Ameriprise Financial  Global Code of Conduct
 2       CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES     Our Vision, Mission,   Brand Promise and Values  have withstood the test   of time and continue   to define our company  Vision   What we aspire to be  To be the most respected and referred financial  services brand    Mission   Our purpose  To help people feel confident about their  financial future    Brand Promise   Our commitment to clients  We shape financial solutions for a lifetime®    Values   What we can expect from each other    Client Focused   Integrity Always   Excellence In All We Do   Respect for Individuals and our Communities  Respect Excellence          Client-focused Integrity always
 3     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 long legacy and success of Ameriprise  depends on the trust and confidence   we work diligently to earn every day.   Our choices and actions matter.      Ameriprise Financial began in 1894 with a clear and singular focus –  to help all levels of investors achieve their most important goals.  Today, our mission is to help people feel confident about their  financial future. We have endured and thrived because of our  unwavering commitment to our values: Client-focused; Integrity  always; Excellence in all we do;   and Respect.  Together, we endeavor to treat people fairly and respectfully and do  what is right for our clients, advisors, employees and shareholders.  Your decisions and actions determine how we operate and what we  can achieve. Our Global Code of Conduct reinforces the core  principles that must guide our behavior. It helps foster an  environment of trust.   I, along with all of our Board of Directors and Executive Leadership  Team, believe strongly in our Code of Conduct.   Thank you for your continued commitment to our values and  adhering to the principles in the Code.      JAMES M. CRACCHIOLO  CHAIRMAN AND CHIEF EXECUTIVE OFFICER
 4     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Contents       • Introduction  − Our Code applies to everyone ......... 5  • Report your concerns ............................ 7  • Our ethical principles  − Treat everyone with dignity   and respect ...................................... 8  − Do the right thing for the client ..... 10  − Obey the law and guard against   criminal activity .............................. 12  − Conduct business ethically ............. 14  − Compete fairly in the marketplace 16  − Protect the company’s reputation   and assets ...................................... 18  − Safeguard and maintain   accurate information ..................... 20  • Navigate your ethical questions .......... 22  • Consequences for non-compliance ..... 23  • Global Resources ................................. 24
 5     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 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. Refer to policies on  Inside, AdvisorCompass, CompliSource or other  company intranet systems for applicable policies.  This Code can’t cover every situation  No code of conduct or ethics can anticipate all of  the circumstances that you may encounter during  your career. If the Code doesn’t address a specific  situation, you are still obligated to act in an ethical  and honest manner. Above all, seek guidance from  your leader, manager or one of the provided  resources (See list of resources on Pages 8 or 24)  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 23.)  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
 6     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES      When we refer to  “Ameriprise” or our  “company,” we mean all  majority-owned businesses  and entities of Ameriprise  Financial, Inc.    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, Ameriprise Bank,  RiverSource, Columbia Threadneedle  Investments or any of our other U.S. or  global subsidiaries is held accountable for  reading, understanding and following the  Code and all company policies applicable to  his or her roles and responsibilities.    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 on pages 7 and 16.
 7     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 global resources listed on page  24, or to the Ethics Hotline:  − Employee Relations Group   Service Center – 1.877.267.4748   or ERGSC@ampf.com  − Ethics Hotline –   • U.S.: 1.800.963.6395 or  ampf.ethicspoint.com  • All other locations: Go to  ampf.ethicspoint.com and select your  location for country and access codes
 8     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  value 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  neurodiversity, 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.
 9     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.    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.
 10     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 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 in the best  interest of and 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.   When making referrals to or any testimonial or  endorsement of Ameriprise Financial, you must be  sure your affiliation with Ameriprise Financial is  readily apparent to or if not readily apparent  disclosed to the prospect, client or investor at the  time of the referral or testimonial or endorsement is  disseminated. 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
 11     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES      We know that trust must be  earned and are committed to  making fair and accurate  disclosures.     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. What  should I do in this situation?  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.
 12     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 and the  rules and regulations applicable to your  responsibilities.  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 employees,  advisors 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
 13     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, 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.
 14     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 and outside business activities  Due to the Company’s diverse businesses, potential  conflicts of interest could result from your outside  business activities. 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.   If a potential conflict of interest is presented,  whether involving gifts, vendor relationships,  outside business activities, or other  circumstances, you should seek guidance from  your applicable Compliance team or the  Ameriprise Corporate Secretary about potential  conflicts of interest, whether involving gifts,  vendor relationships, outside business activities,  or other circumstances.
 15     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?  Yes, depending on your role or band level, you  may be subject to pre-clearance requirements.  For example, financial advisors, Columbia  Threadneedle Investments employees who  work in North America or who are U.S. citizens  working outside the country are all subject to  pre-clearance requirements.  Refer to the  applicable Political Contributions policy to see if  you are covered. Also, if your job changes, you  may become subject to pre-clearance in the  future even if you are not covered now. 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.
 16     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. False or  misleading statements about our competitors are  contrary to our values and damage our reputation.  The General Counsel’s Organization is available  whenever you question the legality of a proposed  activity or need further guidance.  Anti-bribery, anti-corruption, and tax evasion  We are committed to conducting business ethically  and in a manner fully compliant with all applicable  antibribery and corruption laws in the countries in  which Ameriprise operates.  Bribery can be defined as the offering, promising,  giving, accepting or soliciting of any advantage as  an inducement to act in a way which is illegal, or  which amounts to the improper performance of  any duty owed to their employer, to a business or  to a public body. Corruption is the abuse of  entrusted power for private gain.  We also have zero tolerance for facilitation of tax  evasion by employees and third parties. Tax  evasion in the definition of money laundering, and  the policy requires escalation of any potential  financial crimes. Everyone working for the  company should report instances of bribery,  corruption and tax evasion  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 trade secret or similar   [continued on next page] 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   Contact Enterprise Procurement before  engaging a vendor and read the applicable  Acquisition of Goods and Services Policy to  understand the procedures for contracting  with vendors as well as your responsibilities  in the ongoing management of agreements  and relationships with vendors.
 17     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Non-retaliation [continued]  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.    I’m having a business lunch with an  official of a foreign government, who is  an avid golfer, and I want to give him a box of  golf balls as a small gesture 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.
 18     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, identity  theft and other financial crimes. Suspicious activity  takes many forms and is hard to define in absolute  terms, however, common examples of “red flags”  are included in the company’s related policies. If  you ignore or choose not to report suspicious  activity, both you and the company could be  considered willfully blind and held liable for the  criminal activity.  Report concerns by submitting a Report of Unusual  Activity, which can be found on Inside or the  AdvisorCompass® site.   Company property  Our company property, including equipment, supplies,  systems and facilities, must only be used for valid  business purposes. Theft, carelessness and waste have  a direct impact on our profitability. If you suspect  someone was involved in, or is attempting to cover  up, the theft or misuse of company property,  immediately report it to Security Services (or 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,” “Ameriprise Bank,”  “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   Know and follow the social media policies that  apply to your role
 19     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.
 20     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
 21     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,  ERGSC@ampf.com, the Ethics Hotline at  1.800.963.6395 or ampf.ethicspoint.com 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.
 22     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, while in a  company workplace.  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?
 23     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:   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.    Talk to your leader about any situation   that concerns you or reach out to any of   the global resources or those listed on page  24for 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 –  Heather.J.Melloh@ampf.com    Corporate Secretary’s Office –  Wendy.Mahling@ampf.com
 24     CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   ETHICAL PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Global 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.  Employee Relations Group Service Center ERGSC@ampf.com  Ethics Hotline U.S.: 1.800.963.6395 or ampf.ethicspoint.com  All other locations: Go to ampf.ethicspoint.com and select your location for country and access codes  Human Resources Executive Vice President, Human Resources: Kelli.A.Hunter@ampf.com  General Counsel’s Organization Executive Vice President, General Counsel: Heather.J.Melloh@ampf.com  Corporate Secretary’s Office Senior Vice President, Corporate Secretary: Wendy.Mahling@ampf.com  Risk & Control Services Senior Vice President, General Auditor: Ryan.P.Burns@ampf.com  Fraud and Whistleblower Oversight Committee fwbcommitteereporting@ampf.com  Personal Trading Compliance personal.trading@ampf.com   Report suspicious activity Complete a Report of Unusual Activity located on your intranet.  If the situation is urgent, call the Suspicious Activity Hotline – 1.612.671.6166    Concerns may also be raised with certain  regulators listed in the whistleblower policy  applicable to your business area  Austria FMA – 0800 – 249 900; via the online tool, Einführung (bkms-system.net); or via post: Hinweisgeberstelle, Otto  Wagner Platz 5, 1090 Wie  Denmark Danish Financial Supervisory Authority –https://www.dfsa.dk/Whistleblower  France Autorité des Marchés Financiers –(+33)1 64 40 64 44 ; in electronic format (via the online form);   or via post  Germany Federal Financial Supervisory Authority (BaFin) – hinweisgeberstelle@bafin.de or anonymous reports via the  online tool: https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=2BaF6&c=-1&language=ger  Italy  Commissione Nazionale per le Società e la Borsa – 0039 06 8411099; whistleblowing@consob.it; or via  post CONSOB, Via G. B. Martini 3, 00198, Rome.   Banca d’Italia –  Online services platform; or via post: Banca d'Italia, Via Nazionale 91 - 00184 Roma, for the  attention of the Directorate General for Financial Supervision and Regulation - Supervisory Institutional  Relations Directorate - External Relations Support Division (the envelope must be marked Confidential)  Luxembourg Commission de Surveillance du Secteur Financier – whistleblowing@cssf.lu  Netherlands  Dutch Authority for the Financial Markets – Information Line – info@afm.nl   De Nederlandsche Bank Integrity Reporting Desk – meldpuntmisstanden@dnb.nl  Spain Comision Nacional del Mercado de Valores – 900 373 362; whistleblowing@cnmv.es; or via post to  Communication of infringements - Investors Department - CNMV. C/ Edison, 4, 28006 Madrid – C/ Bolivia 56, (4  a Planta) 08018 Barcelona.  Sweden Finansinspektionen – https://www.fi.se/en/about-fi/contact-us/whistleblowers/  United  Kingdom   FCA Whistleblowing– whistle@fca.gov.uk   Prudential Regulation Authority – whistleblowing@bankofengland.co.uk
 Financial Planning | Retirement | Investments | Insurance  Ameriprise Financial, Inc.  Corporate Secretary’s Office  1098 Ameriprise Financial Center, Minneapolis, MN 55474  ameriprise.com  Revised January 1, 2023  © 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.