Exhibit 14(c) Global Code of Conduct OUR VALUES Client-focused Integrity always Excellence Respect

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES From our Chairman and Chief Executive Officer Our clients, advisors, employees, shareholders and regulators rightfully expect us to obey the law and to treat them with integrity. Ameriprise Financial has a proud, more than Our Board of Directors, Executive 125 year history as a successful, client- Leadership Team and I hold ourselves to the The success of focused financial services firm. No company same high standards of conduct that we Ameriprise depends on can thrive for over a century and grow as expect you to honor. For those who lead the trust and confidence we have without a deep commitment to others, it’s your duty to set the right ethical behavior and doing what is right for example for behavior. And it’s up to each of we earn every day. our clients, advisors, employees and us to ensure we treat colleagues and others Our actions matter. shareholders. Our Global Code of Conduct with dignity and respect. emphasizes the core ethical principles that Our vision is to be the most respected and guide our behavior at all times. referred financial services brand. We can The Global Code of Conduct also identifies only achieve our vision if each of us does potential areas of ethical risk. Please read it business the right way. carefully. If you see misconduct, report it to Thank you for your commitment to the your leader. Ask your leader for help when principles in the Code and the continued you are unsure of the right thing to do. We success of our company. will not take action against an individual who reports what he or she believes in good faith to be misconduct. Even if it turns out that no misconduct occurred, you will be protected as long as you acted in good faith. JAMES M. CRACCHIOLO CHAIRMAN AND CHIEF EXECUTIVE OFFICER  2 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Contents • Introduction − Our Code applies to everyone ......... 4 • Report your concerns ............................ 6 • Our ethical principles − Obey the law and guard against criminal activity ................................ 7 − Do the right thing for the client ....... 9 − Conduct business ethically ............. 11 − Compete fairly in the marketplace 13 − Protect the company’s reputation and assets ...................................... 15 − Safeguard and maintain accurate information ..................... 17 − Treat everyone with dignity and respect .................................... 19 • Navigate your ethical questions .......... 21 • Consequences for non-compliance ..... 22 • Resources ............................................. 23  3 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Our Global Code of Conduct applies to everyone at Ameriprise Financial All officers, employees, financial advisors and their staff must follow this Code. Why ethics matter What you need to know You must read and comply with the policies and procedures that apply to you. (See Page 23 for a The culture of any company is determined by We value ethics and integrity. partial list of company policies.) what its directors, officers and employees actually do rather than what they are supposed We maintain an environment where compliance This Code can’t cover every situation to do. It is simply about doing the right thing, day and adherence to the Code of Conduct is the No code of conduct or ethics can anticipate all of in and day out. norm. the circumstances that you may encounter during About the Code your career. If the Code doesn’t address a specific We expect you to: This Code is enterprise-wide and applies to situation, you are still obligated to act in an ethical Comply with the Code everyone working for one of our business areas or and honest manner. Above all, seek guidance from affiliates. Commitment to the ethical principles your leader, manager or one of the provided Act with integrity, due skill, care and helps ensure compliance with resources (See list of resources on Page 6) before diligence the Code. you act. Follow all applicable laws, rules and This Code applies even if you also adhere to Violations of the Code regulations another code of ethics or conduct within your If you violate the Code, you will be subject to Be open and cooperative with our business area. disciplinary action, including possible termination regulators For U.S. employees and employee advisors, of your employment or franchise agreement. Use your best judgment compliance with the Code is a condition of Disciplinary action will depend on the employment. For franchise advisors and their staff, circumstances and will be consistent with the Ask for guidance before you act compliance with the Code is required by the company’s policies and procedures. (See Report ethical concerns promptly franchise agreement. consequences for non-compliance on Page 22.) Be an example of ethical behavior for your Applicable company policies Waivers of the Code team The Code requires you to comply with the Only the Board of Directors of Ameriprise Pay due regard to the interests of our clients provisions of other policies, codes of ethics and Financial, Inc. can grant a waiver of the Code of and treat them fairly other business procedures to which you are Conduct. We will promptly disclose to our Observe proper standards of market subject. shareholders any waivers granted to our executive conduct officers and directors.  4 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES I’m a contractor working on a three- month project. Since I’m not an employee, does the Code apply to me? Yes. Anyone doing business on behalf of Ameriprise Financial, RiverSource, Columbia Threadneedle Investments or any of our other subsidiaries is held accountable for reading, understanding and following the Code and all company policies applicable to his or her roles and responsibilities. When we refer to “Ameriprise” or our “company,” we mean all majority-owned businesses and entities of Ameriprise Financial, Inc. I discovered that my coworker is violating the Code by falsifying financial results. Do I have to report this? Yes. You will have violated the Code if you don’t report your concerns. As long as you act in good faith, you will be protected from retaliation. This important point is covered in more detail in the next section.  5 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Report your concerns If you observe behavior that concerns you, or that you believe in good faith may be illegal or a violation of the Code, you are required to report the issue promptly. Why ethics matter What you need to know the same situation with access to the same facts would also conclude there is a likelihood Your diligence allows us to correct problems that We respond appropriately to all allegations by of misconduct. may involve a violation of law or pose a risk to employees, suppliers, clients or contractors that health, safety or the company’s reputation. the company is not meeting its legal, ethical or Non-retaliation financial obligations. We will not tolerate any retaliation against you if We expect you to report concerns We provide several reporting options for anyone you report possible misconduct in good faith even promptly to your leader, manager or one who suspects breaches of the Code, our policies if it turns out that no misconduct occurred. You of the following resources: or the law. won’t be fired, given a lower performance rating or demoted because you reported possible Employee Relations Group Whistleblower claims misconduct in good faith. Retaliating against a Service Center – ERGSC@ampf.com Acting ethically includes reporting misconduct. If person who has reported a suspected violation is Ethics Hotline – 1.800.963.6395 you don’t report the misconduct of others, you are considered a violation of the Code. not acting ethically and will be held accountable. It Safe Call (EMEA) – +44 0800 915 1571 All reports are investigated, and your report will may not be easy to report misconduct involving a be treated confidentially to the extent allowed FCA Whistleblowing (UK) – colleague or friend, but that is what we expect you by law and company policy. whistle@fca.gov.uk to do. If you believe you have been retaliated against, Public Concern at Work (UK) – You should, in good faith, report an alleged promptly contact any of the resources listed on helpline@pcaw.co.uk impropriety that prevents the company from this page. Commission de Surveillance du Secteur meeting its legal obligations or complying with Leaders are responsible for properly reporting Financier – whistleblowing@cssf.lu generally accepted accounting principles. any allegations they become aware of. A whistleblower is an individual who lawfully Corporate Secretary’s Office – Thomas.R.Moore@ampf.com makes any allegation of impropriety or discloses or provides information or assistance in General Counsel’s Organization – connection with any governmental proceeding Karen.Wilson.Thissen@ampf.com or inquiry. Executive Vice President, Acting in good faith means that you have a Human Resources – sincere belief that a reasonable person in Kelli.A.Hunter@ampf.com  6 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Obey the law and guard against criminal activity We comply with all laws and regulations that apply to our operations, including insider trading laws. Insider trading Why ethics matter What you need to know Insider trading is both illegal and unethical. Insider Legal or regulatory violations can cost our We obey the law in our professional lives just as trading is the practice of buying or selling securities shareholders millions of dollars in legal we do in our personal lives. Being unaware that of any company, including Ameriprise Financial, judgments, fines or penalties. In some cases, you a law or regulation exists won’t excuse any when you are aware of material, non-public could also face fines, the loss of your job and violation you commit. information about that company or its securities. If even imprisonment. The company often sets a We follow the advice of our legal and you are convicted of insider trading, you could be higher standard than what the law requires, so it compliance professionals. sentenced to years in prison. is important to understand all policies that apply to you. We always cooperate fully and honestly with our Personal trading regulatory agencies during examinations and inquiries. Our personal trading rules, policies and procedures We expect you to: apply to everyone who is subject to this Code with Comply with rules, regulations and laws Become familiar with the laws and few exceptions. These rules are derived from regulations that apply to you and your job, Additional rules or regulations may apply to you in securities and investment laws, regulatory guidelines including insider trading laws, which apply your home country or because of your specific job and other corporate policies. They aim to eliminate to everyone responsibilities. Each of us is responsible to know the appearance of conflict between the personal and follow the laws wherever we work. trading activities of our associates and our clients as Complete all mandatory training, disclosures well as the rest of the investing public. and other requirements related to your job Fraud prevention In addition to the general rules that apply broadly Stay current on legal and regulatory Preventing fraud is a responsibility of everyone at to individuals subject to the Code, more restrictive developments you need to know Ameriprise, regardless of level. You have a duty to rules apply to certain persons based on their be mindful of potentially fraudulent activity and to Report suspected insider trading, market access to information and/or their job report anything suspicious promptly. Fraud abuse or fraudulent activity promptly responsibilities. You are responsible for includes a wide variety of illegal acts, all understanding the related company policies that Protect our reputation characterized by the intent to deceive someone. apply to you. Fraud can be committed to the detriment of the company, our clients, our shareholders or others, and can be carried out by people inside as well as outside of the company.  7 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES I told my spouse about a company that Ameriprise Financial is considering buying. Was that wrong? Yes. First, you should not share confidential business information with anyone unless it’s necessary to do your job. Second, if this is material, non-public information and your spouse trades in the stock of Ameriprise or the other company or shares the information with anyone else, you both could face prosecution for insider trading. Am I subject to blackout periods for trading in the company’s stock? It depends on your role within the company. The company’s Board of Directors, certain executive officers and other designated employees are subject to regular quarterly blackout periods, during which they are prohibited from executing transactions in Ameriprise Financial securities. The blackout periods generally begin on Jan. 1, April 1, July 1 and Oct. 1. The beginning date of each blackout period is fixed, regardless of whether that date happens to be a business day. Each blackout period ends one full business day after the public release of the last quarter’s earnings results. If you are subject to the blackout, you will receive emails telling you when it will begin and end.  8 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Do the right thing for the client From initial contact with prospects, through our continued service of existing individual or institutional client and end-client accounts, we stand behind what we say and do. What you need to know In addition, the content must meet applicable Why ethics matter regulatory and legal standards. When preparing We carefully consider the impact of our advertising, marketing and communication for the We maintain our clients’ loyalty and improve decisions on clients. their experience by acting with integrity. Our public, you must ensure that required reviews and first priority is the success of our clients. They We provide exceptional client service. approvals are received prior to first use. have selected us to help them reach their We are committed to making full and fair Suitability financial goals and prepare for retirement on disclosures. their terms. If we break that trust, our clients will Advice and products recommended must be leave us for other firms. Full and fair disclosure suitable for each client. Always take the time to ensure that investment advice and products or You must make full and fair disclosure of all features, services recommended are appropriate given a We expect you to: benefits, risks and fees of products or services sold or client’s age, financial situation, investment marketed to all clients and prospects, particularly Be truthful and accurate planning objectives and risk tolerance. Also, take where your interests may conflict with those of our time to provide clients with the information Never mislead a client or prospect clients. Full and fair disclosure applies to initial client necessary for them to understand fully the communications as well as to subsequent Help clients and prospects understand our features, potential benefits and risks of the recommendations. products and services recommended product or service. When dealing with elderly clients, pay special attention to their Provide clients and prospects with all Your disclosures must be accurate, fair and expected financial needs and tolerance for risk. information they need to make an balanced and presented in the proper context. Do not omit material facts or qualifications if the informed decision Our suitability requirements apply not only to result would be misleading. initial buy, sell and hold recommendations, but Marketing, advertising and communications with also to subsequent recommendations in existing the public accounts. Marketing, advertising and communications with the public, including clients, prospects, investors, analysts and the general public, must be truthful and accurate. You may not make exaggerated or misleading statements, regardless of whether the information is given directly or indirectly. You must answer all questions honestly and completely.  9 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES My job doesn’t involve client contact. Recently, however, someone claiming to be a client was transferred to my number. She was upset about something, but I politely said I couldn’t help her and hung up. Was that wrong? Yes. In this situation, you should ask for the person’s name, address, telephone number and a brief description of the issue. After telling her you will find the right person to help her, talk to your leader about how to follow up. You should never try to answer a question if you are not qualified to do so, but each of us has a responsibility to do the right thing for our clients. We know that trust must be earned and are committed to making fair and accurate disclosures.  10 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Conduct business ethically We have a duty to promote the interests of the company. That means we do not use the company’s property or information for our own benefit or to compete with the company. What you need to know You are prohibited from using your position with Why ethics matter the company, or information acquired during your We do not use company information and employment or relationship with the company, to Employees, officers and directors owe a duty to property for personal gain. the company to advance its legitimate interests. advance your personal interests over the interests Your personal interests, whether you are focused We carefully monitor and control conflicts of of clients or the company. on a promotion or earning more compensation, interest. Gifts or entertainment are never more important than the best interests We do not give, solicit or accept gifts that of our clients or the company. Generally, you may only accept gifts (including could influence our business judgment. business-related meals or entertainment) if the Conflicts of interest value of the gift is not significant and the gift will We expect you to: not place you – or appear to place you – under any You may engage in an outside activity if it does not obligation to the donor. Before accepting a gift, Address conflicts of interest before you take any compete or conflict with the interests of the you should ask yourself if the gift would appear job action or engage in an outside business company or interfere with the responsibilities of significant to others or place you under any activity that may benefit you or your family – your job or the company’s employees. A conflict of obligation. If the answer is yes, then you should this applies to everyone, regardless of whether interest occurs when your private interests not accept the gift. you are a registered person interfere in any way – or even appear to interfere – with the interests of a client or the company. A You may be subject to a specific policy related to Avoid even the appearance of impropriety conflict of interest also arises when you or a accepting or giving gifts over a certain dollar value. Comply with company policies related to member of your family receives improper personal (Please refer to policies that apply to you.) outside business activities, political benefits as a result of your position in the Political contributions and involvement contributions and gifts and entertainment company. We respect your right to participate in the political Advisors, registered persons and investment- You must be especially sensitive to potential process. However, because of U.S. campaign access persons must file reports as required by conflicts of interest when you are considering applicable policies. finance laws, you may not: use company funds or engaging in consulting or other outside activities be reimbursed for a political contribution; allow a All persons subject to the Code and located in that involve the skills and knowledge you use in candidate or campaign to use company facilities or the U.S. must seek guidance from the your job. Simply reporting or disclosing an activity property; use work time or company equipment Corporate Secretary about potential conflicts without first resolving possible conflicts of interest for political or campaign purposes; or allow your of interest, whether involving gifts, vendor may result in a violation of the Code. relationships, outside business activities, or contribution of time or money to appear to be other circumstances. made with, or reimbursed by, company funds.  11 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES A client sent me a case of wine as a gift. I know that if I purchased the wine, it would be expensive. Can I accept this gift? If you are subject to a gift and entertainment policy, you may be required to decline the gift politely and return it. If you are a licensed person, you should seek advice from your registered principal or the Compliance Department. If you don’t know whether a gift policy applies to you, contact the Corporate Secretary or your local Compliance Department. Remember that you are never permitted to solicit a gift from a client, vendor or anyone else doing business with the company. Do I need to pre-clear my political contributions and political volunteer activities? If you are a financial advisor, you are subject to pre-clearance requirements. Otherwise, you need to refer to the Political Contributions policy to see if you are covered. Depending upon changes in your job or band level, you may become subject to pre- clearance in the future even if you are not covered now. Also, it's important to see if your current political contributions may affect your chances to apply for certain jobs in the future, due to the SEC’s pay-to-play rules.  12 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Compete fairly in the marketplace We believe that everyone benefits from fair, free and open markets, and we compete fairly in the marketplace based on the merits of our products and services. What you need to know information, misrepresentation of material facts or any unfair practices. Why ethics matter We must never offer, make or accept unlawful payments or gifts regardless of local business Non-retaliation We operate in a highly regulated industry and customs. under intense media and public scrutiny. An individual shall not be held criminally or civilly liable Regulators and prosecutors recognize the We comply with all antitrust, anti-bribery, anti- under any Federal or State trade secret law for the importance of a strong ethical and compliance corruption, monopoly and competition laws. disclosure of a trade secret that is made: culture. Failure to comply can have serious consequences in confidence to a Federal, State, or local government for the company and for you. official or to an attorney solely for the purpose of We expect you to: Antitrust and competition law reporting or investigating a suspected violation of law; or Deal fairly with clients, vendors, competitors We prohibit agreements intended to limit in a complaint or other document filed in a lawsuit or and other employees competition. We expect you to avoid any agreement with a competitor to limit competition. other proceeding, if such filing is made under seal. Maintain the company’s confidential An individual who files a lawsuit for retaliation by an or proprietary information and When dealing with outside companies, including employer for reporting a suspected violation of law trade secrets contractors and vendors, consider whether they are competing with Ameriprise Financial. may disclose the trade secret to the attorney of the individual and use the trade secret information in the The General Counsel’s Organization is available court proceeding, if the individual files any document whenever you question the legality of a containing the trade secret under seal; and does not proposed activity or need further guidance. disclose the trade secret, except pursuant to court False or misleading statements about our order. competitors are contrary to our values and damage our reputation. Fair dealing All employees, officers and directors should deal fairly with our clients, investors, suppliers and competitors. We don’t take unfair advantage of anyone through manipulation, concealment, abuse of privileged  13 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES I noticed that a contractor made a mistake in its invoice in our favor. What should I do? Call the contractor to discuss the invoice and confirm that we have been undercharged. If so, ask for a corrected invoice. I’m having a business lunch with an official of a foreign government at an inexpensive restaurant. I know that he is an avid golfer, so I plan to give him a box of golf balls as a small gesture of appreciation for meeting with me. What do I need to know? This legal area is complex, so seek advice from the General Counsel’s Organization before you give anything of value to a government official or anyone claiming to represent a government or a government-controlled entity. The United States Foreign Corrupt Practices Act and the UK Bribery Act impose severe penalties if you give anything of value to a government official. Many other countries are also enacting strict laws against bribery and corruption. In this case, even a modest meal and small gift can result in severe penalties for you and the company.  14 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Protect the company’s reputation and assets We diligently safeguard the company’s reputation, its physical and intellectual property and all sensitive information. What you need to know Intellectual property Why ethics matter We consider our reputation one of our most Intellectual property is one of the most valuable Our ability to attract and retain clients, advisors valuable assets. assets of our company. Our logos and branding and employees depends on our reputation as an (e.g., trademarks, service marks) stand as a unique We protect our assets and use them for ethical, honest and law-abiding company. symbol of the quality, integrity and reliability that appropriate business purposes. Anything that you do, whether at work or in your underlie all our products and services. Moreover, personal life, that damages our reputation is a Anti-money laundering and identity theft they serve to identify us to the world and set us apart from our competitors. serious matter. Be especially careful not to post The company maintains policies and procedures to or say anything on social media that could prevent and detect money laundering and identity The use of all logos and brand names, such as embarrass you or damage the reputation and theft. Suspicious activity takes many forms and is “Ameriprise Financial,” “RiverSource,” “Columbia brands we have worked so hard to establish. hard to define in absolute terms, however, Threadneedle Investments,” “Columbia Remember that your obligation to comply common examples of “red flags” are included in Management” and “Threadneedle” must conform with the Code doesn’t stop when you leave the the company’s related policies. If you ignore or with company policy. office. choose not to report suspicious activity, both you We will also never knowingly infringe on the and the company could be considered willfully intellectual property rights of others. You are We expect you to: blind and held liable for the criminal activity. responsible for confirming that the use of any third-party intellectual property is approved and Be alert to situations or actions that may Report concerns by submitting a Report of Unusual done with written permission. This includes, but is be unethical or potentially damaging to the Activity, which can be found on Inside or the ® not limited to, computer programs, brands, logos company’s reputation AdvisorCompass site. and periodicals. Watch for warning signs that may signal Company property fraudulent activity and report any suspicious Our company property, including equipment, activity supplies, systems and facilities, must only be used for Use company property only for valid valid business purposes. Theft, carelessness and business purposes and with proper waste have a direct impact on our profitability. If you authorization suspect someone was involved in, or is attempting to cover up, the theft or misuse of company property, Protect all company and client property immediately report it to your local security personnel and assets against theft or misuse or to SecurityAMPF@ampf.com.  15 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES I hear leaders refer to enterprise risk management. What does it mean to me in my role? Like all financial services companies, we face various risks that could harm our company, clients and shareholders. We invest significant time and money to identify and manage these risks, but of course it’s impossible to eliminate many of them. Even if an event is completely out of our control, such as a natural disaster or act of terrorism, we need to anticipate it as much as possible and be able to respond effectively. Risks can become more serious over time and new risks are emerging constantly. Our Board of Directors and Executive Leadership Team are focused on risk management because it’s crucial to our continued success. We also have talented teams of officers and employees around the world who are devoted to risk management. To be truly effective in identifying, monitoring and managing risk, each of us must think and act like a risk manager. Regardless of your job or level of responsibility, we expect you to be part of our risk management program. Each of us is a risk manager.  16 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Safeguard and maintain accurate information We diligently safeguard our clients’ personal information. We believe that accurate recordkeeping and reporting are essential to our reputation and credibility. Never falsify any document or distort the true Why ethics matter What you need to know nature of any transaction. Many data breaches and cybersecurity incidents We comply with all laws and policies related to the Never enable another person’s efforts to evade are the result of employee mistakes or collection, safeguarding and disclosure of client or taxes or subvert local currency laws. negligence. Carelessly clicking a link in an email sensitive information. or opening an attachment could result in a Confidentiality and privacy Only make payments to the person or firm that serious cybersecurity incident. You’ve probably actually provided the goods or services. We maintain the confidentiality of information read about incidents at other companies that Records management have cost millions of dollars to resolve. You play entrusted to us. Confidential information includes all a role in being attentive and doing everything non-public information that might be of use to We maintain appropriate books and records you can to avoid one at Ameriprise. competitors or harmful to the company or its clients if according to the law and our policies. We do not released. We ensure only employees with a business shred, destroy or alter documents that are related to need-to-know reason are allowed access to such data. any imminent or ongoing investigation, lawsuit, audit, We expect you to: Report privacy incidents or unauthorized access to examination or are required to be maintained for sensitive information to Privacy.Swat.Team@ampf.com. Protect the privacy, confidentiality and regulatory purposes. security of all client, employee, advisor and Financial and business information Signature issues and forgery company information Maintaining accurate and complete business and Employees, advisors or staff may not copy, affix or Keep accurate business and financial records financial records, including financial statements and trace a client’s signature or sign any document on accounts, expense reports, time records and invoices, Safeguard sensitive information from behalf of a client, even if specifically asked to by is not just the job of Accounting and Finance unauthorized disclosure the client. A signature is considered forged if it was personnel. signed by someone other than the person named, Report financial and other business Always record and classify transactions in the or that person’s legally authorized representative. information truthfully, accurately and Whenever a client signature is required, it must be completely proper accounting period and in the appropriate account and department. an original signature of the client or his or her Maintain all business records in accordance legally authorized representative. Never delay or accelerate the recording of revenue with the company’s policies and procedures or expenses. and regulatory requirements Always support estimates and accruals with appropriate documentation based on your best judgment.  17 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES A package mailed by a client containing a completed application and a check looked like it had been opened. Do I need to tell anyone about this? Yes. Even if nothing appeared to be missing, this is still a potential breach of the client’s privacy. Send an email to Privacy.Swat.Team@ampf.com, who will research and identify potential risk. Contact your leader, registered principal, the Employee Relations Group Service Center at 1.877. 267.4748, the Ethics Hotline at 1.800.963.6395 or Safe Call in the UK at 0800 915 1571 if you: Believe financial information or business records are not reported or maintained accurately and completely. Feel pressure to report inaccurate or incomplete financial or business information. Are asked to prepare or destroy documents in violation of company policy.  18 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Treat everyone with dignity and respect We value our people, encourage their development and reward their performance. What you need to know Why ethics matter We are good citizens in our communities. Freedom from fear and violence in the workplace We expect all employees and advisor to behave We prohibit the possession of weapons in the in a values-driven manner, which includes We make all reasonable efforts to maintain a safe workplace or when conducting business on behalf of treating all people with dignity and respect. and healthy work environment for our employees and visitors. the company. You may not assist or permit others to Discriminatory treatment and harassment are possess weapons in the workplace. illegal and violate our company values. We prohibit discrimination or harassment and Therefore, we encourage individuals to report welcome diversity. Importance of diversity any violations. Equal employment opportunity We are committed to valuing and supporting diversity in the workplace and community. Employees, financial advisors and leaders are We expect you to: Employees, field members and staff represent many responsible for complying with the company’s Equal age groups, ethnicities, family structures, races, Treat others the way you would like to Employment Opportunity Policy, Individual Treatment religions, sexual orientations, nationalities and mental be treated Policy and related policies, and anti-discrimination and physical abilities. Be an example to the next generation and anti-harassment laws. Leaders have the added of leaders responsibility of ensuring compliance with those Non-retaliation policies and laws. Support a diverse and safe work environment We do not retaliate against or intimidate an Freedom from discrimination individual who makes a complaint, assists in making a Notify your local or onsite security personnel or complaint or is a witness in an investigation. Our We prohibit discrimination or harassment against any local law enforcement immediately if you see values and the law protect an individual who, in good person on the grounds of race, color, religion, anyone exhibiting threatening behavior or if faith, reports discrimination, harassment, threats of national origin, disability, age, sex, marital status, there is a potentially dangerous situation at violence or any inappropriate behavior. your workplace sexual orientation, gender identity, veteran status or citizenship. Safety, health and the environment Security Services – 1.800.455.5187 Each of us, particularly leaders, is responsible for We make all reasonable efforts to provide and Safe Call (UK) – 0800 915 1571 creating and maintaining a work environment free of maintain a safe and healthy working environment for Employee Relations Group discrimination and harassment. our employees and visitors. Service Center – ERGSC@ampf.com  19 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES A colleague in my department has been acting erratically lately. He complains that he has been treated unfairly at work and talks about “getting even” with people. What should I do? Call Security Services (or your local security personnel) or the Employee Relations Group Service Center immediately and explain the situation. You share the responsibility of helping the company maintain a safe environment for all of our employees and visitors. As long as you act in good faith, you will not face any retaliation for sharing your concerns.  20 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Navigate your ethical questions Consider your actions carefully. Ask for guidance when you need it. What you need to know and contractors, regardless of their work location. We make decisions with integrity. We expect you to: If you are an individual contributor We expect our leaders to set an example of Be aware of the consequences of courteous and respectful behavior toward their We expect all leaders to set the right ethical your actions team members and others. example for the company and its employees, Ask for guidance when you need it regardless of how many people they lead. But even Related policies if you aren’t a leader, we expect you to be an Ask yourself about a potential behavior or The Code of Conduct and the related policies example of this same honest and ethical behavior action: cannot, and do not attempt to, address every for others on your team. Remember that others Is it consistent with the Code and other possible situation or circumstance that you may may model their behavior based on yours, company policies? encounter. You are responsible for becoming especially if you have more experience or have familiar with the Code of Conduct and related been with the company for a longer period of time. Is it ethical? policies, adhering to the principles and rules stated Never make jokes about complying with the law, Is it legal? in them and seeking advice and guidance when our policies and procedures or the Code of you are uncertain as to the proper course of Conduct. Never belittle anyone for asking what the Am I setting a good example? action. right thing to do is. Will it put the company at undue risk? If you are a leader If someone on your team asks for your advice on Will it reflect poorly on the company how to handle an ethical question, encourage or me? Leaders at all levels are responsible for continually him or her to speak with your leader. emphasizing integrity as a standard of Would I want to read about it in the news performance for all employees, demonstrating Be supportive and remind the person that we or on social media? how employees and others should be treated with have a strict policy against retaliation for reports made in good faith. How would I explain my actions to my dignity and respect and creating and maintaining a colleagues, friends and family? work environment free of discrimination and How you behave and what you say matters. harassment. Leaders should always seek legal advice about the laws that may apply to a particular situation. Leaders are responsible for the health, safety and welfare of their departments, and everyone reporting or assigned to them, including visitors  21 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Consequences for non-compliance Remember that asking for guidance before you act may help you avoid disciplinary action for violating the Code or a law, rule or regulation. We expect you to: What you need to know leader or member of management, or failure to perform work as required or assigned; and Talk to your leader or any of these resources We will not accept ignorance or oversight as Violations of safety or health laws or regulations or about any situation that concerns you: excuses for behavior that violates the Code, related policies or any law or regulation. engaging in conduct that creates a safety or health Your Human Resources hazard. business partner We retain the right to determine whether specific actions or behaviors violate the Code of Conduct. In addition, if you violate the law during the course of Employee Relations Group Service Center – your employment you may be subject to criminal and 1.877.267.4748 Violations of the Code civil penalties as well as payment of monetary damages to the company or third parties. Executive Vice President, General Counsel’s Personal conduct that violates the Code includes, but Organization – 1.612.671.3602 is not limited to: Disciplinary action may also be taken against an employee or advisor who: Executive Vice President, Human Resources Willful or negligent damage to company property – 1.612.671.3997 or the property of others; Authorizes, directs, approves, participates in or encourages violations of the Code; Corporate Secretary’s Office – Theft or dishonesty, including falsification of 1.612.678.0106 company records or furnishing false or incomplete Deliberately fails to report or conceals violations or information on expense forms, time records, deliberately withholds or misstates relevant Ethics Hotline – 1.800.963.6395 employment applications or other documents information; Personal Trading Hotline – 1.612.671.5196 related to your employment; Retaliates against any other employee because he Suspicious Activity Hotline – Inappropriate behavior or personal attire or she reported a suspected violation in good faith; 1.612.671.6166 that is unprofessional or embarrasses the company or or its clients, including posting Safe Call (EMEA) – 0800 915 1571 or transmitting offensive or inappropriate material Knew or should have known about a violation by FCA Whistleblowing (UK) – on the internet or any social people under his or her supervision and did not whistle@fca.gov.uk media site; promptly report it. Commission de Surveillance du Secteur Disruptive or offensive behavior while conducting Financier – whistleblowing@cssf.lu company business, including insubordination, willful disregard of company policies or procedures, Public Concern at Work (UK) – disrespect toward a client or potential client, a helpline@pcaw.co.uk  22 

CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES Resources Refer to related company policies, procedures or related resources for questions or additional information. This list contains only a portion of the policies and procedures that may apply to you or that may provide helpful guidance in your role. Search Inside, AdvisorCompass, Complisource or other company intranet systems for these and additional policies. Ameriprise Financial Global Anti-Money Laundering Columbia Threadneedle Investments Privacy and Individual Treatment Policy and Economic Sanctions Policy Information Security and Identity Theft Prevention Intellectual Property Policy Program Ameriprise Financial Personal Trading Policy Mandatory Training: Annual Requirements Communications and Disclosure Policy Ameriprise Financial Political Contributions (“Pay to Mandatory Training: New-Hire Requirements Play”) Policy Corporate Compliance Manual Outside Business Activities Policy Ameriprise Financial Public Appearances and Corporate Supervision Manual Record and Information Management Policy Interaction with the Media Policy Data and Information Sharing Guidelines Client Privacy Principles RiverSource Gifts, Entertainment and Marketing Dual Registration Policy Support Policy Columbia Threadneedle Investments Global Policy – Electronic Communication Acceptable Use Policy Outside Activities and Family Relationships Policy Secure Workplace Policy Equal Employment Opportunity Policy Columbia Threadneedle Investments Employee Social Media Policy Registration and Licensing Facility Rules, Guidelines and Standards Threadneedle Other Conflicts of Interest Policies of Use Columbia Threadneedle Investments Applicable to Covered Persons Firm Registration, Regulatory Filings, and Disclosure Gifts and Business Entertainment Policy - Threadneedle Conflicts of Interest Policy Ameriprise Financial Services, Inc. Policy Threadneedle Gifts & Corporate Hospitality Policy Gifts and Business Entertainment Policy - Columbia Threadneedle Investments Global Policy – Threadneedle Treating Customers Fairly Gifts and Entertainment Policy American Enterprise Investment Services Threadneedle Whistleblowing Policy Columbia Management International Compliance Global Anti-Corruption Policy and Guidelines Your Guide to a Safe and Respectful Workplace Policy for Columbia Management Non-U.S. / Offshore Columbia Threadneedle Investments Global Policy Sales and Service Activities Personal Account Dealing and Code of Columbia Threadneedle Investments Global Policy – Ethics Policy Inside Information Policy Handling Whistleblower Claims Policy Columbia Threadneedle Investments Global Policy – HIPAA Policies and Procedures Manual Political Contributions Policy Identity Theft Prevention Policy Columbia Management Portfolio Holdings Disclosure Information Security Policy Policy  23 

Notes This document does not create a contract of employment or a contract for any specific term or condition of employment between Ameriprise Financial and an employee. Except as provided otherwise by the laws of a foreign jurisdiction, the relationship between Ameriprise Financial and an employee is at-will, meaning that either the employee or the company may terminate it at any time for any reason, with or without advance notice or progressive disciplinary action. The company reserves the right to make changes in or discontinue company policies, compensation plans, benefits and programs as it deems appropriate and these changes may be implemented even if they have not been communicated in this (or by change to this) document or otherwise. If this document refers to any company benefit program, it describes only certain highlights of the company’s benefit program. It does not supersede the actual provisions of the applicable plan documents, which in all cases are the final authority. The applicable plan administrator has the sole authority and discretion to determining your eligibility to participate in the plan, interpret the plan documents and administer of the plans. Ameriprise Financial takes reasonable efforts to ensure the accuracy of the contents of policy documents and in the administration of its policies and programs. The company does not assume responsibility for consequential damages caused by administrative or clerical errors. Financial Planning | Retirement | Investments | Insurance Ameriprise Financial, Inc. Corporate Secretary’s Office 1098 Ameriprise Financial Center, Minneapolis, MN 55474 ameriprise.com Revised October 1, 2019 © Ameriprise Financial, Inc. All rights reserved.