Ameriprise Financial Code of Conduct          1                                 Ameriprise Financial   Code of Conduct
 Click on this icon for Resource Guide              Click on this icon frequently asked questions          Ameriprise Financial Code of Conduct          2      ?   Table of contents   A message from our chairman    and chief executive officer ....................................... HU3 U   Ameriprise Financial    Statement of Integrity .................................................. HU4 U      The code applies to everyone  .............................. HU5 U   Related company policies ........................................ HU8 U      Your responsibilities    Understand and follow the     Code of Conduct  ...................................................... HTU6 UT    Do the right thing for the client ......................... HTU9 UT     Conduct business ethically ..............................HTU11 UT     Compete fairly in the marketplace ...............HTU15 UT     Avoid abuses of your position     or knowledge ..............................................................HTU17 UT    Guard against criminal activity  ......................HTU26     Safeguard the privacy, confidentiality     and security of client information    and records .................................................................HTU30    Protect the company’s reputation     and assets .................................................................. 32    Maintain complete and accurate     business records .....................................................HTU36    Treat people with dignity and respect........HTU33 U8       Glossary ............................................................................... H40   Resource guide - contacts .................................... H43   Frequently asked questions ................................ H44   Supplement 1 .................................................................. 45   Topics covered in the Code of Conduct   Access Persons ............................................................... 21-22   Advertising and marketing  .............................................. HTU10 UT   Anti-money laundering ........................................................ HTU26   Antitrust ......................................................................................... HTU15 UT   Blackout periods............................................................. HTU20, 23 UT   Business activities of family members ..................... HTU12 UT   Business opportunities  ...................................................... HTU11 UT   Client information ................................................................... HTU30   Competing in market ............................................................ HTU15 UT   Confidentiality ........................................................................... HTU25   Consequences for non-compliance .............................. HTU7   Contacts with competitors ................................................ HTU15 UT   Cooperation with regulatory organizations ........... HTU37   Disclosures to clients .............................................................. HTU9 UT   Document retention and destruction ......................... HTU37   Electronic communications .............................................. HTU32   Entertainment  .................................................................. HTU13 UT-14   Equal employment ................................................................. HTU34 UT   Financial data  .......................................................................... HTU36   Fraud prevention  ................................................................... HTU28   Freedom from discrimination  ........................................ HTU38   Gifts to/from clients ............................................................... HTU13 UT   Identity theft ................................................................................ HTU28   Importance of diversity ....................................................... HTU38   Improper personal benefits .............................................. HTU11 UT   Improper payments and reimbursements ............. HTU13 UT   Insider trading  .......................................................................... HTU18   Intellectual property .............................................................. HTU32   Investments and Trading, personal .................. 17, 19   Late trading ................................................................................. HTU19   Market timing ............................................................................. HTU19   Non-retaliation .......................................................................... HTU39   Office of Foreign Assets Control (OFAC)  ............. HTU23 UT   Outside activities ..................................................................... HTU12 UT   Physical assets and property of company ............ HTU32   Political involvement ............................................................. HTU34   Preclearance of trades .............................................. HTU21, 23   Preclearance of political contributions    and activities ............................................................................. 35   Protection from retaliation ................................................... HTU7 UT   Privacy incidents ..................................................................... HTU32   Public communications....................................................... HTU10 UT   Reimbursements to politicians ...................................... HTU13 UT   Reporting suspected violations ........................................ HTU7 UT   Security of information and data .................................. HTU26 UT   Signature issues and forgery ......................................... HTU29   Statements about competition or products ........... HTU16 UT   Suitability of products and services ........................... HTU10 UT   Tipping ........................................................................................... HTU27   Trade secrets  ........................................................................... HTU25   Travel and expense accounts........................................ HTU37   Treatment of employees and others ......................... HTU38   Violence in the workplace  ............................................... HTU39   Whistleblowing ............................................................................ HTU7 UT   Willful blindness ....................................................................... HTU27
 Ameriprise Financial Code of Conduct          3      ?   A message from our chairman   and chief executive officer      Dear colleague:    Our success as a company depends on managing our business with the highest standards of integrity.   We know that a strong reputation is built over years of client service and easy to tarnish, simply with a   poor decision or action. At Ameriprise Financial, our strong reputation is one of our most valuable assets,   earned by serving our clients well for over 120 years.    Our Board of Directors, the Executive Leadership Team and I count on you to help protect our company's   reputation, brand and the value of our franchise. The Ameriprise Financial Code of Conduct is intended to   help you meet our legal and regulatory obligations, evaluate and make ethical business decisions, and   provide a resource you can turn to for guidance. No matter what aspect of our business you are involved   in, Ameriprise has policies and procedures in place to support you to operate ethically, and in full   compliance with the laws and regulations that govern our businesses.    Adhering to our code of conduct is non-negotiable. You are required to read and become familiar with the   code so you are prepared to satisfy the requirements of your job and to handle unfamiliar situations. The   code will tell you how to report suspected violations of the code or laws or regulations. It is part of your   duty to report such violations and we will support anyone who files a complaint honestly and in good faith.   While no code can anticipate every issue you may face, it can help you make decisions that ensure   Ameriprise conducts its business in a way that supports our corporate values.   I want to emphasize that our Board of Directors, Executive Leadership Team and I hold ourselves to the   same high standards of conduct that we expect of you. For those of you who supervise others, it is your   responsibility to demonstrate to the employees who report to you that you are committed to the standards   of our code. Your actions are as important as your words, and your team looks to you to set an example   of honest and ethical behavior.   Today, we continue to do all that we can to earn our clients’ confidence and keep our reputation strong.   The importance of operating with integrity cannot be overstated. It is essential that each of us internalizes   our code of conduct as an important step toward fulfilling our vision of becoming the most respected and   referred financial services brand.    Thank you for your support in ensuring we continue to do business the right way.      Jim Cracchiolo   Chairman and Chief Executive Officer   Ameriprise Financial, Inc.                     > Back to Contents
 Ameriprise Financial Code of Conduct          4      ?   Ameriprise Financial   Statement of Integrity   Ameriprise Financial is committed to conducting business   ethically by acting in the best interests of our clients and adhering   to our values. This commitment is fundamental to protecting our   clients, building advisors’ practices and enhancing our brand.    We earn our clients’ confidence every day by delivering on our   brand promise -- We shape financial solutions for a lifetime®. We   are obligated to do the right thing and live the principles in our   Code of Conduct:    Conduct business ethically      Do the right thing for the client      Treat people with dignity and respect      Protect the company’s reputation and assets    It’s impossible to anticipate every issue we may encounter. But   internalizing these principles will help us make the right decision   when faced with a difficult or unfamiliar situation. Ultimately, we’re   all accountable for meeting the letter and spirit of regulatory and   company rules.   When we manage our business with the highest standard of   integrity, we do right by the client, the advisor, the shareholder   and the company and help fulfill our vision of becoming most   respected and referred financial services brand.            “Our success as a   company depends    on managing our   business with the    highest standard    of integrity.”       Jim Cracchiolo                                                                                       > Back to Contents
 Ameriprise Financial Code of Conduct          5   Q      ?   The code applies to everyone   The Ameriprise Financial Code of Conduct applies to all   Ameriprise Financial and subsidiaries, officers, employees,   financial advisors and their employees, contractors, and   individuals conducting business on behalf of Ameriprise   Financial, Inc. and its subsidiaries and affiliates   (“Ameriprise Financial”). Other people performing services for   the company may be subject to the code by contract or   agreement.   If you have questions about the appropriateness of a situation or   decision, talk to your leader, registered principal or other   appropriate person identified in the Code of Conduct.   For information or questions about the code, please see the   HTUResource Guide UTH on Page 43 or contact the resources listed   below:   Corporate Secretary’s Office   HTUTH homas.R.Moore@ampf.com (612) 678-0106   Employee Relations Group Service Center   HTUERGSC@ampf.comUTH, 1 (877) 267-4748   Ethics Hotline   1 (800) 963-6395   General Counsel’s Organization   HJohn.Junek@ampf.com (612) 671-3651   Yes. The code applies to all   officers, employees, advisors,   employees of advisors and   contractors, regardless of   whether you work full-time or   part-time. Anyone doing business    on behalf of Ameriprise Financial,   RiverSource, Columbia   Management or any of our other   subsidiaries will be held   accountable for reading,   understanding and following the   code and all company policies   applicable to his or her roles and   responsibilities.                                                                                                   I’m a contractor working    on a three-month project at   Ameriprise Financial. Since   I’m not an employee and I’m only   here for three months, does the   code apply to me?
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 Ameriprise Financial Code of Conduct          7   Q      ?   Your responsibilities    Understand and follow the Code of Conduct   You are expected to read, understand and follow this code. You   are also expected to read, understand and follow the policies,   codes of ethics and procedures that apply to you (see HTURelated   company policiesUTH on Page 8). If you have any questions, ask your   leader or registered principal or contact the Corporate   Secretary’s Office at (612) 678-0106.   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.    Personal Conduct   All employees, advisors, and other persons subject to the Code   of Conduct are required to adhere to the highest standards of   honesty, integrity, ethics, personal conduct, and professionalism   during working hours and personal time.  These are examples of   actions that violate the Ameriprise Financial Code of Conduct.   These examples are provided to supplement and reinforce other   such examples provided throughout the Code of Conduct.    However, this is not an exhaustive list and the company retains   the right to determine whether specific actions or behavior violate   the Code of Conduct:    Violation of any company policy, procedure, rule, or any law    or regulation.    Willful or negligent damage to company property or the    property of other persons.    Theft or dishonesty, including falsification of company records    or furnishing false or incomplete information on expense   forms, time records or an application for employment or any   documents related to an application for employment.    Inappropriate behavior which embarrasses or is harmful     to the company or its clients, including the posting or   transmission of offensive or inappropriate material on the   Internet or any social media site.    Disruptive behavior, including insubordination, willful    disregard of company policies or procedures, or disrespect   toward a leader or representative of management, or failure   to perform work as required or assigned.    Violation of safety or health laws or regulations or engaging    in conduct that creates a safety or health hazard.      Related policies:   HTU andling Whistleblower Claims   PolicyUTH  Advisor Compliance   Manual               > Back to Contents   I saw one of the team   leaders in my department   doing something that I   believe is a violation of the Code    of Conduct. She is not my direct   leader, but she does have input   into my review and whether I get   a raise. If I report what I saw, I   am afraid that she will make   negative comments to my direct   leader about my performance so   that I would get a bad review at   the end of the year. What should    I do?      You are obligated to report   suspected violations of the Code of   Conduct. Company policy protects   you from retaliation if you report a   suspected violation in good faith.   However, if you file a malicious   report or report something you   know is not true, then you may be   subject to disciplinary action. If you   have questions about whether you   should report a violation of the   code, contact the Employee   Relations Group Service Center    or Ethics Hotline.
 Ameriprise Financial Code of Conduct          8      ?   Consequences for non-compliance    If you fail to comply with the code, company policy or any   applicable law or regulation, you will be subject to disciplinary   action that may include termination. Disciplinary measures will   depend on the circumstances of the violation and will be applied in   a manner consistent with the company’s policies.    Although this is not an all-inclusive list, disciplinary action will   be taken against an employee or advisor who:     Authorizes, directs, approves, participates in or encourages    violations of the Code of Conduct    Deliberately fails to report or conceals violations of the code or    deliberately withholds or misstates relevant information   concerning a violation of the code    Retaliates against any other employee because of a report by    that employee of a suspected code violation    Should have known about a violation by people under his or her    supervision, or did not act promptly to report and correct    a violation   In addition, people who violate the law during the course of their   employment are subject to criminal and civil penalties, as well as   payment of civil damages to the company or third parties.   Reporting suspected violations    If you have a reasonable and good faith basis to believe that you,   another employee, an officer or advisor, at any level of seniority,   has violated the code or any applicable law or regulation, you must   report the violation promptly so that the company can take   appropriate action. In the event of an investigation, be sure to retain   all relevant documents.   Whistleblowing and protection from   retaliation    A whistleblower is an individual who in good faith reports an alleged   impropriety affecting the company that prevents the company from   meeting its legal obligations or from complying with generally   accepted accounting principles.    Your report will be treated confidentially to the extent allowed   by law and company policy. You will not be subject to retaliation   for reporting a suspected violation in good faith. No adverse   employment action, such as termination, counseling, a lower   performance rating or demotion, may be taken against an   employee solely in retaliation for reporting in good faith potential   violations of the code.    If you believe you have been retaliated against, promptly contact   the General Counsel’s Organization, the Employee Relations   Group Service Center at 1 (877) 267-4748, or the Ethics Hotline at   1 (800) 963-6395.
 Ameriprise Financial Code of Conduct          9      Report violations to your leader promptly. If it is impractical or   inappropriate to notify your leader, contact your registered   principal,    the General Counsel’s Organization, the Employee Relations   Group Service Center at 1   (877) 267-4748, or the   Ethics Hotline at    1 (800) 963-6395.       > Back to Contents
 Ameriprise Financial Code of Conduct          10      ?   Related company policies   The Code of Conduct incorporates into its terms and   requirements the provisions of other related policies, codes of   ethics and procedures to which you are subject. It is important   to know which related policies apply to you. Please read the   related policies that apply to you.    The table below will help you determine which policies apply to   you, based on your job status or responsibilities. These   documents cannot cover every situation you may encounter.   Individual business units or staff groups may issue additional   policies that provide more specific guidance about certain   practices such as doing business with international clients or   privacy guidelines for institutional clients. For the most current   version of the policies, codes and procedures, click on the   applicable link below or go to the Inside or AdvisorCompass®   sites. (Some links may require your Single Sign On or Windows   user name and password.       The list below is not an all-   inclusive list of company   policies. Talk to your leader   about other policies that may   apply to you. For Columbia   Management employees and   investment advisers, please   refer to CompliSource for    other policies which may    apply to you.       Key Columbia Management   Compliance Contacts               > Back to Contents      Applicable to everyone (officers, employees,   advisors, employees of advisors and contractors):   Applicable to advisors (employee and franchise)    and their employees:   HAnti-Money Laundering Policy   Antitrust Guidelines   Client Privacy Principles   Communication and Disclosure Policy    Communication and Disclosure - Procedures &   Guidelines   Conducting Competitive Intelligence Activities    Congressional Gift Rule Guidelines for employees    Electronic Communication Acceptable Use Policy   Equal Employment Opportunity Policy   Global Anti-Corruption Policy and Guidelines   Handling Whistleblower Claims Policy   Identity Theft Prevention Policy   Information Security Policy   Individual Treatment Policy   Intellectual Property   Investor Relations Policy   Payments to Expedite Foreign Government Actions   Public Appearances and Interaction with the Media   Policy - Procedures and Guidelines    Record and Information Management Policy   Social Media Policy   Travel and Expense Policy   Vendor Endorsement Policy   Advisor Compliance Manual      Applicable to certain people based on job function    or responsibilities:   American Enterprise Investment Services Gifts and    Business Entertainment Policy   Ameriprise Financial Services Gifts and Entertainment   Policy   Ameriprise Financial Political Contributions    (“Pay to Play”) Policy   Columbia Management - Anti-Money Laundering   Policy    Global Code of Ethics Personal Accounts Dealing   Policy    Columbia Management Policy - Gifts and Benefits    Columbia Management –  Political Contribution   Policy    Columbia Management Policy – Disclosure of Outside   Activities and Family Relationships    Dual Registration Policy   Outside Business Activities Disclosure Policy for   FINRA Registered Persons   RiverSource Gifts and Benefits Policy
 Ameriprise Financial Code of Conduct          11   Q      ?   Do the right thing for the client    Ameriprise Financial has a duty to conduct business ethically    and with the highest degree of integrity. This duty applies to all   daily business activities, from initial contact with prospects   through the continued service of existing individual or institutional   client accounts.    Performing this duty includes providing full and fair disclosure,   treating our clients fairly, recommending suitable products,   considering the impact of our decisions on clients and providing   exceptional client service. Doing the right thing for our clients   improves the client experience and encourages their continued   business and loyalty.    Full and fair disclosure   Make full and fair disclosure of all material facts, particularly   where your interests may conflict with those of our clients. You   must provide full and fair disclosure of the features, benefits,   risks and fees of products or services sold or marketed to all   clients or prospects.   Your communications must:    Comply with any law or regulation governing the content,    format or required disclosures of the communication    Help clients and prospects understand our products     and services    Be accurate, fair and balanced and presented in the proper    context    Not omit material facts, qualifications or caveats if the result    would be misleading.    You may not make exaggerated or misleading statements,   regardless of whether the information is given directly or   indirectly, and you must answer all questions honestly. You, in   partnership with other employees and advisors, have the   responsibility to provide the client or prospect with all the   information needed to make an informed decision, particularly in   light of the person’s age, risk tolerance and current and projected   financial needs.      Related policies:   HPAdvisor Compliance Manual 8.   Client Information, Suitability and   Disclosure  Advisor Compliance   Manual 14. Communications   with the Public  Communication   and Disclosure Policy    Communication and Disclosure -   Procedures & Guidelines    Public Appearances and   Interaction with the Media Policy    Public Appearances and   Interaction with the Media Policy   - Procedures and Guidelines    Social Media Policy                                                    > Back to Contents      How can I demonstrate   that I provided my client   with full and fair disclosure   about a product I recommended?      First, make sure you have provided   the client with all required   disclosures at the time of your   recommendation. Then follow up   with a summary letter to your client   detailing the discussions you have   had, the decisions made and the   rationale for those decisions.
 Ameriprise Financial Code of Conduct          12   Q      ?   Suitability   Suitability involves determining that investment advice provided   and products or services recommended to each client are   appropriate given the client’s age, financial situation, investment   planning objectives and tolerance for risk, among other factors.   When dealing with elderly clients, pay special attention to their   expected financial needs and tolerance for risk.   Ameriprise Financial suitability requirements apply not only to   initial buy, sell and hold recommendations, but also to   subsequent recommendations in existing accounts, including   additional purchases, surrenders or redemptions, and asset   allocation changes.    Always take the time to ensure suitability requirements are met   and to provide clients with the information necessary for them to   fully understand the relevant information, including the features,   potential benefits and risks of the recommended product or   service. In addition to meeting regulatory requirements, this will   reinforce the company’s image as a knowledgeable, ethical and   qualified provider of financial services.    Advertising, marketing and   communications with the public    Advertising, marketing and communications with the public (e.g.,   clients, prospects, investors, analysts and the general public)   must be truthful, accurate and not misleading. In addition, the   content must meet applicable regulatory and legal standards.   When preparing advertising, marketing and communications for   the public, you must ensure that required reviews and approvals   are received prior to first use. You are not permitted to revise   such materials after all approvals are obtained, unless the   revisions have also been reviewed and approved prior to    first use.         Related policies:   HAdvisor Compliance Manual 8.   Client Information, Suitability and   Disclosure  Advisor Compliance   Manual 14. Communications   with the Public  Communication   and Disclosure Policy    Communication and Disclosure -   Procedures & Guidelines    Public Appearances and   Interaction with the Media Policy    Public Appearances and   Interaction with the Media Policy   - Procedures and Guidelines    Social Media Policy                                                            > Back to Contents      I work for Columbia   Management in the   corporate office. I don’t sell   products to clients or make any   recommendation about which   products they should purchase.   What responsibilities do I have to   ensure suitability?      Responsibility for ensuring that   product purchases are suitable    for the client is not limited to   financial advisors. For example,    one key responsibility is developing   training for our products. Advisors   must understand the products they   sell, including how the products   work, the risks and benefits of the   products, and the current fees    or charges.
 Ameriprise Financial Code of Conduct          13   Q      ?   Conduct business ethically   Conducting business ethically is the cornerstone of our relationships   with employees, clients, prospects, vendors, suppliers, regulatory   bodies and the communities in which we do business. We operate   in a highly regulated industry under intense media and public   scrutiny. We expect you to comply fully with all applicable laws and   regulations. Therefore, it is important to address conflicts of interest   and avoid even the appearance of impropriety.    Improper personal benefits   Do not use your position with the company, or information   acquired during your employment or relationship with the   company, in a manner that may create a conflict, or the   appearance of a conflict, between your personal interests   and the interests of the company or its clients.   Avoid taking improper advantage of your position, company   resources or opportunities gained as a result of your business   activities. This includes but is not limited to opportunities such as   personal loans, guarantees or discounts with terms that are not   generally available to the public or to other similarly situated   employees as part of a compensation or benefits program.   Business opportunities   You or members of your immediate family or household, as   a result of information acquired during your employment or   relationship with the company, may not:    Purchase for personal use the goods or services of the    company’s suppliers on terms other than those available to   the general public or established by company policy    Accept business opportunities, commissions or    advantageous financial arrangements from a client, vendor,   supplier or business partner of the company.      Related policies:   HTAmerican Enterprise Investment   Services Gifts and Business   Entertainment Policy  Ameriprise   Financial Services Gifts and   Business Entertainment PolicyTH     Columbia Management Policy -   Gifts and Benefits    Global Code   of Ethics Personal Accounts   Dealing Policy    Columbia   Management Policy – Disclosure of   Outside Activities and Family   Relationships    Payments to   Expedite Foreign Government   ActionsT    Advisor Compliance   Manual 5. Gifts and Other Non-   Cash Compensation   Advisor   Compliance Manual 13. Regulatory   Disclosures, Attestation and   Outside Business Activities                        > Back to Contents      I recently gave money to a   local food shelf. One of the   people who work for the   charity asked me if I would help   them raise additional funds.    He wanted me to write them a   letter of support on company   letterhead. Can I write the letter on   Ameriprise Financial letterhead to   help them out?      No. Even though you personally   support the charity, you may not   use your affiliation with the   company in any way to support   the charity, including hosting fund-   raising events at your office,   writing a letter of support on   company letterhead, or allowing   the charity to use company   property (e.g., photocopiers). This   would imply that the company   endorses that particular charity.   You can show your support for the   charity by writing a personal letter   encouraging others to make   donations, but it cannot be on   company letterhead.
 Ameriprise Financial Code of Conduct          14   Q      ?   Your outside activities    You may engage in outside activities that do not conflict with the   interests of the company, interfere with your job responsibilities   or the responsibilities of the company’s employees, or damage   or misuse the reputation, trademarks, relationships, confidential   information or other property of the company. Outside activities   must also be of a nature and offered in a manner in which they   do not have the potential to appear to customers or the public as   part of Ameriprise business.   Without prior written approval from the corporate secretary,   you may not:     Simultaneously work for any concern that does business    with or competes with the company    Serve as a director, trustee, officer or similar position (paid    or otherwise) of any business, other than with the company   or one of its subsidiaries. This rule does not apply to   charitable, civic, religious, educational, public, or social   organizations, or to residential boards whose activities do   not conflict with the interests of the company and do not   impose excessive demands on your time.   There is a separate preclearance process for political   contributions and volunteer political activities. Please see page   35 for important details.   You may join industry or trade associations with the prior written   approval of your leader. However, you should ensure that your   work within those organizations is consistent with the interests of   the company and does not involve potential reputational harm to   the company or its brands.   Note that if you are FINRA-registered, you must also seek    prior approval for outside business activities from your   registered principal. Based on their review of the activity,   your registered principal may impose specific conditions or   limitations, including prohibiting the activity, where   necessary, based on the nature of the activity and your role   at the firm.   Business activities of family or    household members    You must disclose to the corporate secretary instances in which:    You seek to hire or engage a family or household member or    their business to provide goods or services to the company.    A member of your immediate family or household works for,    or holds a position that can influence decisions at, a firm that   directly competes or does business with the company.    A member of your immediate family or household holds a    position that interacts with positions of authority at a firm that   directly competes or does business with the company.         Related policies:   HAdvisor Compliance Manual 5. Gifts   and Other Non-Cash Compensation     Advisor Compliance Manual 13.   Regulatory Disclosures, Attestation   and Outside Business Activities    American Enterprise Investment   Services Gifts and Business   Entertainment Policy  Ameriprise   Financial Services Gifts and   Business Entertainment Policy     Columbia Management Policy -   Gifts and Benefits     Global Code   of Ethics Personal Accounts   Dealing Policy    Columbia   Management Policy – Disclosure of   Outside Activities and Family   Relationships    Outside Business   Activities Policy  Payments to   Expedite Foreign Government   Actions           My husband owns a small   restaurant and he regularly   caters business meetings.    He recently told me that he has put   in a bid for a catering job for an   Ameriprise Financial business   meeting. Do I need to let anyone   know about this?      Yes. If you, a member of your   household or a member of your   immediate family is involved with   a company that does business   with Ameriprise Financial, you   must let the Corporate   Secretary’s Office know about the   situation. The Corporate   Secretary’s Office will examine   the situation and determine if   there is a conflict    of interest.
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 Ameriprise Financial Code of Conduct          16   Q      ?   Improper payments and   reimbursements to politicians or   political organizations   You may not offer or accept any improper payments,   reimbursements, gratuities or gifts to government officials,   political parties, political candidates or charities with which they   are affiliated. In this situation, improper means offers and   payments that include a direct or indirect offer or promise to give   money or anything of value to such persons or political parties in   order to assist the company in obtaining business or securing   services or any improper advantage. Political contributions and   volunteer activities are subject to a special preclearance   process. Please see page 35 for important details.   Acceptance of gifts or entertainment   Do not give, solicit or accept gifts that could influence your   business judgment. This includes direct gifts such as cash or   monetary equivalents, objects of value or preferential treatment,   and indirect gifts such as benefits to a family member or a charity   you support.    This gift policy applies to everyone. However, you may be   subject to a specific gift and entertainment policy as part of   your job. For instance, advisors are subject to the policies and   procedures of their broker-dealer. Special rules may apply to   employees involved in seeking business with or providing   services to government entities or clients or entities residing   outside the United States. In addition, some of the company’s   businesses are regulated by government agencies that strictly   limit their employees’ ability to give or accept gifts.    You are responsible for knowing if there is a specific gift   and entertainment policy that applies to you. Contact your   leader, registered principal or the corporate secretary for specific   information and guidance on these rules.    Generally, you may accept entertainment, token gifts or favors   only when the value involved is not significant and clearly will not   place you under any real or perceived obligation to the donor. Do   not offer or accept business meals or attend business functions   at establishments featuring sexually suggestive or otherwise   inappropriate entertainment.    Any gifts that you want to give to your clients or business   partners are subject to a similar standard.            Related policies:   HAdvisor Compliance Manual 5. Gifts   and Other Non-Cash Compensation     Advisor Compliance Manual 13.   Regulatory Disclosures, Attestation   and Outside Business Activities    American Enterprise Investment   Services Gifts and Business   Entertainment Policy  Ameriprise   Financial Services Gifts and   Business Entertainment Policy     Columbia Management Policy -   Gifts and Benefits     Global Code   of Ethics Personal Accounts   Dealing Policy    Columbia   Management Policy – Disclosure of   Outside Activities and Family   Relationships    Outside Business   Activities Policy  Payments to   Expedite Foreign Government   Actions               Over the holidays, one of    my clients 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?      You may be subject to a specific   policy prohibiting accepting or   giving gifts over a certain dollar   value.       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 any gift, you   should ask yourself if the gift would   appear significant to others or   would appear to place you under   any obligation. If the answer is yes,   then you should not accept the gift.
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 Ameriprise Financial Code of Conduct          18      ?   When to consult the corporate secretary    before giving a gift    The person who would receive the gift is a federal, state or    local elected or appointed official, or a member of such a   person’s staff or immediate family.    You plan to pay for the gift with your own money even    though you are giving it for business purposes.    You believe that the gift will influence the recipient’s    judgment in favor of Ameriprise Financial in a specific   business transaction.    The gift is in the form of entertainment that involves air    travel, such as to a resort or golf course, or hotel   accommodations.    You expect to receive something of value in return for the gift.     The recipient is not a family member and works for a state or    federal regulatory or law enforcement agency, and you are   giving the gift based on a personal relationship.   When to consult the corporate secretary about a gift   you have received or been offered    The gift is in the form of cash or a cash equivalent, such as a    gift certificate or card.    The value or nature of the gift makes you uncomfortable.     The gift involves air travel or hotel accommodations.     You regularly negotiate agreements or the terms of business    transactions with the person giving the gift or his or her firm,   or you are in the midst of such negotiations.    The gift, although otherwise permissible under the Code of    Conduct, is part of a regular pattern of gift-giving unrelated to   a year-end holiday.    The gift is given to you to deliver to a member of your family.     You believe that the person giving the gift expects something    of value from you in return.   Some examples of   acceptable gifts include:    A moderately priced bottle   of wine from a supplier,   vendor or client    Tickets to a local sporting or   cultural event    A coffee mug of modest   value given by a supplier   (however, gifts from   customers must never    be solicited)    Modest gifts acknowledging a   personal event such as a   wedding or a birth     Attendance at the annual golf   outing hosted by the   company’s outside law firm   Some examples of   unacceptable gifts include:    A case of fine champagne     Tickets to a distant sporting    event, including airfare or   hotel accommodations    Cash, monetary    equivalents, stored value   products or gift certificates    A lavish personal gift such    as a piece of fine jewelry                                                               > Back to Contents
 Ameriprise Financial Code of Conduct          19   Q      ?   Compete fairly in the marketplace    Ameriprise Financial is committed to competing lawfully, ethically   and fairly in the marketplace based on the merits of our products   and services. We believe in fair competition because everyone   benefits from fair, free and open markets. We compete strictly on   the merits of our products and services, and make no attempt to   restrain or limit trade.    Antitrust and fair competition    Federal and state antitrust, monopoly and competition laws are   designed to preserve free and open competition. These laws   may vary, but their common goal is to ensure that a competitive   marketplace is free to provide consumers with high-quality goods   and services at fair prices and that no conduct interferes with this   process.    Failure to comply with these laws can have serious consequences   for the company, including substantial fines or damages, and   publicity that is damaging to our brands and reputation.    Contacts with competitors    Agreements to limit competition are prohibited. When dealing   with outside companies, including suppliers and vendors,   consider whether they are competing with Ameriprise Financial.   Use independent judgment and avoid even the appearance of   agreeing with a competitor to limit competition. Consult the   General Counsel’s Organization in advance whenever you doubt   the legality of a proposed activity or need further guidance.    As it relates to competitors, the following activities are    strictly prohibited:     Agreeing to establish the price of products and services,    including maximum and minimum prices, pricing formulas,   standardized discounts, terms of sale or concertedly   lowering supply to impact prices    Agreeing to divide up specific customers, classes of    customers, products or services to be sold, or the   geographic location in which business is transacted    Collecting competitive information through unlawful channels    or using information that was obtained illegally or improperly   by others, including through misrepresentation, invasion of   property or privacy, or coercion.      Related policies:   HAntitrust Guidelines   Global Code   of Ethics Personal Accounts   Dealing Policy   Conducting   Competitive Intelligence Activities     Information Security Program Policy    Intellectual Property                                      > Back to Contents   I just started working at   the company, but I used to   work for one of our   competitors. I often get questions   from coworkers who want to   know the long-term business   strategies of my former employer.   Should I share that information   with anyone on my new team?      No. It is improper to reveal    the confidential information    or trade secrets of a former   employer. If you are uncomfortable   discussing this situation with your    leader, contact your business   unit’s compliance officer or the   General Counsel’s Organization    for assistance.
 Ameriprise Financial Code of Conduct          20      ?      Certain types of joint ventures or other formal activities that   include an exchange of information may be possible under   limited and very controlled circumstances with advice from   experts in this area. These situations are carefully planned and   monitored to be consistent with our values and applicable fair   competition laws. Violations of these guidelines may expose you   and Ameriprise Financial to criminal and/or civil penalties. If you   are in doubt, seek advice from the General Counsel’s   Organization.    Truthful statements    Statements about our products and our competitors must be   truthful, complete and not misleading. Statements include   advertising materials and written or oral statements to clients,   prospects, regulators or others.    False or misleading statements about our competitors are   inconsistent with our values and harmful to our reputation.                                                                                                                               > Back to Contents
 Ameriprise Financial Code of Conduct          21   Q      ?   Avoid abuses of your position or knowledge    Ameriprise Financial has a responsibility to conduct business   legally, ethically and with the highest degree of integrity. We   must use the authority, resources and information entrusted to   us only for the company’s legitimate business purposes and not   for personal gain.    Ameriprise Financial Personal   Trading Policies   Ameriprise Financial maintains a number of policies designed to   monitor the personal trading activities of its associates. These   are derived from securities and investment laws, regulatory   guidelines and other corporate policies aimed at eliminating the   appearance of conflict between the personal trading activities of   our associates and our clients, as well as the rest of the investing   public.   Applicability of rules and policies    Our personal trading rules apply to everyone that is subject to   this Code of Conduct with few exceptions. If the Code of   Conduct applies to you as defined on page 5, all of the   Ameriprise Financial Trading Policies likewise apply to you.   These policies will also apply to securities trading in which you   have a beneficial interest, such as accounts held in your name or   the name of any of the following individuals:    Your spouse/partner     Financially dependent members of your household     Other members of your household     Certain entities over which you exercise investment    discretion or control (e.g. Trusts, Powers of Attorney)   In addition to the general rules that apply broadly to individuals   subject to the Code of Conduct, more restrictive rules apply to   certain populations that are deemed as “Access Persons,” based   on their access to information. The Access Person definition and   their applicable policies are described beginning on page 21.      Related Policies:   Advisor Compliance Manual 1.1 –   Personal Trade and Ethics  Global   Code of Ethics Personal Accounts   Dealing Policy                                                    Is my spouse subject to all   of the personal trading   rules and policies contained   in the Code of Conduct?      Yes. Personal trading rules and   policies not only apply to you as a   direct associate, but also accounts   that you hold a “beneficial interest.”   In other words, accounts where you   can influence transactions in the   account based on your relationship   to the owner of the account (i.e. a   spouse or domestic partner). Make   sure you:    Discuss these policies with   impacted parties to ensure   their understanding.    Contact Personal Trade   Compliance if you have   questions about the   applicability of a trading policy   to you or your household.
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 Ameriprise Financial Code of Conduct          23   Q      ?   Ameriprise Financial Approved Broker Policy –   “Limited Choice”    In order to comply with SEC expectations concerning the   monitoring of trading activity within personal accounts,   Ameriprise Financial maintains a “limited choice” policy which   dictates where certain types of securities must be held and   traded.   Unless you have an exception approved by Personal Trade   Compliance, your personal securities accounts must be held and   trading must be conducted through one of three brokers:   Ameriprise Financial Brokerage, Charles Schwab or Merrill   Lynch. Please note: Certain financial advisor groups may be   restricted to Ameriprise Brokerage accounts only.   To gain a better understanding of what types of securities are   subject to the policy, you can review the “Securities Reporting List”   reference sheet. Please contact Personal Trade Compliance to   request a copy.    New associates have 45 days from their state date to comply with   this policy.    Ameriprise Financial Insider Trading Policy    Ameriprise Financial prohibits illegal insider trading. 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 the information could affect the stock price or a reasonable   investor’s investment decisions, it is considered material. If the   information has not been widely disseminated to the public   through major newswire services, national news services or   financial news services, it is considered non-public.    You may only share material, non-public information if:     The individual has a business need-to-know     You are confident that the individual receiving the material,    non-public information won’t share it inappropriately.   Sharing inside information with another person who buys or sells   securities and does not have a business need-to-know is known   as tipping — and is illegal. Your conduct may be illegal even if   you do not benefit personally and the person you shared the   inside information with does not buy or sell any related   securities.   If you engage in insider trading or tipping, you can be   subject    to substantial civil and criminal penalties and disciplinary   action, including termination of your employment or your   franchise agreement.            I work with several local   banks that sell our life   insurance and annuity   products. During a weekly   conference call, the sales manager   at one of the banks told me they   are going to merge with another   bank. I think the merger will make   the bank’s stock go up, but the   bank hasn’t yet made a formal   announcement about the merger.   Is it okay to buy the bank’s stock?      No. The information about    the upcoming merger is non-public,   as the bank has not yet made a   formal announcement. Because   you have knowledge that the   general public does not have,   buying or selling the bank’s stock   would be insider trading.
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 Ameriprise Financial Code of Conduct          25   Q      ?   Personal trading prohibitions   Certain personal trading activities are expressly prohibited:    Speculative trading of company stock: Ameriprise    Financial prohibits speculative trading of its company stock   (NYSE symbol AMP), which is characterized by multiple   transactions in a short period of time, transactions in “put” or   “call” options, short sales or similar derivative transactions.   This includes soliciting speculative trades in Ameriprise   Financial securities or offering or soliciting an opinion on   Ameriprise Financial stock.    Note: Advisors may solicit sale trades of Ameriprise stock   only for account diversification purposes.    Equity IPO purchases: Ameriprise Financial prohibits    purchasing initial public offerings (IPOs) of equity securities,   other than IPOs of closed-end funds. Initial offerings of other   types of securities may be acceptable; contact Personal   Trade Compliance to discuss.    Market timing: Ameriprise Financial prohibits market timing.    Market timing is the rapid or short-term trading, usually of a   mutual fund, at the expense of long-term shareholders.   Market timing activity may adversely impact a mutual fund’s   performance by limiting the ability of the investment manager   to fully invest the mutual fund’s assets or by increasing   transaction costs.    Most mutual funds, including Columbia and RiverSource   mutual funds, have policies against market timing. Consult   the prospectus of a mutual fund to understand its policy on   market timing activity.     Late trading: Ameriprise Financial prohibits late trading. Late    trading is the illegal practice of buying or selling, or allowing an   investor to buy or sell, a fund after a market has closed. Late   trading occurs when a fund, broker or other intermediary   permits an investor to place an order after closing that receives   the market-close price, allowing the investor to take unfair   advantage of information that becomes public after closing.   Unusual Trading Activity   We may ask to review specific transactions with you or your   broker if clarification is necessary. You may also be asked to   supply Personal Trade Compliance with a written or oral   explanation of your personal trade(s). Examples of situations   that may require explanation include, but are not limited to:    Significant changes in trading volume or consistently    excessive trading volume    Patterns of short-term, in and out trading     Significant positions in illiquid securities     A number of associated persons trading in the same security    in the same time frame         Related Policies:   Advisor Compliance Manual 1.1 –   Personal Trade and Ethics  Global   Code of Ethics Personal Accounts   Dealing Policy    > Back to Contents   I currently have an IRA   account at Ameriprise that   contains a position of   company stock. As a means to   protect the stock against possible   price fluctuations, and generate   some additional income within the   qualified account, I want to write   some covered calls on the   company stock. Is this something   that I am able to do?      No. While the practice of writing   “covered calls” is an established   strategy to protect existing shares   against a downturn in the market   and generate extra income for an   account, the prohibition against the   purchase or sale of option   contracts on company stock does   not allow for this activity.
 Ameriprise Financial Code of Conduct          26   Q      ?   Trading blackout periods   As part of our expanding service offering, clients of Ameriprise   Financial can receive proprietary research reports and   recommendations made through the Investment Research   Group.   In order to allow this information to be provided to clients after its   publishing and reduce the risk of “front running” and/or “insider   trading” accusations, Ameriprise Financial imposes a “same-day”   blackout restriction from the time an initial recommendation or   change is made on a security.   Same day trading blackouts are announced on the Inside and   AdvisorCompass sites and begin on the day the research is   issued and continue for the remainder of the trading day.   Violations of these blackouts will result in a compliance reversal   of the trade and possible sanctions.   Preclearance for investments in   private placements/limited offerings   All covered persons need to obtain approval to invest in any   limited offerings (private placements, including private funds),   i.e., a security not offered to the general public. Approvals must   be obtained in writing from your immediate leader and Personal   Trade Compliance before investing.    How to obtain approval:    Write an explanation of the investment and submit the request to   your leader. Required information you must include in your request:    The nature of the investment      How you were solicited      Approximate dollar amount you are planning to invest    Financial advisors should also disclose:    Whether or not the opportunity was being offered to any clients     Whether the security is likely to be purchased by a client in    the future   Your leader will approve or reject your request, and return    the request to you. If approved, email the request to   Private.Placement.Preclearance@ampf.com. You cannot   enter into the proposed transaction without approval from   Personal Trade Compliance.                                          As an advisor with a lot of   clients in my community, I   sometimes am approached   by clients who are involved with   local start-up companies that hold   private offerings as a means to   raise capital for their growth and   expansion. Am I prohibited from   investing in these ventures because   of my status as an advisor?      Not necessarily. It is possible for   advisors to invest in private   placements or limited offerings    that their clients are also invested   in or may be directly involved with.   However, extra caution is advised   to ensure that no conflicts of   interest are present between the   advisor, their client and Ameriprise   Financial.    You must pre-clear these   opportunities with your registered   principal and the Personal Trade   Compliance Department.
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 Ameriprise Financial Code of Conduct          28   Q      ?   Reporting obligations   Initial Account and Holdings Disclosure: All new covered   persons upon joining Ameriprise Financial must disclose all   brokerage accounts in which they have a beneficial interest   through an “Initial Account and Holdings Disclosure.” The   disclosure is facilitated through iTrade, a web-based tool   available on the Inside and AdvisorCompass sites. The   disclosure must be completed within 10 business days of joining   the firm.   Disclosing new accounts: All covered persons must notify the   Personal Trading group at the time the covered person opens a   new brokerage account (contact Personal Trading to obtain a   Brokerage Account Notification form). If a covered person wishes   to personally trade in securities other than registered mutual   funds, the brokerage account must be held with one of the three   approved brokerage firms (Ameriprise, Charles Schwab or   Merrill) as required by the Limited Choice Policy discussed   previously.   Access person policies   Access person definition and populations    The SEC requires investment adviser firms to perform certain   monitoring and reporting functions in relation to individuals that   are deemed as “Access Persons.”   An Access Person is defined as:    An individual with access to nonpublic information regarding    clients’ securities transactions    An individual involved in making securities recommendations    to clients    An individual with access to nonpublic information regarding    the portfolio holdings of affiliated mutual funds   Common populations at Ameriprise Financial that fall under the   Access Person definition include, but are not limited to:    Employee and franchise advisors and all their licensed staff    members (associated financial advisors, paraplanners etc.)    Employees of the Columbia Management organization and    certain support partners    Members of the Investment Research Group and other    individuals in the corporate office who meet the Access   Person definition                                    My spouse just opened a   new account at Charles   Schwab. I know that Schwab   is one of our approved brokers   under the Limited Choice Policy, so   is there anything else I need to do   about the account?      Yes. Even though Charles   Schwab is an approved broker   through the Limited Choice   Policy, you are still required to   report any newly opened   securities accounts to Personal   Trade Compliance.    To do so, contact Personal Trade   Compliance and request a   Brokerage Account Notification   Form (BAN Form). Complete the   form and return it to Personal   Trade Compliance so they can   register the account on their   monitoring systems.
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 Ameriprise Financial Code of Conduct          30      ?   Specific rules for Access Persons    In addition to the policies and rules initially described for covered   persons, Access Persons are subject to specific trading   restrictions and monitoring based on their position with the firm   and required compliance controls established for their business   lines. Access Persons must also complete various certifications   or attestations as required. Listed below are the resources by   group that should be referenced to learn these rules:   Columbia Management: If you are a direct employee of the   Columbia Management organization or are part of a business   group that directly supports Columbia, you are subject to the   rules and policies contained in the Columbia Management   Investment Adviser Code of Ethics. You may refer to the most   recent copy of the Code of Ethics on Inside.   You must also complete an Annual Certification of Accounts and   Holdings and the Quarterly Certification of Transactions.   Investment Research Group (IRG): If you are a member of the   Investment Research Group, you are subject to trading   preclearance rules that are explained in the IRG Personal   Trading Reference Guide. You may refer to the most recent copy   of the guide on Inside.   Members of the IRG must complete the Annual Attestation and   the Quarterly Certification of Transactions.   Employee and franchise advisors and licensed staff: All   Employee Advisors, Franchise Advisors and their licensed staff   members are subject to the rules and policies contained in the   Financial Advisor Personal Trading Reference Guide. You may   refer to the most recent copy of the guide on the AdvisorCompass   site.   You must complete the Annual Attestation and the Quarterly   Certification of Transactions.   Communications for all access groups will be issued prior to the   attestations or certifications so impacted personnel can complete   their reporting obligations on time.         Related Policies:   Advisor Compliance Manual 1.1 –   Personal Trade and Ethics  Global   Code of Ethics Personal Accounts   Dealing Policy                                          > Back to Contents
 Ameriprise Financial Code of Conduct          31      ?   Blackout periods and preclearance of   transactions in Ameriprise Financial   securities   The company’s outside directors, certain executive officers, and   other designated employees are subject to regular quarterly   blackout periods, during which they are prohibited from   executing transactions in Ameriprise Financial securities. Such   blackout periods are not legally required, but are a common   method of reducing the possibility of insider trading during   periods when there is an increased likelihood of material, non-   public information being available.   The blackout periods begin on January 1, April 1, July 1 and   October 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 two full business   days after the public release of earnings results for the   preceding quarter.   Those people who are subject to the blackout period will receive   two emails distributed by the Corporate Secretary’s Office. One   email will alert them to the beginning of the blackout period   approximately one week before it starts. This email provides   additional details about the restrictions on trading in Ameriprise   securities and a copy of the related securities trading policy.   The second email informs these people of the date on which the   blackout will end and when they may resume trading in company   securities. This email is distributed promptly after the public   disclosure of the prior quarter’s earnings has been made.   In special circumstances, the length of the quarterly blackout   period may be extended or a special blackout period may be   imposed on a designated group of employees.   The company’s outside directors and those executive officers   who are subject to Section 16 of the Securities Exchange Act of   1934 are required to pre-clear their transactions in company   securities (and those of their immediate family members sharing   their household) with the Corporate Secretary’s Office. This   requirement is imposed only on this limited group, and they are   reminded of it each quarter.   Please note that violations of the blackout period are taken seriously   and may result in disciplinary actions, up to and including the   termination of employment or a franchise agreement.   Remember these key points:    Even if you are not subject    to either the blackout period   or the pre-clearance   requirement, you are still   subject to the federal   securities laws governing   insider trading, explained   earlier in the Code of   Conduct.    If you receive an email    notifying you of the date on   which the blackout period   will end, that does not   permit you to trade in   company securities if you   are aware of material non-   public information about the   company or its securities.    If you are considering    trading in the company’s   securities and you think that   you might be aware of   material non-public   information about the   company or its securities,   don’t hesitate to call the   corporate secretary for   advice. This is also true for   contemplated trades in the   securities of other   companies. Always err on   the side of caution and seek   legal advice before you   trade.
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 Ameriprise Financial Code of Conduct          33      ?   Portfolio Holdings Disclosure Policy    Ameriprise Financial has implemented controls over the disclosure   of information about securities held in the portfolios managed by its   asset management affiliates. These controls are designed to   safeguard against improper use of portfolio holdings information.    All requests to disclose portfolio holdings information — to advisors,   clients or any entity — must meet certain conditions or be approved   in writing by the Portfolio Holdings Committee prior to release. The   Portfolio Holdings Disclosure Policy identifies the scenarios where   portfolio holdings information may be disclosed without pre-   approval. All other requests to disclose portfolio holdings   information to advisors, clients, prospects or any other individual or   entity must be approved in writing by the Portfolio Holdings   Committee before that information is released. This control is   designed to protect against selective disclosure — meaning, the   release of information that could potentially benefit some investors   over others.    To determine if the required conditions for release of portfolio   holdings information are met, or if prior approval to release portfolio   holdings information is required, please refer to the Portfolio   Holdings Disclosure Policy.      Related policies:   HGlobal Code of Ethics Personal   Accounts Dealing Policy H   HInvestor Relations Policy                                                                                                                     > Back to Contents
 Ameriprise Financial Code of Conduct          34   Q      ?   Confidential information and trade   secrets    During the normal course of work, you may learn or create   information about the company that is sensitive and not known   by the general public, such as business strategies, marketing   plans, client lists or salary data. As an employee, you have a   duty to protect the company’s confidential information and trade   secret information. Not only can intentional misuse or disclosure   of trade secrets result in disciplinary action, it is a crime   punishable by fines and imprisonment. Accordingly, you must not   discuss the company’s confidential information or trade secrets   in places where you can be overheard by others, such as   elevators, hallways, restaurants, airports or buses.    You may not share confidential information and trade   secrets if:    You have signed a project-specific nondisclosure agreement    relating to such information    You have not confirmed with your leader that the person    requesting or otherwise to be provided with the information   has also signed the project-specific nondisclosure   agreement.   You may share the company’s confidential or trade secret   information with other Ameriprise Financial employees, other   companies, vendors or non-Ameriprise Financial personnel only   if:    The information is not subject to a project-specific    nondisclosure agreement    The individual with whom you plan to share the information    is an Ameriprise Financial employee, has an absolute   business need-to-know and the person is aware of the   confidential nature of the information.   If the individual is a contractor or vendor who has an absolute   business need-to-know and the person is aware of the   confidential nature of the information:    You must verify that the person is subject to a confidentiality    agreement – never assume he or she has signed a   confidentiality or nondisclosure agreement.     After you have verified that a confidentiality agreement is in    place, ensure that the person is told that the information is   the company’s proprietary and confidential information.           Related policies:   HAdvisor Compliance Manual 7 -   Privacy  Identity Theft Prevention   Policy  Information Security    Intellectual Property                                        How do I know what   information is considered a   trade secret?      A trade secret is any information   (e.g., formula, methods of doing   business, software, customer and   price lists) that is (i) secret, (ii)   useful in the operation of a   business and (iii) sufficiently   valuable (either in a competitive   context or by virtue of the effort   expended to collect or create it) to   justify protection under the law.   For information regarding use,   storage and distribution of   sensitive information, or to learn   more about properly classifying   information used to complete your   job, refer to Information Security   Policy 2.0 Information   Classification and Safeguarding.
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 Ameriprise Financial Code of Conduct          36      ?   Guard against criminal activity   Ameriprise Financial has an obligation to take reasonable steps   to detect, prevent and report criminal activity such as money   laundering, terrorist financing, fraud and identity theft. Financial   companies involved in criminal activity face serious   consequences, including fines, increased regulatory scrutiny,   criminal charges and damage to their reputation, even if the   involvement in the criminal activity was unintentional.    Anti-money laundering    Money laundering occurs when individuals or groups attempt to   conceal the true origin or ownership of funds generated from   illegal activities. The purpose of money laundering is to distance   the funds from their illegal source by moving them through the   financial system. This process attempts to make the funds look   like they came from legitimate activities.    The USA PATRIOT Act was enacted in 2001 to help combat   money laundering, terrorism and other illegal activities. The act   requires financial institutions to:     Establish an anti-money laundering program     Designate an anti-money laundering officer     Provide ongoing anti-money laundering training     Create procedures and controls designed to detect, prevent    and report money laundering     Conduct independent audits of the procedures and controls    to ensure the effectiveness of the anti-money laundering   program.   If you have reason to suspect money laundering or fraudulent   activity, you must immediately discuss your suspicions with your   leader, business unit compliance liaison (BUCL) or registered   principal, and file a Report of Suspicious Activity (RSA) Form, if   necessary. You can obtain an RSA by sending an email to Anti-   Money Laundering Office with “RSA Request” in the subject line.   You will automatically receive an electronic RSA with instructions   on how to complete and submit the report. You may also contact   the Suspicious Activity Hotline at (612) 671-6166.    Money laundering red flags    Red flags are warning signs that   may make you suspect that a   client, prospect or account may   be involved in money laundering   or fraudulent activity.    Common red flags include (but   are not limited to):     Transactions that are    inconsistent with the client’s   or prospect’s stated goals    Inconsistent personal or    transaction information     Requests to rush a    transaction or make an   exception to standard   procedures     Unusual lack of concern    regarding risks,   commissions or other   transaction costs     Client’s or prospect’s    location is in a country   known as a haven for illegal   or terrorist activity     Problems providing, or    unwillingness to verify,   personal identification   information    Excessive negative account    activity, such as bounced   checks and maintenance   calls   A red flag is not a guarantee of   money laundering or fraudulent   activity, but it does require you to   take additional steps to review   and report the situation.       Related policies:   HAnti-Money Laundering Policy    Columbia Management - Anti-   Money Laundering Policy       Advisor Compliance Manual 15.    Anti-Money Laundering          > Back to Contents
 Ameriprise Financial Code of Conduct          37   Q   Q      ?   Tipping    Tipping has another meaning aside from sharing inside   information with someone who buys or sells securities. In this   situation, tipping is informing someone who is suspected of being   involved in illegal activities that he or she is under suspicion or is   being investigated. Tipping, even unintentionally, is illegal. Under   no circumstance should you inform someone that he or she is   under investigation for, or suspected of, money laundering.    Willful blindness    You are obligated to watch for red flags that may signal money   laundering and then to report any suspicious activity. “Willful   blindness” occurs when you have knowledge or sufficient evidence   to suspect money laundering activity or other illegal activities, but   choose not to report the information. If you ignore red flags or other   warning signs, or if you choose to not report suspected activity, both   you and the company could be considered willfully blind and be held   liable for the criminal activity.   Office of Foreign Assets Control (OFAC)    The Office of Foreign Assets Control (OFAC), a division of the U.S.   Department of the Treasury, administers and enforces economic and   trade sanctions based on foreign policy and national security goals.    You must not do business with a country, group or individual on   OFAC’s Specially Designated Nationals and Blocked Persons   List.    If you have questions related to OFAC, please contact the Anti-   Money Laundering Office.                                                                                     The Anti-Money   Laundering Office called me   to ask about    a client’s recent transactions and   where the money may have came   for some recent purchases. She’s a   great client and a good friend, and   I know she would never do   anything illegal. I feel like I should   let her know what’s happening.   May I do that?      No. Under no circumstances should   you let your client know that she   may be under investigation for   money laundering or other types of   criminal activity. Informing the client   is illegal, and both you and the   company could be penalized.          When I met with a   prospective client, she was   evasive about her financial   situation and where her money   came from even after I explained   that the information was required   by law. My best friend who   referred the prospective client to   me says he has known her for years   and that she has nothing to hide —   she is just being private. Can I rely   on my friend’s judgment?      No. Before doing business with a   prospective client, you are   obligated to determine the source   of funds. You cannot rely on   anyone else’s opinion as to the   legitimacy of the source of funds.   If a prospective or existing client   refuses to provide information   based on your inquiries, you must   complete a Report of Suspicious   Activity Form available by sending   an email to the Anti-Money   Laundering Office.
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 Ameriprise Financial Code of Conduct          39      ?   Fraud prevention    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 organization, and it can be done by people   inside as well as outside of the company.    Fraud adversely affects clients, shareholders, advisors and   employees of the company. Fraud prevention is the responsibility   of everyone at all levels. You have a duty to be mindful of   potential fraudulent activity and to immediately report any   suspicious activity.    Identity theft and identity fraud   Identity theft and identity fraud refer to an individual illegally   obtaining the personal information of another person and using   the information for criminal acts and/or economic gain.    The company is committed to safeguarding personal client   information. It is the responsibility of all officers, employees and   advisors, at all levels, to help protect our clients from becoming   victims of identity theft.    The Fair and Accurate Credit Transaction Act is intended to help   prevent identity theft. The act requires financial institutions to:    Establish an identity theft prevention program     Designate an identity theft prevention officer     Create procedures and controls designed to detect, prevent    and mitigate identity theft    Provide identity theft prevention training    Identity theft red flags   Red flags are warning signs that   may help you identify possible   identity theft.    Common red flags include (but   are not limited to):    Documents provided for    identification appear to have   been altered    Personal identifying    information provided is   inconsistent with client   information on file    Mail sent to a client is    returned repeatedly as   undeliverable although   transactions continue to be   conducted    Unauthorized transactions    are made in a client’s   account     A change of address    request is followed by a   request to add authorized   users on the account   A red flag is not a guarantee of   identity theft, but it does require   you to take additional steps to   review and report the situation.       Related policies:   H HTAnti-Money Laundering Policy    Columbia Management - Anti-   Money Laundering Policy       Advisor Compliance Manual 15.    Anti-Money Laundering   Identity   Theft Prevention Policy  H T andling   Whistleblower Claims PolicyTH TH                                                      > Back to Contents
 Ameriprise Financial Code of Conduct          40   Q      ?   You can help identify fraud by:    Verifying the identity of the person asking for information      Abiding by rules for releasing information to third parties,    such as other financial institutions, family members and   vendors    Following the policies for securing, concealing, recycling and    shredding documents that contain sensitive client   information and records    Knowing what information you can and cannot include in    emails, voicemails and faxes   If you suspect that personal information of a client, employee or   advisor has been compromised, report the breach to Hthe Privacy   Swat Team.    Signature issues and forgery    At Ameriprise Financial, a signature is considered forged if it was   signed by someone other than the person named, or that person’s   legally authorized representative. This applies to both unauthorized   and fraudulent forgeries as well as when a client authorizes you to   sign forms (forgery of convenience).    Whenever a client signature is required, it must be an original   signature of the client or his or her legally authorized   representative, such as an attorney-in-fact. If signatures are   required from more than one person, each person’s signature   must be his or her own.    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.      Related policies:   HAnti-Money Laundering Policy    Columbia Management - Anti-   Money Laundering Policy       Advisor Compliance Manual 15.    Anti-Money Laundering   Identity   Theft Prevention Policy  Handling   Whistleblower Claims Policy                                                                        > Back to Contents   One of my clients is elderly   and unable to leave his   house very often. He insists   that I keep a couple of pre-signed   forms in my desk because having   to travel to my office each time he   needs to set up an account is   difficult. With pre-signed forms, he   can just call me and tell me what he   wants to do. Since I’m doing him a   favor, is this okay?      No. Keeping pre-signed forms in   your office for a client is against   company policy, even if the client   asks you to do this as a personal   favor. This policy is to protect the   client, you and the company.   Keeping pre-signed forms is a   serious violation, and may result   in termination of employment or   termination of the franchise   agreement. One option for the   client would be for him to have an   attorney-in-fact who is authorized   to sign documents for him.
 Ameriprise Financial Code of Conduct          41   Q   Q      ?   Safeguard the privacy, confidentiality and security    of information and records    You are responsible for understanding and complying with all   policies protecting the privacy, confidentiality and security of   client, employee, advisor and company information. Only those   employees with a business need to know are allowed access to   such data. If you have questions about what to disclose, contact   your leader or other appropriate resource before taking action.   Secure client information and   records   Ameriprise Financial is obligated to safeguard client information and   use it only for business purposes. We do this by following our Client   Privacy Principles, which govern how we collect, use, safeguard and   disclose client information and by following the laws, regulations   and company policies related to privacy. Unaffiliated companies   selected as Ameriprise Financial business partners agree to keep   our client information confidential and secure.   All clients receive a copy of the Ameriprise Financial Privacy   Notice annually. All new clients receive the Ameriprise Financial   Privacy Notice at the start of the business relationship. The   company’s Internet Privacy Statement explains how Ameriprise   Financial collects, uses, safeguards and discloses the   information consumers provide on the Ameriprise Financial   website.   Regardless of your role, you may only use or disclose   confidential client information for one or more of the following   reasons:     It is necessary to transact business and provide service     to clients.     It has been authorized by the client.      It is required to provide financial products and services that    are jointly offered with other financial institutions.     It is part of the company’s compliance efforts to reduce fraud    and criminal activity.     It is necessary to fulfill our legal or regulatory obligations.     Different rules may apply for   certain business units, including   those dealing with institutional   clients. Understand and follow   your business unit’s applicable   policies.                                     > Back to Contents   A client sent a package by   courier with a completed   product application and a   check for the initial purchase. When   I received the package it looked like   it had been opened. Everything   appeared to be there, so I don’t   think anything was stolen. 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. You   should send an email to the Privacy   Swat Team to let them know what   happened. They will research the   incident, identify the nature and   magnitude of the risk, and work with   the vendor to investigate the cause.         Is it okay to send company   information or client   information to my personal   email account in order to work   from home?      No. The Electronic Communication   Acceptable Use Policy states that   company email should only be used   for company-related business.   Sending any company files or   sensitive information to personal   email accounts is prohibited.
 Ameriprise Financial Code of Conduct          42   Q      ?   Report potential privacy incidents    A privacy incident is the loss of control or unauthorized   disclosure of confidential, sensitive information. Examples   of privacy incidents include:     Lost or stolen computers or files containing client information    (including breaches inside and outside of the company)    Errors that result in client information being given to    unauthorized people (e.g., misdirected communications or   mailing errors)    A client’s unauthorized access to other clients’ information.    Privacy incidents create the potential for identity theft and other   related crimes. If an incident occurs or is suspected to have   occurred, you have an obligation to report the breach promptly.   To learn more about reducing your risk of identity theft, request a   copy of the brochure “Reduce your risk of Identity Theft” by   contacting the Privacy Office.   To report a privacy incident, send an email to the Privacy Swat   TeamH. If physical equipment, including laptops, PDAs or cellular   telephones, is lost or stolen, or if there has been a physical theft   of client or company data, you must contact the Minneapolis   Security Console at 1 (800) 455-5187 or (612) 671-2454.         Related policies:   HClient Privacy Principles    Information Security Policy  Public   Communications Policy  Public   Communications Procedures    Record and Information   Management Policy  Advisor   Compliance Manual 7. Privacy    Advisor Compliance Manual 16.   Books & Records & Other   Documentation                                                                                                   > Back to Contents    I know I should encrypt   attachments that contain   sensitive information before   I email them outside of the   company network, but I don’t   know how.      The Electronic Communication   Acceptable Use Policy states that   you must use an encrypted   attachment to send client   information and records via email   outside the corporate network.   Please see instructions “HT ow to   encrypt a file using WinZipTH.”
 Ameriprise Financial Code of Conduct          43      ?   Protect the company’s reputation and assets   Ameriprise Financial has an obligation to our employees, clients,   advisors and shareholders to protect the reputation and assets of   the company. We must ensure that appropriate safeguards are   in place to protect the company’s physical and intellectual   property, sensitive information and reputation in the marketplace.    The company’s reputation is a valuable asset that affects   whether or not someone will be our client; or whether we are   proud to work for Ameriprise Financial. Be alert to situations or   actions that may be unethical or potentially damaging to the   company’s reputation. Report suspected violations of the Code   of Conduct, company policies, regulations and laws promptly to   your leader or use one of the other reporting methods explained   on HTPage 7 TH.   Protection and proper use of   company physical assets and property    Company property must be used only for valid business   purposes and with proper authorization.    Company property must be protected against theft or misuse.   This includes protection of laptop computers, personal digital   assistants and mobile phones. Ensure that all computer   equipment is properly secured and not left unattended. To   properly secure your laptop always use a cable lock. When away   from the computer, press Ctrl-Alt-Delete and lock the computer   (to avoid unauthorized access/use) and ensure that your laptop   has whole disk encryption (WDE).   Protection and proper use of    intellectual property    Intellectual property is one of the most valuable assets of a   company and includes copyrights, patents, trademarks, trade   secrets, logos and design rights.    Our logos and the names “Ameriprise Financial” and   “RiverSource” are examples of company trademarks. You must   use them properly to protect the company’s brands and goodwill,   as our trademarks are key to building and maintaining our   reputation with the public, clients and regulatory authorities.   Furthermore, you may not register or attempt to register a   trademark, service market or domain name that either   incorporates, in whole or in part, or is confusingly similar to any   current or proposed, registered or unregistered, trademark or   service mark owned by the Company or its affiliates or   subsidiaries for any reason.   The theft or misuse of    company property will result    in disciplinary action. If you   suspect someone was   involved in or is attempting to   cover up the theft or misuse of   company property,   immediately report your   suspicion to Corporate   Security by calling the   Minneapolis Security Console    at 1 (800) 455-5187 or    (612) 671-2454.
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 Ameriprise Financial Code of Conduct          45   Q      ?   Publications, documentation, training materials, computer codes,   software, methods, systems and other work that you create for   the company are examples of items that can be protected by   copyrights. To the extent permitted by law, your work and   inventions, whether or not patented or protected by copyright,   trade secret or trademark, are considered company property.    We will never knowingly infringe on the intellectual property   rights of others. You are responsible for ensuring that the use of   any third-party intellectual property such as computer programs,   competitors’ brands and logos and periodicals is proper and   done with the owner’s permission. For example, you may not   copy a computer program at work for use at home or make   copies of news articles for broad distribution.   If you have a creation you think may be eligible for a patent, or if   you are unsure about the proper use of a trademark, copyright,   patent or other intellectual property, you should contact the   General Counsel’s Organization. If you become aware of people   misusing the company’s trademarks, promptly notify the General   Counsel’s Organization.   Electronic Communication   Acceptable    Use Policy    The Electronic Communication Acceptable Use Policy governs the   appropriate use of the Ameriprise Financial electronic   communication resources by employees, advisors, contractors   and third parties. Electronic communication resources include   any device or system that facilitates the processing, storage or   transfer of electronic information. This includes, but is not limited   to, desktop and portable computer systems (e.g., laptops, PDAs   and cell phones), voicemail and electronic mail (email), internet   access and fax machines. You are required to employ   reasonable precautions to safeguard Ameriprise Financial   sensitive information from unauthorized disclosure.   When using these network devices:     Use strong passwords and keep them confidential.     Do not send unencrypted sensitive information outside the    corporate network.    Limit personal use of the internet to non-working hours only    as authorized by your leader.    Use corporate email for company-related business only             Related policies:   HConducting Competitive Intelligence   Activities  Electronic   Communication Acceptable Use   Policy  Intellectual Property Policy     Advisor Compliance Manual 7.   Privacy  Social Media Policy                     I wrote a computer   program for my team that   we use for monthly status   reporting on our projects. I’ve   shown it to friends in other parts of   the company, and now they want to   use it for their projects, too. Do you   think this might be something the   company could patent?      Yes. Whether or not the company   would pursue a patent depends on   a number of factors.  However, this   is    not your concern. If you have   something that you believe might be   new, useful and non-obvious (you   haven’t seen anything like it in the   marketplace) submit your idea to the   Ameriprise Patent Program for   review. Simply fill out the HTPatent   Invention DisclosureTH Form found on   Inside and email it to Intellectual   Property Legal Mail.         ?
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 Ameriprise Financial Code of Conduct          47   Q      ?   Political involvement    Ameriprise Financial encourages you to be involved in the   political process and respects your right to participate as you see   fit, provided that you comply with federal and state election laws.   Since federal law and many state laws prohibit corporations   from making political contributions, you cannot:     Use company funds to make a political contribution     Be reimbursed by the company for a political contribution     Allow a candidate or campaign to use company facilities or    property    Use work time, company equipment, personnel or other    assets, including phones, computers, faxes, mailroom or   photocopiers, for political or campaign purposes    Use or allow the use of company stationery, letterhead or    anything that would give the impression of a political   endorsement   Any contribution of time or money that you choose to make   cannot be made or appear to be made with, or reimbursed by,   company funds.    Please see more information about political   contributions and the Ameriprise Financial   Political Contributions Policy on page 35.                                                                                                                     How do I know whether    I need to preclear my   political contributions and   volunteer political activities?      If you are an advisor, you are   subject to preclearance.    Otherwise, you need to read the   applicable related policy to see if   you are covered.  Depending   upon changes in your job or Band   level, you may become subject to   preclearance in the future even if   you are not covered now.  Also,   it's important to see if your current   political contributions may affect   your chances to apply for certain   jobs in the future.
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 Ameriprise Financial Code of Conduct          49   Q   Q      ?   Preclearance of state and local   political contributions and volunteer   activities    The United States Securities and Exchange Commission and   various state and local government entities have enacted what   are commonly called “pay to play” rules. “Pay to play” is the   phrase used to describe political contributions or other payments   made to state and local officials or third parties for the purpose of   obtaining investment advisory or management business from   governmental entities. Under the federal rules, certain   contributions and payments to state and local officials, including   those running for federal office, may result in the loss of   compensation for our investment adviser subsidiaries for a   period of up to two years. State and local pay to play rules differ   significantly from the federal rules with respect to the people   covered, the amount of contributions permitted, and the effect of   a prohibited contribution.   In order to avoid a violation of the federal, state, and local pay to   play rules, we have adopted the Ameriprise Financial Political   Contributions Policy. The policy covers all advisors and   certain other people designated in the policy. Among   other things, the policy requires the people covered by it to   preclear all of their political volunteer activities and contributions   and payments to state and local officials, including those running   for federal office. The preclearance requirement applies   regardless of the amount of the contribution. Please read the   Political Contributions Compliance Policy carefully to see if you   are covered and, if so, what you must do to comply with it.   Even if you are not covered by the policy currently, you should   read it carefully if you plan to transfer to one of our investment   adviser subsidiaries or apply for a promotion that causes you to   be covered by the policy. Under certain circumstances, your   political contributions to state and local officials may deny you a   job or promotion or significantly delay your career plans.                     Related policies:   HAmeriprise Financial Political   Contributions (“Pay to Play”) Policy     Columbia Management Policy -   Gifts and Benefits  Global Code of   Ethics Personal Accounts Dealing   Policy   Columbia Management  -   Political Contribution Policy     Congressional Gift Rule Guidelines   for employees  Advisor   Compliance Manual  Vendor   Endorsement Policy                              Don’t these preclearance   requirements violate my   First Amendment rights of   free association and speech?      The federal agencies that have   adopted pay to play rules have   concluded that they do not violate   the First Amendment rights of   those persons they affect.  Such   rules have been upheld in federal   court.  We have no choice but to   enforce reasonable policies and   procedures designed to avoid any   violations of federal, state, or local   pay to play rules.         I don’t intend to influence   improperly the judgment of   any state or local officials to   whom I contribute. Why should I   have to preclear those contributions   if I am covered by the policy?      Your intent in making a   contribution doesn’t matter for   preclearance purposes.  Even if   you are making a contribution to   your brother who is running for a   school board seat, you would still   have to preclear the contribution.
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 Ameriprise Financial Code of Conduct          51   Q      ?   Maintain complete and accurate business records   Ameriprise Financial has a responsibility to maintain complete   and accurate business records. This means that certain   information about the company’s business, earnings and   financial condition must be documented and reported in an   accurate, complete and understandable manner. We must   comply with laws and regulations regarding how information is   reported and disseminated. We must also ensure that certain   information is retained in accordance with the time schedule and   format outlined by regulatory authorities.    Financial data   Each time you report financial information, provide   documentation for expenses, or approve payment of invoices,   the information must be truthful, accurate and complete. If you   are involved in the preparation of the company’s financial   statements, you must follow generally accepted accounting   principles (GAAP) and all other applicable accounting standards   and rules, so that our statements fairly and completely reflect our   operations and financial condition.   Contact your leader, registered principal, the Employee   Relations Group Service Center at 1 (877) 267-4748, or   Ethics Hotline at 1 (800) 963-6395 if you:    Believe financial information and business records are not    being reported or maintained accurately and completely    Feel pressure to report inaccurate or incomplete financial    information    Are asked to prepare or destroy documents in violation of    company policy    Learn that misleading, incomplete or false information was    given to an accountant, auditor, regulatory authority or   government agency      Related policies:   HTInformation Security Policy    HAdvisor Compliance Manual 16.   Books & Records & Other   Documentation   Record and   Information Management Policy                                       My manager started   working for the company   last week. Earlier, he had a   similar position with a competitor.   We have set monthly goals in my   department, and our year-end   ratings are based on meeting these   monthly goals. My manager asked   me to report my monthly results in   a new way, telling me that this is   how his previous employer did it.   However, I believe that reporting   my results this new way would be   misleading. What should I do?      You should tell your manager that   you believe his new method of   reporting results would be   misleading, and that you are not   comfortable following his directions.   If your leader insists that you    report results his way, you should   talk to his leader or the Employee   Relations Group Service Center at    1 (877) 267-4748.
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 Ameriprise Financial Code of Conduct          53   Q      ?   Travel and expense accounts   You may only request payment or seek reimbursement from the   company for actual and reasonable business expenses. When   possible, you should use your corporate card to pay for business   expenses. Corporate cards may not be used for personal   expenses, and you should not use a personal card to pay for   business expenses. Political contributions are not business   expenses and the company will not pay for or reimburse you for   such contributions. Leaders are responsible for ensuring   employees comply with the Travel & Expense (“T&E”)   Reimbursement Policy.   Documentation of payments   If you request payment or seek reimbursement for an expense,   you must provide the appropriate documentation, obtain the   correct approvals and follow the Travel & Expense (“T&E”)   Reimbursement Policy.   Document retention and destruction   Company documents must be kept in accordance with the   company’s Records and Information Management Policy and   Procedures. You may not shred, destroy or alter in any way   documents that are related to any imminent or ongoing   investigation, lawsuit, audit, examination or are required to be   maintained for regulatory purposes. If you have questions about   whether you can shred or destroy a particular document, check   with your leader or the General Counsel’s Organization.   Cooperation with regulatory   organizations   All inquiries and requests for documents and information from   regulatory organizations must be responded to in a thorough,   accurate, prompt, consistent, honest and professional manner   that protects the company’s interests and maintains our   credibility with regulators. You may not attempt to influence   regulators or respond to their requests with inaccurate,   incomplete or deliberately misleading information. Regulatory   requests, reports of examination and all related information must   be treated as confidential company information and may only be   shared with others on a strict need-to-know basis. If you fail to   meet these standards, you will be subject to disciplinary action,   including termination of your employment.            Related policy:   Consolidated Regulator   Communications Policy  Advisor   Compliance Manual 16. Books &   Records & Other Documentation     Records and Information   Management Policy   Records   and Information Management   Manual   Travel and Expense   PolicyTH                              My leader asked me to delay   sending an invoice to   Accounts Payable until the   next quarter. What should I do?      All goods purchased or services   rendered should be expensed,   capitalized or accounted for in the   period incurred. If you believe that   your invoice should be sent   promptly, speak with someone at   your supporting accounting   function or your business unit’s   controller. You can also contact the   Employee Relations Group Service   Center at 1 (877) 267-4748.
 Ameriprise Financial Code of Conduct          54      > Back to Contents
 Ameriprise Financial Code of Conduct          55   Q      ?   Treat people with dignity and respect   Ameriprise Financial is committed to treating people with dignity   and respect. We strive to provide a work environment that is   diverse and free from any form of harassment or discrimination.   We will not tolerate violence, threats of violence, stalking,   intimidation of others or attempts to instill fear in others.   Treatment of employees and others   Leaders at Ameriprise Financial have a responsibility to   demonstrate how employees and others are treated with dignity   and respect.   Importance of diversity   We are committed to valuing and supporting diversity in the   workplace and community. Employees, field members and staff   represent many age groups, ethnicities, family structures, races,   religions, sexual orientations, nationalities and mental and   physical abilities. This diversity enriches our thoughts, creativity,   innovation and ability to positively impact those around us.   Freedom from discrimination   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 is prohibited.   Leaders are responsible for creating and maintaining a work   environment free of discrimination and harassment.   Leaders must enforce and follow anti-discrimination and   anti-harassment laws that include, but are not limited to:    State and local laws prohibiting sexual harassment and    discrimination    The Age Discrimination in Employment Act (ADEA)     Title VII of the Civil Rights Act of 1964     The Americans with Disabilities Act (ADA)       Related policies:   TEqual Employment Opportunity   Policy  Handling Whistleblower   Claims Policy  TIndividual   Treatment Policy                                                > Back to Contents   What should I do if I believe   I have been discriminated   against or harassed during   the course of my employment?      If you believe you have been   unlawfully discriminated against or   harassed, you should report this   to your leader or the Employee   Relations Group Service Center at   1 (877) 267-4748.
 Ameriprise Financial Code of Conduct          56      ?      Freedom from fear and violence in the workplace   You may not possess weapons in the workplace or while   conducting company business. You may not assist or permit   others to possess weapons in the workplace   Non-retaliation   Retaliation or intimidation directed toward anyone who makes a   complaint, assists in making a complaint or is a witness in an   investigation is prohibited. The law and our values protect   anyone, who in good faith, reports discrimination, harassment or   threats of violence.   Equal employment opportunity   Employees, financial advisors and leaders are responsible for   complying with the company’s Equal Employment Opportunity   Policy and related policies, and anti-discrimination and anti-   harassment laws. Leaders have the added responsibility for   ensuring compliance with those policies and laws.   Safety, health and the environment   Ameriprise Financial is committed to ensuring that all reasonable   efforts are made to provide and maintain a safe and healthy   working environment for our employees and visitors.   Leaders are responsible for the health, safety and welfare of   their departments, and everyone reporting or assigned to them   including visitors and contractors, regardless of their work   location.      If you see anyone   exhibiting threatening   behavior, notify local security   personnel immediately.   If there is no security staff at   your worksite, contact   Corporate Security at 1 (800)   455-5187 or the Employee   Relations Group Service   Center at 1 (877) 267-4748.   Field members and staff    should contact local security    or law enforcement   authorities immediately if   there is a potentially   dangerous situation at their   workplace.                                                                                    > Back to Contents
 Ameriprise Financial Code of Conduct          57      ?   Glossary    Antitrust laws   Antitrust laws apply to virtually all industries   and to every level of business, including   financial services. They prohibit a variety of   practices that restrain trade.   Examples of illegal practices are price-fixing   conspiracies, corporate mergers likely to   reduce the competitive vigor of particular   markets, and predatory acts designed to   achieve or maintain monopoly power.   Client information and records   Client information and records includes any   personal or financial information relating to a   client or client group. A list that identifies   individuals as current or former clients also falls   within the definition. Client information and   records are categorized as asset classification   Level 3 or 4.   Conflicts of interest   A conflict of interest is a situation in which   someone in a position of trust (such as a   lawyer, a politician, financial advisor or an   executive or director of a corporation) has   competing professional and/or personal   interests. Such competing interests can make it   difficult to fulfill his or her duties fairly. Even if   there is no evidence of improper actions, a   conflict of interest can create an appearance of   impropriety that can undermine confidence in   the ability of that person to act properly.   Forgery   Forgery is an illegal modification or   reproduction of an instrument, document,   signature or legal tender, or any other means of   recording information. This includes copying,   tracing or affixing another person’s signature.   At Ameriprise Financial, a signature is   considered forged if it was signed by someone   other than the person named, or that person’s   legally authorized representative. This applies   to both unauthorized or fraudulent forgeries as   well as when a client authorizes you to sign his   or her name on forms (forgery of convenience).   Identity theft   Identity theft is the deliberate assumption of   another person’s identity, usually to gain   access to their finances. Identity theft is   committed many different ways. Some identity   thieves sift through trash bins looking for bank   account and credit card statements; other more   high-tech methods involve accessing corporate   databases to steal lists of customer information.   Once they have the information they are   looking for, identity thieves can ruin a person’s   credit rating and the standing of other personal   information. Many types of identity theft can be   prevented. One way is to continually check the   accuracy of personal documents and promptly   deal with any discrepancies.   Insider trading   Insider trading is the practice of buying or   selling securities based on inside information.   Prohibitions against this practice include tipping   related to stock, options, debt securities or any   other securities of the company or any of its   subsidiaries, as well as to transfers into or out   of the company stock fund under a savings and   retirement plan. It even applies to securities of   other companies if you learn something in the   course of your duties that might affect their   value. Violations can subject individuals to   significant fines and even imprisonment.                           > Back to Contents
 Ameriprise Financial Code of Conduct          58      ?   Intellectual property   Intellectual property (IP) is any creative idea or   other expression of the mind that may have   commercial value. Intellectual property rights   are the only property right mentioned in the   United States Constitution. The most well-   known forms of intellectual property rights   include copyrights, patents, trademarks and   trade secrets.    A copyright may exist in creative and artistic    works (such as software, books, movies,   music, paintings and photographs)    A patent may be granted in relation to a new    and useful invention (such as business   methods or computer programs)    A trademark is anything used to identify and    distinguish one’s goods and services (such   as words, graphics, taglines, colors, sounds   and smells)    A trade secret is any information used in the    operation of a business that is secret and   from which the owner derives competitive   value/advantage by virtue of the fact that it is   the only party with the information (e.g., the   recipe for Coke®, customer lists and price   lists)   Late trading   Late trading of mutual fund shares occurs when   investors placing trades after market close   receive the market close price. These late   traders can use the information revealed after   market close to guide their trades, buying funds   when their current value is greater than their   closing value and selling the funds when the   reverse is true. Doing so allows them to earn   returns at the expense of the fund’s long-term   shareholders.   Market timing   Market timing, also known as NAV or stale   price arbitrage, is the rapid, short-term trading   of an asset with the goal of exploiting price   discrepancies across markets.   In terms of mutual funds, market timing is bad   for long-term investors because rapid traders   increase the associated costs of the mutual   fund, which are passed onto the long-term fund   holders. Every time an investor buys or sells   units of a mutual fund, the fund company must   buy and sell the equal portion of the actual   securities within the fund. With each   transaction, there is a service charge (i.e.,   commission). These service charges eat into   the returns of the people who are holding the   fund for the long term.   Material, non-public information   Material, non-public information is information   about a company that is not known to the   general public and that could influence a typical   investor’s decision to buy, sell or hold that   company’s securities.   Examples include:    Financial or operational performance    estimates or results    Major management or business plan    changes    News of an impending regulatory or legal    action    Negotiations to purchase or partner with    another company    Development of a major new product or    service    An increase or decrease in dividends     A stock split or other recapitalization     A redemption or purchase by the company    of its securities   Money laundering   Money laundering is the process by which   individuals attempt to conceal or disguise the   true origin or ownership of proceeds from illegal   activities.   Money laundering occurs in three stages:     Placement: the initial point of entry for funds    derived from criminal activities    Layering: distancing the proceeds from the    source by transactional activities    Integration: the re-entry of the laundered    proceeds into the economy in such a way   that the funds appear to be legitimate   Mutual fund   Mutual funds are open-ended investment   companies and are generally registered with   the SEC under the Investment Company Act of   1940. The funds are composed of a collection   of stocks, bonds or other securities owned by a   large group of investors with similar objectives   and managed by a professional fund manager.      > Back to Contents
 Ameriprise Financial Code of Conduct          59      ?   Net asset value (NAV)   NAV is the dollar value of a single mutual fund   share, based on the value of the underlying   assets of the fund minus its liabilities, divided   by the number of shares outstanding. It is   calculated at the end of each business day.   Office of Foreign Assets Control (OFAC)   The Office of Foreign Assets Control (OFAC) is   a division of the United States Department of   the Treasury. OFAC administers and enforces   economic and trade sanctions based on foreign   policy and national security goals. U.S.   individuals and companies are prohibited from   doing business with any foreign countries,   terrorists, narcotics traffickers and other   individuals and groups that are on a list issued   by OFAC.   The penalties for doing business with an   individual or country on the OFAC list are very   serious, including civil and criminal fines and   imprisonment.   Pay to Play   Pay to play is the shorthand phrase used to   describe political contributions or other   payments made to state or local officials or   third parties for the purpose of obtaining   investment advisory or management business   from governmental entities.  If you are required   to preclear your political contributions or   volunteer activities, however, your intent is   irrelevant for preclearance purposes.   Privacy incident   A privacy incident is the loss of control or   unauthorized disclosure of confidential,   sensitive information such as stolen laptops or   mailing errors.   Redemption   A transaction through which the owner of a   security returns an investor’s principal in a   security.   Securities   A security is a type of transferable interest   representing financial value such as stocks,   bonds, notes and mutual funds.   Sensitive information   Sensitive information includes client information   and records; employees’ and advisors’   personal and financial information; or   confidential, proprietary business information   that if improperly disclosed could negatively   impact our clients, our reputation, our company,   or our brand. Sensitive information is classified   as asset classification Level 3 or 4.   Tipping (insider trading)    Tipping in the context of insider trading is the   sharing of inside information with another   person who buys or sells securities and does   not have a business need-to-know. You could   be held liable even if you do not benefit   personally and the person you shared the   inside information with does not buy or sell any   related securities.    Tipping (money laundering)    Tipping in the context of money laundering is   informing someone who is known or suspected   of being involved in money laundering or other   illegal activities that their conduct is considered   suspicious or is being reported to law   enforcement authorities.    Whistleblower    A whistleblower is an individual who reports   misconduct to people or entities that have the   power to take corrective action. Examples   include providing information related to:    Mail, wire, bank or securities fraud     Improprieties that prevent the company from    meeting its legal obligations or from   complying with generally accepted   accounting principles    Violations of the company Code of Conduct    Willful blindness   Willful blindness is the failure to perform due   diligence, or when suspicions are aroused,   failing to make further inquiries or report the   information.   Any employee, financial advisor or contractor   who has knowledge of or reason to suspect   illegal activity and processes a transaction   without reporting or notifying the proper   individuals may be charged with money   laundering. This is known as willful blindness   and may result in civil and criminal penalties   and imprisonment.                                    > Back to Contents
 Ameriprise Financial Code of Conduct          60      ?   Resource guide - contacts   If you have a question not addressed in the Code of Conduct, contact the following Ameriprise   Financial employees who are familiar with specific subjects discussed in the Code of Conduct, or reach   out to one of the Columbia Management contacts listed in this link - Key Columbia Management   Compliance Contacts. If you a general question about the Code of Conduct, contact Thomas R.   Moore, corporate secretary and chief governance officer, at (612) 678-0106 or   thomas.r.moore@ampf.com.    Subjects Addressed in the Code of   Conduct Contact – Telephone Number and Email   Advertising and marketing Surabhi Ahmad (617) 897-9621 surabhi.x.ahmad@ampf.com   Anti-money laundering James Fiebelkorn (612) 671-5059 james.fiebelkorn@ampf.com   Antitrust and fair competition   Ameriprise – Mike Burton (612) 671-1285 HTmichael.g.burton@ampf.comT   RiverSource – David Weiser (612) 671-1788 HTdavid.h.weiser@ampf.com TH    Blackouts on trading in company   securities   Thomas Moore (612) 678-0106  HTthomas.r.moore@ampf.comT   Business records Penny Zuber (612) 678-2720  HTpenny.a.zuber@ampf.com T   Company physical assets and property Rod Prior (612) 671-8802  HTrod.a.prior@ampf.comT   Confidential information and trade   secrets   Mike Newman (612) 678-0298  HTmichael.j.newman@ampf.com T   Disclosure requirements to clients   Ameriprise – Mike Burton (612) 671-1285 HTmichael.g.burton@ampf.comTH    Columbia – Scott Plummer (612) 671-1947 HTscott.r.plummer@ampf.com TH    Document retention and destruction Penny Zuber (612) 678-2720  HTpenny.a.zuber@ampf.com T   Electronic Communication Acceptable    Use Policy   Steven Jensen (612) 671-5421 steven.g.jensen@ampf.com    Karen Wilson (612) 671-3602 HTkaren.e.wilson@ampf.com T   Employment issues   Employee Relations Group  1 (877) 267-4748 HTERGSC@ampf.comT   Mark Matuga (612) 671-2254 HTmark.r.matuga@ampf.comT   Forgery and signature issues James Fiebelkorn (612) 671-5059 james.fiebelkorn@ampf.com   Fraud prevention James Fiebelkorn (612) 671-5059 james.fiebelkorn@ampf.com   Gifts and entertainment   Ameriprise  – Thomas Moore (612) 678-0106  HTthomas.r.moore@ampf.comT   RiverSource – Scott Creutzmann (612) 671-3678 HTscott.e.creutzmann@ampf.comTH    Identity theft James Fiebelkorn (612) 671-5059 james.fiebelkorn@ampf.com   Information security Steven Jensen (612) 671-5421 steven.g.jensen@ampf.com   Insider trading Thomas Moore  (612) 678-0106  HTthomas.r.moore@ampf.comT   Intellectual property Mike Newman (612) 678-0298  HTmichael.j.newman@ampf.com T   Late trading Thomas Moore (612) 678-0106  HTthomas.r.moore@ampf.comT   Market timing Thomas Moore (612) 678-0106  HTthomas.r.moore@ampf.comT   Office of Foreign Assets Control James Fiebelkorn (612) 671-5059 james.fiebelkorn@ampf.com   Outside business activities Thomas Moore (612) 678-0106  HTthomas.r.moore@ampf.comT   Political activities and contributions,   including AmeriprisePAC Thomas Moore (612) 678-0106  HTthomas.r.moore@ampf.comT   Privacy of information   Kate Dedenbach (248) 205-5817    kathleen.a.dedenbach@ampf.com   Regulatory organizations and inquiries Chris Long (612) 671-6362  HTchris.r.long@ampf.comT   Regulatory examinations Chris Long (612) 671-6362 chris.r.long@ampf.com   Reporting potential Code of Conduct   violations Your leader or the Ethics Hotline  1 (800) 963-6395   Reporting potential criminal activity Rod Prior (612) 671-8802  HTrod.a.prior@ampf.comT   Reporting potential information security   events (i.e., hacking, viruses) or misuse   of company computer systems and   network   Steven Jensen (612) 671-5421 steven.g.jensen@ampf.com   Reporting potential privacy incidents Privacy Swat Team  HTprivacy.swat.team@ampf.com T   Retaliation, protection from   Employee Relations Group  1 (877) 267-4748 HTERGSC@ampf.comT   John Junek (612) 671-3651  HTjohn.junek@ampf.comT   Doug Parish (612) 671-0947  HTdouglas.j.parish@ampf.comT   Safety, health and the environment Rod Prior (612) 671-8802  HTrod.a.prior@ampf.comT   Security of electronic information Steven Jensen (612) 671-5421 steven.g.jensen@ampf.com   Violence in the workplace Rod Prior (612) 671-8802  HTrod.a.prior@ampf.comT
 Ameriprise Financial Code of Conduct          61   Whistleblower program   John Junek (612) 671-3651  HTjohn.junek@ampf.comT   Doug Parish (612) 671-0947  HTdouglas.j.parish@ampf.comTH
 Ameriprise Financial Code of Conduct          62      ?   Frequently asked questions   To find the answer to these frequently asked questions, click on the question to be directed to the   appropriate section in the Code of Conduct. If you do not find an answer to your question, please contact   one of the employees listed in the HTResource Guide TH on Page 44.   • HTCan I personalize my advertisements    to clientsTH?   • Are all advisors subject to the Code of   Conduct?   • HTAm I subject to blackout periods for trading TH in   Ameriprise Financial securites?   • HTCan I use company letterhead for my non-   profit workTH?   • HTIf a client asks me about a competitor TH, can    I say that the other firm’s products and   services are inferior to ours?   • How can I tell if a situation involves a   potential conflict of interest?   • Am I allowed to do consulting work on my   personal time and get paid for it?   • My client doesn’t want to be bothered with   disclosures. Can I accommodate the client   and just skip the disclosures?   • How do I know if it is all right to shred or   otherwise dispose of documents or files?   • HTCan I delay submitting an expense? T   • HTWhich gift policy applies to me TH?   • HTDo I need to seek approval before accepting   or giving a gift?T   • Can I get in trouble if I tell a friend or family   member information about Ameriprise   Financial?   • How can I tell if an investment is suitable   for a client?   • What restrictions are there on my   investments other than Ameriprise   Financial?   • What is insider trading?   • I wrote a marketing brochure to be sent to   clients that is based on previously-used   marketing material. Do I still need to have it   reviewed?   • HT ow do I know if I have material, non-public   information? T   • HTDo I need to get pre-approval to start an   outside business?T   • Can I be involved in a political campaign   during my normal workings hours?   • HTCan I give money to a political candidate   using company funds? T   • How freely should I cooperate with   regulators?   • Can I work a second job?   • HTShould I ask a client about suspicious   transactions? T   • HTIf I suspect a violation, am I obligated to   report it? T   • Can a friend of mine be a vendor for   Ameriprise Financial?   • HTWhat is a “whistleblower”TH?                                                   > Back to Contents
 Ameriprise Financial Code of Conduct          63   Ameriprise Financial, Inc.   Supplement Number 1 to the Code of Conduct   (March 2011)    Ameriprise Financial, Inc. (“Ameriprise Financial”) is committed to conducting business   ethically by acting in the best interests of our clients and adhering to our values and principles.    The Code of Conduct requires every individual associated with Ameriprise Financial (including   financial advisors and their employees) to do the right thing and operate in accordance with five   principles:   • Conduct business ethically;   • Do the right thing for the client;   • Treat people with dignity and respect;    • Excel in all we do; and   • Serve as ambassadors/stewards for our brand.   This supplement to the Code of Conduct provides additional guidance regarding certain conduct   that violates the principle of treating people with dignity and respect.  This is a supplement to,   and not a replacement of, the Code of Conduct.  Everyone associated with Ameriprise Financial   is expected to read, understand and comply with the guidance provided in this supplement in   addition to the Code of Conduct and other applicable policies and procedures of Ameriprise   Financial.  If you have any questions about the application of this supplement or the   appropriateness of a situation, action or decision, talk to your leader, registered principal or other   appropriate personnel identified in the Code of Conduct.  For additional information or questions   about this supplement, please contact the resources listed below:   Corporate Secretary’s Office   thomas.r.moore@ampf.com, (612) 678-0106   Employee Relations Group Service Center   ERGSC@ampf.com, (877) 267-4748   Ethics Hotline   (800) 963-6395 (If you use this resource, your information will be treated anonymously if   you so wish.)   Treating People with Dignity and Respect   Ameriprise Financial is committed to treating every person, including clients, service providers   or vendors, franchisees (and their employees), advisors, employees, management, and directors,   with dignity and respect.  Ameriprise Financial is committed to maintaining a safe, secure and   hospitable work environment and will not tolerate violence, threats of violence, stalking,   intimidation, attempts to instill fear in others, slander, libel, or defamatory statements.  In   addition, we ask that you voice your opinions and views in a respectful manner.  No person   associated with or representing Ameriprise Financial is permitted to engage, or to condone or   support others engaged, in conduct that violates this principle.  This is a non-exclusive list of the   types of conduct that is prohibited and is provided for purposes of illustration:   • The use of any form of communication, whether written, oral or electronic, to advocate   political, religious, or social ideologies or viewpoints to senior home office or field
 Ameriprise Financial Code of Conduct          64   leadership in a manner which could reasonably be interpreted as insulting, disrespectful   or derogatory.  If you wish to voice disagreement with a company policy, please   communicate with your human resources contact or direct field leadership.  If you are   dissatisfied with the resolution at that level, you may escalate the issue to the home   office, provided that the escalation is conducted in a manner consistent with your   obligations under this Supplement and the Code of Conduct.   • The use of any form of communication, whether written, oral or electronic, to threaten,   intimidate, harass, insult, or instill fear in any other person.   • Displays, acts or gestures that could reasonably be anticipated to intimidate another or   cause another to be concerned for his or her safety and well-being or the safety and well-   being of others.   •  Acts or conduct that could reasonably be anticipated to result in harm or damage,   whether physical, emotional, reputational or financial, to another person.   Ameriprise Financial management, in its sole discretion, will determine whether this supplement   has been violated.     Non Retaliation   No individual who, in good faith, makes a complaint under this supplement shall be subject to   retaliation.  Any concerns regarding retaliation may be made to any of the resources identified in   this supplement or in the Code of Conduct    Consequences for Non-Compliance   If you fail to comply with this supplement, Ameriprise Financial may, in its discretion, impose   consequences on you including disciplinary action up to and including termination of your   employment, franchise, contract or other relationship with Ameriprise Financial.  Furthermore,   violation of  this supplement is a violation of the Ameriprise Financial Code of Conduct and may   result in any of the consequences identified in the section entitled "Consequences for Non-   Compliance" in the Code of Conduct.
 Financial Planning | Retirement | Investments | Insurance | Banking      Ameriprise Financial, Inc.   1098 Ameriprise Financial Center, Minneapolis, MN 55474   ameriprise.com      The Code of Conduct and the related policies do not attempt to address every possible situation or   circumstance that may arise. Officers, employees, advisors and others 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 they are uncertain as to the proper course of action. The company will not accept   ignorance or oversight as excuses for behavior that violates the Code of Conduct, related policies or any law or   regulation.   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. 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 in   determining eligibility and in interpretation and administration 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.      Revised December 2014   For internal/vendor/agency use only. Not for distribution to the general public.    © 2014 Ameriprise Financial, Inc. All rights reserved.