Personal trading rules & procedures and insider trading policy
Personal trading rules & procedures
Ameriprise Financial has adopted personal trading rules and procedures within the Ameriprise Financial Code of Ethics and Personal Trading Policy. These rules are designed to list standards of business conduct and to mitigate potential conflicts of interest for all persons of Ameriprise Financial when they engage in personal securities transactions. You may request a copy of the Ameriprise Financial Code of Ethics and Personal Trading Policy from your financial advisor or by contacting us at 800.862.7919.
The standards of business conduct include compliance with applicable laws and regulations and with policies and procedures, such as those contained in the Ameriprise Global Code of Conduct. Under the personal trading rules, persons are required to report their personal securities holdings and transactions, including transactions in certain mutual funds; must pre-clear certain investments; are restricted with respect to the timing of certain investments; and are prohibited from making certain investments. In addition, the Personal Trading Policy requires Ameriprise employee financial advisors and their employees, its independent contractor franchisee financial advisors and their employees, and its affiliated investment advisers to conduct most personal trades through one of three designated broker-dealers unless an exception has been granted and report any changes in their selected broker-dealer.
Insider trading policy
Ameriprise Financial and its related persons may come into possession of material nonpublic information that, if disclosed, might affect an investor’s decision to buy, sell or hold a security.
Under applicable law, Ameriprise Financial and its related persons are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is a client. Accordingly, should Ameriprise Financial or its related persons come into possession of material nonpublic information with respect to any company, they may be prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, their clients when following policies and procedures designed to comply with law. Ameriprise Financial and its affiliates have adopted an “Insider Trading Policy” in accordance with Section 204A of the Advisers Act that establishes procedures to prevent the misuse of material nonpublic information by Ameriprise Financial and its associated persons.