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                                                                  EX-99.CODE ETH

Advantus Index 500 Fund, Inc.
Exhibit 10(a)(1) to Form N-CSR


                                 ADVANTUS FUNDS
                   CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND
                            SENIOR FINANCIAL OFFICERS

I.       COVERED OFFICERS/PURPOSE OF THE CODE

         The Advantus Mutual Funds and Advantus Series Fund ("Advantus Funds")
code of ethics (this "Code") applies to the Advantus Funds' Principal Executive
Officer, Principal Financial Officer, and Principal Accounting Officer (the
"Covered Officers" each of whom are 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
         Securities and Exchange Commission ("SEC") and in other public
         communications made by the 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.

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, the
Advantus Funds. 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 with the Advantus Funds.

         Certain conflicts of interest arise out of the relationships between
Covered Officers and the Advantus 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 Advantus
Funds because of their status as "affiliated persons" of the Advantus Funds. The
Advantus Funds and the investment adviser, Advantus Capital Management
("Advantus

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Capital") 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 the Advantus Funds and Advantus Capital 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 Advantus Funds or for Advantus Capital, or for both), be involved in
establishing policies and implementing decisions that will have different
effects on Advantus Capital and the Advantus Funds. The participation of the
Covered Officers in such activities is inherent in the contractual relationship
between the Advantus Funds and Advantus Capital and is consistent with the
performance by the Covered Officers of their duties as officers of the Advantus
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. In addition, it is recognized by the Advantus
Funds' Boards of Directors ("Boards") 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. The overarching principle is that the
personal interest of a Covered Officer should not be placed improperly before
the interest of the Advantus Funds.

         Each Covered Officer must:
     -   not use his personal influence or personal relationships improperly to
         influence investment decisions or financial reporting by the Advantus
         Funds whereby the Covered Officer would benefit personally to the
         detriment of the Advantus Funds;

     -   not cause the Advantus Funds to take action, or fail to take action,
         for the individual personal benefit of the Covered Officer rather than
         the benefit the Advantus Funds;

     -   not use material non-public knowledge of portfolio transactions made or
         contemplated for the Advantus Funds to trade personally or cause others
         to trade personally in contemplation of the market effect of such
         transactions;

         There are some conflict of interest situations that should always be
reported to the Audit Committee of the Advantus Funds, if material. Examples of
these include:

     -   service as a director on the board of any public or private company;

     -   any ownership interest in, or any consulting or employment relationship
         with, any of the Advantus Funds service providers, other than its
         investment adviser, principal underwriter, administrator or any
         affiliated person thereof;

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     -   a direct or indirect financial interest in commissions, transaction
         charges or spreads paid by the Advantus Funds 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.

III.     DISCLOSURE AND COMPLIANCE

     -   Each Covered Officer should familiarize himself with the disclosure
         requirements generally applicable to the Advantus Funds;

     -   Each Covered Officer should not knowingly misrepresent, or cause others
         to misrepresent, facts about the Advantus Funds to others, whether
         within or outside the Advantus Funds, including to the Advantus Funds'
         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
         Advantus Funds and Advantus Capital with the goal of promoting full,
         fair, accurate, timely and understandable disclosure in the reports and
         documents the Advantus Funds file with, or submit to, the SEC and in
         other public communications made by the Advantus 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 thereafter as applicable, upon becoming a
         Covered Officer), affirm in writing to the Board that he has received,
         read, and understands the Code;

     -   annually thereafter affirm to the Board that he has complied with the
         requirements of the Code;

     -   not retaliate against any other Covered Officer or any employee of the
         Advantus Funds or their affiliated persons for reports of potential
         violations that are made in good faith;

     -   notify the Advantus Vice President and Director of Legal Services and
         the Audit Committee of the Advantus Funds Board promptly if he knows of
         any violation of this Code. Failure to do so is itself a violation of
         this Code; and

     -   report at least annually the following categories of affiliations or
         other relationships related to conflicts of interest:

              -  service as a director on the board of any public or private
                 company
              -  family relationship with any other director on the board
                 of a public or private company

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              -  any ownership interest in, or any consulting or employment
                 relationship with any of the Advantus Funds service providers
              -  a direct or indirect financial interest in commissions,
                 transaction charges or spreads paid by the Advantus Funds for
                 effecting portfolio transactions
              -  a material pending legal proceeding that would have a material
                 adverse affect to the Advantus Funds.


         The Advantus Vice President and Director of Legal Services 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. However, any approvals or waivers sought by the
   President of the Advantus Funds will be considered by the Audit Committee of
   the Advantus Funds Board.

         The Advantus Funds will follow these procedures in investigating and
   enforcing this Code:

     -   the Advantus Vice President and Director of Legal Services will take
         all appropriate action to investigate any potential violations
         reported to her;

     -   if, after such investigation, the Advantus Vice President and Director
         of Legal Services believes that no violation has occurred, then no
         further action is required;

     -   any matter that the Advantus Vice President and Director of Legal
         Services believes is a violation will be reported to the Audit
         Committee of the Advantus Funds Board;

     -   if the Audit Committee of the Advantus Funds Board concurs that a
         violation has occurred, it will consider appropriate action, which may
         include review of, and appropriate modifications to, applicable
         policies and procedures; notification to appropriate personnel of the
         Advantus Capital; or a recommendation to dismiss the Covered Officer;

     -   the Audit Committee of the Advantus Funds Board will be responsible for
         granting waivers, 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 Advantus
   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 Advantus Funds, Advantus Capital - the
   Funds' adviser, Securian Financial Services - principal underwriter, or other
   service providers govern or purport to govern the behavior or activities of
   the Covered Officers who are subject to this Code, they are superseded by
   this Code to the extent that they overlap or conflict with the provisions of
   this Code. The Advantus Funds', Advantus Capital's and Securian Financial
   Services code of ethics under Rule 17j-1 under the Investment Company

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   Act and the adviser's more detailed policies and procedures set forth in the
   Code of Ethics for Advantus Capital Management, Inc. and Affiliates are
   separate requirements applying to the Covered Officers and others, and are
   not part of this Code.

VI.      AMENDMENTS

         Any amendments to this Code, other than amendments to Exhibit A, must
   be approved or ratified by a majority vote of the Advantus Fund Board.

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 Advantus Fund Board,
   appropriate Fund Counsel, appropriate Minnesota Life associates, and
   appropriate Advantus Capital associates.

VIII.    INTERNAL USE

         The Code is intended solely for the internal use by the Advantus Funds
   and does not constitute an admission, by or on behalf of any Fund, as to any
   fact, circumstance, or legal conclusion.


   Date: July 24, 2003

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EXHIBIT A

                     PERSONS COVERED BY THIS CODE OF ETHICS

Dianne M. Orbison, President of the Advantus Funds (Principal Executive Officer)

Gary M. Kleist, Vice President and Treasurer of the Advantus Funds (Principal
Financial Officer)

Tamara J. Parks, Assistant Secretary of the Advantus Funds (Principal
Accounting Officer)