Attached files
| file | filename |
|---|---|
| EX-32.1 - EXHIBIT 32.1 - AMERIPRISE CERTIFICATE CO | ex321-ye16.htm |
| 10-K - 10-K - AMERIPRISE CERTIFICATE CO | acc123116.htm |
| EX-31.2 - EXHIBIT 31.2 - AMERIPRISE CERTIFICATE CO | ex312-ye16.htm |
| EX-31.1 - EXHIBIT 31.1 - AMERIPRISE CERTIFICATE CO | ex311-ye16.htm |
| EX-24.(A) - EXHIBIT 24.(A) - AMERIPRISE CERTIFICATE CO | a24apoadirectors.htm |
| EX-14.(C) - EXHIBIT 14.(C) - AMERIPRISE CERTIFICATE CO | a14cglobalcodeofconduct.htm |
| EX-10.(D) - EXHIBIT 10(D) - AMERIPRISE CERTIFICATE CO | ex10d-ye16.htm |
December 15, 2016
Global Asset Management – Personal Account Dealing/Code of Ethics Policy
1
AMERIPRISE GLOBAL ASSET MANAGEMENT
PERSONAL ACCOUNT DEALING AND
CODE OF ETHICS POLICY
Entities that have adopted – See Appendix A
December 15, 2016
Global Asset Management – Personal Account Dealing/Code of Ethics Policy
2
Table of Contents
Introduction – Standards of Business Conduct .............................................................................................................. 3
A. General Principles - Required Standard of Business Conduct ............................................................................ 3
B. Duty Owed to Clients .......................................................................................................................................... 3
C. Conflicts of Interest – Prevention and Management ............................................................................................ 4
D. Additional Standards of Conduct and Regulatory Requirements ........................................................................ 4
E. Reporting of Potential Code of Ethics or other Compliance Violations/Breaches ................................................ 5
F. Non-Compliance with the Policy .......................................................................................................................... 5
Applicability of Policy and General Requirements For all Covered Persons .................................................................. 5
A. Applicability and Scope of the Policy ................................................................................................................... 5
B. Insider Dealing Restrictions – Misuse of Material Nonpublic Information ............................................................ 6
C. Notification of Brokerage Accounts and Holding Brokerage Accounts at Designated Broker-Dealers ................ 7
Specific Personal Trading Restrictions For all Covered Persons ................................................................................... 7
A. Client Conflict – Prohibition on “Front Running” .................................................................................................. 7
B. Prior Approval (Pre-Clearance) of Personal Security Transactions..................................................................... 7
C. Short-Term Trading Prohibition (30 Day Holding Period) .................................................................................... 8
D. Initial Public Offerings (“IPOs”) and Limited Offerings ......................................................................................... 9
E. Participation in Investment Clubs ........................................................................................................................ 9
F. Derivatives .......................................................................................................................................................... 9
G. Frequent and Unusual Trading Activity ............................................................................................................... 9
Additional Trading Restrictions for Investment Employees .......................................................................................... 10
A. Rules Applicable to Portfolio Managers and other Designated Covered Persons ............................................. 10
14 Day Blackout Period ....................................................................................................................................... 10
B. Rules Applicable to Research Analysts ............................................................................................................. 10
C. Rules Applicable to Trading Personnel ............................................................................................................. 10
3 Day Blackout Period ......................................................................................................................................... 10
Reporting and Administration Requirements ............................................................................................................... 11
A. Reporting Requirements ................................................................................................................................... 11
B. Confidentiality.................................................................................................................................................... 11
C. Certification of Compliance with and Annual Review of Policy .......................................................................... 11
D. Resources ......................................................................................................................................................... 12
E. Recordkeeping Requirements ........................................................................................................................... 12
Appendix A – Entities that have adopted Global Policy ............................................................................................... 13
Appendix B – Other Policies Applicable to Covered Persons ...................................................................................... 14
Appendix C – Compliance and Reporting Resources .................................................................................................. 15
Appendix D – Individual Securities Requirements ....................................................................................................... 16
Appendix E – Covered Funds List ............................................................................................................................... 17
Appendix F – Options/Shorting Trading Guidelines ..................................................................................................... 18
Appendix G – Limited Choice Policy ............................................................................................................................ 19
December 15, 2016
Global Asset Management – Personal Account Dealing/Code of Ethics Policy
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Introduction – Standards of Business Conduct
A. General Principles - Required Standard of Business Conduct
The conduct of personal dealings in investments by Covered Persons (refer to Section A: Applicability
of Policy and Scope of Policy for definition of Covered Persons) employed by or affiliated with the
Ameriprise Global Asset Management Entities1 (the “Firms”) is a matter of the utmost importance to
the organization, its clients, its regulators and to employees themselves. It is essential that the Firms
appropriately manage access to privileged information concerning clients’ portfolios, the Firms’ trading
intentions and trading activities, and that the Firms discharge their duties in a way that does not harm
the interests of clients, the Firms or breach any legal or regulatory requirements. It is important that the
Firms are not seen to act on privileged information for personal gain.
B. Duty Owed to Clients
Various regulations applicable to the Firms impose a fiduciary duty to act in the exclusive best interest
of their clients at all times recognizing their role as a “Trusted Adviser”. A number of specific
obligations flow from the duty that is owed to clients, including:
• To act solely in the best interests of clients at all times.
• To make full and fair disclosure of all material facts, particularly where the Firms’ interests may
conflict with those of its clients.
• To act in a manner which satisfies the fiduciary duty owed to clients.
• To refrain from favoring the interest of a particular client over the interests of another client.
• To keep all information about clients (including former clients) confidential, including the
client’s identity, client’s securities holdings information, and other non-public information.
• To exercise a high degree of care to ensure that adequate and accurate representations and other
information is presented appropriately.
In connection with providing investment management services to clients, this includes prohibiting
any activity which directly or indirectly:
• Defrauds a client in any manner.
• Misleads a client, including any statement that omits material facts.
• Operates or would operate as a fraud or deceit on a client.
• Functions as a manipulative practice with respect to a client.
• Functions as a manipulative practice with respect to securities.
1 See Appendix A
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Specifically, the fiduciary duty owed to clients means the following outcomes must be achieved:
• To have a reasonable, independent basis for investment advice.
• To ensure that investment advice is suitable to the client’s investment objectives, needs and
circumstances.
• To refrain from effecting Personal Securities Transactions inconsistent with clients’ interests.
• To obtain best execution for clients’ securities transactions.
C. Conflicts of Interest – Prevention and Management
All Covered Persons must be vigilant in terms of identifying circumstances that may present a conflict
of interest. A conflict of interest is any situation that presents an incentive to act other than in the best
interest of a client or without objectivity. A conflict of interest may arise, for example, when a Covered
Person engages in a transaction that potentially favors:
(i) The Firms’ interests over a client’s interest
(ii) The interest of a Covered Person over a client’s interest
(iii)One client’s interest over another client’s interest
In addition to this Ameriprise Global Asset Management Personal Account Dealing and Code of Ethics
Policy (“Policy”), the Firms have adopted various policies designed to prevent, or otherwise manage,
conflicts of interest in contexts outside of personal trading (certain of these policies are listed in
Appendix B). To effectively manage conflicts of interest, all Covered Persons must seek to prevent
conflicts of interest, including the appearance of a conflict.
The requirements set forth in this Policy do not identify all possible conflicts of interest that may arise
in relation to personal transactions. Employees are encouraged to seek assistance from their local
Compliance resources (see Appendix C) whenever they have any questions concerning obligations
under the Policy, including conflicts of interest situations or concerns.
D. Additional Standards of Conduct and Regulatory Requirements
Covered Persons must comply with other policies adopted by the individual Ameriprise Global Asset
Management Entities that are intended to promote fair and ethical standards of business conduct and
comply with related regulatory requirements. These policies are listed in Appendix B.
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Global Asset Management – Personal Account Dealing/Code of Ethics Policy
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E. Reporting of Potential Code of Ethics or other Compliance Violations/Breaches
The Firms have various resources for Covered Persons to raise compliance issues and concerns on a
confidential basis (refer to Appendix C for a list of Compliance resources). In general, a Covered
Person should first discuss a compliance issue with their supervisor, department head, Chief
Compliance Officer, Compliance Executive, or other resource listed on Appendix C. In the event that a
Covered Person does not feel comfortable discussing compliance issues through these channels, the
employee may anonymously report suspected violations of law or company policy by contacting their
local resources (refer to Appendix C). Employees are encouraged to report these questionable practices
so that the Firms have an opportunity to address and resolve these issues before they become more
significant regulatory or legal issues.
F. Non-Compliance with the Policy
Violations/Breaches of this Policy are taken seriously and may result in disciplinary actions and/or
sanctions. Disciplinary actions could be up to and including termination of employment and sanctions
will vary depending on local requirements or the circumstances (e.g., depending on the severity of the
violation, if a record of previous violations exists, etc.).
Applicability of Policy and General Requirements For all Covered Persons
A. Applicability and Scope of the Policy
1. Employees, Contractors, Directors and others who are “Covered Persons”
This Policy applies to all Covered Persons. Covered Persons include:
• All Columbia Threadneedle employees and contractors.
• Any other individual with a specific role (including working on a project) which compels
Covered Person status due to access to proprietary information (e.g., holdings/transactions),
such as the member of a staff group that provides ongoing audit, technology, finance,
compliance, or legal support to Firms.
• Any other persons that may be deemed appropriate by Compliance.
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2. Applicability of Policy to Certain Household Members, Trusteeships and Executorships of
Covered Persons
This Policy governs a Covered Person’s personal securities transactions as well as those securities
transactions in which a Covered Person is deemed to have a direct or indirect Beneficial Ownership
and over which a Covered Person exercises direct or indirect influence or control (“Affiliated
Accounts”). An account generally is covered by this Policy if it is:
• In the Covered Person’s name
• In the name of the Covered Person’s spouse/partner and/or any financially dependent
members of the Covered Person’s household,
• Of a partnership in which the Covered Person or a member of his/her immediate family
is a partner with direct or indirect investment discretion
• Of a trust in which the Covered Person (or a member of his/her immediate family) is a
beneficiary and a trustee with direct or indirect investment discretion
• Of a closely held corporation in which the Covered Person or a member of his/her
immediate family holds shares and have direct or indirect investment discretion
It is the responsibility of the Covered Person to seek advice in the event that it is not clear whether
certain personal securities transactions are covered by this Policy.
B. Insider Dealing Restrictions – Misuse of Material Nonpublic Information
A Covered Person who is in possession of material nonpublic information (often referred to as “Inside
Information”) about securities or financial instruments is prohibited from buying, selling, recommending or
trading such securities or financial instruments. In addition, a Covered Person must not communicate or
disclose such information to others who may misuse it. Material nonpublic information may include
nonpublic information about a pooled investment vehicle (e.g., UCITS, open-end and closed-end mutual
funds, and private funds) that are advised or sub-advised by the Firm. The Firms each have adopted
specific policies that address these prohibitions, and set forth specific protocols for handling material
nonpublic information (see Appendix B which identifies the specific policies).
December 15, 2016
Global Asset Management – Personal Account Dealing/Code of Ethics Policy
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C. Notification of Brokerage Accounts and Holding Brokerage Accounts at
Designated Broker-Dealers (Limited Choice)
Covered Persons must promptly disclose their brokerage accounts to their Firm’s Compliance group,
and ensure that each broker-dealer with which he/she maintains an account sends to the Compliance
group, as soon as practicable, copies of all confirmations of his/her securities transactions and of
all monthly, quarterly and annual account statements.
North America employees must receive approval from Personal Trading Compliance prior to opening
any new brokerage account in order to comply with new FINRA Rule 3210.
Specific Personal Trading Restrictions For all Covered Persons
A. Client Conflict – Prohibition on “Front Running”
Covered Persons are prohibited from engaging in a Personal Securities Transaction that involves the
purchase or sale of a Reportable Security when such Covered Person has knowledge that such security
(1) is being considered for purchase or sale by a client account or (2) is being purchased or sold by a
client account.
B. Prior Approval (Pre-Clearance) of Personal Security Transactions
Covered Persons must obtain approval – often referred to as pre-clearance - from Compliance prior to
effecting a securities trade in most categories of investments. This pre-clearance requirement extends
to securities transactions in all accounts for which the Covered Person has Beneficial Ownership
(discussed above). If the Covered Person receives pre-clearance approval, it is valid only for the
duration of the locally defined approval period; if a Covered Person does not effect the pre-cleared
personal trade(s) within that locally approved time period, the Covered Person must request and obtain
pre-clearance for the proposed personal trade(s) again before the trade(s) are effected. If the Covered
Person does not receive pre-clearance approval, he/she must not effect the requested Personal Securities
Transaction (but may request approval on a subsequent day).
Covered Persons are required to obtain such pre-clearance approval for the majority of investments.
Please refer to Appendix D that identifies those categories of investments to which pre-clearance is or is
not applicable.
Private Placements/Limited Offerings: Investments in private placement offerings require approval by
the Compliance group (e.g., private placements, non-exchange traded REITs, hedge funds, fixed
income new issues, etc.).
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Gifts and Charitable Donations: Approval is not necessary for a gift of securities to a Non-Profit
Organization, but Compliance should be notified in advance and the Short-Term and 14-day Blackout
rules do not apply. For gifting securities to a For-Profit Organization, individual, trust or other person or
entity (other than a Non-Profit Organization), the pre-clearance requirement and 14-day Blackout rule
do apply if you are purchasing the securities you intend to give.
C. Short-Term Trading Prohibition (30 Day Holding Period)
1. Individual Securities at a Profit
Covered Persons are prohibited from engaging in short-term trading of Reportable Securities.
This means that Covered Persons may not buy (or add to their existing position), then sell the
same securities (or equivalent) within 30 calendar days if the trade would result in a gain.
Covered Persons must wait until calendar day 31 (Trade Date + 30) to trade out of a position at a
profit.
When calculating the 30-day holding period, the average cost method must be used.
2. Covered Funds and other Pooled Investment Vehicles
A Covered Person is prohibited from short term trading in any Covered Fund (e.g., mutual fund,
SICAV, OEIC, or other pooled investment vehicle, see Appendix E) held for less than 30 calendar
days, or a longer time if specified in the Covered Fund’s prospectus or similar disclosure
document. Covered Persons are prohibited from engaging in market timing (short-term trading)
in shares of any Mutual Fund or other pooled vehicles and must comply with the holding period
policy established by any Mutual Fund held, even though the Mutual Fund may not be a Covered
Fund. Please see the Mutual Fund’s prospectus for further information.
Transactions exempted from short-term trading prohibitions:
Money market fund investments, automated investments and withdrawal programs, and Dividend
Reinvestments are not subject to the 30 day holding period.
Please note that Columbia Threadneedle provides discounts on investments to employees in
certain of its products but operates a holding period of a minimum 60 working days in order to
qualify for those discounts. Please refer to the Columbia Threadneedle –EMEA and Asia
Compensation & Benefits intranet site for information.
December 15, 2016
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D. Initial Public Offerings (“IPOs”) and Limited Offerings
Covered Persons require pre-clearance approval to purchase Initial Public Offerings (“IPOs”) or
Limited Offerings, including additions to existing holdings but excluding capital calls for previously
approved commitments. Such approval will only be granted when it is established that there is no
conflict or appearance of a conflict with any Client or other possible impropriety (such as where the
Security in the Limited Offering is appropriate for purchase by a Client, or when his/her participation in
the Limited Offering is suggested by a person who has a business relationship with any such
Company or expects to establish such a relationship). The 30-day holding period also applies to
IPOs.
E. Participation in Investment Clubs
No Covered Person may participate in private investment clubs or other similar groups.
F. Derivatives
Covered Persons are strongly discouraged from investing in any form of derivative that could give rise
to an open ended, unlimited liability. Most derivative trading is subject to pre-clearance requirements,
option trading guidelines and the Short Term Trading Prohibition. (See Appendix F for additional
guidance).
G. Frequent and Unusual Trading Activity
Compliance monitors patterns of personal trading activity and may require additional information from
a Covered Person with respect to a specific trade or series of transactions. In addition, frequent trading
activity is strongly discouraged. Although no set limit of trades during a period of time is expressly
stated by the Firms, Covered Persons should understand that they may come under scrutiny for frequent
trading activity, which could result in corrective measures if the activity is deemed especially excessive.
December 15, 2016
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Additional Trading Restrictions for Investment Employees
A. Rules Applicable to Portfolio Managers and other Designated Covered Persons
14 Day Blackout Period
Portfolio Managers (and other Covered Persons specifically identified by Compliance) are not
permitted to transact in any security that is purchased or sold in a client account 7 calendar days before
and 7 calendar days after a client account they manage trades in that same (or equivalent) security. This
means a Portfolio Manager must wait until calendar day 8 to trade the security. Application of this
rule may be applied broader based on team function and location.
Because it is a Portfolio Manager’s responsibility to put his/her client’s interests ahead of his/her
own, he/she may not delay taking appropriate action for a client account in order to avoid potential
adverse consequences in his/her personal account. In certain limited instances, Compliance, at their
discretion, may determine that a trade should be deemed to have not caused a black out violation (e.g.,
unexpected significant client redemption or inflow triggering a sale or purchase in all securities held in
the client portfolio).
B. Rules Applicable to Research Analysts
Research Analysts (those who publish research for the use by Columbia Threadneedle) are prohibited
from engaging in a personal securities transaction that involves securities issued by issuers on their
Coverage List at the security (not issuer) level. This restriction includes securities convertible into,
options on, and derivatives of, such securities.
C. Rules Applicable to Trading Personnel
3 Day Blackout Period
Traders are not permitted to transact in any security that is purchased or sold in a client account 3
calendar days after the client transaction. This means a Trader must wait until calendar day 4 to
trade the security. Application of this rule may be adjusted based on team function and location.
December 15, 2016
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Reporting and Administration Requirements
A. Reporting Requirements
1. Initial Holdings Report and Certification: Upon becoming a Covered Person under this Policy, one
must disclose all securities holdings (as indicated in Appendix D) in which they have Beneficial
Ownership (as indicated on page 5 and 6). All brokerage accounts must be disclosed.
All Covered Persons are notified of this requirement and are provided with a copy of this Policy
when they first become subject to the Policy. This initial certification must be completed within 10
days of becoming a Covered Person. This information must be current as of the date no more than
45 days prior to the date the person becomes a Covered Person.
2. Annual Certification: Covered Persons are also required to complete an annual accounts and
holdings certification. This certification allows the Covered Person to validate the Brokerage
Accounts and certain securities holdings in which they have Beneficial Ownership (as indicated on
page 5 and 6). Covered Persons also certify that they have received, read and understand the Policy.
This information must be current as of a date no more than 45 days prior to the date the report was
submitted.
3. Quarterly Certification: On a quarterly basis, Covered Persons must also certify to securities
transactions outside of a previously reported and approved Brokerage Account. The quarterly
certification must be completed within 30 calendar days of the last day of the quarter.
B. Confidentiality
All reports and other documents and information supplied by or on behalf of any Covered Person in
accordance with the requirements of this Policy will be treated as confidential, but are subject to
review as provided herein and in the procedures by Legal, Compliance and other involved
departments of the Firms, by Personal Trading, senior management, by representatives relevant
regulatory authority of the asset management business’ regulatory or self-regulatory authority, or
otherwise as required by law, regulation, or court order.
C. Annual Review of Policy
At least annually, each Chief Compliance Officer/Compliance Executive of the Ameriprise Global
Asset Management Entities must review the adequacy of this Policy and the policies and procedures
herein referenced
December 15, 2016
Global Asset Management – Personal Account Dealing/Code of Ethics Policy
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D. Resources
Refer to Appendix C for Compliance and Legal resources.
E. Recordkeeping Requirements
Each respective Compliance group is primarily responsible for maintaining records created with respect
to this Policy and the procedures adopted to implement it. All records must be maintained for five
years after the end of the fiscal year in which the documents were later of creation or last use, the first
two years in an easily accessible place.
December 15, 2016
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Appendix A – Entities that have adopted Global Policy
Columbia Management Investment Advisers, LLC
Columbia Management Investment Distributors, Inc.
Columbia Management Investment Services, Corp.
Threadneedle Asset Management Holdings SARL (TAMHS)
Threadneedle Asset Management Ltd.
Threadneedle Asset Management Limited (TAML)
Threadneedle Asset Management Malaysia Sdn Bhd
Threadneedle International Limited
Threadneedle International Investment GmbH
Threadneedle International Limited (TINTL)
Threadneedle Investment Services Limited (TISL)
Threadneedle Investments Singapore (PTE) Limited (TIS)
Threadneedle Investments Taiwan Limited
Threadneedle Management Luxembourg SA. (TMLUX)
Threadneedle Management Services Limited
Threadneedle Navigator ISA Manager Limited (TNIML)
Threadneedle Pensions Limited (TPEN)
Threadneedle Portfolio Services Hong Kong Limited, Korea Representative Office
Threadneedle Portfolio Services Hong Kong Limited (TPSHKL)
Threadneedle Portfolio Services Limited (TPSL)
Threadneedle Unit Trust Manager Limited (TUTML)
It should be noted that Columbia Management includes Wanger Acorn trading data to also cover non- CWAM
employees under one consolidated Code.
December 15, 2016
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Appendix B – Other Policies Applicable to Covered Persons
Additional Policies Relevant to Covered Persons Employed by or Affiliated with Columbia Management:
Ameriprise Financial Global Code of Conduct
Ameriprise Handling Whistleblower Claims Policy
Ameriprise Limited Choice Policy
Columbia Management Activities Involving Outside Entities or Family Relationships Policy
Columbia Management Gifts, Entertainment and Other Benefits Policy
Columbia Management Material Nonpublic Information Policy
Columbia Management Political Contributions Policy
Columbia Management Portfolio Holdings Disclosure Policy
Columbia Management Privacy 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
Columbia Threadneedle Investments – EMEA and APAC Gifts, Entertainment and Other Benefits Policy
Threadneedle Treating Customers Fairly
Threadneedle Whistleblowing Policy
December 15, 2016
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Appendix C – Compliance and Reporting Resources
Personal Trading - 612-671-5196 or send email to Personal.Trading@ampf.com
Columbia Threadneedle EMEA and Asia Personal Trading
personalaccountdealing@columbiathreadneedle.com
Contact the Compliance Team if you are ever at doubt as to your obligations under this Policy.
Ameriprise Financial provides a dedicated resource through NAVEX Global (formerly known as
Ethicspoint) (800-963-6395), a comprehensive and confidential reporting service for U.S. employees to
report suspected fraud, abuse or other misconduct.
Threadneedle employees, in accordance with the Threadneedle Whistleblowing Policy, may contact the
following for reporting, investigating and remedying any wrongdoing in the workplace.
Safecall 0800 915
1571
FCA
whistleblowing
line
whistle@fca.gov.uk 020 7676
9200
Public Concern at
Work
helpline@pcaw.co.uk 020 7404
6609
December 15, 2016
Global Asset Management – Personal Account Dealing/Code of Ethics Policy
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Appendix D – Individual Securities Requirements
Pre-clearance Requirements – All securities are subject to prior approval under the Global Asset Management
Personal Account Dealing and Code of Ethics Policy (“Policy”) except those listed below:
• Ameriprise Financial Stock (other rules - blackout, holding periods still apply, no speculative trading)
• Annuities and Life Insurance (where there is no specific investment exposure)
• Bank products (checking/savings, CDs, etc.)
• Currencies
• Debt securities issued by any government
• Dividend Reinvestment Plans (DRIPS)
• Futures
• Money Market Funds
• Non Investment derivatives – sporting bets only
• Open-End Mutual Funds
• Columbia Threadneedle - EMEA and Asia Products*
• Unit Investment Trusts (UITs)
*Pre-clearance is required on Columbia Threadneedle – EMEA and Asia OEICS/SICAVS by FPDC/SPC members
Ameriprise 401(K) – Covered Persons must report Schwab PCRA accounts. ETF and Closed End Fund transactions
within these PCRA accounts also require pre-clearance.
Holding Reporting Requirements* – All securities are subject to the reporting requirements under the Policy,
including covered open-end funds, except those listed below:
• Annuities (report only Covered Funds listed on Appendix E)
• Bank products (checking/savings, CDs etc.)
• Currencies
• Debt securities issued by any government
• 529 plans
• Money Market Funds
• Open-End Mutual Funds (Note: Holdings of Covered Open – End Funds list on Appendix E are reportable in
the quarterly and annual certifications)
*All brokerage accounts are reportable even if the holdings in those accounts are not.
All other securities not listed above are subject to the Limited Choice Policy (Appendix G) and 30 Day Holding
Period.
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Appendix E – Covered Funds List
The Global Asset Management Personal Account Dealing and Code of Ethics Policy (“Policy”) speaks to certain
rules concerning activity within Covered Funds. Closed-End Funds, ETFs and Mutual Funds for which
Columbia Management Investment Advisers, LLC serves as an investment adviser or for which an affiliate
of Columbia Management Investment Advisers, LLC serves as principal underwriter are considered
“Covered Funds.”
The following is the list of Covered Funds as of December 2016:
• All Columbia Mutual Funds (both retail and variable), including Columbia Acorn Funds,
Wanger Funds, Active Portfolios® and CMG Ultra Short Term Bond Fund
• All Columbia Exchange-Traded Funds (ETFs)
• All Columbia Threadneedle – EMEA and Asia Funds
• Columbia Seligman Premium Technology Growth Fund, Inc.
• Tri-Continental Corporation
• Third-Party Funds Sub Advised by CMIA:
AC Alternatives Long Short Fund
AST Columbia Adaptive Risk Allocation Portfolio
Bishop Street Dividend Value Fund
Bishop Street Strategic Growth Fund
CGCM Large Cap Equity Fund
Mercer US Large Cap Growth Equity Fund
SA Columbia Focused Growth Portfolio
SA Columbia Focused Value Portfolio
SunAmerica Series Trust Technology Portfolio
VALIC Company I Large Cap Core Fund
Voya Multi-Manager Large Cap Core Portfolio
VY Columbia Contrarian Core Portfolio
VY Columbia Small Cap Value II Portfolio
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Appendix F – Options/Shorting Trading Guidelines
SHORTING TRADING – GENERAL GUIDELINES
Shorting individual securities is prohibited. Shorting broad based market securities (ETFs) is permitted.
OPTIONS TRADING – GENERAL GUIDELINES
All persons subject to the Global Asset Management Personal Account Dealing and Code of Ethics Policy
(“Policy”) are strongly discouraged from dealing in any form of derivative that could give rise to an open
ended, unlimited liability.
All Covered Persons must obtain pre-clearance via PTA prior to placing an options trade.
Short term trading at a profit is prohibited under the code. Covered Persons may not trade options that will
result in a gain if held less than 30 days. Covered Persons must wait trade date plus 30 days before closing
the position at a profit.
ACCEPTABLE TRANSACTIONS:
• Options that have an expiration greater than 30 days and
• Out of the money option contracts
• In the money option contracts only if there is an underlying position held greater than 30 days
PROHIBITED TRANSACTIONS:
• Options that have an expiration less than 30 days
• In the money option contracts – unless there is an underlying position held greater than 30 days
• Buying and selling options contracts at a profit held less than 30 days
KEY REMINDERS:
• Covered Persons are required to preclear the option ticker symbol (please use the new option
symbology) and not the underlying ticker.
• Covered Persons are responsible for calculating the 30 day holding period (Trade date + 30 days),
you must use the average cost method (PTA does not calculate the 30 day holding period).
• Receiving pre-clearance does not exclude you from other personal trading rules included in the
Policy.
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Appendix G – Limited Choice Policy
In order to comply with SEC expectations concerning the monitoring of trading activity within Covered
Person accounts, Ameriprise Financial maintains a “limited choice” brokerage policy which dictates where
certain types of securities must be held and traded.
Unless you have an exception approved by Personal Trade Compliance, your personal securities must
be held and trading must be conducted through one of these brokers:
Ameriprise/Columbia Threadneedle North America- Ameriprise Financial Brokerage, Charles
Schwab, Merrill Lynch
Columbia Threadneedle EMEA and Asia – Barclays, Hargreaves Lansdowne, Equiniti, Interactive
Brokers, UOB Kay Hian, DBS Bank of Singapore, (Charles Schwab and Merrill Lynch – restricted to
U.S based accounts only)
You must immediately* report any new accounts opened by completing the following steps:
1. Add the account to the PTA system using the “Add Brokerage Account” functionality.
2. Notify your broker of your association with Ameriprise Financial or Columbia Threadneedle. You
are responsible for notifying your broker that you are affiliated with or employed by a
broker/dealer and ensuring that Personal Trade Compliance is provided with duplicate statements
and confirmations for your account(s).
* North America employees must receive approval from Personal Trading Compliance prior to
opening any new brokerage account in order to comply with new FINRA rule 3210.
The types of securities that are subject to the Limited Choice Policy are specified on the Individual
Securities Requirements List Appendix D.
If you maintain a Brokerage Account outside of the limited choice brokers that holds securities subject to
the limited choice policy, you have the following options:
1. You may transfer the subject holdings to a like-ownership account at one of the approved brokers.
2. You may liquidate the subject holdings (subject to the requirements in the Code) and either hold
the proceeds as cash or reinvest in non-subject securities.
3. You may apply for an exception.
Exceptions to the Limited Choice Policy are rare. If you believe your situation warrants an exception (e.g.
managed discretionary accounts), contact Personal Trading for a Limited Choice Exception Request Form.
An exception does not make you exempt from complying will all other requirements in Global Asset
Management Personal Account Dealing and Code of Ethics Policy (“Policy”).