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Exhibit-99.CODE ETH
CODE OF ETHICAL CONDUCT
OF
FIRST AMERICAN FUNDS, INC.
FIRST AMERICAN INVESTMENT FUNDS, INC.
FIRST AMERICAN STRATEGY FUNDS, INC.
FIRST AMERICAN INSURANCE PORTFOLIOS, INC.
AMERICAN MUNICIPAL INCOME PORTFOLIO INC.
MINNESOTA MUNICIPAL INCOME PORTFOLIO INC.
FIRST AMERICAN MINNESOTA MUNICIPAL INCOME FUND II, INC.
AMERICAN INCOME FUND, INC.
AMERICAN STRATEGIC INCOME PORTFOLIO INC.
AMERICAN STRATEGIC INCOME PORTFOLIO INC. II
AMERICAN STRATEGIC INCOME PORTFOLIO INC. III
AMERICAN SELECT PORTFOLIO INC.
I. COVERED OFFICERS/PURPOSE OF THE CODE
The First American Funds' Code of Ethical Conduct (this "Code") for the
investment companies within the complex (collectively, "Funds" and each,
"Company") applies to each such Company's officers (the "Covered Officers", a
list of which is set forth in Exhibit A) for the purpose of promoting:
- 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 registrant files with, or submits to,
the SEC and in other public communications made by a Company;
- compliance with applicable laws and governmental rules and
regulations;
- 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.
The Code also applies to each Covered Officer's immediate family
members as long as they are living in the same household. Therefore, for
purposes of interpretation, each obligation, requirement or prohibition that
applies to a Covered Officer also applies to such Covered Officer's family
members.
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Currently, all Covered Officers are employees of affiliated Company
service providers- the Funds' investment advisor and co-administrator, U.S.
Bancorp Asset Management, Inc. ("USBAM"), and the Funds' other co-administrator,
U.S. Bancorp Fund Services ("USBFS"). The phrase "Covered Officers" does not
include partners of Dorsey & Whitney, the Funds' outside counsel.
II. COVERED OFFICERS SHOULD HANDLE ETHICALLY ACTUAL AND APPARENT CONFLICTS
OF INTEREST
OVERVIEW. A "conflict of interest" occurs when a Covered Officer's
private interest interferes with the interests of, or his service to, a Company.
For example, a conflict of interest would arise if a Covered Officer, or a
member of his family, receives improper personal benefits as a result of his
position in the Company.
Certain conflicts of interest covered by this Code arise out of the
relationships between Covered Officers and a Company 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 Company because of their status as "affiliated persons" of a
Company. The Company's and USBAM's compliance programs and procedures 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 a Company and USBAM/USBFS 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 a
Company or for the adviser/administrator, or for all), be involved in
establishing policies and implementing decisions which will have different
effects on the adviser/administrator and the Company. The participation of the
Covered Officers in such activities is inherent in the contractual relationship
between the Company and the adviser/administrator and is consistent with the
performance by the Covered Officers of their duties as officers of a Company.
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. In addition, it is recognized by the Funds' Board of
Directors that the Covered Officers may also be officers or employees of one or
more other investment companies covered by this or other Codes.
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.
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THE OVERARCHING PRINCIPLE IS THAT THE PERSONAL INTEREST OF A COVERED OFFICER
SHOULD NOT BE PLACED IMPROPERLY BEFORE THE INTEREST OF A COMPANY.
Each Covered Officer must:
- not use his personal influence or personal relationships
improperly to influence investment decisions or financial
reporting by a Company whereby the Covered Officer would benefit
personally;
- not cause a Company to take action, or fail to take action, for
the individual personal benefit of the Covered Officer rather than
the benefit of such Company;
- not intentionally or recklessly take or direct any action or
failure to act that results in any SEC filing or other public
Company communication being materially misleading, while
personally benefiting such Covered Officer; and,
- not request cash or gifts, including any entertainment or similar
benefit, from any firm or party, with which a Company has current
or prospective business dealings, including Company directors,
Fund affiliates and service providers.
There are some conflicts of interest situations that should always be
reviewed with the adviser's General Counsel. These include, but are not limited
to:
- the receipt of cash or GIFTS IN EXCESS OF $100 from any one firm
or party, including Company directors, Fund affiliates and service
providers, with which a Company has current or prospective
business dealings;
- the receipt of any ENTERTAINMENT OR SIMILAR BENEFIT from any firm
or party, including Company directors, Fund affiliates and service
providers, with which a Company has current or prospective
business dealings unless such entertainment is reasonable in cost,
appropriate as to time and place, includes a representative of the
firm or party, and not so frequent as to raise any question of
impropriety;
- any ownership interest in, or any consulting or employment
relationship with, any Company service providers, other than its
investment adviser, principal underwriter, administrator or any
affiliated person thereof; and
- a direct or indirect financial interest in commissions,
transactions charges or spreads paid by a Company for effecting
portfolio transactions or for selling or redeeming shares other
than an interest arising from the Covered Officer's employment,
such as compensation or equity ownership.
In all instances, Covered Officers are expected to use reason,
judgement and common sense to avoid any question or appearance of impropriety.
Covered Officers should seek the assistance of the adviser's General Counsel in
case of questions.
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III. DISCLOSURE AND COMPLIANCE
- Each Covered Officer must familiarize himself with the disclosure
requirements generally applicable to a Company;
- each Covered Officer should not knowingly misrepresent, or cause
others to misrepresent, facts about a Company to others, whether
within or outside a Company, including to a Company's directors
and auditors, and to governmental regulators and self-regulatory
organizations;
- each Covered Officer should, to the extent appropriate within his
area of responsibility, consult with other officers and employees
of the Funds and the adviser 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.
IV. REPORTING AND ACCOUNTABILITY
Each Covered Officer must:
- upon adoption of the Code or upon being made subject to the Code,
affirm in writing to the Funds' Board that such Covered Officer
has received, read, and understands the Code;
- annually affirm in writing to the Funds' Board that such Covered
Officer has complied with the requirements of the Code;
- annually report in writing to USBAM's Compliance Department all
affiliations that might give rise to a conflict of interest with
respect to such person's status as a Covered Officer;
- quarterly report to USBAM's Compliance Department the following:
- all cash and gifts with a value in excess of $100 received
from any firm or party that has current or prospective
business dealings with a Company;
- all receipt of any entertainment or similar benefit from any
firm or party, including Company directors, Fund affiliates
and service providers, with which a Company has current or
prospective business dealings;
- not retaliate against any Fund affiliate employee, service
provider employee or Covered Officer for reports of potential
violations that are made in good faith; and
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- notify USBAM's General Counsel promptly if he knows of any
violation of this Code. Failure to do so is itself a violation of
this Code.
USBAM's 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. In doing so, such
General Counsel is authorized and encouraged to consult with Company counsel and
counsel to the Company's independent directors. However, approvals,
interpretations, or waivers sought by a Company's President will be considered
by such Company's Qualified Legal Compliance Committee (the "Committee").
The Funds will follow these procedures in investigating and enforcing
this Code:
- the General Counsel will take all appropriate action to
investigate any violations and potential violations reported to
it;
- if, after such investigation, the General Counsel reasonably
believes that no violation has occurred, the General Counsel is
not required to take any further action and such conclusion will
be documented and reported to the Committee at its next regularly
scheduled meeting;
- any matter the General Counsel believes is a violation will be
reported in writing to the Committee;
- if the Committee concurs that a violation has occurred, it will
inform and make a recommendation to the Board, which will consider
appropriate action, which may include review of, and appropriate
modifications to, applicable policies and procedures; notification
of the appropriate supervisory executives of either the investment
adviser, the applicable service provider, or any applicable parent
company thereof; or a recommendation to dismiss the Covered
Officer;
- the Committee will be responsible for granting waivers (defined as
a material departure from a provision of this Code), as
appropriate; and
- any changes to or waivers of this Code will, to the extent
required, be disclosed as provided by SEC rules.
V. 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. USBAM's code of ethics
under Rule 17j-1 under the Investment Company Act, USBAM's more detailed
operational and regulatory compliance policies and procedures, and U.S.
Bancorp's Code of Ethics are separate requirements applying to the Covered
Officers and others, and are not specifically a part of this Code.
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VI. AMENDMENTS
Any amendments to this Code, other than amendments to Exhibit A, must
be approved or ratified by a majority vote of the Company's board, including a
majority of independent directors.
VII. CONFIDENTIALITY
All reports and records prepared or maintained pursuant to this Code
will be considered confidential and shall be maintained and protected
accordingly. Except as otherwise required by law or this Code, such matters
shall not be disclosed to anyone other than the Company Board, Company counsel,
counsel to the independent directors, USBAM's Compliance Department, and the
appropriate senior managers of USBAM and its affiliates.
VIII. INTERNAL USE
The Code is intended solely for the internal use by the Funds and does
not constitute an admission, by or on behalf of any Company, as to any fact,
circumstance, or legal conclusion.
Date: 2003
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