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                                  EXHIBIT 14.1

                              AMEXDRUG CORPORATION
                                 CODE OF ETHICS

As a public company, it is of critical importance that Amexdrug Corporation's
("Amexdrug") filings with the Securities and Exchange Commission be accurate and
timely. Depending on their position with Amexdrug, employees may be called upon
to provide information to assure that Amexdrug's public reports are complete,
fair, and understandable. Amexdrug expects all of its employees to take this
responsibility seriously and to provide prompt and accurate answers to inquiries
related to Amexdrug's public disclosure requirements.

Amexdrug's Chief Executive Officer (CEO) and Chief Financial Officer (CFO) bear
a special responsibility for promoting integrity throughout Amexdrug, with
responsibilities to stakeholders both inside and outside of Amexdrug. The CEO
and CFO have a special role both to adhere to the principles of integrity and
also to ensure that a culture exists throughout Amexdrug as a whole that ensures
the fair and timely reporting of Amexdrug's financial results and conditions.
Because of this special role, the CEO, CFO, principal accounting officer or
controller, or persons performing similar functions are bound by Amexdrug's Code
of Ethics, and by accepting the Code of Ethics, each agrees that they will:

-        Act with honesty and integrity, avoiding actual or actual conflicts of
         interest in personal and professional relationships.

-        Provide information that is accurate, complete, objective, relevant,
         timely and understandable to ensure full, fair, accurate, timely, and
         understandable disclosure in the reports and documents that Amexdrug
         files with, or submits to, government agencies and in other public
         communications.

-        Comply with the rules and regulations of federal, state and local
         governments, and other appropriate private and public regulatory
         agencies.

-        Act in good faith, responsibly, with due care, competence and
         diligence, without misrepresenting material facts or allowing one's
         independent judgment to be subordinated.

-        Respect the confidentiality of information acquired in the course of
         one's work, except when authorized or otherwise legally obligated to
         disclose. Confidential information acquired in the course of one's work
         will not be used for personal advantage.

-        Share job knowledge and maintain skills important and relevant to
         stakeholders needs.

-        Proactively promote and be an example of ethical behavior as a
         responsible partner among peers, in the work environment and in the
         community.

-        Achieve responsible use of, and control over, all Amexdrug assets and
         resources employed by, or entrusted to yourself, and your department.

-        Receive the full and active support and cooperation of Amexdrug's
         Officers and all employees in the adherence to this Code of Ethics.

-        Promptly report to the CEO or CFO any conduct believed to be in
         violation of law or business ethics or in violation of any provision of
         this Code of Ethics, including any transaction or relationship that
         reasonably could be expected to give rise to such a conflict. Further,
         to promptly report to the Chair of Amexdrug's Audit Committee (or to
         one or more of Amexdrug's directors during periods of time when
         Amexdrug has no Audit Committee) such conduct if by the CEO or CFO or
         if they fail to correct such conduct by others in a reasonable period
         of time.


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