Attached files
file | filename |
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EX-32 - EXHIBIT 32 - AMERIPRISE CERTIFICATE CO | exhibit32.htm |
EX-31.2 - EXHIBIT 31.2 - AMERIPRISE CERTIFICATE CO | exhibit312.htm |
EX-31.1 - EXHIBIT 31.1 - AMERIPRISE CERTIFICATE CO | exhibit311.htm |
EX-24.(B) - EXHIBIT 24.(B) - AMERIPRISE CERTIFICATE CO | exhibit24b.htm |
EX-24.(A) - EXHIBIT 24.(A) - AMERIPRISE CERTIFICATE CO | exhibit24a.htm |
EX-14.(B) - EXHIBIT 14.(B) - AMERIPRISE CERTIFICATE CO | exhibit14b.htm |
EX-10.(N) - EXHIBIT 10.(N) - AMERIPRISE CERTIFICATE CO | exhibit10n.htm |
EX-10.(M) - EXHIBIT 10.(M) - AMERIPRISE CERTIFICATE CO | exhibit10m.htm |
EX-10.(L) - EXHIBIT 10.(L) - AMERIPRISE CERTIFICATE CO | exhibit10l.htm |
EX-10.(C) - EXHIBIT 10.(C) - AMERIPRISE CERTIFICATE CO | exhibit10c.htm |
10-K - 10-K - AMERIPRISE CERTIFICATE CO | acc123117.htm |
Exhibit 14(c)
Global Code of Conduct
OUR VALUES
Client-focused Integrity always Excellence Respect
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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.
The success of
Ameriprise depends on
the trust and confidence
we earn every day.
Our actions matter.
Ameriprise Financial has a proud, more than
120 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 commitment to
ethical behavior and doing what is right for
our clients, advisors, employees and
shareholders. Our Global Code of Conduct
emphasizes the core ethical principles that
must guide our behavior at all times.
The Global Code of Conduct also identifies
potential areas of ethical risk. Please read it
carefully. When you see misconduct, report it
to your leader. Ask your leader for help when
you are unsure of the right thing to do. We
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.
Our Board of Directors, Executive
Leadership Team and I hold ourselves to the
same high standards of conduct that we
expect you to honor. For those who lead
others, it’s your duty to set the right
example for behavior. And it’s up to each of
us to ensure we treat team members and
others with dignity and respect.
Our vision is to be the most respected and
referred financial services brand. We can
only achieve our vision if each of us does
business the right way. Thank you for your
commitment to the principles in the Code
and the continued success of our company.
JAMES M. CRACCHIOLO
CHAIRMAN AND CHIEF EXECUTIVE OFFICER
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
Contents
• Introduction
− This 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
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
This Code applies to everyone
at Ameriprise Financial
All officers, employees, financial advisors and their staff must follow this Code.
What you need to know
We value ethics and integrity.
We maintain an environment where
compliance and adherence to the Code of
Conduct is the norm.
About the Code
This Code is enterprise-wide and applies to
everyone working for one of the company’s
business areas or affiliates. Commitment to the
ethical principles helps ensure compliance with the
Code.
This Code applies even if you also adhere to
another code of ethics or conduct within your
business area.
For U.S. employees and employee advisors,
compliance with the Code is a condition of
employment. For franchise advisors and their staff,
compliance with the Code is required by the
franchise agreement.
Applicable company policies
The Code requires you to comply with the
provisions of other policies, codes of ethics and
other business procedures to which you are
subject.
You must read and comply with the policies and
procedures that apply to you. (See Page 23 for a
partial list of company policies.)
This Code can’t cover every situation
No code of conduct or ethics can anticipate all of
the circumstances that you may encounter during
your career. If the Code doesn’t address a specific
situation, you are still obligated to act in an ethical
and honest manner. Above all, seek guidance from
your leader, manager or one of the provided
resources (See list of resources on Page 6) before
you act.
Violations of the Code
If you violate the Code, you will be subject to
disciplinary action, including possible termination
of your employment or franchise agreement.
Disciplinary action will depend on the
circumstances and will be consistent with the
company’s policies and procedures. (See
consequences for non-compliance on Page 22.)
Waivers of the Code
Only the Board of Directors of Ameriprise
Financial, Inc. can grant a waiver of the Code of
Conduct. We will promptly disclose to our
Why ethics matter
The culture of any company is determined by
what its directors, officers and employees
actually do rather than what they are supposed
to do. It is simply about doing the right thing,
day in and day out.
We expect you to:
Comply with the Code.
Act with integrity.
Follow all applicable laws, rules and
regulations.
Use your best judgment.
Ask for guidance before you act.
Report ethical concerns promptly.
Be an example of ethical behavior for your
team.
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
shareholders any waivers granted to our executive officers and directors.
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, too, 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 very important point
is covered in more detail in the next
section.
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
Report your concerns
If you observe behavior that concerns you, or that you believe in good faith may be
illegal or a violation of the Code, you are required to report the issue promptly.
What you need to know
We respond appropriately to all allegations by
employees, suppliers, clients or contractors
that the company is not meeting its legal,
ethical or financial obligations.
We provide several reporting options for
anyone who suspects breaches of the Code,
our policies or the law.
Whistleblower claims
Acting ethically includes reporting misconduct. If
you don’t report the misconduct of others, you are
not acting ethically and will be held accountable. It
may not be easy to report misconduct involving a
colleague or friend, but that is what we expect you
to do.
You should, in good faith, report an alleged
impropriety that prevents the company from
meeting its legal obligations or complying with
generally accepted accounting principles.
A whistleblower is an individual who lawfully
makes any allegation of impropriety or
discloses or provides information or assistance
in connection with any governmental
proceeding or inquiry.
Acting in good faith means that you have a
sincere belief that a reasonable person in the
same situation with access to the same facts
would also conclude there is a likelihood of
misconduct.
Non-retaliation
We will not tolerate any retaliation against you if
you report possible misconduct in good faith even
if it turns out that no misconduct occurred. You
won’t be fired, given a lower performance rating or
demoted solely because you reported possible
misconduct in good faith. Retaliating against a
person who has reported a suspected violation is
considered a violation of the Code.
All reports are investigated and your report
will be treated confidentially to the extent
allowed by law and company policy.
If you believe you have been retaliated
against, promptly contact any of the resources
listed on this page.
Leaders are responsible for properly reporting
any allegations they become aware of.
Why ethics matter
Your diligence allows us to correct problems
that may involve a violation of law or pose a risk
to health, safety or the company’s reputation.
We expect you to report concerns
promptly to your leader, manager or one
of the following resources:
Employee Relations Group
Service Center – ERGSC@ampf.com
Ethics Hotline – 1.800.963.6395
Safe Call (UK) – 0800 915 1571
FCA Whistleblowing (UK) –
whistle@fca.gov.uk
Public Concern at Work (UK) –
helpline@pcaw.co.uk
Corporate Secretary’s Office –
Thomas.R.Moore@ampf.com
General Counsel’s Organization –
karen.wilson.thissen@ampf.com
Executive Vice President,
Human Resources –
Kelli.A.Hunter@ampf.com
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
Obey the law and guard against criminal activity
We comply with all laws and regulations that apply to our operations, including insider
trading laws.
What you need to know
We obey the law in our professional lives just
as we do in our personal lives. Being unaware
that a law or regulation exists won’t excuse
any violation you commit.
We follow the advice of our legal and
compliance professionals.
We always cooperate fully and honestly with
our regulatory agencies during examinations
and inquiries.
Comply with rules, regulations and laws
Additional rules or regulations may apply to you in
your home country or because of your specific job
responsibilities. Each of us is responsible to know
and follow the laws wherever we work.
Fraud prevention
Preventing fraud is a responsibility of everyone at
all levels. You have a duty to be mindful of
potential fraudulent activity and to promptly
report anything suspicious. Fraud includes a wide
variety of illegal acts, all characterized by the
intent to deceive someone. Fraud can be
committed to the detriment of the company, our
clients, our shareholders or others, and can be
carried out by people inside as well as outside of
the company.
Insider trading
Insider trading is both illegal and unethical. Insider
trading is the practice of buying or selling securities
of any company, including Ameriprise Financial,
when you are aware of material, non-public
information about that company or its securities. If
you are convicted of insider trading, you could be
sentenced to years in prison.
Personal trading
Our personal trading rules, policies and procedures
apply to everyone who is subject to this Code with
few exceptions. These rules are derived from
securities and investment laws, regulatory guidelines
and other corporate policies. They aim to eliminate
the appearance of conflict between the personal
trading activities of our associates and our clients as
well as the rest of the investing public.
In addition to the general rules that apply broadly
to individuals subject to the Code, more restrictive
rules apply to certain persons based on their
access to information and/or their job
responsibilities. You are responsible for
understanding the related company policies that
apply to you.
Why ethics matter
Legal or regulatory violations can cost our
shareholders millions of dollars in legal
judgments, fines or penalties. In some cases,
you could also face fines, the loss of your job
and even imprisonment. The company often
sets a higher standard than what the law
requires, so it is important to understand all
policies that apply to you.
We expect you to:
Become familiar with the laws and
regulations that apply to you and your job,
including insider trading laws, which apply
to everyone.
Complete all mandatory training,
disclosures and other requirements related
to your job.
Stay current on legal and regulatory
developments you need to know.
Report suspected insider trading, market
abuse or fraudulent activity promptly.
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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, 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.
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
Do the right thing for the client
From initial contact with prospects, through our continued service of existing individual
or institutional client and end-client accounts, we stand behind what we say and do.
What you need to know
We carefully consider the impact of our
decisions on clients.
We provide exceptional client service.
We are committed to making full and fair
disclosures.
Full and fair disclosure
You must make full and fair disclosure of all features,
benefits, risks and fees of products or services sold or
marketed to all clients and prospects, particularly
where your interests may conflict with those of our
clients. Full and fair disclosure applies to initial client
communications as well as to subsequent
recommendations.
Your disclosures must be accurate, fair and
balanced and presented in the proper context. Do
not omit material facts or qualifications if the
result would be misleading.
Marketing, advertising and communications with
the public
Marketing, advertising and communications with
the public, including clients, prospects, investors,
analysts and the general public, must be truthful
and accurate. You may not make exaggerated or
misleading statements, regardless of whether the
information is given directly or indirectly. You must
answer all questions honestly and completely.
In addition, the content must meet applicable
regulatory and legal standards. When preparing
advertising, marketing and communication for the
public, you must ensure that required reviews and
approvals are received prior to first use.
Suitability
Advice and products recommended must be
suitable for each client. Always take the time to
ensure that investment advice and products or
services recommended are appropriate given a
client’s age, financial situation, investment
planning objectives and tolerance for risk. Also,
take time to provide clients with the information
necessary for them to fully understand the
features, potential benefits and risks of the
recommended product or service. When dealing
with elderly clients, pay special attention to their
expected financial needs and tolerance for risk.
Our suitability requirements apply not only to
initial buy, sell and hold recommendations, but
also to subsequent recommendations in existing
accounts.
Why ethics matter
We maintain our clients’ loyalty and improve their
experience by acting with integrity. Our first
priority is the success of our clients. They have
selected us to help them reach their financial
goals, support their children’s education and
prepare for retirement on their terms. If we break
that trust, our clients will leave us for other firms.
We expect you to:
Be truthful and accurate.
Never mislead a client or prospect.
Help clients and prospects understand our
products and services.
Provide clients and prospects with all
information they need to make an informed
decision about our products and services.
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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.
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
Conduct business ethically
We have a duty to promote the interests of the company. That means we do not use the
company’s property or information for our own benefit or to compete with the company.
What you need to know
We do not use company information and
property for personal gain.
We carefully monitor and control conflicts of
interest.
We do not give, solicit or accept gifts that
could influence our business judgment.
Conflicts of interest
You may engage in outside activities that do not
compete or conflict with the interests of the
company or interfere with the responsibilities of
your job or the company’s employees.
A conflict of interest occurs when your private
interests interfere in any way – or even appear to
interfere – with the interests of a client or the
company. A conflict of interest also arises when
you or a member of your family receives improper
personal benefits as a result of your position in the
company.
You are prohibited from using your position with
the company, or information acquired during your
employment or relationship with the company, to
advance your personal interests over the interests
of clients or the company.
Gifts or entertainment
Generally, you may only accept gifts (including
business-related meals or entertainment) if the
value of the gift is not significant and the gift will
not place you – or appear to place you – under any
obligation to the donor.
Before accepting a gift, you should ask yourself if
the gift would appear significant to others or place
you under any obligation. If the answer is yes, then
you should not accept the gift.
You may be subject to a specific policy related to
accepting or giving gifts over a certain dollar value.
(Please refer to policies that apply to you.)
Political contributions and involvement
We respect your right to participate in the political
process. However, because of U.S. campaign
finance laws, you may not:
Use company funds or be reimbursed for a
political contribution
Allow a candidate or campaign to use
company facilities or property
Use work time or company equipment for
political or campaign purposes
Allow your contribution of time or money to
appear to be made with, or reimbursed by,
company funds
Why ethics matter
Employees, officers and directors owe a duty to the
company to advance its legitimate interests. Your
personal interests, whether winning a promotion or
earning more compensation, are never more
important than the best interests of our clients or
the company.
We expect you to:
Address conflicts of interest before you act. If
you are about to take any job action that may
benefit you or your family, seek guidance
before you act.
Avoid even the appearance of impropriety.
Comply with company policies related to
outside business activities, political
contributions and gifts and entertainment.
Advisors, registered persons and investment-
access persons must file reports as required
by applicable policies.
All other U.S. employees may report or
disclose to the Corporate Secretary’s Office
using the Prior Approval and Disclosure form
found on Inside.
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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, you should call the
Corporate Secretary. 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.
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
Compete fairly in the marketplace
We believe that everyone benefits from fair, free and open markets, and we compete
fairly in the marketplace based on the merits of our products and services.
What you need to know
We must never offer, make or accept unlawful
payments or gifts regardless of local business
customs.
We comply with all antitrust, anti-bribery,
anticorruption, monopoly and competition laws.
Failure to comply can have serious consequences
for the company and for you.
Antitrust and competition law
We prohibit agreements intended to limit
competition. We expect you to avoid any
agreement with a competitor to limit competition.
When dealing with outside companies,
including contractors and vendors, consider
whether they are competing with Ameriprise
Financial.
The General Counsel’s Organization is
available whenever you question the legality
of a proposed activity or need further
guidance.
False or misleading statements about our
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
information, misrepresentation of material facts or
any unfair practices.
Non-retaliation
An individual shall not be held criminally or civilly liable
under any Federal or State trade secret law for the
disclosure of a trade secret that is made:
in confidence to a Federal, State, or local
government official or to an attorney solely for the
purpose of reporting or investigating a suspected
violation of law; or
in a complaint or other document filed in a lawsuit
or other proceeding, if such filing is made under
seal.
An individual who files a lawsuit for retaliation by an
employer for reporting a suspected violation of law
may disclose the trade secret to the attorney of the
individual and use the trade secret information in the
court proceeding, if the individual files any document
containing the trade secret under seal; and does not
disclose the trade secret, except pursuant to court
order.
Why ethics matter
We operate in a highly regulated industry and
under intense media and public scrutiny.
Regulators and prosecutors recognize the
importance of a strong ethical and compliance
culture.
We expect you to:
Deal fairly with clients, vendors,
competitors and other employees.
Maintain the company’s confidential or
proprietary information and trade secrets.
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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. That’s what we
would expect if we made that mistake in one
of our invoices.
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 very 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.
Protect the company’s reputation and assets
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
We diligently safeguard the company’s reputation, its physical and intellectual property
and all sensitive information.
What you need to know
We consider our reputation one of our most
valuable assets.
We protect our assets and use them for
appropriate business purposes.
Anti-money laundering and identity theft
The company maintains policies and procedures to
prevent and detect money laundering and identity
theft. Suspicious activity takes many forms and is
hard to define in absolute terms; however,
common examples of “red flags” are included in
the company’s related policies. If you ignore or
choose not to report suspicious activity, both you
and the company could be considered willfully
blind and held liable for the criminal activity.
Report concerns by submitting a Report of Unusual
Activity, which can be found on Inside or the
AdvisorCompass® site.
Company property
Our company property, including equipment,
supplies, systems and facilities, must only be used for
valid business purposes. Theft, carelessness and
waste have a direct impact on our profitability. If you
suspect someone was involved in, or is attempting to
cover up, the theft or misuse of company property,
immediately report it to your local security personnel
or to SecurityAMPF@ampf.com.
Intellectual property
Intellectual property is one of the most valuable
assets of our company. Our logos and branding
(e.g., trademarks, service marks) stand as a unique
symbol of the quality, integrity and reliability that
underlie all our products and services. Moreover,
they serve to identify us to the world and set us
apart from our competitors.
The use of all logos and brand names, such as
“Ameriprise Financial,” “RiverSource,” “Columbia
Threadneedle Investments,” “Columbia
Management” and “Threadneedle” must conform
with company policy.
We will also never knowingly infringe on the
intellectual property rights of others. You are
responsible for confirming that the use of any
third-party intellectual property is approved and
done with written permission. This includes, but is
not limited to, computer programs, brands, logos
and periodicals.
Why ethics matter
Our ability to attract and retain clients, advisors
and employees depends on our reputation as an
ethical, honest and law-abiding company.
Anything that you do, whether at work or in your
personal life, that damages our reputation is a
serious matter. Be especially careful not to post or
say anything on social media that could embarrass
you or damage the reputation and brand we have
worked so hard to establish. Remember that your
obligation to comply with the Code doesn’t stop
when you leave the office.
We expect you to:
Be alert to situations or actions that may
be unethical or potentially damaging to the
company’s reputation.
Watch for warning signs that may signal
fraudulent activity and report any suspicious
activity.
Use company property only for valid
business purposes and with proper
authorization.
Protect all company and client property
and assets against theft or misuse.
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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.
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
Safeguard and maintain accurate information
We diligently safeguard the personal information of our clients. We believe that
accurate recordkeeping and reporting are essential to our reputation and credibility.
What you need to know
We collect, safeguard and disclose client or
sensitive information only in compliance with the
law and our policies.
Confidentiality and privacy
We maintain the confidentiality of information
entrusted to us by the company and our clients.
Confidential information includes all non-public
information that might be of use to competitors or
harmful to the company or its clients if released. Only
employees with a business need-to-know reason are
allowed access to such data. Report privacy incidents or
unauthorized access to sensitive information to
Privacy.Swat.Team@ampf.com.
Financial and business information
Maintaining accurate and complete business and
financial records, including financial statements and
accounts, expense reports, time records and invoices,
is not just the job of Accounting and Finance
personnel.
Always record and classify transactions in the
proper accounting period and in the appropriate
account and department.
Never delay or accelerate the recording of
revenue or expenses.
Always support estimates and accruals with
appropriate documentation based on your best
judgment.
Never falsify any document or distort the true
nature of any transaction.
Never enable another person’s efforts to evade
taxes or subvert local currency laws.
Only make payments to the person or firm that
actually provided the goods or services.
Records management
We maintain appropriate books and records
according to the law and our policies. We do not
shred, destroy or alter documents that are related to
any imminent or ongoing investigation, lawsuit, audit,
examination or are required to be maintained for
regulatory purposes.
Signature issues and forgery
Employees, advisors or staff may not copy, affix or
trace a client’s signature or sign any document on
behalf of a client, even if specifically asked to by
the client. A signature is considered forged if it was
signed by someone other than the person named,
or
that person’s legally authorized representative.
Whenever a client signature is required, it must be
Why ethics matter
Many data breaches and cybersecurity incidents
are the result of employee mistakes or negligence.
Carelessly clicking a link in an email or opening an
attachment could result in a serious cybersecurity
incident. You’ve probably read about incidents at
other companies that have cost millions to
resolve. You play a role in being attentive and
doing everything you can to avoid one at
Ameriprise.
We expect you to:
Protect the privacy, confidentiality and
security of client, employee, advisor and
company information.
Keep accurate business and financial records.
Safeguard sensitive information from
unauthorized disclosure.
Report financial and other business
information truthfully, accurately and
completely.
Maintain all business records in accordance
with the company’s policies and procedures.
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
an original signature of the client or his or her legally authorized representative.
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.
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
Treat everyone with dignity and respect
We value our people, encourage their development and reward their performance.
What you need to know
We are good citizens in our communities.
We make all reasonable efforts to maintain a
safe and healthy work environment for our
employees and visitors.
We prohibit discrimination or harassment.
Equal employment opportunity
Employees, financial advisors and leaders are
responsible for complying with the company’s Equal
Employment Opportunity Policy, Individual Treatment
Policy and related policies, and anti-discrimination
and anti-harassment laws. Leaders have the added
responsibility of ensuring compliance with those
policies and laws.
Freedom from discrimination
We prohibit discrimination or harassment against any
person on the grounds of race, color, religion,
national origin, disability, age, sex, marital status,
sexual orientation, gender identity, veteran status or
citizenship.
Each of us, particularly leaders, is responsible for
creating and maintaining a work environment free of
discrimination and harassment.
Freedom from fear and violence in the workplace
We prohibit the possession of weapons in the
workplace or when conducting business on behalf of
the company. You may not assist or permit others to
possess weapons in the workplace.
Importance of diversity
We are committed to valuing and supporting
diversity in the workplace and community.
Employees, field members and staff represent many
age groups, ethnicities, family structures, races,
religions, sexual orientations, nationalities and mental
and physical abilities.
Non-retaliation
We do not retaliate against or intimidate an
individual who makes a complaint, assists in making a
complaint or is a witness in an investigation. Our
values and the law protect an individual who, in good
faith, reports discrimination, harassment, threats of
violence or any inappropriate behavior.
Safety, health and the environment
We make all reasonable efforts to provide and
maintain a safe and healthy working environment for
our employees and visitors.
Why ethics matter
We expect all persons to behave in a values-
driven manner, which includes welcoming
diversity and treating all people with dignity and
respect. Discriminatory treatment and
harassment are illegal and violate our company
values. Therefore, we encourage individuals to
report any violations.
We expect you to:
Treat others the way you would like to
be treated.
Be an example to the next generation
of leaders.
Support a diverse and safe work
environment.
Notify your local or onsite security personnel or
local law enforcement immediately if you see
anyone exhibiting threatening behavior or if
there is a potentially dangerous situation at
your workplace.
Security Services
1.800.455.5187
Safe Call (UK)
0800 915 1571
Employee Relations Group
Service Center
ERGSC@ampf com
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
A colleague in my department has been
acting very 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 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.
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
Navigate your ethical questions
Consider your actions carefully. Ask for guidance when you need it.
What you need to know
We make decisions with integrity.
We expect our leaders to set an example of
courteous and respectful behavior toward their
team members and others.
Related policies
The Code of Conduct and the related policies
cannot, and do not attempt to, address every
possible situation or circumstance that you may
encounter. You are responsible for becoming
familiar with the Code of Conduct and related
policies, adhering to the principles and rules stated
in them and seeking advice and guidance when
you are uncertain as to the proper course of
action.
If you are a leader
Leaders at all levels are responsible for continually
emphasizing integrity as a standard of
performance for all employees, demonstrating
how employees and others should be treated with
dignity and respect and creating and maintaining a
work environment free of discrimination and
harassment.
Leaders should always seek legal advice about
the laws that may apply to a particular
situation.
Leaders are responsible for the health, safety
and welfare of their departments, and
everyone reporting or assigned to them,
including visitors and contractors, regardless
of their work location.
If you are an individual contributor
We expect all leaders to set the right ethical
example for the company and its employees,
regardless of how many people they lead. But even
if you aren’t a leader, we expect you to be an
example of this same honest and ethical behavior
for others on your team. Remember that others
may model their behavior based on yours,
especially if you have more experience or have
been with the company for a longer period of time.
Never make jokes about complying with the law,
our policies and procedures or the Code of
Conduct. Never belittle anyone for asking what the
right thing to do is.
If someone on your team asks for your advice
on how to handle an ethical question,
encourage him or her to speak with your
leader.
Be supportive and remind the person that we
have a strict policy against retaliation for
reports made in good faith.
How you behave and what you say matters.
We expect you to:
Be aware of the consequences of your actions.
Ask for guidance when you need it.
Ask yourself about a potential behavior or
action:
Is it consistent with the Code and other
company policies?
Is it ethical?
Is it legal?
Am I setting a good example?
Will it put the company at undue risk?
Will it reflect poorly on the company
or me?
Would I want to read about it in the news
or on social media?
How would I explain my actions to my
colleagues, friends and family?
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CONTENTS | INTRODUCTION | REPORT YOUR CONCERNS | ETHICAL PRINCIPLES | NAVIGATE YOUR ETHICAL QUESTIONS | CONSEQUENCES FOR NON-COMPLIANCE | RESOURCES
Consequences for non-compliance
Remember that asking for guidance before you act may help you avoid disciplinary
action for violating the Code or a law, rule or regulation.
What you need to know
We will not accept ignorance or oversight as
excuses for behavior that violates the Code,
related policies or any law or regulation.
We retain the right to determine whether
specific actions or behaviors violate the Code of
Conduct.
Violations of the Code
Personal conduct that violates the Code includes, but
is not limited to:
Willful or negligent damage to company
property or property of others
Theft or dishonesty, including falsification of
company records or furnishing false or
incomplete information on expense forms, time
records, employment applications or other
documents related to your employment
Inappropriate behavior that is harmful or
embarrasses the company or its clients, including
posting or transmitting offensive or
inappropriate material on the internet or any
social media site
Disruptive behavior, including insubordination,
willful disregard of company policies or
procedures, disrespect toward a leader or
member of management or failure to perform
work as required or assigned
Violations of safety or health laws or regulations
or engaging in conduct that creates a safety or
health hazard
In addition, if you violate the law during the course of
your employment you may be subject to criminal and
civil penalties as well as payment of monetary
damages to the company or third parties.
Disciplinary action may be taken against an
employee or advisor who:
Authorizes, directs, approves, participates in or
encourages violations of the Code
Deliberately fails to report or conceals violations
or deliberately withholds or misstates relevant
information
Retaliates against any other employee because
he or she reported a suspected violation in good
faith
Knew or should have known about a violation by
people under his or her supervision and did not
promptly report it
We expect you to:
Talk to your leader or any of these resources
about any situation that concerns you:
Your Human Resources
business partner
Employee Relations Group Service Center –
1.877.267.4748
General Counsel’s Organization –
1.612.671.3651
Executive Vice President, Human Resources –
1.612.671.3997
Corporate Secretary’s Office –
1.612.678.0106
Ethics Hotline – 1.800.963.6395
Personal Trading Hotline – 1.612.671.5196
Suspicious Activity Hotline – 1.612.671.6166
Safe Call (UK) – 0800 915 1571
FCA Whistleblowing (UK) –
whistle@fca.gov.uk
Public Concern at Work (UK) –
helpline@pcaw.co.uk
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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
and Economic Sanctions Policy
Ameriprise Financial Personal Trading Policy
Ameriprise Financial Political Contributions ("Pay to
Play") Policy
Ameriprise Financial Public Appearances and
Interaction with the Media Policy
Antitrust Guidelines
Client Privacy Principles
Columbia Management Activities Involving Outside
Entities or Family Relationships Policy
Columbia Management Employee Registration and
Licensing
Columbia Management Firm Registration, Regulatory
Filings, and Disclosure Policy
Columbia Management Gifts, Entertainment and
Other Benefits Policy
Columbia Management International Compliance
Policy for Columbia Management Non-U.S. / Offshore
Sales and Service Activities
Columbia Management Material Nonpublic
Information Policy
Columbia Management Political Contributions Policy
Columbia Management Portfolio Holdings Disclosure
Policy
Columbia Management Privacy and Information
Security and Identity Theft Prevention Program
Conducting Competitive Intelligence Activities
Corporate Compliance Manual
Corporate Supervision Manual
Dual Registration Policy
Electronic Communication Acceptable Use Policy
Enterprise Abandoned Property Policy
Equal Employment Opportunity Policy
Facility Rules, Guidelines and Standards of Use
Fair Labor Standards Act
Gifts and Business Entertainment Policy -
Ameriprise Financial Services, Inc.
Gifts and Business Entertainment Policy - American
Enterprise Investment Services
Global Anti-Corruption Policy and Guidelines
Global Asset Management Code of Ethics Personal
Accounts Dealing Policy
Handling Whistleblower Claims Policy
HIPAA Policies and Procedures Manual
Identity Theft Prevention Policy
Individual Treatment Policy
Intellectual Property
Licensing and Registration
Mandatory Training: Annual Requirements
Mandatory Training: New-Hire Requirements
Notification to Consolidated Regulator of Intra-
Group Transactions Policy
Outside Business Activities Policy
Public Communications Policy
Record and Information Management
RiverSource Gifts, Entertainment and Benefits
Policy
Social Media Policy
Threadneedle Other Conflicts of Interest Policies
Applicable to Covered Persons
Threadneedle Market Abuse & Insider Dealing
Policy
Threadneedle Conflicts of Interest Policy
Threadneedle Outside Activities & Family
Relationships Policy
Threadneedle Gifts & Corporate Hospitality Policy
Threadneedle Treating Customers Fairly
Threadneedle Whistleblowing Policy
Your Guide to a Safe and Respectful Workplace
Policy Snapshot
Financial Planning | Retirement | Investments | Insurance
Ameriprise Financial, Inc.
Corporate Secretary’s Office
1098 Ameriprise Financial Center, Minneapolis, MN 55474
ameriprise.com
Revised July 1, 2017
© Ameriprise Financial, Inc. All rights reserved.
Notes
This document does not create a contract of employment or a contract for any specific term or condition of employment between Ameriprise Financial and an
employee. Except as provided otherwise by the laws of a foreign jurisdiction, the relationship between Ameriprise Financial and an employee is at-will,
meaning that either the employee or the company may terminate it at any time for any reason, with or without advance notice or progressive disciplinary
action. The company reserves the right to make changes in or discontinue company policies, compensation plans, benefits and programs as it deems
appropriate and these changes may be implemented even if they have not been communicated in this (or by change to this) document or otherwise.
If this document refers to any company benefit program, it describes only certain highlights of the company’s benefit program. It does not supersede the actual
provisions of the applicable plan documents, which in all cases are the final authority. The applicable plan administrator has the sole authority and discretion to
determining your eligibility to participate in the plan, interpret the plan documents and administer of the plans.
Ameriprise Financial takes reasonable efforts to ensure the accuracy of the contents of policy documents and in the administration of its policies and programs.
The company does not assume responsibility for consequential damages caused by administrative or clerical errors.