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:
i. 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;
ii. annually thereafter affirm to the Boards that he or she has
complied with the requirements of the Code;
iii. 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
iv. 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;
v. will take all appropriate action to investigate such reported
violations;
vi. 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