Exhibit 14.1

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                  CORPORATE CODE OF BUSINESS ETHICS AND CODUCT

Introduction

Frontline Ltd. (the "Company" or "Frontline") and all entities controlled by the
Company  have a strong  commitment  to  promoting  honest  conduct  and  ethical
business  conduct by all Employees (as defined  below) and  compliance  with the
laws that  govern  the  conduct of our  business  worldwide.  We believe  that a
commitment to honesty,  ethical  conduct and integrity is a valuable  asset that
builds trust with our  customers,  suppliers,  employees,  shareholders  and the
communities in which we operate. To implement our commitment,  we have developed
a code of business ethics and conduct (the "Code").  This Code has been designed
to deter  wrongdoing  and to promote honest and ethical  conduct,  including the
ethical  handling of actual or apparent  conflicts of interest  between personal
and professional  relationships and avoidance of conflicts of interest. The Code
establishes  rules and  standards  regarding  behavior and  performance  and any
violation of the rules and  standards  embodied in the Code is not tolerated and
will subject those responsible to disciplinary action.

The Code applies to all entities  controlled  by the Company and all  employees,
directors, officers and agents of the Company (collectively,  "Employees").  All
Employees  are required to read and  understand  the Code and certain  Employees
will be required to provide a  certification  to that effect.  We encourage  all
Employees to ask questions regarding the application of the Code.  Employees may
direct such questions to their manager (in the absence of an actual or potential
conflict of interest), an officer of the Company or to a Board member.

Employees  individually are ultimately responsible for their compliance with the
Code.  Every manager will also be responsible for  administering  the Code as it
applies to Employees and operations within each manager's area of supervision.

Employees  who observe or become aware of a situation  that they believe to be a
violation  of the Code have an  obligation  to notify  their  manager or a Board
member unless the Code directs otherwise.  Violations involving a manager should
be reported  directly to a Board member.  When a manager  receives a report of a
violation,  it will be the  manager's  responsibility  to handle  the  matter in
consultation with a Board member. If an Employee reporting a violation wishes to
remain  anonymous,  all  reasonable  steps will be taken to keep their  identity
confidential.  All communications will be taken seriously and, if warranted, any
reports of violations will be investigated.

Procedures Regarding Waivers

Because of the importance of the matters involved in this Code,  waivers will be
granted only in limited  circumstances and where and circumstances would support
a waiver. Waivers of the Code may only be made by the Board.

                                                          The Board of Directors

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                  CORPORATE CODE OF BUSINESS ETHICS AND CODUCT

Compliance with Laws, Rules and Regulations

All Employees are  responsible  for complying  with the various laws,  rules and
regulations  of  the  countries  and  regulatory  authorities  that  affect  the
Company's business. Questions with respect o your duties under the law should be
directed to your manager.

Honest and Fair Dealing

Employees  must  endeavor  to deal  honestly,  ethically  and  fairly  with  the
Company's customers,  suppliers,  competitors and employees.  No Employee should
take unfair  advantage of anyone  through  manipulation,  concealment,  abuse of
privilege  information,  misrepresentation  of  material  facts,  or  any  other
unfair-dealing practice.

Conflict of Interest and Corporate Opportunity

Employees must:

a)   avoid any interest that conflicts or appears to conflict with the interests
     of the Company or that could reasonably be determined to harm the Company's
     reputation and

b)   report any actual or potential conflict of interest (including any material
     transaction or relationship  that reasonably could be expected to give rise
     to such conflict) immediately to their manager or a Board member and adhere
     to instructions concerning how to address such conflict of interest.

A  conflict  of  interest  exists  if  actions  by any  Employee  are,  or could
reasonably  appear  to  be,  influenced   directly  or  indirectly  by  personal
considerations, duties owed to persons or entities other than the Company, or by
actual or potential personal benefit or gain.

Employees owe a duty to advance the legitimate interests of the Company when the
opportunities to do so arise.  Employees may not take for themselves  personally
opportunities  that  are  discovered  through  the  use of  corporate  property,
information or position.

Confidentiality and Privacy

It is important  that you protect the  confidentiality  of Company  information.
Employees may have access to propriety and confidential  information  concerning
the Company's business, clients and suppliers. Confidential information includes
such  items  as  non-public   information  concerning  the  Company's  business,
financial results and prospects and potential corporate transactions.  Employees
are required to keep such information  confidential during employment as well as
thereafter,   and  not  to  use,  disclose,  or  communicate  that  confidential
information  other than in the course of  employment.  The  consequences  to the
Company and the Employee  concerned  can be severe  where there is  unauthorized
disclosure of any non-public, privileged or proprietary information.

To ensure the  confidentiality  of any  personal  information  collected  and to
comply with applicable laws, any Employee in possession of non-public,  personal
information about the Company's customers,  potential  customers,  or Employees,
must maintain the highest  degree of  confidentiality  and must not disclose any
personal information unless authorization is obtained.

Proper Use of Company Assets

The Company's  assets are only to be used for legitimate  business  purposes and
only by authorized Employees or their designees. This applies to tangible assets
(such as office equipment, telephone, copy machines, etc.) and intangible assets
(such  as  trade  secrets  and  confidential  information).   Employees  have  a
responsibility to protect the Company's assets from theft and loss and to ensure
their efficient use. Theft,  carelessness  and waste have a direct impact on the
Company's  profitability.  If you become aware of theft,  waste or misuse of the
Company's assets you should report this to your manager.

Corporate communications policy

Only certain  designated  Employees may discuss the Company with the news media,
securities analysts and investors.  All inquiries from regulatory authorities or
government  representatives  should  be  referred  to the  appropriate  manager.
Employees  exposed to media  contact when in the course of  employment  must not
comment on rumours or speculation regarding the Company's activities.

Securities Trading

Investment by Employees in Frontline securities is encouraged.  However, because
we are a public  company  we are  subject  to a number  of laws  concerning  the
purchase of our shares and other  publicly  traded  securities.  Company  policy
prohibits  Employees and their family members from trading  securities  while in
possession of material,  non-public  information  relating to the Company or any
other  company,  including  a  customer  or  supplier  that  has  a  significant
relationship with the Company.

Information  is  "material"  when  there  is a  substantial  likelihood  that  a
reasonable investor would consider the information important in deciding whether
to buy, hold or sell securities. In short, any information that could reasonably
affect the price of  securities  is material.  Information  is  considered to be
"public"  only  when it has been  released  to the  public  through  appropriate
channels and enough time has elapsed to permit the  investment  market to absorb
and  evaluate the  information.  If you have any doubt as to whether you possess
material nonpublic  information,  you should contact your manager, an officer of
the Company or the Company's representative in charge of insider trading matters
and the advice of legal counsel may be sought.

Directors,  officers and senior  managers  ("primary  insiders")  are subject to
various  reporting  and  insider  trading  requirements.  Primary  insiders  are
required  to  obtain  clearance  in  advance  of  any  contemplated   securities
transactions  from the  Company's  representative  in charge of insider  trading
matters  or the  Board  and are also  required  to  comply  with  all  reporting
requirements.

At any time,  the Board of  Directors  has  authority  to  designate a "blackout
period" over all trading in Frontline  securities (even during a Window Period).
A blackout  period  compels  all  trading in the  securities  affected  to cease
immediately  for the period  designated  by the Board of  Directors.  A blackout
period may be exercised over securities of companies with which the Company does
or may do  business or in which the  Company  invests or may invest.  No one may
disclose to any outside third party that a blackout period has been designated.

Failure to comply  with the  Company's  securities  trading  policy may  subject
Employees or Employees'  family members to criminal or civil penalties,  as well
as to  disciplinary  action by the Company up to and including  termination  for
cause.  Responsibility  for  complying  with  applicable  laws  as  well  as the
Company's policy rests with Employees individually. Drugs and Alcohol

Company policy prohibits the illegal use, sale, purchase,  transfer,  possession
or consumption of controlled substances,  other than medically prescribed drugs,
while on the Company  premises.  Company  policy also  prohibits the use,  sale,
purchase,  transfer or possession of alcoholic  beverages by Employees  while on
Company premises, except as authorized by the Company. This policy requires that
the company must abide by applicable laws and regulations relative to the use of
alcohol or other controlled substances. The Company, in its discretion, reserves
the right to randomly test Employees for the use of alcohol or other  controlled
substances unless prohibited by prevailing local law.

Policies against Discrimination and Harassment

The  Company  prohibits  discrimination  against  any  Employee  or  prospective
Employee on the basis of sex, race, color,  age,  religion,  sexual  preference,
marital status, national origin, disability, ancestry, political opinion, or any
other basis prohibited by the laws that govern its operations.

The Company prohibits unlawful  harassment.  Employees are expected to treat one
another with respect.  "Harassment" includes any conduct likely to cause offense
or humiliation to any person or that might, on reasonable  grounds, be perceived
by a reasonable  person to place a condition on employment or on any opportunity
for training or promotion.

Electronic communication

Electronic  communications  include  all  aspects  of  voice,  video,  and  data
communications,  such as voice mail, e-mail, fax, and Internet. Employees should
use electronic  communications  for business  purposes and refrain from personal
use.  Among other things,  you should not  participate in any online forum where
the business of the Company or its customers or suppliers is discussed: this may
give rise to a violation of the Company's  confidentiality policy or subject the
Company to legal  action  for  defamation.  The  Company  reserves  the right to
inspect  all  electronic  communications  involving  the  use of  the  Company's
equipment,  software,  systems,  or  other  facilities  ("Systems")  within  the
confines of applicable local law and Employees should not have an expectation of
privacy when using Company Systems.

Integrity of Corporate Records

All business  records,  expense accounts,  vouchers,  bills,  payrolls,  service
records,  reports to  government  agencies  and other  reports  must  accurately
reflect the facts.  Without  limiting the  foregoing,  all reports and documents
filed with the U.S. Securities and Exchange Commission,  as well as other public
communications should be full, fair, accurate and understandable.

The books and records of  Frontline  must be prepared  with care and honesty and
must accurately reflect our transactions. All corporate funds and assets must be
recorded in accordance  with Company  procedures.  No  undisclosed or unrecorded
funds or assets shall be established for any purpose.

The  Company's   accounting   personnel  must  provide  the  independent  public
accountants and the Board with all information they request. Employees must not,
and must not  direct  others  to,  take any  action to  fraudulently  influence,
coerce,  manipulate or mislead  independent  public  accountants  engaged in the
audit or  review  of the  Company's  financial  statements  for the  purpose  of
rendering those financial statements materially misleading.

Entertainment, Gifts, Payments and Bribery

Decisions  by the  Company  and  its  agents  relating  to the  procurement  and
provision  of goods and  services  should  always be free from even a perception
that  favorable  treatment  was  sought,  received  or  given as the  result  of
furnishing  or receiving  gift,  favours,  hospitality,  entertainment  or other
similar  gratuity.  The giving or  receiving of anything of value to induce such
decisions is  prohibited.  You should never  solicit a gift or favour from those
with whom we do  business.  Providing  or receiving  gifts or  entertainment  of
nominal value motivated by commonly accepted business courtesies is permissible,
but not if such  gifts or  entertainment  would  reasonably  be  expect to cause
favouritism or a sense of obligation.

No bribes or other similar payments and benefits, directly or indirectly,  shall
be paid to employees of suppliers or customers.

Compliance with Anti-Trust Laws

The Company's business may be subject to United States, European Union and other
foreign  government  anti-trust and similar laws. All Employees must comply with
such laws and you should  confer with your manager  whenever you have a question
with respect to the possible anti-competitive effect of particular transactions.

Health, Safety and Environmental Protection

The Company will conduct its business in a manner designed to protect the health
and safety of its Employees, its customers, the public, and the environment. The
Company's  policy is to operate its business and its vessels in accordance  with
all applicable  safety,  environmental  and safety laws and regulations so as to
ensure  the  protection  of the  environment  and the  Company's  personnel  and
property. All Employees should conduct themselves in a manner that is consistent
with this policy. Any departure or suspected  departure from this policy must be
reported promptly.


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                                 ACKNOWLEDGEMENT


     I understand that it is my  responsibility  to read, to understand,  and to
keep up to date the  contents  of the  Frontline  Code of  Business  Ethics  and
Conduct  (the  "Code")  and to seek  clarification  or further  information,  if
needed, and to comply with the contents of the Code.

     I acknowledge that I have received a copy of the Code for my review. I also
understand  that  breach or  violation  of the Code may  result in  disciplinary
action (which may include termination of employment).

     I further  acknowledge that I have been afforded the opportunity to ask any
questions I have concerning the content of the Code.

Signature
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