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NAVTECH, Inc. and SUBSIDIARIES
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EXHIBIT 14 - Code of Ethics


                                  NAVTECH, INC.

                                 CODE OF ETHICS

Introduction

This Code of Ethics (the "Code")  embodies the  commitment of Navtech,  Inc. and
our subsidiaries to conduct our business in accordance with all applicable laws,
rules and regulations and the highest ethical  standards.  All Senior  Financial
Officers (as  hereinafter  defined) are expected to adhere to the principles and
procedures  set  forth  in  this  Code.  For  purposes  of  Section  406  of the
Sarbanes-Oxley Act of 2002 and the rules promulgated thereunder, this Code shall
be our code of ethics for our principal  executive officer,  principal financial
officer,  principal  accounting  officer or  controller,  or persons  performing
similar  functions  (collectively,  "Senior Financial  Officers").  This Code is
separate  and apart from,  and in addition to, any policies our company may have
in effect, from time to time,  relating to our employees,  officers and Board of
Directors.

A. Code Compliance and Reporting

Our Senior  Financial  Officers  should  strive to identify and raise  potential
issues  before they lead to problems,  and should ask about the  application  of
this Code whenever in doubt. Any Senior  Financial  Officer who becomes aware of
any existing or  potential  violation  of this Code should  promptly  notify the
Audit  Committee  of our Board of Directors  (see Exhibit A attached  hereto for
contact  information)  (we refer to such  contacts  as the  "Appropriate  Ethics
Contact").  We will  take  such  disciplinary  or  preventive  action as we deem
appropriate to address any existing or potential  violation of this Code brought
to our attention.

Any questions  relating to how these  policies  should be interpreted or applied
should be addressed to the Appropriate Ethics Contact.

 B. Personal Conflicts of Interest

A "personal  conflict of interest" occurs when an individual's  private interest
improperly  interferes with the interests of the company.  Personal conflicts of
interest,  whether  actual or apparent,  are  prohibited  as a matter of company
policy,  unless they have been approved or waived by the company. In particular,
a Senior Financial  Officer must never use or attempt to use his or her position
at the company to obtain any improper  personal  benefit for himself or herself,
for his or her  family  members,  or for any other  person,  including  loans or
guarantees of obligations, from any person or entity.

Service  to the  company  should  never be  subordinated  to  personal  gain and
advantage.  Conflicts of interest,  whether actual or apparent,  should,  to the
extent possible, be avoided.

Any  Senior  Financial  Officer  who  is  aware  of a  material  transaction  or
relationship  that could  reasonably  be  expected to give rise to a conflict of
interest should discuss the matter promptly with the Appropriate Ethics Contact.


NAVTECH, INC.                                                            Page 36
2003 10-KSB
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C. Public Disclosure

It is  company  policy  that  the  information  in  our  public  communications,
including  our  filings  made with the United  States  Securities  and  Exchange
Commission,  be full,  fair,  accurate,  timely and  understandable.  Our Senior
Financial  Officers who are involved in the company's  disclosure  process,  are
responsible  for acting in  furtherance  of this policy.  In  particular,  these
individuals   are  required  to  maintain   familiarity   with  the   disclosure
requirements  applicable  to the  company  and  are  prohibited  from  knowingly
misrepresenting,  omitting,  or causing others to misrepresent or omit, material
facts  about the  company to others,  whether  within or  outside  the  company,
including the company's independent auditors.

D. Compliance with Laws, Rules and Regulations

It is company policy to comply with all applicable  laws, rules and regulations.
It is the personal  responsibility of each Senior Financial Officer to adhere to
the standards and restrictions imposed by those laws, rules and regulations.  If
a Senior  Financial  Officer is not aware or  familiar  with the laws,  rules or
regulations that apply specifically to our business,  they must request that the
Appropriate Ethics Contact provide such information.

Generally,  it is both  illegal  and  against  company  policy  for  any  Senior
Financial Officer who is aware of material nonpublic information relating to the
company,  any of the  company's  clients or any other  private  or  governmental
issuer  of  securities  to buy or sell  any  securities  of  those  issuers,  or
recommend that another person buy, sell or hold the securities of those issuers.
Any Senior  Financial  Officer who is uncertain  about the legal rules involving
his or her  purchase  or sale of any company  securities  or any  securities  in
issuers  with which he or she is  familiar  by virtue of his or her work for the
company  should  consult with the  Appropriate  Ethics Contact before making any
such purchase or sale.

E.  Amendment, Modification and Waiver

This Code may be amended or modified by our Board of Directors.  Waivers of this
Code may only be granted by the Board of  Directors  or a committee of the Board
with specific delegated authority.  Waivers will be disclosed as required by the
Securities  Exchange  Act  of  1934,  as  amended,  and  the  rules  promulgated
thereunder and any applicable  rules relating to the  maintenance of the listing
of our securities on any stock exchange.




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                                                                       EXHIBIT A
                                                                       ---------

                           Appropriate Ethics Contact


Navtech, Inc. Audit Committee
c/o Navtech Systems Support, Inc.
175 Columbia Street West
Suite 102
Waterloo, Ontario Canada N2L-5Z5

Or via Email at: auditcommittee@navtechinc.com