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CONTENTS INTRODUCTION REPORT Y OUR CONCERNS ETHICAL PRINCIPLES NAV IGATE Y OUR ETHICAL QUESTIONS CONSEQUENCES FOR NON-COMPLIANCE RESOURCESObey the law and guard against criminal activityWe comply with all laws and regulations that apply to our operations, including insidertrading laws.Why ethics matterLegal or regulatory violations can cost ourshareholders millions of dollars in legaljudgments, fines or penalties and lostclients. In some cases, you could also facefines, the loss of your job and evenimprisonment. The company often sets ahigher standard than what the law requires,so it is important to understand all policiesthat apply to you.We expect you to:Become familiar with the laws andregulations that apply to you and yourjob, including insider trading laws, whichapply to everyoneComplete all mandatory training,disclosures and other requirementsrelated to your jobStay current on legal and regulatorydevelopments you need to knowReport suspected insider trading, marketabuse or fraudulent activity promptlyProtect our reputationWhat you need to knowWe obey the law in our professional lives justas we do in our personal lives. Beingunaware that a law or regulation exists won’texcuse any violation you commit.We follow the advice of our legal andcompliance professionals.We always cooperate fully and honestly withour regulatory agencies during examinationsand inquiries.Comply with rules, regulations and lawsAdditional rules or regulations may apply to youin your home country or because of yourspecific job responsibilities. Each of us isresponsible to know and follow the lawswherever we work.Fraud preventionPreventing fraud is a responsibility of everyoneat Ameriprise, regardless of level. You have aduty to be mindful of potentially fraudulentactivity and to report anything suspiciouspromptly. Fraud includes a wide variety ofillegal acts, all characterized by the intent todeceive someone. Fraud can be committed tothe detriment of the company, our clients, ourshareholders or others, and can be carried outby people inside as well as outside of thecompany.Insider tradingInsider trading is both illegal and unethical.Insider trading is the practice of buying orselling securities of any company, includingAmeriprise Financial, when you are aware ofmaterial, non-public information about thatcompany or its securities. If you are convictedof insider trading, you could be sentenced toyears in prison.Personal tradingOur personal trading rules, policies andprocedures apply to everyone who is subject tothis Code with few exceptions. These rules arederived from securities and investment laws,regulatory guidelines and other corporate policies.They aim to eliminate the appearance of conflictbetween the personal trading activities of ourassociates and our clients as well as the rest ofthe investing public.In addition to the general rules that applybroadly to individuals subject to the Code,more restrictive rules apply to certain personsbased on their access to information and/ortheir job responsibilities. You are responsiblefor understanding the related company policiesthat apply to you. 7

CONTENTS INTRODUCTION REPORT Y OUR CONCERNS ETHICAL PRINCIPLES NAV IGATE Y OUR ETHICAL QUESTIONS CONSEQUENCES FOR NON-COMPLIANCE RESOURCESI told my spouse about a company thatAmeriprise Financial is consideringbuying. Was that wrong?Yes. First, you should not shareconfidential business information withanyone unless it’s necessary to do yourjob. Second, if this is material, nonpublic information and your spousetrades in the stock of Ameriprise or theother company or shares the informationwith anyone else, you both could faceprosecution for insider trading.Am I subject to blackout periods fortrading in the company’s stock?It depends on your role within thecompany. The company’s Board ofDirectors, certain executive officers andother designated employees are subjectto regular quarterly blackout periods,during which they are prohibited fromexecuting transactions in AmeripriseFinancial securities. The blackoutperiods generally begin on Jan. 1, April1, July 1 and Oct. 1. The beginning dateof each blackout period is fixed,regardless of whether that date happensto be a business day. Each blackoutperiod ends one full business day afterthe public release of the last quarter’searnings results. If you are subject tothe blackout, you will receive emailstelling you when it will begin and end. 8

CONTENTS INTRODUCTION REPORT Y OUR CONCERNS ETHICAL PRINCIPLES NAV IGATE Y OUR ETHICAL QUESTIONS CONSEQUENCES FOR NON-COMPLIANCE RESOURCESDo the right thing for the clientFrom initial contact with prospects, through our continued service of existing individualor institutional client and end-client accounts, we stand behind what we say and do.Why ethics matterWe maintain our clients’ loyalty and improvetheir experience by acting with integrity. Ourfirst priority is the success of our clients.They have selected us to help them reachtheir financial goals and prepare forretirement on their terms. If we break thattrust, our clients will leave us for other firms.We expect you to:Act in the best interest of clientsBe truthful and accurateNever mislead a client or prospectHelp clients and prospects understandour products and servicesProvide clients and prospects with allinformation they need to make aninformed decisionWhat you need to knowWe carefully consider the impact of ourdecisions on clients.We provide exceptional client service.We are committed to making full and fairdisclosures.Standards of ConductWe conduct our business according to allapplicable legal and professional standards ofconduct. These standards of conduct may varydepending on our role or relationship with a clientand may impose specific obligations on us, suchas: acting as a fiduciary in the best interests ofthe client; not favoring the interests of one clientover the interests of another client; or makingrecommendations that are suitable based on aclient’s personal situation and risk tolerance.Regardless of our legal and professionalobligations, we act honestly and in good faithwith our clients. We want clients to be able tomake informed decisions based on all theinformation necessary to understand the featuresand potential benefits and risks of our productsand services.Full and fair disclosureYou must make full and fair disclosure of allfeatures, benefits, risks and fees of products orservices sold or marketed to all clients andprospects, particularly where your interests mayconflict with those of our clients. Full and fairdisclosure applies to initial client communicationsas well as to subsequent recommendations.Your disclosures must be accurate, fair andbalanced and presented in the proper context.Do not omit material facts or qualifications ifthe result would be misleading.Marketing, advertising and communicationswith the publicMarketing, advertising and communicationswith the public, including clients, prospects,investors, analysts and the general public,must be truthful and accurate. You may notmake exaggerated or misleading statements,regardless of whether the information is givendirectly or indirectly. You must answer allquestions honestly and completely.In addition, the content must meet applicableregulatory and legal standards. When preparingadvertising, marketing and communication for thepublic, you must ensure that required reviews andapprovals are received prior to first use. 9

CONTENTS INTRODUCTION REPORT Y OUR CONCERNS ETHICAL PRINCIPLES NAV IGATE Y OUR ETHICAL QUESTIONS CONSEQUENCES FOR NON-COMPLIANCE RESOURCESMy job doesn’t involve client contact.Recently, however, someone claiming to be aclient was transferred to my number. Shewas upset about something, but I politelysaid I couldn’t help her and hung up. Wasthat wrong?Yes. In this situation, you should ask for theperson’s name, address, telephone numberand a brief description of the issue. Aftertelling her you will find the right person tohelp her, talk to your leader about how tofollow up. You should never try to answer aquestion if you are not qualified to do so, buteach of us has a responsibility to do the rightthing for our clients.We know that trust must beearned and are committedto making fair andaccurate disclosures. 10

CONTENTS INTRODUCTION REPORT Y OUR CONCERNS ETHICAL PRINCIPLES NAV IGATE Y OUR ETHICAL QUESTIONS CONSEQUENCES FOR NON-COMPLIANCE RESOURCESConduct business ethicallyWe have a duty to promote the interests of the company. That means we do not use thecompany’s property or information for our own benefit or to compete with the company.Why ethics matterEmployees, officers and directors owe a dutyto the company to advance its legitimateinterests. Your personal interests, whetheryou are focused on a promotion or earningmore compensation, are never more importantthan the best interests of our clients or thecompany.We expect you to:Address conflicts of interest before you takeany job action or engage in an outsidebusiness activity that may benefit you oryour family – this applies to everyone,regardless of whether you are a registeredpersonAvoid even the appearance of improprietyComply with company policies related tooutside business activities, politicalcontributions and gifts and entertainmentAdvisors, registered persons andinvestment-access persons must file reportsas required by applicable policies.All persons subject to the Code andlocated in the U.S. must seek guidancefrom the Corporate Secretary aboutpotential conflicts of interest, whetherinvolving gifts, vendor relationships,outside business activities, or othercircumstances.What you need to knowWe do not use company information andproperty for personal gain.We carefully monitor and control conflictsof interest.We do not give, solicit or accept gifts thatcould influence our business judgment.Conflicts of interestYou may engage in an outside activity if it doesnot compete or conflict with the interests of thecompany or interfere with the responsibilities ofyour job or the company’s employees. A conflictof interest occurs when your private interestsinterfere in any way – or even appear tointerfere – with the interests of a client or thecompany. A conflict of interest also ariseswhen you or a member of your family receivesimproper personal benefits as a result of yourposition in the company.You must be especially sensitive to potentialconflicts of interest when you are consideringengaging in consulting or other outsideactivities that involve the skills and knowledgeyou use in your job. Simply reporting ordisclosing an activity without first resolvingpossible conflicts of interest may result in aviolation of the Code.You are prohibited from using your position withthe company, or information acquired duringyour employment or relationship with thecompany, to advance your personal interestsover the interests of clients or the company.Gifts or entertainmentGenerally, you may only accept gifts (includingbusiness-related meals or entertainment) if thevalue of the gift is not significant and the giftwill not place you – or appear to place you –under any obligation to the donor. Beforeaccepting a gift, you should ask yourself if thegift would appear significant to others or placeyou under any obligation. If the answer is yes,then you should not accept the gift.You may be subject to a specific policy relatedto accepting or giving gifts over a certain dollarvalue. (Please refer to policies that apply to you.)Political contributions and involvementWe respect your right to participate in thepolitical process. However, because of U.S.campaign finance laws, you may not: usecompany funds or be reimbursed for a politicalcontribution; allow a candidate or campaign touse company facilities or property; use worktime or company equipment for political orcampaign purposes; or allow your contributionof time or money to appear to be made with, orreimbursed by, company funds. 11

CONTENTS INTRODUCTION REPORT Y OUR CONCERNS ETHICAL PRINCIPLES NAV IGATE Y OUR ETHICAL QUESTIONS CONSEQUENCES FOR NON-COMPLIANCE RESOURCESA client sent me a case of wine as a gift.I know that if I purchased the wine,it would be expensive. Can I acceptthis gift?If you are subject to a gift andentertainment policy, you may be requiredto decline the gift politely and return it. Ifyou are a licensed person, you shouldseek advice from your registered principalor the Compliance Department. If youdon’t know whether a gift policy applies toyou, contact the Corporate Secretary oryour local Compliance Department.Remember that you are never permitted tosolicit a gift from a client, vendor oranyone else doing business with thecompany.Do I need to pre-clear my politicalcontributions and political volunteeractivities?If you are a financial advisor, you aresubject to pre-clearance requirements.Otherwise, you need to refer to thePolitical Contributions policy to see if youare covered. Depending upon changes inyour job or band level, you may becomesubject to pre-clearance in the future evenif you are not covered now. Also, it'simportant to see if your current politicalcontributions may affect your chances toapply for certain jobs in the future, due tothe SEC’s pay-to-play rules. 12

CONTENTS INTRODUCTION REPORT Y OUR CONCERNS ETHICAL PRINCIPLES NAV IGATE Y OUR ETHICAL QUESTIONS CONSEQUENCES FOR NON-COMPLIANCE RESOURCESCompete fairly in the marketplaceWe believe that everyone benefits from fair, free and open markets, and we competefairly in the marketplace based on the merits of our products and services.What you need to knowWhy ethics matterWe operate in a highly regulated industry andunder intense media and public scrutiny.Regulators and prosecutors recognize theimportance of a strong ethical andcompliance culture.We expect you to:Deal fairly with clients, vendors,competitors and other employeesMaintain the company’s confidentialor proprietary information andtrade secretsWe must never offer, make or acceptunlawful payments or gifts regardless of localbusiness customs.We comply with all antitrust, anti-bribery, anticorruption, monopoly and competition laws.Failure to comply can have seriousconsequences for the company and for you.Antitrust and competition lawWe prohibit agreements intended to limitcompetition. We expect you to avoid anyagreement with a competitor to limitcompetition.When dealing with outside companies,including contractors and vendors, considerwhether they are competing with AmeripriseFinancial.The General Counsel’s Organization isavailable whenever you question the legalityof a proposed activity or need furtherguidance.False or misleading statements about ourcompetitors are contrary to our values anddamage our reputation.competitors. We don’t take unfair advantage ofanyone through manipulation, concealment,abuse of privileged information, misrepresentationof material facts or any unfair practices.Non-retaliationAn individual shall not be held criminally or civillyliable under any Federal or State trade secret lawfor the disclosure of a trade secret that is made:in confidence to a Federal, State, or localgovernment official or to an attorney solely forthe purpose of reporting or investigating asuspected violation of law; orin a complaint or other document filed in alawsuit or other proceeding, if such filing is madeunder seal.An individual who files a lawsuit for retaliation by anemployer for reporting a suspected violation of lawmay disclose the trade secret to the attorney of theindividual and use the trade secret information inthe court proceeding, if the individual files anydocument containing the trade secret under seal;and does not disclose the trade secret, exceptpursuant to court order.Fair dealingAll employees, officers and directors should dealfairly with our clients, investors, suppliers and 13

CONTENTS INTRODUCTION REPORT Y OUR CONCERNS ETHICAL PRINCIPLES NAV IGATE Y OUR ETHICAL QUESTIONS CONSEQUENCES FOR NON-COMPLIANCE RESOURCESI noticed that a contractor made amistake in its invoice in our favor. Whatshould I do?Call the contractor to discuss the invoiceand confirm that we have beenundercharged. If so, ask for a correctedinvoice.I’m having a business lunch with an officialof a foreign government at an inexpensiverestaurant. I know that he is an avid golfer,so I plan to give him a box of golf balls as asmall gesture of appreciation for meetingwith me. What do I need to know?This legal area is complex, so seek advicefrom the General Counsel’s Organizationbefore you give anything of value to agovernment official or anyone claiming torepresent a government or a governmentcontrolled entity. The United States ForeignCorrupt Practices Act and the UK BriberyAct impose severe penalties if you giveanything of value to a government official.Many other countries are also enactingstrict laws against bribery and corruption. Inthis case, even a modest meal and smallgift can result in severe penalties for youand the company. 14

CONTENTS INTRODUCTION REPORT Y OUR CONCERNS ETHICAL PRINCIPLES NAV IGATE Y OUR ETHICAL QUESTIONS CONSEQUENCES FOR NON-COMPLIANCE RESOURCESProtect the company’s reputation and assetsWe diligently safeguard the company’s reputation, its physical and intellectual propertyand all sensitive information.What you need to knowWhy ethics matterOur ability to attract and retain clients,advisors and employees depends on ourreputation as an ethical, honest and lawabiding company. Anything that you do,whether at work or in your personal life, thatdamages our reputation is a serious matter.Be especially careful not to post or sayanything on social media that couldembarrass you or damage the reputation andbrands we have worked so hard to establish.Remember that your obligation to complywith the Code doesn’t stop when you leavethe office.We expect you to:Be alert to situations or actions that maybe unethical or potentially damaging tothe company’s reputationWatch for warning signs that may signalfraudulent activity and report anysuspicious activityUse company property only for validbusiness purposes and with properauthorizationProtect all company and client propertyand assets against theft or misuseWe consider our reputation one of our mostvaluable assets.We protect our assets and use them forappropriate business purposes.Anti-money laundering and identity theftThe company maintains policies andprocedures to prevent and detect moneylaundering and identity theft. Suspiciousactivity takes many forms and is hard to definein absolute terms, however, common examplesof “red flags” are included in the company’srelated policies. If you ignore or choose not toreport suspicious activity, both you and thecompany could be considered willfully blind andheld liable for the criminal activity.Report concerns by submitting a Report ofUnusual Activity, which can be found on Insideor the AdvisorCompass site.Company propertyOur company property, including equipment,supplies, systems and facilities, must only beused for valid business purposes. Theft,carelessness and waste have a direct impact onour profitability. If you suspect someone wasinvolved in, or is attempting to cover up, the theftor misuse of company property, immediatelyreport it to your local security personnel or toSecurityAMPF@ampf.com.Intellectual propertyIntellectual property is one of the most valuableassets of our company. Our logos and branding(e.g., trademarks, service marks) stand as aunique symbol of the quality, integrity andreliability that underlie all our products andservices. Moreover, they serve to identify us tothe world and set us apart from ourcompetitors.The use of all logos and brand names, such as“Ameriprise Financial,” “RiverSource,”“Columbia Threadneedle Investments,”“Columbia Management” and “Threadneedle”must conform with company policy.We will also never knowingly infringe on theintellectual property rights of others. You areresponsible for confirming that the use of anythird-party intellectual property is approved anddone with written permission. This includes,but is not limited to, computer programs,brands, logos and periodicals. 15

CONTENTS INTRODUCTION REPORT Y OUR CONCERNS ETHICAL PRINCIPLES NAV IGATE Y OUR ETHICAL QUESTIONS CONSEQUENCES FOR NON-COMPLIANCE RESOURCESI hear leaders refer to enterpriserisk management. What does itmean to me in my role?Like all financial ser

Ameriprise Financial has a proud, more The success of Ameriprise depends on the trust and confidence we earn every day. Our actions matter. advisors, employees and shareholders. than 125 year history as a successful, client-focused financial services firm. No company can thrive for over a century and grow as we have without a deep