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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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