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                                                             Exhibit-99.CODE ETH

Advantus Cornerstone 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)