Global Code of Conduct  OUR VALUES  Respect Excellence  Client-focused Integrity always  Exhibit 14(c)
    2       CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  From our Chairman and Chief Executive Officer  Our clients, advisors, employees, shareholders and regulators rightfully expect us to comply with federal,  state, and local statues and regulations, and to treat our stakeholders with integrity.     The success of Ameriprise  depends on the trust and  confidence we work diligently  to earn every day. Our  choices and actions matter.  Ameriprise Financial has a proud, more than  125-year history as a successful, client- focused financial services firm. Our vision is  to be the most respected and referred  financial services brand. We can only achieve  our vision if each of us does business the  right way. We have thrived because of our  deep commitment to our values (Client- focused; Integrity Always; Excellence in all we  do; and Respect) and doing what is right for  our clients, advisors, employees and  shareholders.  Your actions and decisions are critical to  demonstrating how we operate and what we  can achieve. Our Global Code of Conduct  reinforces the core principles that guide our  behavior at all times. It also identifies  potential areas of ethical risk. Please read it  carefully.   If you observe misconduct, report it to your  leader. We will not take action against  anyone who reports what one believes in  good faith to be misconduct.   Our Board of Directors, Executive Leadership  Team and I believe strongly in our Code of  Conduct and continue to refine it as we  evolve as a leading financial services firm. If  you lead others, it is your responsibility to  set the right example for behavior and  conduct. And it’s up to each of us to ensure  we treat colleagues and others with dignity  and respect.  Thank you for your continued commitment to  our values and doing what is right by  adhering to the principles in the Code.          JAMES M. CRACCHIOLO  CHAIRMAN AND CHIEF EXECUTIVE OFFICER
    3     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Contents       • Introduction  − Our Code applies to everyone .............. 4  • Report your concerns .................................. 6  • Our ethical principles  − Obey the law and guard against   criminal activity ................................... 7  − Do the right thing for the client ............ 9  − Conduct business ethically ................ 11  − Compete fairly in the marketplace ..... 13  − Protect the company’s reputation   and assets ......................................... 15  − Safeguard and maintain   accurate information .......................... 17  − Treat everyone with dignity   and respect ....................................... 19  • Navigate your ethical questions ................ 21  • Consequences for non-compliance ........... 22  • Resources ................................................. 23
    4     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Our Global Code of Conduct applies to everyone  at Ameriprise Financial   All officers, employees, financial advisors and their staff must follow this Code.  What you need to know   We value ethics and integrity.   We maintain an environment where  compliance and adherence to the Code of  Conduct is the norm.  About the Code  This Code is enterprise-wide and applies to  everyone working for one of our business areas  or affiliates. Commitment to the ethical  principles helps ensure compliance with   the Code.  This Code applies even if you also adhere to  another code of ethics or conduct within your  business area.   For U.S. employees and employee advisors,  compliance with the Code is a condition of  employment. For franchise advisors and their  staff, compliance with the Code is required by  the franchise agreement.   Applicable company policies  The Code requires you to comply with the  provisions of other policies, codes of ethics  and other business procedures to which you  are subject.   You must read and comply with the policies  and procedures that apply to you. (See Page 23  for additional information.)  This Code can’t cover every situation  No code of conduct or ethics can anticipate all  of the circumstances that you may encounter  during your career. If the Code doesn’t address  a specific situation, you are still obligated to  act in an ethical and honest manner. Above all,  seek guidance from your leader, manager or  one of the provided resources (See list of  resources on Page 6) before you act.  Violations of the Code  If you violate the Code, you will be subject to  disciplinary action, including possible  termination of your employment or franchise  agreement. Disciplinary action will depend on  the circumstances and will be consistent with  the company’s policies and procedures. (See  consequences for non-compliance on Page 22.)  Waivers of the Code  Only the Board of Directors of Ameriprise  Financial, Inc. can grant a waiver of the Code of  Conduct. We will promptly disclose to our  shareholders any waivers granted to our  executive officers and directors.  Why ethics matter  The culture of any company is determined by  what its directors, officers and employees  actually do rather than what they are  supposed to do. It is simply about doing the  right thing, day in and day out.  We expect you to:   Comply with the Code   Act with integrity, due skill, care   and diligence   Follow all applicable laws, rules   and regulations   Be open and cooperative with   our regulators   Use your best judgment    Ask for guidance before you act   Report ethical concerns promptly   Be an example of ethical behavior   for your team   Pay due regard to the interests of   our clients and treat them fairly    Observe proper standards of market  conduct
    5     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 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 important  point is covered in more detail in the  next section.
    6     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Report your concerns   If you observe behavior that concerns you, or that you believe in good faith may be illegal or a  violation of the Code, you are required to report the issue promptly.  What you need to know   We respond appropriately to all allegations  by employees, suppliers, clients or  contractors that the company or individuals  are not meeting its legal, regulatory, ethical  or financial obligations.   We provide several reporting options for  anyone who suspects breaches of the  Code, our policies, regulations or the law.   Whistleblower claims  Acting ethically includes reporting misconduct.  If you don’t report the misconduct of others,  you are not acting ethically and will be held  accountable. It may not be easy to report  misconduct involving a colleague or friend, but  that is what we expect you to do.  You should, in good faith, report an alleged  impropriety that prevents the company from  meeting its regulatory and legal obligations or  complying with generally accepted accounting  principles.   A whistleblower is an individual who  lawfully makes any allegation of impropriety  or discloses or provides information or  assistance in connection with any  governmental proceeding or inquiry.   Acting in good faith means that you have a  sincere belief that a reasonable person in  the same situation with access to the  same facts would also conclude there is a  likelihood of misconduct.  Non-retaliation  We will not tolerate any retaliation against you  if you report possible misconduct in good faith  even if it turns out that no misconduct  occurred. You won’t be fired, given a lower  performance rating or demoted because you  reported possible misconduct in good faith.  Retaliating against a person who has reported  a suspected violation is considered a violation  of the Code.    All reports are investigated, and your report  will be treated confidentially to the extent  allowed by law and company policy.    If you believe you have been retaliated  against, promptly contact any of the  resources listed on this page.   Leaders are responsible for properly  reporting any allegations they become  aware of.    Why ethics matter  Your diligence allows us to correct problems   that may involve a violation of regulation, law   or pose a risk to health, safety or the company’s  reputation.  We expect you to:   Report unusual or suspicious activity,  including activities that could be  associated with financial crime, such as  check fraud, market manipulation, money  laundering or other possible ethical  issues.   Report concerns promptly to your leader,  another trusted leader, Employee  Relations, to one of the resources listed  on page 23, or to the applicable ethics  hotline:  − Employee Relations Group   Service Center – 1.877.267.4748  − Ethics Hotline – 1.800.963.6395  − Safe Call (EMEA and APAC) –   +44 0800 915 1571
    7     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Obey the law and guard against criminal activity  We comply with all laws and regulations that apply to our operations, including insider  trading laws.  What you need to know   We obey the law in our professional lives  just as we do in our personal lives. Being  unaware that a law or regulation exists  won’t excuse any violation you commit.    We follow the advice of our legal and  compliance professionals.   We always cooperate fully and honestly  with our regulatory agencies during  examinations and inquiries.  Comply with rules, regulations and laws  Additional rules or regulations may apply to you  in your home country or because of your  specific job responsibilities. Each of us is  responsible to know and follow the laws  wherever we work.  Fraud prevention  Preventing fraud is a responsibility of everyone  at Ameriprise, regardless of level. You have a  duty to be mindful of potentially fraudulent  activity and to report anything suspicious  promptly. Fraud includes a wide variety of  illegal acts, all characterized by the intent to  deceive someone. Fraud can be committed to  the detriment of the company, our clients, our  shareholders or others, and can be carried out  by people inside as well as outside of the  company.  Insider trading  Insider trading is both illegal and unethical.  Insider trading is the practice of buying or  selling securities of any company, including  Ameriprise Financial, when you are aware of  material, non-public information about that  company or its securities. If you are convicted  of insider trading, you could be sentenced to  years in prison.  Personal trading  Our personal trading rules, policies and  procedures apply to everyone who is subject to  this Code with few exceptions. These rules are  derived from securities and investment laws,  regulatory guidelines and other corporate  policies. They aim to eliminate the appearance  of conflict between the personal trading  activities of our associates and our clients as  well as the rest of the investing public.  In addition to the general rules that apply  broadly to individuals subject to the Code,  more restrictive rules apply to certain persons  based on their access to information and/or  their job responsibilities. You are responsible  for understanding the related company policies  that apply to you.   Why ethics matter  Legal or regulatory violations can cost our  shareholders millions of dollars in legal  judgments, fines or penalties and lost  clients. In some cases, you could also face  fines, the loss of your job and even  imprisonment. The company often sets a  higher standard than what the law requires,  so it is important to understand all policies  that apply to you.   We expect you to:   Become familiar with the laws and  regulations that apply to you and your   job, including insider trading laws, which  apply to everyone   Complete all mandatory training,  disclosures and other requirements   related to your job   Stay current on legal and regulatory  developments you need to know   Report suspected insider trading, market  abuse or fraudulent activity promptly   Protect our reputation
    8     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES      I told my spouse about a company that  Ameriprise Financial is considering  buying. Was that wrong?  Yes. First, you should not share  confidential business information with  anyone unless it’s necessary to do your  job. Second, if this is material, non- public information and your spouse  trades in the stock of Ameriprise or the  other company or shares the information  with anyone else, 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.
    9     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Do the right thing for the client  From initial contact with prospects, through our continued service of existing individual or  institutional client and end-client accounts, we stand behind what we say and do.  What you need to know   We carefully consider the impact of our  decisions on clients.   We provide exceptional client service.   We are committed to making full and fair  disclosures.  Standards of Conduct  We conduct our business according to all  applicable legal and professional standards of  conduct. These standards of conduct may vary  depending on our role or relationship with a  client and may impose specific obligations on  us, such as: acting as a fiduciary in the best  interests of the client; not favoring the  interests of one client over the interests of  another client; or making recommendations  that are suitable based on a client’s personal  situation and risk tolerance.  Regardless of our legal and professional  obligations, we act honestly and in good faith  with our clients. We want clients to be able to  make informed decisions based on all the  information necessary to understand the  features and potential benefits and risks of our  products and services.      Full and fair disclosure  You must make full and fair disclosure of all  features, benefits, risks and fees of products or  services sold or marketed to all clients and  prospects, particularly where your interests may  conflict with those of our clients. Full and fair  disclosure applies to initial client communications  as well as to subsequent recommendations.   Your disclosures must be accurate, fair and  balanced and presented in the proper context.  Do not omit material facts or qualifications if  the result would be misleading.  Marketing, advertising and communications  with the public   Marketing, advertising and communications  with the public, including clients, prospects,  investors, analysts and the general public,  must be truthful and accurate. You may not  make exaggerated or misleading statements,  regardless of whether the information is given  directly or indirectly. You must answer all  questions honestly and completely.   In addition, the content must meet applicable  regulatory and legal standards. When preparing  advertising, marketing and communication for the  public, you must ensure that required reviews and  approvals are received prior to first use.     Why ethics matter  We maintain our clients’ loyalty and improve  their experience by acting with integrity. Our  first priority is the success of our clients.  They have selected us to help them reach  their financial goals and prepare for  retirement on their terms. If we break that  trust, our clients will leave us for other firms.  We expect you to:   Act in the best interest of clients    Be truthful and accurate   Never mislead a client or prospect   Help clients and prospects understand our  products and services   Provide clients and prospects with all  information they need to make an   informed decision
    10     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES        My job doesn’t involve client contact.  Recently, however, someone claiming to be  a client was transferred to my number. She  was upset about something, but I politely  said I couldn’t help her and hung up. Was  that wrong?  Yes. In this situation, you should ask for the  person’s name, address, telephone number  and a brief description of the issue. After  telling her you will find the right person to  help her, talk to your leader about how to  follow up. You should never try to answer a  question if you are not qualified to do so, but  each of us has a responsibility to do the right  thing for our clients.    We know that trust must be  earned and are committed to  making fair and accurate  disclosures.
    11     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Conduct business ethically  We have a duty to promote the interests of the company. That means we do not use the  company’s property or information for our own benefit or to compete with the company. What you need to know   We do not use company information and  property for personal gain.    We carefully monitor and control conflicts  of interest.    We do not give, solicit or accept gifts that  could influence our business judgment.  Conflicts of interest  You may engage in an outside activity if it does  not compete or conflict with the interests of the  company or interfere with the responsibilities of  your job or the company’s employees. A conflict  of interest occurs when your private interests  interfere in any way – or even appear to interfere  – with the interests of a client or the company. A  conflict of interest also arises when you or a  member of your family receives improper  personal benefits as a result of your position in  the company.   You must be especially sensitive to potential  conflicts of interest when you are considering  engaging in consulting or other outside activities  that involve the skills and knowledge you use in  your job. Simply reporting or disclosing an activity  without first resolving possible conflicts of  interest may result in a violation of the Code.  You are prohibited from using your position with  the company, or information acquired during your  employment or relationship with the company, to  advance your personal interests over the  interests of clients or the company.  Gifts or entertainment  Generally, you may only accept gifts (including  business-related meals or entertainment) if the  value of the gift is not significant and the gift will  not place you – or appear to place you – under  any obligation to the donor. Before accepting a  gift, you should ask yourself if the gift would  appear significant to others or place you under  any obligation. If the answer is yes, then you  should not accept the gift.  You may be subject to a specific policy and/or  local market rules related to accepting or giving  gifts over a certain dollar value. (Please refer to  policies that apply to you.)  Political contributions and involvement  We respect your right to participate in the political  process. However, because of U.S. campaign  finance laws, you may not: use company funds or  be reimbursed for a political contribution; allow a  candidate or campaign to use company facilities  or property; use work time or company equipment  for political or campaign purposes; or allow your  contribution of time or money to appear to be  made with, or reimbursed by, company funds.  Why ethics matter  Employees, officers and directors owe a duty  to the company to advance its legitimate  interests. Your personal interests, whether  you are focused on a promotion or earning  more compensation, are never more important  than the best interests of our clients or the  company.   We expect you to:   Address conflicts of interest before you  take any job action or engage in an   outside business activity that may benefit  you or your family – this applies to  everyone, regardless of whether you are   a registered person   Avoid even the appearance of impropriety   Comply with company policies related to  outside business activities, political  contributions and gifts and entertainment   Advisors, registered persons and  investment-access persons must file  reports as required by applicable policies.   All persons subject to the Code and located  in the U.S. must seek guidance from the  Corporate Secretary about potential  conflicts of interest, whether involving gifts,  vendor relationships, outside business  activities, or other circumstances.
    12     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES      A client sent me a case of wine as a  gift. I know that if I purchased the  wine, it would be expensive. Can I  accept this gift?  If you are subject to a gift and  entertainment policy, you may be required  to decline the gift politely and return it. If  you are a licensed person, you should  seek advice from your registered principal  or the Compliance Department. If you  don’t know whether a gift policy applies to  you, contact the Corporate Secretary or  your local Compliance Department.  Remember that you are never permitted to  solicit a gift from a client, vendor or  anyone else doing business with the  company.      Do I need to pre-clear my political  contributions and political volunteer  activities?  If you are a financial advisor, you are  subject to pre-clearance requirements.  Otherwise, you need to refer to the  Political Contributions policy to see if you  are covered. Depending upon changes in  your job or band level, you may become  subject to pre-clearance in the future even  if you are not covered now. Also, it's  important to see if your current political  contributions may affect your chances to  apply for certain jobs in the future, due to  the SEC’s pay-to-play rules.
    13     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Compete fairly in the marketplace  We believe that everyone benefits from fair, free and open markets, and we compete fairly in  the marketplace based on the merits of our products and services. What you need to know   We must never offer, make or accept  unlawful payments or gifts regardless of  local business customs.    We comply with all antitrust, anti-bribery,  anti-corruption, monopoly and competition  laws. Failure to comply can have serious  consequences for the company and for  you.  Antitrust and competition law  We prohibit agreements intended to limit  competition. We expect you to avoid any  agreement with a competitor to limit  competition.    When dealing with outside companies,  including contractors and vendors, consider  whether they are competing with  Ameriprise Financial.    The General Counsel’s Organization is  available whenever you question the  legality of a proposed activity or need  further guidance.    False or misleading statements about our  competitors are contrary to our values and  damage our reputation.      Fair dealing  All employees, officers and directors should deal  fairly with our clients, investors, suppliers and  competitors. We don’t take unfair advantage of  anyone through manipulation, concealment,  abuse of privileged information, misrepresentation  of material facts or any unfair practices.   Non-retaliation  An individual shall not be held criminally or civilly  liable under any Federal or State trade secret law  for the disclosure of a trade secret that is made:   in confidence to a Federal, State, or local  government official or to an attorney solely  for the purpose of reporting or investigating  a suspected violation of law; or   in a complaint or other document filed in a  lawsuit or other proceeding, if such filing is  made under seal.   An individual who files a lawsuit for retaliation  by an employer for reporting a suspected  violation of law may disclose the trade secret  to the attorney of the individual and use the  trade secret information in the court  proceeding, if the individual files any document  containing the trade secret under seal; and  does not disclose the trade secret, except  pursuant to court order.  Why ethics matter  We operate in a highly regulated industry and  under intense media and public scrutiny.  Regulators and prosecutors recognize the  importance of a strong ethical and  compliance culture.   We expect you to:   Deal fairly with clients, vendors,  competitors and other employees   Maintain the company’s confidential   or proprietary information and   trade secrets
    14     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES      I noticed that a contractor made a   mistake in its invoice in our favor. What  should I do?  Call the contractor to discuss the invoice  and confirm that we have been  undercharged. If so, ask for a corrected  invoice.       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 complex, so seek advice  from the General Counsel’s Organization  before you give anything of value to a  government official or anyone claiming to  represent a government or a government- controlled entity. The United States Foreign  Corrupt Practices Act and the UK Bribery  Act impose severe penalties if you give  anything of value to a government official.  Many other countries are also enacting  strict laws against bribery and corruption. In  this case, even a modest meal and small  gift can result in severe penalties for you  and the company.
    15     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Protect the company’s reputation and assets  We diligently safeguard the company’s reputation, its physical and intellectual property and  all sensitive information. What you need to know   We consider our reputation one of our most  valuable assets.   We protect our assets and use them for  appropriate business purposes.  Anti-money laundering and identity theft  The company maintains policies and  procedures to prevent and detect money  laundering and identity theft. Suspicious  activity takes many forms and is hard to define  in absolute terms, however, common examples  of “red flags” are included in the company’s  related policies. If you ignore or choose not to  report suspicious activity, both you and the  company could be considered willfully blind and  held liable for the criminal activity.  Report concerns by submitting a Report of  Unusual Activity, which can be found on Inside  or the AdvisorCompass® site. BMO Global Asset  Management EMEA team reports concerns to  AML@bmogam.com.  Company property  Our company property, including equipment,  supplies, systems and facilities, must only be  used for valid business purposes. Theft,  carelessness and waste have a direct impact on  our profitability. If you suspect someone was  involved in, or is attempting to cover up, the theft  or misuse of company property, immediately  report it to your local security personnel or to  SecurityAMPF@ampf.com.  Intellectual property  Intellectual property is one of the most valuable  assets of our company. Our logos and branding  (e.g., trademarks, service marks) stand as a  unique symbol of the quality, integrity and  reliability that underlie all our products and  services. Moreover, they serve to identify us to  the world and set us apart from our  competitors.  The use of all logos and brand names, such as  “Ameriprise Financial,” “RiverSource,”  “Columbia Threadneedle Investments,”  “Columbia Management” and “Threadneedle”  must conform with company policy.  We will also never knowingly infringe on the  intellectual property rights of others. You are  responsible for confirming that the use of any  third-party intellectual property is approved and  done with written permission. This includes,  but is not limited to, computer programs,  brands, logos and periodicals.  Why ethics matter  Our ability to attract and retain clients,  advisors and employees depends on our  reputation as an ethical, honest and law- abiding company. Anything that you do,  whether at work or in your personal life, that  damages our reputation is a serious matter.  Be especially careful not to post or say  anything on social media that could  embarrass you or damage the reputation and  brands we have worked so hard to establish.  Remember that your obligation to comply   with the Code doesn’t stop when you leave  the office.   We expect you to:   Be alert to situations or actions that may   be unethical or potentially damaging to the  company’s reputation   Watch for warning signs that may signal  fraudulent activity and report any  suspicious activity   Use company property only for valid   business purposes and with proper  authorization   Protect all company and client property   and assets against theft or misuse
    16     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES      I hear leaders refer to enterprise risk  management. What does it mean to me  in my role?  Like all financial services companies, we  face various risks that could harm our  company, clients and shareholders. We  invest significant time and money to  identify and manage these risks, but of  course it’s impossible to eliminate many  of them. Even if an event is completely  out of our control, such as a natural  disaster or act of terrorism, we need to  anticipate it as much as possible and be  able to respond effectively. Risks can  become more serious over time and new  risks are emerging constantly.  Our Board of Directors and Executive  Leadership Team are focused on risk  management because it’s crucial to our  continued success. We also have  talented teams of officers and  employees around the world who are  devoted to risk management. To be truly  effective in identifying, monitoring and  managing risk, each of us must think  and act like a risk manager.   Regardless of your job or level of  responsibility, we expect you to be part  of our risk management program. Each  of us is a risk manager.
    17     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Safeguard and maintain accurate information  We diligently safeguard our clients’ personal information. We believe that accurate  recordkeeping and reporting are essential to our reputation and credibility. What you need to know   We comply with all laws and policies  related to the collection, safeguarding and  disclosure of client or sensitive  information.  Confidentiality and privacy  We maintain the confidentiality of information  entrusted to us. Confidential information includes all  non-public information that might be of use to  competitors or harmful to the company or its clients  if released. We ensure only employees with a  business need-to-know reason are allowed access  to such data. Report privacy incidents or  unauthorized access to sensitive information to  Privacy.Swat.Team@ampf.com.   Financial and business information  Maintaining accurate and complete business and  financial records, including financial statements  and accounts, expense reports, time records and  invoices, is not just the job of Accounting and  Finance personnel.   Always record and classify transactions in  the proper accounting period and in the  appropriate account and department.    Never delay or accelerate the recording of  revenue or expenses.   Always support estimates and accruals  with appropriate documentation based on  your best judgment.   Never falsify any document or distort the  true nature of any transaction.   Never enable another person’s efforts to  evade taxes or subvert local currency laws.    Only make payments to the person or firm  that actually provided the goods or  services.  Records management  We maintain appropriate books and records  according to the law and our policies. We do not  shred, destroy or alter documents that are related  to any imminent or ongoing investigation, lawsuit,  audit, examination or are required to be  maintained for regulatory purposes.  Signature issues and forgery   Employees, advisors or staff may not copy,  affix or trace a client’s signature or sign any  document on behalf of a client, even if  specifically asked to by the client. A signature  is considered forged if it was signed by  someone other than the person named, or that  person’s legally authorized representative.  Whenever a client signature is required, it must  be an original signature of the client or his or  her legally authorized representative.  Why ethics matter  Many data breaches and cybersecurity  incidents are the result of employee  mistakes or negligence. Carelessly clicking a  link in an email or opening an attachment  could result in a serious cybersecurity  incident. You’ve probably read about  incidents at other companies that have cost  millions of dollars to resolve. You play a role  in being attentive and doing everything you  can to avoid one at Ameriprise.  We expect you to:   Protect the privacy, confidentiality and  security of all client, employee, advisor   and company information   Keep accurate business and financial  records   Safeguard sensitive information from  unauthorized disclosure   Report financial and other business  information truthfully, accurately and  completely   Maintain all business records in  accordance with the company’s policies  and procedures and regulatory  requirements
    18     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES        A package mailed by a client containing  a completed application and a check  looked like it had been opened. Do I  need to tell anyone about this?   Yes. Even if nothing appeared to be  missing, this is still a potential breach of  the client’s privacy. Send an email to  Privacy.Swat.Team@ampf.com, who will  research and identify potential risk.      Contact your leader, registered  principal, the Employee Relations Group  Service Center at 1.877. 267.4748, the  Ethics Hotline at 1.800.963.6395 or  Safe Call (EMEA and APAC) at +44  0800 915 1571 if you:   Believe financial information or  business records are not reported or  maintained accurately and  completely.   Feel pressure to report inaccurate or  incomplete financial or business  information.    Are asked to prepare or destroy  documents in violation of company  policy.
    19     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Treat everyone with dignity and respect  We value our people, encourage their development and reward their performance.  What you need to know   We are good citizens in our communities.    We make all reasonable efforts to maintain  a safe and healthy work environment for  our employees and visitors.   We prohibit discrimination or harassment  and welcome diversity.   Equal employment opportunity  Our employees, including financial advisors and  leaders are responsible for complying with the  company’s Equal Employment Opportunity Policy,  Individual Treatment Policy and related policies,  and anti-discrimination and anti-harassment laws.  Leaders have the added responsibility of ensuring  compliance with those policies and laws.  Freedom from discrimination  Our employees are prohibited from engaging in   discrimination or harassment against any person  on the grounds of race, color, religion, national  origin, disability, age, sex, marital status, sexual  orientation, gender identity, veteran status or  citizenship.  Each of us, particularly leaders, is responsible for  creating and maintaining a work environment free  of discrimination and harassment for our  employees.    Freedom from fear and violence in the  workplace  We prohibit the possession of weapons in our  workplace or when conducting business on behalf  of the company. You may not assist or permit  others to possess weapons in the workplace.  Importance of diversity  We are committed to valuing and supporting  diversity in the workplace and community.  Employees, field members and staff represent  many age groups, ethnicities, family structures,  races, religions, sexual orientations, nationalities  and mental and physical abilities.   Non-retaliation  We do not retaliate against or intimidate an  individual who makes a complaint, assists in  making a complaint or is a witness in an  investigation. Our values and the law protect an  individual who, in good faith, reports  discrimination, harassment, threats of violence or  any inappropriate behavior.  Safety, health and the environment  We make all reasonable efforts to provide and  maintain a safe and healthy working environment  for our employees and visitors. Why ethics matter  We expect all employees and advisor to behave  in a values-driven manner, which includes  treating all people with dignity and respect.  Discriminatory treatment and harassment are  illegal and violate our company values. We  encourage individuals to report any violations.   We expect you to:   Treat others the way you would like to   be treated   Be an example to the next generation   of leaders   Support a diverse and safe work  environment   Notify your local or onsite security  personnel or local law enforcement  immediately if you see anyone exhibiting  threatening behavior or if there is a  potentially dangerous situation at your  workplace   Report safety concerns to:   Minneapolis – 1.612.671.2454   or 1.612.671.3333.   United States – 1.800.455.5187   United Kingdom, European Union   or India – 00.1.612.671.2454 or  00.1.612.671.3333.
    20     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES        A colleague in my department has been  acting 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) or the Employee  Relations Group Service Center  immediately and explain the situation.  You share the responsibility of helping  the company maintain a safe  environment for all of our employees and  visitors. As long as you act in good faith,  you will not face any retaliation for  sharing your concerns.
    21     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Navigate your ethical questions  Consider your actions carefully. Ask for guidance when you need it.  What you need to know   We make decisions with integrity.   We expect our leaders to set an example of  courteous and respectful behavior toward  their team members and others.  Related policies  The Code of Conduct and the related policies  cannot, and do not attempt to, address every  possible situation or circumstance that you  may encounter. You are responsible for  becoming familiar with the Code of Conduct  and related policies, adhering to the principles  and rules stated in them and seeking advice  and guidance when you are uncertain as to the  proper course of action.  If you are a leader  Leaders at all levels are responsible for  continually emphasizing integrity as a standard  of performance for all employees,  demonstrating how employees and others  should be treated with dignity and respect and  creating and maintaining a work environment  free of discrimination and harassment.   Leaders should always seek legal advice  about the laws that may apply to a  particular situation.   Leaders are responsible for the health,  safety and welfare of their departments,  and everyone reporting or assigned to  them, including visitors and contractors,  regardless of their work location.  If you are an individual contributor  We expect all leaders to set the right ethical  example for the company and its employees,  regardless of how many people they lead. But  even if you aren’t a leader, we expect you to be  an example of this same honest and ethical  behavior for others on your team. Remember  that others may model their behavior based on  yours, especially if you have more experience  or have been with the company for a longer  period of time. Never make jokes about  complying with the law, our policies and  procedures or the Code of Conduct. Never  belittle anyone for asking what the right thing to  do is.    If someone on your team asks for your  advice on how to handle an ethical  question, encourage him or her to speak  with your leader.   Be supportive and remind the person that  we have a strict policy against retaliation  for reports made in good faith.   How you behave and what you say matters.     We expect you to:   Be aware of the consequences of   your actions   Ask for guidance when you need it   Ask yourself about a potential behavior or  action:   Is it consistent with the Code and  other company policies?   Is it ethical?   Is it legal?   Am I setting a good example?   Will it put the company at undue  risk?   Will it reflect poorly on the company   or me?   Would I want to read about it in the  news or on social media?   How would I explain my actions to my  colleagues, friends and family?
    22     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Consequences for non-compliance  Remember that asking for guidance before you act may help you avoid disciplinary action for  violating the Code or a law, rule or regulation.  What you need to know   We will not accept ignorance or oversight  as excuses for behavior that violates the  Code, related policies or any law or  regulation.   We retain the right to determine whether  specific actions or behaviors violate the  Code of Conduct.   Violations of the Code  Personal conduct that violates the Code includes,  but is not limited to:   Willful or negligent damage to company  property or the property of others;   Theft or dishonesty, including falsification  of company records or furnishing false or  incomplete information on expense forms,  time records, employment applications or  other documents related to your  employment;   Inappropriate behavior or personal attire   that is unprofessional or embarrasses the  company or its clients, including posting   or transmitting offensive or inappropriate  material on the internet or any social   media site;   Disruptive or offensive behavior while  conducting company business, including  insubordination, willful disregard of  company policies or procedures, disrespect  toward a client or potential client, a leader  or member of management, or failure to  perform work as required or assigned; and   Violations of safety or health laws or  regulations or engaging in conduct that  creates a safety or health hazard.  In addition, if you violate the law during the  course of your employment you may be subject to  criminal and civil penalties as well as payment of  monetary damages to the company or third  parties.  Disciplinary action may also be taken against  an employee or advisor who:   Authorizes, directs, approves, participates  in or encourages violations of the Code;   Deliberately fails to report or conceals  violations or deliberately withholds or  misstates relevant information;   Retaliates against any other employee  because he or she reported a suspected  violation in good faith; or   Knew or should have known about a  violation by people under his or her  supervision and did not promptly report it. We expect you to:   Talk to your leader about any situation   that concerns you   Reach out to any of the following global  resources or those listed on page 23   for assistance:   Your Human Resources   business partner    Employee Relations Group Service  Center – ERGSC@ampf.com   Executive Vice President,  Human Resources –  Kelli.A.Hunter@ampf.com   General Counsel’s Organization –  Karen.Wilson.Thissen@ampf.com    Corporate Secretary’s Office –  Wendy.Mahling@ampf.com
    23     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Resources  Reach out to resources below or refer to related company policies, procedures or related  resources to report concerns and for questions or additional information.  What you need to know   We provide the following reporting options   for you to report ethical and other concerns:   Employee Relations Group   Service Center – ERGSC@ampf.com   Ethics Hotline – 1.800.963.6395   Safe Call (EMEA and APAC) –   +44 0800 915 1571   Executive Vice President,  Human Resources –  Kelli.A.Hunter@ampf.com   General Counsel’s Organization –  Karen.Wilson.Thissen@ampf.com    Corporate Secretary’s Office –  Wendy.Mahling@ampf.com   General Auditor –  Ryan.P.Burns@ampf.com   Fraud and Whistleblower Oversight  Committee – fwbcommitteereporting@ampf.com  Personal Trading Compliance:   Contact: personal.trading@ampf.com    BMO Personal Trading Group –  compliance.oversight@bmogam.com  Report suspicious activity:    Complete a Report of Unusual Activity  located on your intranet.   If the situation is urgent, call Suspicious  Activity Hotline – 1.612.671.6166   For Columbia Threadneedle BMO team,  contact AML@bmogam.com.   Concerns may also be raised with certain  regulators listed in the whistleblower policy  applicable to your business area    Commission de Surveillance du Secteur  Financier – whistleblowing@cssf.lu   FCA Whistleblowing (UK) –   whistle@fca.gov.uk   Protect (UK) – protect-advice.org.uk    Dutch Authority for the Financial Markets –  Information Line – info@afm.nl   De Nederlandsche Bank Integrity Reporting  Desk – meldpuntmisstanden@dnb.nl    We expect you to:   Report concerns to your leader or one of  the resources listed on this page.   Understand the policies and procedures  that impact your job. You can search   Inside, AdvisorCompass, Complisource   or other company intranet systems for  applicable policies.
 Financial Planning | Retirement | Investments | Insurance  Ameriprise Financial, Inc.  Corporate Secretary’s Office  1098 Ameriprise Financial Center, Minneapolis, MN 55474  ameriprise.com  Revised November 1, 2021   © Ameriprise Financial, Inc. All rights reserved.  Notes    This document does not create a contract of employment or a contract for any specific term or condition of employment between Ameriprise  Financial and an employee. Except as provided otherwise by the laws of a foreign jurisdiction, the relationship between Ameriprise Financial and an  employee is at-will, meaning that either the employee or the company may terminate it at any time for any reason, with or without advance notice or  progressive disciplinary action. The company reserves the right to make changes in or discontinue company policies, compensation plans, benefits  and programs as it deems appropriate and these changes may be implemented even if they have not been communicated in this (or by change to  this) document or otherwise.   If this document refers to any company benefit program, it describes only certain highlights of the company’s benefit program. It does not  supersede the actual provisions of the applicable plan documents, which in all cases are the final authority. The applicable plan administrator has  the sole authority and discretion to determining your eligibility to participate in the plan, interpret the plan documents and administer of the plans.   Ameriprise Financial takes reasonable efforts to ensure the accuracy of the contents of policy documents and in the administration of its policies  and programs. The company does not assume responsibility for consequential damages caused by administrative or clerical errors.