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Exhibit 14.1

SUB SURFACE WASTE MANAGEMENT OF DELAWARE INC., AND SUBSIDIARY
CODE OF BUSINESS CONDUCT AND ETHICS

1. General Principles

The purpose of this Code is to describe our standards of ethics and business
conduct.

It is the intent of Sub Surface Waste Management of Delaware, Inc. (the Company)
to conduct its business with integrity and ethics which applies to all
employees, officers and directors. As representatives of the Company, we should
each be personally committed to demonstrating a high standard of business
conduct. This includes obeying the spirit and letter of all applicable laws and
regulations and to avoid activities that may be, or appear to be, illegal,
unethical or improper.

2. Compliance with Laws and Company Code of Business Conduct and Ethics

All Company officers, employees and directors are expected and directed to
comply with all laws and Company's Code of Business Conduct and Ethics (the
Code).

Each employee, officer and director has an obligation to behave according to
ethical standards that comply with the Company's policy, and the letter and
spirit of applicable laws, rules and regulations. It is everyone's
responsibility to know and understand legal and policy requirements as they
apply to his or her Company responsibilities.

3. Accuracy of Company Records

Each officer and employee must help maintain the integrity of the Company's
financial and other records.

Management, directors, audit committee members, shareholders, creditors,
governmental entities and others depend on Company's business records for
reliable and accurate information. The Company's books, records, accounts and
financial statements must appropriately and accurately reflect the Company's
transactions and conform to applicable legal requirements and the Company's
system of internal controls. In particular, the Company is committed to fair,
accurate, timely and understandable disclosure in all reports filed with the
Securities and Exchange Commission (SEC) and in other public communications, and
each person subject to this Code is required to provide truthful and timely
information in support of this commitment.

4. Securities Trading Policies

Never trade securities on the basis of confidential information acquired in the
course of your Company duties or while you are at the workplace.

There are times when employees, officers or directors possess information about
the Company, its subsidiaries or affiliates or about a company with which the
Company does business that is not known to the investing public. Such insider
information may relate to, among other things, strategies, plans of the Company,
new products or processes, mergers, acquisitions or dispositions of business or
securities, problems facing the Company, sales, profitability, negotiations
relating to significant contracts or business relationships, significant
litigation or financial information.

If any information is of the type that a reasonable investor would consider
important in reaching an investment decision, the Company employee, officer or
director who possesses such information must not buy or sell Company securities,
nor provide the information to others, until such information becomes public.
Use of material, non-public information in the above manner is not only
unethical, but also illegal. An employee, officer or director who is unsure how
the law applies in a given instance, should seek guidance before he or she
trades. Each officer, director and employee shall at all times comply with the
Company's Policy on Insider Trading and Disclosure.



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5. Contact with Government Officials

The Company complies with all applicable laws, rules and regulations relating to
lobbying or attempting to influence government officials.

Bribery, kickbacks or other improper or illegal payments have no place in the
Company's business. In addition, information provided to governments must be
accurate and interactions with government officials must be honest and ethical.
All activities that might constitute lobbying or attempts to influence
government officials must first be reviewed with and approved by legal counsel.

Before doing business with foreign, national, state or local government, an
employee or officer must know the applicable rules. An employee who is in doubt,
should not interpret the rules by him or herself, but should discuss the matter
with his or her supervisor or an Executive Vice President.

6. Conflicts of Interest

Each employee, officer and director must avoid any situation in which his or her
personal interests conflict with or interfere with the Company's interests.

Each employee and officer owes the Company a duty of loyalty. Employees and
officers must make business decisions solely in the best interests of the
Company. Conflicts may arise when an employee or officer receives improper
personal benefits as a result of the persons position with the Company or gains
personal enrichment through access to confidential information. A conflict
situation can also arise when an employee or officer takes actions or has
interests that may make it difficult to perform his or her Company work
objectively and effectively. For that reason, all employees and officers must
exercise great care not to allow their personal interests to potentially
conflict with the Company's interests. Each employee, officer and director shall
act with honesty and integrity, avoiding conflicts of interest between personal
and professional relationships. The following is a non-exhaustive list of
examples of prohibited conflicts of interest for employees and officers of the
Company.

-        Selling competitive services, consulting with or employment in any
         capacity with a competitor, supplier or customer of the Company.
-        Having a substantial equity, debt, or other financial interest in any
         supplier or customer.
-        Having a financial interest in any transaction involving the purchase
         or sale by the Company of any product, material, equipment, services or
         property.
-        Misusing the Company's confidential or proprietary information,
         including the unauthorized disclosure or use of such information.
-        Taking, misappropriating or using materials, equipment or other assets
         of the Company for any unauthorized or undisclosed purpose.
-        Receiving loans or guarantees of obligations from the Company without
         Board of Director authorization.

Directors also owe the Company a duty of loyalty. The duty of loyalty mandates
that the best interests of the Company and its shareholders take precedence over
any interest possessed by a director not shared by the shareholders generally.
In the event that a conflict (or the appearance of a conflict) arises or is
anticipated, directors must bring the matter to the attention of the Chairman of
the Audit Committee.

7. Political Contributions and Related Policies

Generally Company funds or resources may not be used to make a political
contribution to any political candidate or political party.

Exceptions to the basic policy are allowed only where such contributions are
permitted by law such as through a bona fide Political Action Committee. Company
policy does not permit the use of any Company facilities or resources by
employees for political campaigning, political fundraising or partisan political
purposes. A decision by an employee to contribute any personal time, money or
other resources to a political campaign or political activity must be totally
voluntary.

8. Business Courtesies and Gratuities

The Company's policy is not to offer or accept kickbacks or bribes, or gifts of
substantial value.



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Company employees, officers and directors may only exchange non-monetary and
modestly valued gifts that promote goodwill with our business partners and do
not improperly influence others. We will accept only approved and widely
available discounts and do not encourage, accept or exchange gratuities or
payments for providing services to others.

Business courtesies such as meals, transportation and entertainment provided to
a customer must be modest in amount and related to a legitimate business purpose
(e.g., explanation or demonstration of Company products, application of
products, service capabilities, or training). Such courtesies must not violate
the law, regulations, or reasonable customs of the market place. If you have any
questions about whether any business courtesies, gratuities or gifts are not
appropriate, please contact your supervisor or an Executive Vice President.

9. Company Opportunities

Do not use a Company opportunity for personal gain.

Employees, officers and directors owe a duty to the Company to advance its
legitimate interests when the opportunity to do so arises. Employees, officers
and directors are prohibited (without the specific consent of the Board of
Directors or an appropriate committee thereof) from (1) taking for themselves
personally opportunities that are discovered through the use of company
property, information or their position, (2) using company property, information
or their position for personal gain, or (3) competing with the Company directly
or indirectly.

10. Intellectual Property and Confidential Information

The Company invests substantial resources in developing proprietary intellectual
property and confidential information.

Confidential information is information that is not generally known or readily
available to others. It includes non-public information that might be of value
to competitors if it were disclosed. It must not be shared with others outside
the Company except pursuant to approved business relationships or when required
by law. Confidential information includes, but is not limited to, intellectual
property and trade secrets, contents of proposals, business plans, marketing and
sales programs, customer and prospective customer information and lists, pricing
and policies, financial information not otherwise disclosed, and any other
information which the Company deems confidential. All information from a Client
and all data produced for a Client is strictly confidential.

Every Company employee, officer and director is obligated to protect the
Company's confidential information as well as that of its customers, suppliers
and third parties who disclose information to the Company in confidence. Company
employees, officers and directors must not accept confidential information from
a third party, including competitors, unless specifically authorized to do so by
an authorized supervisor or officer of the Company and following an appropriate
grant of rights from such third party.

11. Protection and Proper Use of Company Assets

Our shareholders trust us to manage Company assets appropriately.

Collectively, employees, officers and directors have a responsibility for
safeguarding and making proper and efficient use of the Company's assets. Each
of us has an obligation to prevent the Company's property from loss, damage,
misuse, theft, embezzlement or destruction. We seek to ensure that the Company
equipment, supplies and other assets are used for legitimate business purposes
unless otherwise specifically authorized, and to protect all tangible and
intangible Company property.

12. Fair Dealing with Competitors, Customers and Suppliers

Respect the rights of customers and suppliers.

The Company's success depends on building productive relationships with our
customers and suppliers based on integrity, ethical behavior and mutual trust.
In addition, customers have individual needs and expectations representing
unique opportunities for mutual success.

The Company bases its supplier relationships on fundamental concepts of
integrity, fairness, and mutual respect.



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The Company strives to outperform its competition fairly and honestly. The
Company seeks and develops competitive advantages through superior performance,
not through unethical or illegal business practice. Each Company employee,
officer and director should endeavor to deal fairly with the Company's
customers, suppliers and competitors. No one should take unfair advantage
through manipulation, concealment, abuse of privileged information,
misrepresentation of material facts or any other intentional unfair dealing.

13. Personal Behavior in the Workplace

The Company is committed to providing equal opportunity in employment and will
not tolerate illegal discrimination or harassment.

The Company strives to enhance and support the diversity of its employee group.
All are expected to deal with each other in an atmosphere of trust and respect
in a manner consistent with the Company's core values and comply with all
policies disseminated by the Company covering such behavior.

14. Public Disclosure of Code and Waivers

Waivers to the Code granted only by Board of Directors.

The existence and content of this Code of Business Conduct and Ethics will be
disclosed to shareholders and may be available on the Company's website. It is
expected that waivers of this Code rarely, if ever, would be acceptable. Any
waiver of a provision of Code for executive officers or directors may be granted
only by the Board of Directors, with only the independent members voting, and
such waiver must be promptly disclosed to shareholders.

15. Accountability for Adherence to the Code

Violations may lead to Termination.

Each employee, officer and director must accept responsibility for adherence to
this Code. Violations of this Code may lead to serious sanctions including, for
an employee, discipline up to and including immediate termination, at the sole
discretion of the Company. The Company may, in addition, seek civil recourse
against an employee, officer or director and/or refer alleged criminal
misconduct to law enforcement agencies.

16. Reporting Suspected Illegal or Unethical Behavior

The Company maintains an open door policy and an anonymous method for employees
to raise concerns and to encourage the reporting of suspected violations of law
or the Code of Business Conduct and Ethics without fear of retribution or
retaliation.

If you have questions about an ethical situation, you are encouraged to talk
with your supervisor about any behavior you believe may be illegal or unethical.
You will be assured confidentiality, to the limit of the law. If you do not feel
it is appropriate to discuss the issue with these persons, the Company has
established a method to report concerns or potential violations anonymously (see
below).

It is against the Company's policy to retaliate against any employee, officer or
director for good faith reporting of violation of this Code. If you feel you
have been retaliated against for raising your good faith reporting, you should
immediately contact your supervisor.

17. Coordination with Other Company Policies

All other Policies remain in effect.

The provisions of this Code are in addition to, and do not modify, replace or
supersede, the Company's other policies or procedures including, but not limited
to the Company's other statements of policy or procedure, whether written or
oral.

Additionally, this Code is not intended to be and does not constitute a contract
of employment between the Company and its employees. If you are an employee and
do not have an Employment Agreement with the Company, you are an employee
at-will. This means that you have the option of resigning from your employment
at any time, for any reason, with or without prior notice. Conversely, the
Company has the same option to terminate your employment at any time, for any
reason or no reason, with or without prior notice.

Effective December 31, 2004