AXP STRATEGY SERIES INC
485APOS, EX-99, 2001-01-05
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                                EXHIBIT INDEX

(p)(3)    Code of Ethics adopted under Rule 17j-1 by AXP Small Cap Growth Fund's
          subadvisor INVESCO Funds Group Inc.

(p)(4)    Code of Ethics adopted under Rule 17j-1 by AXP Small Cap Growth Fund's
          subadvisor Neuberger Berman Management Inc.

(p)(5)    Code of Ethics adopted under Rule 17j-1 by AXP Small Cap Growth Fund's
          subadvisor RS Investment Management, L.P.


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