Exhibit 14(c)                                                                                                          Global Code of Conduct                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        OUR VALUES                                                                                                                                                                                                                                                   Client-focused      Integrity always      Excellence           Respect
 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                                        125 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 colleagues and others   Our actions matter.                  shareholders. Our Global Code of Conduct with dignity and respect.                                        emphasizes the core ethical principles that                                                                             Our vision is to be the most respected and                                        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.                                         carefully. If you see misconduct, report it to                                                                             Thank you for your commitment to the                                        your leader. Ask your leader for help when                                                                             principles in the Code and the continued                                        you are unsure of the right thing to do. We                                                                             success of our company.                                        will not take action against an individual who                                        reports what he or she believes in good faith                                         to be misconduct. Even if it turns out that no                                         misconduct occurred, you will be protected as                                         long as you acted in good faith.           JAMES M. CRACCHIOLO                                                                                   CHAIRMAN AND CHIEF EXECUTIVE OFFICER                                                                                                            2   
 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                                                                                                            3   
 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.    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  actually do rather than what they are supposed    We maintain an environment where compliance    This Code can’t cover every situation  to do. It is simply about doing the right thing, day and adherence to the Code of Conduct is the                                                                                                   No code of conduct or ethics can anticipate all of  in and day out.                                   norm.                                                                                                   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      Comply with the Code                        everyone working for one of our business areas or and honest manner. Above all, seek guidance from                                                  affiliates. Commitment to the ethical principles your leader, manager or one of the provided      Act with integrity, due skill, care and                                                  helps ensure compliance with                     resources (See list of resources on Page 6) before      diligence                                                  the 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 clients provisions of other policies, codes of ethics and Financial, Inc. can grant a waiver of the Code of      and treat them fairly                       other business procedures to which you are       Conduct. We will promptly disclose to our      Observe proper standards of market          subject.                                         shareholders any waivers granted to our executive      conduct                                                                                      officers and directors.                                                                                                                                                4   
 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.                                                                                                                                                                        5   
 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 that  health, safety or the company’s reputation.       the company is not meeting its legal, ethical or Non-retaliation                                                    financial obligations.                         We will not tolerate any retaliation against you if  We expect you to report concerns                                                    We provide several reporting options for anyone you report possible misconduct in good faith even  promptly to your leader, manager or one           who suspects breaches of the Code, our policies if it turns out that no misconduct occurred. You  of the following resources:                       or the law.                                    won’t be fired, given a lower performance rating or                                                                                                   demoted 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 (EMEA) – +44 0800 915 1571                                                            All reports are investigated, and your report will                                                  may not be easy to report misconduct involving a   be treated confidentially to the extent allowed     FCA Whistleblowing (UK) –                                                   colleague or friend, but that is what we expect you by law and company policy.      whistle@fca.gov.uk                           to do.                                                                                                     If you believe you have been retaliated against,     Public Concern at Work (UK) –                                                   You should, in good faith, report an alleged       promptly contact any of the resources listed on     helpline@pcaw.co.uk                                                  impropriety that prevents the company from         this page.     Commission de Surveillance du Secteur        meeting its legal obligations or complying with                                                                                                     Leaders are responsible for properly reporting     Financier – whistleblowing@cssf.lu           generally accepted accounting principles.                                                                                                     any allegations they become aware of.                                                    A whistleblower is an individual who lawfully     Corporate Secretary’s Office –                                                                     Thomas.R.Moore@ampf.com                        makes any allegation of impropriety or discloses                                                    or provides information or assistance in     General Counsel’s Organization –               connection with any governmental proceeding     Karen.Wilson.Thissen@ampf.com                  or inquiry.     Executive Vice President,                      Acting in good faith means that you have a     Human Resources –                              sincere belief that a reasonable person in      Kelli.A.Hunter@ampf.com                                                                                                                                           6   
 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.                                                                                                       Insider trading  Why ethics matter                                 What you need to know                                                                                                     Insider trading is both illegal and unethical. Insider  Legal or regulatory violations can cost our         We obey the law in our professional lives just as                                                                                                     trading is the practice of buying or selling securities  shareholders millions of dollars in legal           we do in our personal lives. Being unaware that                                                                                                     of any company, including Ameriprise Financial,  judgments, fines or penalties. In some cases, you   a law or regulation exists won’t excuse any                                                                                                     when you are aware of material, non-public  could also face fines, the loss of your job and     violation you commit.                                                                                                      information about that company or its securities. If  even imprisonment. The company often sets a                                                      We follow the advice of our legal and          you are convicted of insider trading, you could be  higher standard than what the law requires, so it                                                      compliance professionals.                      sentenced to years in prison.  is important to understand all policies that apply  to you.                                             We always cooperate fully and honestly with our Personal trading                                                      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      Become familiar with the laws and                                                              few exceptions. These rules are derived from      regulations that apply to you and your job,   Additional rules or regulations may apply to you in securities and investment laws, regulatory guidelines      including insider trading laws, which apply   your home country or because of your specific job and other corporate policies. They aim to eliminate      to everyone                                   responsibilities. Each of us is responsible to know the appearance of conflict between the personal                                                    and follow the laws wherever we work.            trading activities of our associates and our clients as      Complete all mandatory training, disclosures                                                   well as the rest of the investing public.      and other requirements related to your job    Fraud prevention                                                                                                     In addition to the general rules that apply broadly      Stay current on legal and regulatory          Preventing fraud is a responsibility of everyone at to individuals subject to the Code, more restrictive      developments you need to know                 Ameriprise, regardless of level. You have a duty to rules apply to certain persons based on their                                                    be mindful of potentially fraudulent activity and to      Report suspected insider trading, market                                                       access to information and/or their job                                                    report anything suspicious promptly. Fraud      abuse or fraudulent activity promptly                                                          responsibilities. You are responsible for                                                    includes a wide variety of illegal acts, all     understanding the related company policies that      Protect our reputation                        characterized by the intent to deceive someone.                                                                                                     apply to you.                                                                                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.                                                                                                                                                                                                  7   
 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.                                                                                                                                      8   
 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         decisions on clients.  their experience by acting with integrity. Our                                                       public, you must ensure that required reviews and  first priority is the success of our clients. They   We provide exceptional client service.          approvals are received prior to first use.   have selected us to help them reach their            We are committed to making full and fair        Suitability  financial goals and prepare for retirement on        disclosures.  their terms. If we break that trust, our clients will                                                Advice and products recommended must be  leave us for other firms.                          Full and fair disclosure                          suitable for each client. Always take the time to                                                                                                       ensure that investment advice and products or                                                     You must make full and fair disclosure of all features,                                                                                                       services recommended are appropriate given a  We expect you to:                                  benefits, risks and fees of products or services sold or                                                                                                       client’s age, financial situation, investment                                                     marketed to all clients and prospects, particularly     Be truthful and accurate                                                                          planning objectives and risk tolerance. Also, take                                                     where your interests may conflict with those of our                                                                                                       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 understand fully the                                                     communications as well as to subsequent     Help clients and prospects understand our                                                         features, potential benefits and risks of the                                                     recommendations.      products and services                                                                             recommended product or service. When dealing                                                                                                       with elderly clients, pay special attention to their     Provide clients and prospects with all          Your disclosures must be accurate, fair and                                                                                                       expected financial needs and tolerance for risk.     information they need to make an                balanced and presented in the proper context. Do                                                     not omit material facts or qualifications if the     informed decision                                                                                 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   
 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   
 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       property for personal gain.   the company to advance its legitimate interests.                                                   advance your personal interests over the interests  Your personal interests, whether you are focused      We carefully monitor and control conflicts of of clients or the company.  on a promotion or earning more compensation,          interest.                                    Gifts or entertainment  are never more important than the best interests      We do not give, solicit or accept gifts that  of our clients or the company.                                                                     Generally, you may only accept gifts (including                                                        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  We expect you to:                                                                                  not place you – or appear to place you – under any                                                    You may engage in an outside activity if it does not                                                                                                     obligation to the donor. Before accepting a gift,     Address conflicts of interest before you take any compete or conflict with the interests of the                                                                                                     you should ask yourself if the gift would appear     job action or engage in an outside business    company or interfere with the responsibilities of                                                                                                     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     this applies to everyone, regardless of whether interest occurs when your private interests                                                                                                     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.)     outside business activities, political         benefits as a result of your position in the                                                                                                     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 without first resolving possible conflicts of interest                                                                                                     for political or campaign purposes; or allow your        of 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   
 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.                                                                                                                                     12   
 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                            information, misrepresentation of material facts or                                                                                                     any unfair practices.   Why ethics matter                                   We must never offer, make or accept unlawful                                                      payments or gifts regardless of local business Non-retaliation  We operate in a highly regulated industry and                                                      customs.   under intense media and public scrutiny.                                                           An individual shall not be held criminally or civilly liable  Regulators and prosecutors recognize the            We comply with all antitrust, anti-bribery, anti- under any Federal or State trade secret law for the  importance of a strong ethical and compliance       corruption, monopoly and competition laws.     disclosure of a trade secret that is made:  culture.                                            Failure to comply can have serious consequences  in confidence to a Federal, State, or local government                                                      for the company and for you.                     official or to an attorney solely for the purpose of  We expect you to:                                 Antitrust and competition law                      reporting or investigating a suspected violation of                                                                                                       law; or      Deal fairly with clients, vendors, competitors We prohibit agreements intended to limit                                                                                                       in a complaint or other document filed in a lawsuit or      and other employees                           competition. We expect you to avoid any                                                    agreement with a competitor to limit competition.  other proceeding, if such filing is made under seal.       Maintain the company’s confidential                                                                                                      An individual who files a lawsuit for retaliation by an      or proprietary information and                  When dealing with outside companies, including                                                                                                     employer for reporting a suspected violation of law      trade secrets                                   contractors and vendors, consider whether they                                                      are competing with Ameriprise Financial.       may disclose the trade secret to the attorney of the                                                                                                     individual and use the trade secret information in the                                                      The General Counsel’s Organization is available court proceeding, if the individual files any document                                                      whenever you question the legality of a        containing the trade secret under seal; and does not                                                      proposed activity or need further guidance.    disclose the trade secret, except pursuant to court                                                      False or misleading statements about our       order.                                                      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                                                                                                                                            13   
 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.                                                                                                                                                             14   
 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   Our ability to attract and retain clients, advisors valuable assets.                               assets of our company. Our logos and branding   and employees depends on our reputation as an                                                      (e.g., trademarks, service marks) stand as a unique                                                       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.  Anything that you do, whether at work or in your                                                    underlie all our products and services. Moreover,  personal life, that damages our reputation is a    Anti-money laundering and identity theft         they serve to identify us to the world and set us                                                                                                      apart from our competitors.  serious matter. Be especially careful not to post  The company maintains policies and procedures to  or say anything on social media that could                                                     prevent and detect money laundering and identity The use of all logos and brand names, such as  embarrass you or damage the reputation and         theft. Suspicious activity takes many forms and is “Ameriprise Financial,” “RiverSource,” “Columbia   brands we have worked so hard to establish.       hard to define in absolute terms, however,       Threadneedle Investments,” “Columbia   Remember that your obligation to comply           common examples of “red flags” are included in   Management” and “Threadneedle” must conform   with the Code doesn’t stop when you leave the     the company’s related policies. If you ignore or with company policy.   office.                                                      choose not to report suspicious activity, both you We will also never knowingly infringe on the                                                     and the company could be considered willfully    intellectual property rights of others. You are   We expect you to:                                 blind and held liable for the criminal activity. responsible for confirming that the use of any                                                                                                      third-party intellectual property is approved and      Be alert to situations or actions that may     Report concerns by submitting a Report of Unusual                                                                                                      done with written permission. This includes, but is      be unethical or potentially damaging to the    Activity, which can be found on Inside or the                                                                   ®                                  not limited to, computer programs, brands, logos      company’s reputation                           AdvisorCompass  site.                                                                                                      and periodicals.      Watch for warning signs that may signal        Company property      fraudulent activity and report any suspicious  Our company property, including equipment,      activity                                       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                                                     cover up, the theft or misuse of company property,      Protect all company and client property        immediately report it to your local security personnel      and assets against theft or misuse             or to SecurityAMPF@ampf.com.                                                                                                                                                15   
 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   
 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.                                                                                                         Never falsify any document or distort the true  Why ethics matter                                  What you need to know                                                                                                                                   nature of any transaction.  Many data breaches and cybersecurity incidents       We comply with all laws and policies related to the                                                                                                        Never enable another person’s efforts to evade  are the result of employee mistakes or               collection, safeguarding and disclosure of client or                                                                                                        taxes or subvert local currency laws.   negligence. Carelessly clicking a link in an email   sensitive information.  or opening an attachment could result in a         Confidentiality and privacy                        Only make payments to the person or firm that  serious cybersecurity incident. You’ve probably                                                       actually provided the goods or services.                                                     We maintain the confidentiality of information  read about incidents at other companies that                                                        Records management  have cost millions of dollars to resolve. You play entrusted to us. Confidential information includes all  a role in being attentive and doing everything     non-public information that might be of use to   We maintain appropriate books and records  you can to avoid one at Ameriprise.                competitors or harmful to the company or its clients if according to the law and our policies. We do not                                                     released. We ensure only employees with a business shred, destroy or alter documents that are related to                                                     need-to-know reason are allowed access to such data. any imminent or ongoing investigation, lawsuit, audit,  We expect you to:                                  Report privacy incidents or unauthorized access to examination or are required to be maintained for                                                     sensitive information to Privacy.Swat.Team@ampf.com.       Protect the privacy, confidentiality and                                                        regulatory purposes.      security of all client, employee, advisor and  Financial and business information               Signature issues and forgery       company information                                                     Maintaining accurate and complete business and   Employees, advisors or staff may not copy, affix or      Keep accurate business and financial records   financial records, including financial statements and trace a client’s signature or sign any document on                                                     accounts, expense reports, time records and invoices,      Safeguard sensitive information from                                                            behalf of a client, even if specifically asked to by                                                     is not just the job of Accounting and Finance      unauthorized disclosure                                                                         the client. A signature is considered forged if it was                                                     personnel.                                       signed by someone other than the person named,      Report financial and other business                                                       Always record and classify transactions in the or that person’s legally authorized representative.      information truthfully, accurately and                                                          Whenever a client signature is required, it must be      completely                                       proper accounting period and in the appropriate                                                       account and department.                        an original signature of the client or his or her      Maintain all business records in accordance                                                     legally authorized representative.                                                       Never delay or accelerate the recording of revenue      with the company’s policies and procedures                                                           or expenses.                                         and regulatory requirements                                                       Always support estimates and accruals with                                                       appropriate documentation based on your best                                                       judgment.                                                                                                                                             17   
 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   
 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                              Why ethics matter                                                      We are good citizens in our communities.       Freedom from fear and violence in the workplace  We expect all employees and advisor to behave                                                      We prohibit the possession of weapons in the  in a values-driven manner, which includes           We make all reasonable efforts to maintain a safe                                                                                                     workplace or when conducting business on behalf of  treating all people with dignity and respect.       and healthy work environment for our employees                                                      and visitors.                                  the company. You may not assist or permit others to  Discriminatory treatment and harassment are                                                        possess weapons in the workplace.  illegal and violate our company values.             We prohibit discrimination or harassment and  Therefore, we encourage individuals to report       welcome diversity.                             Importance of diversity  any violations.                                                     Equal employment opportunity                     We are committed to valuing and supporting                                                                                                     diversity in the workplace and community.                                                    Employees, financial advisors and leaders are  We expect you to:                                                                                  Employees, field members and staff represent many                                                    responsible for complying with the company’s Equal                                                                                                     age groups, ethnicities, family structures, races,     Treat others the way you would like to         Employment Opportunity Policy, Individual Treatment                                                                                                     religions, sexual orientations, nationalities and mental     be treated                                     Policy and related policies, and anti-discrimination                                                                                                     and physical abilities.      Be an example to the next generation           and anti-harassment laws. Leaders have the added     of leaders                                     responsibility of ensuring compliance with those Non-retaliation                                                    policies and laws.     Support a diverse and safe work environment                                                     We do not retaliate against or intimidate an                                                    Freedom from discrimination                      individual who makes a complaint, assists in making a     Notify your local or onsite security personnel or                                               complaint or is a witness in an investigation. Our                                                    We prohibit discrimination or harassment against any     local law enforcement immediately if you see                                                    values and the law protect an individual who, in good                                                    person on the grounds of race, color, religion,     anyone exhibiting threatening behavior or if                                                    faith, reports discrimination, harassment, threats of                                                    national origin, disability, age, sex, marital status,     there is a potentially dangerous situation at                                                   violence or any inappropriate behavior.     your workplace                                 sexual orientation, gender identity, veteran status or                                                    citizenship.                                     Safety, health and the environment        Security Services – 1.800.455.5187                                                    Each of us, particularly leaders, is responsible for We make all reasonable efforts to provide and        Safe Call (UK) – 0800 915 1571                                                    creating and maintaining a work environment free of maintain a safe and healthy working environment for        Employee Relations Group                    discrimination and harassment.                   our employees and visitors.       Service Center – ERGSC@ampf.com                                                                                                                                                                                                                                                    19   
 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.                                                                                                                                    20   
 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                              and contractors, regardless of their work                                                                                                        location.                                                       We make decisions with integrity.  We expect you to:                                                                                   If you are an individual contributor                                                       We expect our leaders to set an example of     Be aware of the consequences of                   courteous and respectful behavior toward their We expect all leaders to set the right ethical     your actions                                      team members and others.                       example for the company and its employees,     Ask for guidance when you need it                                                                regardless of how many people they lead. But even                                                     Related policies                                 if you aren’t a leader, we expect you to be an     Ask yourself about a potential behavior or      The Code of Conduct and the related policies     example of this same honest and ethical behavior     action:                                         cannot, and do not attempt to, address every     for others on your team. Remember that others        Is it consistent with the Code and other     possible situation or circumstance that you may  may model their behavior based on yours,        company policies?                            encounter. You are responsible for becoming      especially if you have more experience or have                                                     familiar with the Code of Conduct and related    been with the company for a longer period of time.        Is it ethical?                                                     policies, adhering to the principles and rules stated Never make jokes about complying with the law,        Is it legal?                                 in them and seeking advice and guidance when     our policies and procedures or the Code of                                                     you are uncertain as to the proper course of     Conduct. Never belittle anyone for asking what the        Am I setting a good example?                                                     action.                                          right thing to do is.         Will it put the company at undue risk?                                                     If you are a leader                                If someone on your team asks for your advice on        Will it reflect poorly on the company                                                           how to handle an ethical question, encourage        or me?                                       Leaders at all levels are responsible for continually him or her to speak with your leader.                                                     emphasizing integrity as a standard of        Would I want to read about it in the news    performance for all employees, demonstrating       Be supportive and remind the person that we        or on social media?                          how employees and others should be treated with    have a strict policy against retaliation for reports                                                                                                        made in good faith.        How would I explain my actions to my         dignity and respect and creating and maintaining a        colleagues, friends and family?              work environment free of discrimination and        How you behave and what you say matters.                                                      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                                                                                                                                             21   
 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.    We expect you to:                                 What you need to know                              leader or member of management, or failure to                                                                                                       perform work as required or assigned; and  Talk to your leader or any of these resources       We will not accept ignorance or oversight as                                                                                                       Violations of safety or health laws or regulations or  about any situation that concerns you:              excuses for behavior that violates the Code, related                                                      policies or any law or regulation.               engaging in conduct that creates a safety or health      Your Human Resources                                                                             hazard.      business partner                                We retain the right to determine whether specific                                                      actions or behaviors violate the Code of Conduct.  In addition, if you violate the law during the course of      Employee Relations Group Service Center –                                                      your employment you may be subject to criminal and      1.877.267.4748                                Violations of the Code                           civil penalties as well as payment of monetary                                                                                                     damages to the company or third parties.      Executive Vice President, General Counsel’s   Personal conduct that violates the Code includes, but      Organization – 1.612.671.3602                 is not limited to:                               Disciplinary action may also be taken against an                                                                                                     employee or advisor who:      Executive Vice President, Human Resources       Willful or negligent damage to company property      – 1.612.671.3997                                or the property of others;                       Authorizes, directs, approves, participates in or                                                                                                       encourages violations of the Code;      Corporate Secretary’s Office –                  Theft or dishonesty, including falsification of      1.612.678.0106                                  company records or furnishing false or incomplete  Deliberately fails to report or conceals violations or                                                      information on expense forms, time records,      deliberately withholds or misstates relevant      Ethics Hotline – 1.800.963.6395                                                      employment applications or other documents       information;      Personal Trading Hotline – 1.612.671.5196       related to your employment;                                                                                                       Retaliates against any other employee because he      Suspicious Activity Hotline –                   Inappropriate behavior or personal attire        or she reported a suspected violation in good faith;      1.612.671.6166                                  that is unprofessional or embarrasses the company or                                                      or its clients, including posting       Safe Call (EMEA) – 0800 915 1571                or transmitting offensive or inappropriate material  Knew or should have known about a violation by      FCA Whistleblowing (UK) –                       on the internet or any social                    people under his or her supervision and did not      whistle@fca.gov.uk                              media site;                                      promptly report it.     Commission de Surveillance du Secteur           Disruptive or offensive behavior while conducting      Financier – whistleblowing@cssf.lu              company business, including insubordination,                                                      willful disregard of company policies or procedures,      Public Concern at Work (UK) –                                                       disrespect toward a client or potential client, a      helpline@pcaw.co.uk                                                                                                                                                   22   
 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 Global Policy –   Electronic Communication Acceptable Use Policy      Outside Activities and Family Relationships Policy                                                     Secure Workplace Policy                                                          Equal Employment Opportunity Policy      Columbia Threadneedle Investments Employee                                                             Social Media Policy      Registration and Licensing                          Facility Rules, Guidelines and Standards           Threadneedle Other Conflicts of Interest Policies                                                          of Use      Columbia Threadneedle Investments                                                                      Applicable to Covered Persons       Firm Registration, Regulatory Filings, and Disclosure  Gifts and Business Entertainment Policy -       Threadneedle Conflicts of Interest Policy                                                           Ameriprise Financial Services, Inc.       Policy                                                                                                 Threadneedle Gifts & Corporate Hospitality Policy                                                           Gifts and Business Entertainment Policy -      Columbia Threadneedle Investments Global Policy –                                                      Threadneedle Treating Customers Fairly       Gifts and Entertainment Policy                      American Enterprise Investment Services                                                                                                             Threadneedle Whistleblowing Policy        Columbia Management International Compliance        Global Anti-Corruption Policy and Guidelines                                                                                                              Your Guide to a Safe and Respectful Workplace      Policy for Columbia Management Non-U.S. / Offshore  Columbia Threadneedle Investments Global                                                                                                                     Policy       Sales and Service Activities                        Personal Account Dealing and Code of       Columbia Threadneedle Investments Global Policy –   Ethics Policy       Inside Information Policy                           Handling Whistleblower Claims Policy      Columbia Threadneedle Investments Global Policy –   HIPAA Policies and Procedures Manual       Political Contributions Policy                      Identity Theft Prevention Policy       Columbia Management Portfolio Holdings Disclosure   Information Security Policy      Policy                                                                                                                                                       23   
 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.                            Financial Planning | Retirement | Investments | Insurance  Ameriprise Financial, Inc.  Corporate Secretary’s Office  1098 Ameriprise Financial Center, Minneapolis, MN 55474  ameriprise.com   Revised October 1, 2019   © Ameriprise Financial, Inc. All rights reserved.