efforts to provide and  maintain a safe and healthy working  environment for our employees and visitors.                                                                    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.                                                                                                                                                                                                                                              20
 Exhibit 14(c)               CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                             Navigate your ethical questions                             Consider your actions carefully. Ask for guidance when you need it.                                                 What you need to know                          everyone reporting or assigned to them,                                                                                              including visitors and contractors, regardless                                               •  We make decisions with integrity.  We expect you to:                                                                           of their work location.                                               •  We expect our leaders to set an example of If you are an individual contributor  • Be aware of the consequences of your actions. courteous and respectful behavior toward their                                                                                          We expect all leaders to set the right ethical                                                  team members and others.  • Ask for guidance when you need it.                                                    example for the company and its employees,  • Ask yourself about a potential behavior or Related policies                           regardless of how many people they lead. But even    action:                                    The Code of Conduct and the related policies if you aren’t a leader, we expect you to be an                                                                                          example of this same honest and ethical behavior    −  Is it consistent with the Code and other cannot, and do not attempt to, address every                                                                                          for others on your team. Remember that others       company policies?                       possible situation or circumstance that you may                                               encounter. You are responsible for becoming may model their behavior based on yours,    −  Is it ethical?                          familiar with the Code of Conduct and related especially if you have more experience or have    −  Is it legal?                            policies, adhering to the principles and rules stated been with the company for a longer period of time.                                               in them and seeking advice and guidance when Never make jokes about complying with the law,    −  Am I setting a good example?            you are uncertain as to the proper course of our policies and procedures or the Code of    −  Will it put the company at undue risk?  action.                                    Conduct. Never belittle anyone for asking what the                                                                                          right thing to do is.     −  Will it reflect poorly on the company   If you are a leader       or me?                                                                             •   If someone on your team asks for your advice                                               Leaders at all levels are responsible for continually on how to handle an ethical question,    −  Would I want to read about it in the news emphasizing integrity as a standard of       encourage him or her to speak with your       or on social media?                     performance for all employees, demonstrating   leader.                                               how employees and others should be treated with    −  How would I explain my actions to my                                               dignity and respect and creating and maintaining a • Be supportive and remind the person that we       colleagues, friends and family?                                               work environment free of discrimination and    have a strict policy against retaliation for                                               harassment.                                    reports made in good faith.                                               •  Leaders should always seek legal advice about • How you behave and what you say matters.                                                   the laws that may apply to a particular                                                   situation.                                               •  Leaders are responsible for the health, safety                                                  and welfare of their departments, and                                                                                                                                                                                                                                                           21
 Exhibit 14(c)              CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                            Consequences for non-compliance                            Remember that asking for guidance before you act may help you avoid disciplinary                            action for violating the Code or a law, rule or regulation.                                                What you need to know                          or potential client, a leader or member of  We expect you to:                                                                          management, or failure to perform work as                                              •  We will not accept ignorance or oversight as  Talk to your leader or any of these resources                                              required or assigned; and                                                 excuses for behavior that violates the Code,  about any situation that concerns you:                                                 related policies or any law or regulation. • Violations of safety or health laws or regulations  •  Your Human Resources                                                                    or engaging in conduct that creates a safety or                                              •  We retain the right to determine whether    health hazard.     business partner                            specific actions or behaviors violate the Code of  •  Employee Relations Group Service Center –   Conduct.                                In addition, if you violate the law during the course of     1.877.267.4748                                                                      your employment you may be subject to criminal and                                              Violations of the Code                     civil penalties as well as payment of monetary  •  General Counsel’s Organization –                                              Personal conduct that violates the Code includes, but damages to the company or third parties.     1.612.671.3602                                              is not limited to:                         Disciplinary action may also be taken against an  •  Executive Vice President, Human Resources –                                              •  Willful or negligent damage to company  employee or advisor who:     1.612.671.3997                                                 property or the property of others;     •   Authorizes, directs, approves, participates in or  •  Corporate Secretary’s Office –                                              •  Theft or dishonesty, including falsification of encourages violations of the Code;     1.612.678.0106                                                 company records or furnishing false or  •   Deliberately fails to report or conceals violations  •  Ethics Hotline – 1.800.963.6395             incomplete information on expense forms, time or deliberately withholds or misstates relevant  •  Personal Trading Hotline – 1.612.671.5196   records, employment applications or other   information;                                                 documents related to your employment;  •  Suspicious Activity Hotline – 1.612.671.6166                                        •   Retaliates against any other employee because                                              •  Inappropriate behavior or personal attire   he or she reported a suspected violation in good  •  Safe Call (UK) – 0800 915 1571                                                 that is unprofessional or embarrasses the   faith; or  •  FCA Whistleblowing (UK) –                   company or its clients, including posting                                                                                          •   Knew or should have known about a violation by     whistle@fca.gov.uk                          or transmitting offensive or inappropriate                                                 material on the internet or any social      people under his or her supervision and did not  •  Public Concern at Work (UK) –               media site;                                 promptly report it.    helpline@pcaw.co.uk                                              •  Disruptive or offensive behavior while                                                 conducting company business, including                                                 insubordination, willful disregard of company                                                 policies or procedures, disrespect toward a client                                                                                                                                                                                                                                                                 22
 Exhibit 14(c)        CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES                          Resources                          Refer to related company policies, procedures or related resources for questions or                          additional information.    This list contains only a portion of the policies and procedures that may apply to you or that may provide helpful guidance in your role. Search Inside,  AdvisorCompass, Complisource or other company intranet systems for these and additional policies.  •   Ameriprise Financial Global Anti-Money Laundering • Columbia Threadneedle Investments Privacy and  •   Individual Treatment Policy       and Economic Sanctions Policy                       Information Security and Identity Theft Prevention • Intellectual Property Policy                                                          Program  •   Ameriprise Financial Personal Trading Policy                                                       •   Mandatory Training: Annual Requirements                                                       •   Communications and Disclosure Policy  •   Ameriprise Financial Political Contributions (“Pay to                                              •   Mandatory Training: New-Hire Requirements       Play”) Policy                                   •   Corporate Compliance Manual                                                                                                          •   Outside Business Activities Policy   •   Ameriprise Financial Public Appearances and     •   Corporate Supervision Manual                                                                                                          •   Record and Information Management Policy      Interaction with the Media Policy               •   Data and Information Sharing Guidelines  •   Client Privacy Principles                                                                          •   RiverSource Gifts, Entertainment and Marketing                                                      •   Dual Registration Policy                           Support Policy   •   Columbia Threadneedle Investments               •   Electronic Communication Acceptable Use Policy      Activities Involving Outside Entities or Family                                                    •   Secure Workplace Policy      Relationships Policy                            •   Equal Employment Opportunity Policy            •   Social Media Policy  •   Columbia Threadneedle Investments Employee      •   Facility Rules, Guidelines and Standards       •   Threadneedle Other Conflicts of Interest Policies      Registration and Licensing                          of Use                                             Applicable to Covered Persons   •   Columbia Threadneedle Investments               •   Gifts and Business Entertainment Policy -      •   Threadneedle Market Abuse & Insider Dealing      Firm Registration, Regulatory Filings, and Disclosure Ameriprise Financial Services, Inc.              Policy       Policy                                          •   Gifts and Business Entertainment Policy -      •   Threadneedle Conflicts of Interest Policy                                                           American Enterprise Investment Services  •   Columbia Threadneedle Investment Gifts,                                                            •   Threadneedle Outside Activities & Family      Entertainment and Other Benefits Policy         •   Global Anti-Corruption Policy and Guidelines       Relationships Policy   •   Columbia Management International Compliance    •   Columbia Threadneedle Investments Global       •   Threadneedle Gifts & Corporate Hospitality Policy       Policy for Columbia Management Non-U.S. / Offshore  Personal Account Dealing and Code of                                                                                                          •   Threadneedle Treating Customers Fairly       Sales and Service Activities                        Ethics Policy                                                                                                          •   Threadneedle Whistleblowing Policy    •   Columbia Threadneedle Investments Material     •    Handling Whistleblower Claims Policy      Nonpublic Information Policy                   •    HIPAA Policies and Procedures Manual           •   Your Guide to a Safe and Respectful Workplace                                                                                                             Policy   •   Columbia Threadneedle Investments Political    •    Identity Theft Prevention Policy       Contributions Policy                                                      •    Information Security Policy  •   Columbia Management Portfolio Holdings Disclosure      Policy                                                                                                                                                                                                                                                                                                               23
 Exhibit 14(c)    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 o r 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.   Financial Planning | Retirement | Investments | Insurance  Ameriprise Financial, Inc.  Corporate Secretary’s Office  1098 Ameriprise Financial Center, Minneapolis, MN 55474  ameriprise.com  Revised July 1, 2018  © Ameriprise Financial, Inc. All rights reserved.