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.(B) - EXHIBIT 14.(B) - AMERIPRISE CERTIFICATE CO | a14bcoecmia.htm |
| EX-10.(D) - EXHIBIT 10(D) - AMERIPRISE CERTIFICATE CO | ex10d-ye16.htm |
Global Code of Conduct
OUR VALUES
Client-focused Integrity
always
Excellence Respect
2
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 two full business days 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.
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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
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 an original signature of the client or his or
her legally authorized representative.
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
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 | CONSEQUENCES FOR NON-COMPLIANCE | NAVIGATE YOUR ETHICAL QUESTIONS | 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 January 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.