<Page>
EX-99.CODE ETH
Advantus Enterprise 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
<Page>
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;
<Page>
- 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
<Page>
- 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
<Page>
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
<Page>
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)