Exhibit (a)(1)
Ex. 99.CODE ETH.
RIVERSOURCE FUNDS
CODE OF ETHICS
FOR
PRINCIPAL EXECUTIVE AND SENIOR FINANCIAL OFFICERS
PURPOSE OF THE CODE; COVERED OFFICERS
This code of ethics ("Code") for the RiverSource Funds (collectively, "Funds,"
and each, "Fund") applies to the Funds' Principal Executive Officer and
Principal Financial Officer (the "Covered Officers," each of whom is identified
in Exhibit A) for the purpose of promoting, in connection with his or her
duties:
- honest and ethical conduct, including the ethical handling of
actual or apparent conflicts of interest between personal and
professional relationships;
- full, fair, accurate, timely, and understandable disclosure in
reports and documents that a Fund files with, or submits to, the
Securities and Exchange Commission ("SEC") and in other public
communications made by the Funds;
- compliance with laws and governmental rules and regulations
applicable to the conduct of the Funds' business and their
financial reporting;
- the prompt internal reporting of violations of the Code to an
appropriate person or persons identified in the Code; and
- accountability for adherence to the Code.
Each Covered Officer should adhere to a high standard of business ethics and
should be sensitive to situations that may give rise to actual as well as
apparent conflicts of interest.
COVERED OFFICERS SHOULD HANDLE ETHICALLY ACTUAL AND APPARENT CONFLICTS OF
INTEREST
A "conflict of interest" occurs when a Covered Officer's private interest
interferes with the interests of, or his or her service to, the Funds. For
example, a conflict of interest would arise if a Covered Officer, or a member of
his or her family, receives improper personal benefits as a result of his or her
position with the Funds.
Certain conflicts of interest arise out of the relationships between Covered
Officers and the Funds and already are subject to conflict of interest
provisions in the Investment Company Act of 1940 ("Investment Company Act") and
the Investment Advisers Act of 1940 ("Investment Advisers Act"). For example,
Covered Officers may not individually engage in certain transactions, such as
the purchase or sale of securities or other property, with the Funds because of
their status as "affiliated persons" of the Funds. The compliance programs and
procedures of the Funds and of Ameriprise Financial, Inc. and its affiliates
("Ameriprise") are designed to prevent, or identify and correct, violations of
these provisions. This Code does not, and is not intended to, repeat or replace
these programs and procedures, and such conflicts fall outside of the parameters
of this Code.
Although typically not presenting an opportunity for improper personal benefit,
conflicts arise from, or as a result of, the contractual relationship between
the Funds and Ameriprise, of which the Covered Officers are also officers or
employees. As a result, this Code recognizes that the Covered Officers will, in
the normal course of their duties, whether formally for the Funds or for
Ameriprise, or for both, be involved in establishing policies and implementing
decisions that will have different effects on Ameriprise and the Funds. The
participation of the Covered Officers in such activities is inherent in the
contractual relationship between the Funds and Ameriprise and is consistent with
the performance by the Covered Officers of their duties as officers of the
Funds.
Thus, if performed in conformity with the provisions of the Investment Company
Act and the Investment Advisers Act, such activities will be deemed to have been
handled ethically.
Other conflicts of interest are covered by the Code, even if such conflicts
of interest are not subject to provisions in the Investment Company Act and the
Investment Advisers Act. The following list provides examples of conflicts of
interest under the Code, but Covered Officers should keep in mind that these
examples are not exhaustive. The overarching principle is that the personal
interest of a Covered Officer should not be placed improperly before the
interest of the Funds.
Each Covered Officer must:
- not use his or her personal influence or personal relationships
improperly to influence investment decisions or financial
reporting by the Funds whereby the Covered Officer would benefit
personally to the detriment of the Funds;
- not cause the Funds to take action, or fail to take action, for
the individual personal benefit of the Covered Officer rather
than the benefit of the Funds; and
- not use material non-public knowledge of portfolio transactions
made or contemplated for the Fund to trade personally or cause
others to trade personally in contemplation of the market effect
of such transactions.
DISCLOSURE AND COMPLIANCE
Each Covered Officer
- should familiarize himself or herself with the disclosure
requirements generally applicable to the Funds;
- should not knowingly misrepresent, or cause others to
misrepresent, facts about the Funds to others, whether within or
outside the Funds, including any member of the Board of Directors
or Board of Trustees of any Fund ("Boards"), auditors,
governmental regulators, and representatives of self-regulatory
organizations;
- should, to the extent appropriate within his or her area of
responsibility, consult with other officers and employees of the
Funds and Ameriprise with the goal of promoting full, fair,
accurate, timely, and understandable disclosure in the reports
and documents the Funds file with, or submit to, the SEC and in
other public communications made by the Funds; and
It is the responsibility of each Covered Officer to promote compliance with
the standards and restrictions imposed by applicable laws, rules, and
regulations.
REPORTING AND ACCOUNTABILITY
Each Covered Officer must:
- upon adoption of the Code (or thereafter as applicable, upon
becoming a Covered Officer), affirm in writing to the Boards that
he or she has received, read, and understands the Code;
- annually thereafter affirm to the Boards that he or she has
complied with the requirements of the Code;
- not retaliate against any other Covered Officer or any employee
of Ameriprise for reports of potential violations that are made
in good faith; and
- notify the Funds' General Counsel promptly if he or she knows of
any violation of this Code. Failure to do so is itself a
violation of this Code.
APPLYING THE CODE
The Funds' General Counsel is responsible for applying this Code to
specific situations in which questions are presented under it and has the
authority to interpret this
Code in any particular situation. Any approvals or waivers sought by a Covered
Officers will be considered by each Board or appropriate committee of the Board.
The Funds' General Counsel
- shall notify the Boards whenever any evidence of a material
violation has been reported, it being understood that the Funds'
General Counsel may determine whether to provide such notice
immediately or at the next meetings of the Boards based on the
nature of the violation;
- will take all appropriate action to investigate such reported
violations;
- shall make a determination after the investigation and
- if the Funds' General Counsel believes that no violation has
occurred, the Boards will be so notified and no further
action is required;
- if the Funds' General Counsel believes a violation has
occurred, the matter shall be reported to the Boards or the
committees of the Funds affected by the potential violation
for further determination;
- if the Boards or the committees determine that a violation
has occurred the Boards will consider appropriate action,
which may include: a review of applicable policies and
procedures; the appropriate modifications to such policies
and procedures; the notification to appropriate personnel of
the investment adviser or its board; or a recommendation to
dismiss the Covered Officer;
- will cause to be made such disclosures as are required by SEC
rules if any changes to or waivers of this Code is made by the
Boards; and
- shall maintain a record of each reported evidence of material
violation, the response thereto, and all related correspondence
for a period of not less than 10 years.
OTHER POLICIES AND PROCEDURES
This Code shall be the sole code of ethics adopted by the Funds for
purposes of Section 406 of the Sarbanes-Oxley Act and the rules and forms
applicable to registered investment companies thereunder. Insofar as other
policies or procedures of the Funds or Ameriprise govern or purport to govern
the activities of the Covered Officers, they are
superseded by this Code to the extent that they overlap or conflict with the
provisions of this Code. Ameriprise's code of ethics under Rule 17j-1 under the
Investment Company Act is a separate requirement applying to the Covered
Officers and others, and is not part of this Code.
AMENDMENTS
Any amendments to this Code, other than amendments to Exhibit A, must be
approved or ratified by a majority vote of each Fund's Board, including a
majority of its independent directors.
Adopted: July 9, 2003; Amended: April 12, 2006
EXHIBIT A
Persons Covered by this Code of Ethics:
Patrick T. Bannigan
President
Jeffrey P. Fox
Treasurer
Paula R. Meyer*
William F. Truscott**
* Until August 5, 2006.
** Until November 9, 2006.