Exhibit 14(c)                        Ameriprise Financial  Global Code of Conduct
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE 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
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE 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 statutes 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 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
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES     Contents    • Introduction  − Our Code applies to everyone ......... 5  • Report your concerns ............................ 6  • Our core principles  − Treat everyone with dignity   and respect ...................................... 7  − Do the right thing for the client ....... 9  − Obey the law and guard against   criminal activity .............................. 10  − Conduct business ethically ............. 12  − Compete fairly in the marketplace 14  − Protect the company’s reputation   and assets ...................................... 16  − Safeguard and maintain   accurate information ..................... 18  • Navigate your ethical questions .......... 20  • Consequences for non-compliance ..... 21  • Global Resources ................................. 22
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Our Global Code of Conduct applies   to everyone at Ameriprise Financial  Our Principles in Action  We value ethics and integrity.  We maintain an environment where compliance  and adherence to the Code of Conduct is the norm.  About the Global Code of Conduct  This Global Code of Conduct (or “Code of Conduct” or  “Code”) is enterprise-wide and applies to everyone  working for one of our business areas or affiliates,  including all officers, employees, and financial advisors  and their staff. 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 accountable for reading,  understanding and following the Code and all company  policies applicable to their roles and responsibilities.  Commitment to our core principles helps ensure  compliance with the Code.  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. Contractors are  also required to comply with the Code.  This Code applies even if you also adhere to another  code of ethics or conduct within your business area.   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.  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 21.)  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.  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 6 or 22) before you act.  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 if you  are unsure whether your actions will  comply with the Code  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
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Report your concerns   Our Principles in Action  We respond appropriately to all allegations by  employees, suppliers, clients or contractors  that the company or individuals are not  meeting their 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.  If you observe behavior that causes you concern,  you should, in good faith, report a suspected  breach of the Code, policies, regulations or the  law, or any other 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.  Reporting issues to the company does not prevent  you from also reporting conduct that you believe  to be an actual or potential violation of law to the  government or regulators. Refer to page 22 for  resources.  Non-retaliation  We will not tolerate any retaliation against you for  reporting 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 carefully reviewed and  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.    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 policy  violations or ethical issues. Even if you are  unsure if the activity is a violation, it’s  important to report it to uphold the  reputation and integrity of the company.  Report concerns promptly to your leader,  another trusted leader, Employee  Relations, to one of the global resources  listed on page 22, or to the Ethics Hotline:  − People Resource Center –  1.877.267.4748 or  PeopleResourceCenter@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
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Treat everyone with dignity   and respect  Our Principles in Action  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 and inclusion.   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 and harassment  Our employees are prohibited from engaging in  discrimination or harassment against any person on  the grounds of race, color, religion, sex, sexual  orientation, gender identity, gender expression,  national origin, ancestry,  age, physical or mental  disability, medical condition, pregnancy, veteran  status, genetic information, citizenship status marital  status, family status or any other basis prohibited by  law.   Each of us, particularly leaders, is responsible for  creating and maintaining a work environment free of  discrimination and harassment for our employees.  Discriminatory treatment and harassment are illegal  and violate our company values. We expect individuals  to report any violations.  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. Call Security  Services (or your local security personnel) or the  People Resource Center to report a dangerous  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.  Importance of diversity and inclusion  We are committed to valuing and supporting diversity  in the workplace and community. Employees, advisors  and staff represent many age groups, ethnicities, family  structures, races, religions, sexual orientations,  nationalities, neurodiverse mental abilities and  physical abilities.  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.  We value our people, encourage their  development and reward their  performance. We expect all  employees and advisors to behave in  a values-driven manner, which  includes treating all people with  dignity and respect.   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, inclusive and safe  work environment  Notify your local or onsite security  personnel and/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.
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES    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.
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Do the right thing for the client  Our Principles in Action  We maintain our clients’ loyalty and improve  their experience by acting with integrity.   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. 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 may  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 the  information they need to make an   informed decision
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Obey the law and guard against  criminal activity  Our Principles in Action  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  Each of us is responsible to know and follow the laws  wherever we work and the rules and regulations  applicable to your responsibilities. 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. Additional rules or regulations may  apply to you in your home country or because of  your specific job 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.  You should not share confidential business  information with anyone unless it’s necessary to do  your job. If you share material, non-public  information with a person who trades in the stock of  Ameriprise or another implicated company or shares  the information with anyone else, you both could  face prosecution for insider trading.     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
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  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.  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.
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Conduct business ethically Our Principles in Action  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.   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. 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.   Engaging in an activity without first disclosing and  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. In addition, you may not conduct  outside business activities during normal business hours  or by using Company resources.  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.) If you are subject to a gift and entertainment policy,  you may be required to decline a gift or return it. If you  are a licensed person, you should seek advice from your  registered principal or Compliance Department. If you  don’t know whether a gift policy applies to you, contact  your Compliance Department. Remember that you are  never permitted to solicit a gift from a client, vendor or  anyone else doing business with the company.  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     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 and submit a Request  for Prior Approval or Disclosure if  appropriate.
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES    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.  In addition, 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.
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Compete fairly in the marketplace. Our Principles in Action  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 in violation of competition laws.   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.  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. A growing number of  jurisdictions, including the United States and the  United Kingdom, impose severe penalties if you give  anything of value to a government official. Even a  modest meal and small gift can result in severe  penalties for you and the company.  We also have zero tolerance for facilitation of tax  evasion by employees and third parties. Tax evasion  is one form of money laundering, and the Ameriprise  Financial Global Anti-Money Laundering and  Economic Sanctions 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.      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. 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.
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES      Non-retaliation  An individual shall not be held criminally or civilly  liable under any trade secret or similar law, for the  disclosure of a trade secret that is made:  in confidence to a 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.
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES   Protect the company’s reputation   and assets Our Principles in Action  We diligently safeguard the company’s  reputation, its physical and intellectual  property and all sensitive information.   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. Our ability to do business relies on  our physical and intellectual assets.  We consider our reputation one of  our most valuable assets.  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 and use  common sense while engaging in social  media that is consistent with our values  and the law
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES    Risk Management  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.  Our Reputation  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.
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Safeguard and maintain accurate  information Our Principles in Action  We diligently safeguard our clients’ personal  information. We believe that accurate  recordkeeping and reporting are essential to our  reputation and credibility.   We comply with all applicable 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.  Contact your leader, registered principal, the People  Resource Center at 1.877. 267.4748,  PeopleResourceCenter@ampf.com , or the Ethics  Hotline at 1.800.963.6395, 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.     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 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 clients, employees,  advisors 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
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES      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.
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Navigate your ethical questions.  Our Principles in Action  We consider our actions carefully. Ask for  guidance when you need it.   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  them to speak with their 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?
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Consequences for non-compliance  Our Principles in Action  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 and/or its clients or employees,  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, workspace colleagues, or  vendors, 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, advisor or contractor 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, advisor  or contractor 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. 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:  Report concerns to your leader or one of  the resources listed in this policy.  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 22 for assistance:  Your Human Resources   business partner   People Resource Center– PeopleResourceCenter@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
 CONTENTS     |     INTRODUCTION     |     REPORT YOUR CONCERNS     |   OUR CORE PRINCIPLES   |     NAVIGATE YOUR ETHICAL QUESTIONS     |     CONSEQUENCES FOR NON-COMPLIANCE     |     RESOURCES  Reach out to the resources below or  refer to related company policies,  procedures to report concerns and for  questions or additional information  Global Resources  People Resource Center  PeopleResourceCenter@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.  Report safety concerns 0BMinneapolis – 1.612.671.2454  or 1.612.671.3333  1BUnited States – 1.800.455.5187  2BUnited Kingdom, European Union or India – 00.1.612.671.2454 or 00.1.612.671.3333    Reporting to the Company does not prevent you from  reporting conduct that you believe to be an actual or  potential violation of law to the government or  regulators, which include, among others, those listed  here.                   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  Dubaï Dubaï Financial Services Authority – whistle@dfsa.ae  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  United States Securities and Exchange Commission - www.sec.gov/complaint/select
 Financial Planning | Retirement | Investments | Insurance  Ameriprise Financial, Inc.  Corporate Secretary’s Office  1098 Ameriprise Financial Center, Minneapolis, MN 55474  ameriprise.com  Revised January 1, 2024  © 2024 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  determine 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.