**EXHIBIT 14**

**March 2004**

**Oppenheimer Holdings Inc. Oppenheimer & Co. Inc.Code of Conduct and Business Ethics for Directors, Officers andEmployees 1. Introduction**

This Code of Conduct and Business Ethics (the"Code") applies to all directors, officers andemployees of Oppenheimer Holdings Inc., Oppenheimer & Co.Inc. and all other subsidiaries of Oppenheimer Holdings Inc.(collectively "Oppenheimer"). Some subsidiaries,departments and specialized areas have specific codes of conductor ethics or the like in place that cover conduct or regulatoryissues that only apply to that area or field. If you work for oneof these subsidiaries or specialized areas such specific codes ofconduct of ethics apply to you in addition to the Code.

**2. Purpose of the Code**

The purpose of the Code is to promote and foster the honestand ethical conduct of the directors, officers and employees ofOppenheimer.

Our Basic Principles are:

> 
adhere to the law wherever Oppenheimer does business;

avoid putting yourself or Oppenheimer in a conflict of        interest;

conduct yourself honestly and with integrity; 

keep Oppenheimer transactions, communications and        information, accurate, confidential and secure, and        Oppenheimer assets safe; and 

treat everyone fairly and equitably – whether        customers, suppliers, employees or others who deal with        Oppenheimer.

**3. Compliance with Law**

You must know, respect and comply with all laws, rules, andregulations applicable to the conduct of Oppenheimer's businessesin the areas in which you work. Oppenheimer actively promotescompliance with the laws, rules, and regulations that governOppenheimer's business. Obeying both the letter and spirit of thelaw is one of the foundations of Oppenheimer’s ethicalstandards. You must follow and obey the laws of all the statesand countries where we operate. While you are not expected to bean expert on every detail of all the laws that govern ourbusiness in every jurisdiction, you are expected to understandthe laws and regulations applicable to your duties at Oppenheimerand to understand the regulatory environment within which thefirm operates well enough to know when to seek advice from yourManager, a Senior Officer or from the Senior Vice President andCorporate Counsel.

> 
**A. Brokerage Accounts**

In accordance with industry regulations, Oppenheimer employeesand officers and their immediate families must maintain theirbrokerage accounts at Oppenheimer. Exceptions to this policy arerarely granted and must be approved by your Manager, the Directorof Compliance or the Senior Vice President and Corporate Counsel.

> 
**B. Insider Trading**

Securities laws and Oppenheimer policy prohibit you fromacting upon material non-public information to benefit yourselfor others. Information is "material" if there is asubstantial likelihood that a reasonable investor would considerit important in making an investment decision, or it couldreasonably be expected to affect the price of an issuer'ssecurities. At times, our policies may limit the ability of someemployees to enter into transactions. Anyone with ongoingpossession of non-public information may be unable to tradepersonally in the securities of the companies about which he orshe has information. Those having access to confidential ornon-public information must not use or share that informationexcept in connection with the legitimate conduct of Oppenheimerbusiness. Oppenheimer strives to prevent the misuse of materialnon-public information by, among other things, limiting access toconfidential information and limiting and monitoringcommunications between various Oppenheimer departments including,without limitation, the investment banking, asset management,sales, research, and trading departments. In addition to civiland criminal proceedings and penalties, misuse of confidentialinformation or engaging in insider trading will result indisciplinary action, up to and including termination.

> 
**C. Money Laundering and Antiterrorism Laws**

Oppenheimer complies with federal, state,. and internationallaws prohibiting money laundering and with the safeguards againstterrorist activity contained in the USA Patriot Act. Under nocircumstances should you participate in any money launderingactivity. In addition to severe criminal penalties, moneylaundering by Oppenheimer employees and violations of the USAPatriot Act will result in disciplinary action, up to andincluding termination. Any suspicious deposits, or any otherclient activity that raises questions about the source of theclient's funds, should be reported immediately to your Manager,the firm’s Anti-Money Laundering Officer (currently Mr.James Gianni at (212) 668-5024, or the Office of the GeneralCounsel.

> 
**D. Proper Record-Keeping and Disclosure        Requirements**

Oppenheimer requires honest and accurate accounting andrecording of financial and other information in order to makeresponsible business decisions and provide an accurate account ofOppenheimer's performance to stakeholders and regulators. It is aviolation of law and Oppenheimer policy for any employee toattempt to improperly influence or mislead any person engaged inauditing or reviewing our financial accounts and statements.Oppenheimer is committed to full compliance with all requirementsapplicable to its regulatory and public disclosures. Oppenheimerrequires that its financial and other reporting fairly presentthe financial condition, results of operations, and cash flow ofOppenheimer and that it comply in all respects with applicablelaw, governmental rules, and regulations, including generallyaccepted accounting principles (GAAP) in the United States andCanada and applicable rules of the U.S. Securities and ExchangeCommission, the New York Stock Exchange, Canadian securitiesregulators, the Toronto Stock Exchange and other securitiesregulators. Oppenheimer has implemented disclosure controls andprocedures to ensure that its public disclosures are timely,compliant, and otherwise full, fair, accurate, andunderstandable. All employees and officers responsible for thepreparation of Oppenheimer's public disclosures, or who provideinformation as part of that process, have a responsibility toensure that such disclosures and information are complete,accurate, and in compliance with Oppenheimer's disclosurecontrols and procedures.

> 
**E. Document Retention and Destruction**

Without exception, all officers and employees must fullycomply with Oppenheimer's document retention and destructionpolicy. It is a criminal offense to destroy documents that aresubject to a subpoena or other legal process. Once a legalproceeding has begun, or even when one is threatened orreasonably likely, federal and state obstruction-of-justicestatutes require Oppenheimer to preserve documents relevant tothe issues in that proceeding even before specific documents arerequested. Any Oppenheimer employee who fails to comply with thispolicy, as well as industry regulations and state and federallaws, is subject to termination and may also face criminal orcivil prosecution, with possible fines and prison terms.

> 
**F. Cooperation with Investigations and Law        Enforcement**

It is Oppenheimer's policy to cooperate with governmentinvestigators and law enforcement officials. Every Oppenheimeremployee must also cooperate with investigations bynon-governmental regulators with oversight of our business, suchas securities exchanges, as well as with internal Oppenheimerinvestigations. All inquiries or requests or demands forinformation from external investigators must be immediatelyreferred to the Office of the General Counsel. The Office of theGeneral Counsel must coordinate all responses to externalinvestigators' questions. Failure to cooperate with legitimateinvestigations will result in disciplinary action, up to andincluding termination.

> 
**G. Privacy**

All Oppenheimer personnel must comply with all applicableprivacy laws in their handling of client matters and client andOppenheimer records. Any questions about the applicability ofprivacy laws should be referred to the Office of the GeneralCounsel.

**4. Conflicts of Interest**

A conflict of interest occurs when your private interestsinterfere, or appear to interfere, in any way, with the interestsof Oppenheimer. Conflicts of interest can arise when you takeaction or have interests that may make it difficult for you toperform your duties to Oppenheimer effectively. Conflicts ofinterest also arise when you, or a member of your family,receives improper personal benefits as a result of your positionwith Oppenheimer. Loans to, or guarantees of obligations of, anyemployees, officers, directors or any of their family members arelikely to pose conflicts of interest, as are transactions of anykind between Oppenheimer and any other organization in which youor any member of your family have an interest.

Engaging in any conduct that represents a conflict of interestis prohibited. If you have any doubt whether or not conduct wouldbe considered a conflict of interest, please consult yourManager, a Senior Officer or the Senior Vice President andCorporate Counsel. You must also disclose any materialtransaction or relationship that could reasonably be expected togive rise to such a conflict to the Senior Vice President andCorporate Counsel. If a conflict of interest cannot be avoided,it must be managed in an ethical, responsible manner, so as notto create the perception of impropriety.

As a Director, Senior Executive, or Financial Officer oremployee of Oppenheimer, it is imperative that you avoid anyinvestment, interest or association that interferes, mightinterfere, or might be perceived to interfere, with yourindependent exercise of judgment in Oppenheimer's best interest.

> 
**A. Ownership of Securities and Outside Business        Activities**

As a Senior Executive or employee of Oppenheimer, you mustreport all outside business activities, including ownership ofprivately held stock and limited partnership interests, to yourManager and to the appropriate Oppenheimer Compliance Officer sothat a review for potential conflicts of interest can beconducted. Outside business activities and interests includeserving as a partner or a stockholder in another business, as anofficer in a family-owned corporation, or as an outside directorof another company. The appropriateness of you engaging in theseand other types of outside business activities, interest, orinvestment opportunities depends on many factors, including thenature and extent of the outside interest, the potential forconflicts of interest, the relationship between Oppenheimer andthe outside entities, and the duties involved. You must receiveprior written approval for any outside business activity andprivate investment from the Director of Compliance. You have anobligation to keep Oppenheimer apprised of these activities andprovide updated information about the outside interests. Serviceby you as a director, officer, or employee of any othercorporation or business must be authorized in writing by theDirector of Compliance. Unless approved in writing by theDirector of Compliance or the Senior Vice President and CorporateCounsel, you may not serve as a director of a publicly tradedcompany. 

Directors of Oppenheimer should inform the Chairman and ChiefExecutive Officer of Oppenheimer Holdings Inc. prior to acceptingappointments to the boards of directors or advisory boards of anypublic or privately held company. The disclosure requirements andother possible conflict-of-interest issues involved must beanalyzed and discussed.

> 
**B. Public Office**

You are required to notify and receive the approval of theDirector of Compliance or the Senior Vice President and CorporateCounsel before committing to a candidacy for elective office or aformal position on a company committee and before accepting anappointment to a public or civic office. Oppenheimer must takesteps to ensure that conflicts of interest are not raised by suchcampaign or public service. In general, you may run for and servein local, elective, or appointed civic offices, provided theactivity, including campaigning:

> 
occurs outside work hours;

involves no use of Oppenheimer's name, facilities,        client lists, other corporate assets, or corporate        funding;

is confined solely to you in your capacity as a        private citizen and not as a representative of        Oppenheimer; and 

does not present an actual or perceived conflict of        interest for Oppenheimer, as determined in the sole        judgment of Oppenheimer.

**5. Corporate Opportunities**

You may not advance your personal interests at the expense ofOppenheimer. You owe a duty to Oppenheimer to advanceOppenheimer's legitimate interests to the best of your abilitieswhenever the opportunity arises. You must not take for yourselfpersonally opportunities you discover through your employmentwith Oppenheimer or the use of Oppenheimer property, information,or position, which is in violation of Oppenheimer's policies. Inaddition, Oppenheimer property, information, or position must notbe used for personal gain. You may not compete with Oppenheimerwhile employed by Oppenheimer.

**6. Confidentiality Obligations**

> 
**A. Non-Public Information**

You must maintain the confidentiality of information entrustedto you by Oppenheimer and provided by our clients, suppliers andservice providers. In the conduct of its business, Oppenheimerreceives a great deal of non-public information. Much of thisinformation may be sensitive, with the potential to affect marketconditions, negotiations, strategic positioning, andrelationships with clients, competitors, suppliers or serviceproviders. You must exercise care not to misuse non-publicinformation obtained during your employment, including clientlists, information about Oppenheimer personnel and clients, andbusiness plans and ideas. The obligation to maintain theconfidentiality of information may be subject to legal orregulatory requirements to disclose that information. In suchcases, the Office of the General Counsel will help determine whatdisclosure is required and how it is to be made.

> 
**B. Media, Publishing, and Public Appearances**

You may not provide non-public corporate information topersons outside Oppenheimer, including the media. Any inquiriesor questions relative to the media should be referred to theChief Executive Officer or the President of Oppenheimer HoldingsInc. 

> 
**C. Client Information Privacy**

Oppenheimer protects the confidentiality and security ofclient information [Oppenheimer's Privacy Policy for clientinformation provides that:

> 
Oppenheimer does not        sell or rent clients' personal information;

you may not discuss the        business affairs of any client with any other person,        except on a strict need-to-know basis;

Oppenheimer does not        release client information to third parties, except upon        a client's authorization or when permitted or required by        law; and 

third-party service        providers and suppliers with access to client information        are required to keep client information confidential and        use it only to provide services to or for Oppenheimer.

**7. Fair Dealing**

You must deal fairly with Oppenheimer's clients, suppliers,service providers, competitors, and employees. Competitiveadvantage must result from superior performance, not unethical orillegal business dealings. While Oppenheimer seeks to outperformour competitors, it must be done honestly and fairly.

> 
**A. Unethical Behavior, Relationships with        Competitors**

You may not take unfair advantage of anyone through unethicalor illegal measures, such as manipulation, concealment, abuse ofprivileged information, misrepresentation of material facts, orany other unfair dealing practices. It is improper, and may beillegal, to hire competitors' employees for the purpose ofobtaining clients or trade secrets or other proprietaryinformation. It is also against Oppenheimer's policy to seekincreased revenues by disparaging our competitors. Our goal is toincrease business by offering superior and innovative financialproducts and services. Oppenheimer advertising must be truthful,not deceptive, and in compliance with applicable laws,regulations, and corporate policies. All advertising andmarketing materials must be approved using the establishedapproval procedures. You must guard against unfair competitivepractices and exercise extreme caution to avoid conduct thatmight violate antitrust laws or other rules prohibitinganti-competitive activities. Violations may result in criminal orcivil proceedings and penalties. If a competitor or third-partyproposes to discuss unfair collusion, price-fixing, or otheranti-competitive activities, your responsibility is to object,terminate the conversation, or leave the meeting and report theincident promptly to your manager, a Senior Officer or the SeniorVice President and Corporate Counsel. You must avoid anydiscussion with competitors of proprietary or confidentialinformation, business plans, or topics such as pricing or salespolicies – the discussion of which could be viewed as anattempt to make joint rather than independent business decisions.

> 
**B. Gifts, Gratuities, Political Contributions, and        Other Payments Related to Oppenheimer Business**

You, your associates or members of your family may not,directly or indirectly, accept or receive bonuses, fees, gifts,frequent or excessive entertainment, or any similar form ofconsideration that is of more than nominal value from any personor entity with which Oppenheimer does, or seeks to do, business.It also is generally against corporate policy to give gifts orgratuities, other than within accepted guidelines, withoutreceiving specific approval by the Director of Compliance or theSenior Vice President and Corporate Counsel. You may not givegifts of any value to government officials without specificapproval by the Director of Compliance or the Senior VicePresident and Corporate Counsel. Oppenheimer policy forbidsbribes, payoffs, contributions, or payments of any kind by anyOppenheimer employee, officer or director to any person,government official, or entity for the purpose of improperlyobtaining or retaining business or influencing consideration ofany business activity. This policy covers all types of paymentsthat may or may not be considered legal under the circumstances.Special rules may apply to payments or gifts (includingentertainment) to officers, directors, employees, or otheraffiliates of government owned or controlled entities and certainhighly regulated entities (such as banks or insurance companies),as well as entities located in certain jurisdictions.

**8. Respect for the Individual**

> 
**A. Conduct Business Activities in an Atmosphere of        Good Faith and Respect**

It is Oppenheimer's policy, to treat each individual withdignity, consideration, and respect. All Oppenheimer employeesshould be honest and fair with others, share the credit whencredit is due, avoid public criticism of one another, andencourage an atmosphere in which openness, cooperation, andconsultation are the norms. Internal relationships with fellowemployees should be based on the same high standards of integrityand ethical responsibility that are observed with Oppenheimerclients, shareholders, and the public.

Oppenheimer is committed to promoting diversity within itsworkforce; achieving it is an important competitive advantage inthe global marketplace. Oppenheimer has a strict policy of equalopportunity in hiring, developing, promoting, and compensatingemployees. We seek to attract, retain, and reward employees whoperform their work to the highest standards, basing promotions onqualification and merit. Discrimination is not tolerated on thegrounds of race, national origin, religion, gender, age,disability, sexual orientation, or veteran status. Just as we donot tolerate illegal discrimination in any form, we also do nottolerate illegal sexual or any other form of harassment at anylevel of Oppenheimer. Employees who experience or observework-related discrimination, harassment, or similar problems havean obligation to report it to their Manager, the Director ofHuman Resources, or the Senior Vice President and CorporateCounsel.

Indebtedness between employees is best avoided and must notreach a level that may compromise the objectivity essential inmanager employee relationships or in the discharge of job-relatedresponsibilities. Any indebtedness between employees and theirdirect or indirect supervisors (regardless of which one isborrower or lender) must be limited to nominal amounts.

**9. Protecting Oppenheimer Information,Assets, and Property**

> 
**A. Business Use**

You must protect Oppenheimer's assets and ensure theirefficient use. You may only use Oppenheimer property forlegitimate business purposes. Any suspected fraud or theft ofOppenheimer property must be reported for investigationimmediately. Oppenheimer's assets include our capital,facilities, equipment, proprietary information, technology,business plans, ideas for new products and services, tradesecrets, inventions, copyrightable materials, and client lists.Information owned by Oppenheimer must be treated with the samecare as any other asset, and every Oppenheimer employee has arole in protecting its confidentiality and integrity.

> 
**B. Proprietary Information and Intellectual        Property**

Your obligation to protect Oppenheimer's assets applies to ourproprietary information. Proprietary information includesbusiness, marketing, and service plans; unpublished financialdata and reports; databases; customer information; and salary andbonus information, as well as intellectual property such as tradesecrets, patents, trademarks, and copyrights. Unauthorized use ordistribution of this material is a violation of Oppenheimer'spolicy, and it may also be illegal and result in civil andcriminal proceedings and penalties. Intellectual property refersto a company's intangible assets, such as the company's businessmethods, inventions, trademarks, and publications. All inventionsand copyrightable material conceived by an employee within thescope of his or her employment are the exclusive property ofOppenheimer, and as a condition of continued employment, theemployee must do whatever is necessary to transfer to Oppenheimerthe technical ownership of such inventions or materials. It isthe responsibility of every employee to protect Oppenheimer'sintellectual property. In addition, Oppenheimer also respects theintellectual property of other parities. The unauthorized use ofanother party's patented, trademarked, or copyrighted(electronic, audio, video, text) materials is strictlyprohibited, regardless of their source. In addition, Oppenheimerdoes not permit the use of software or other devices whoseprimary purpose is the circumvention or violation of another'sintellectual property rights. Please contact the Senior VicePresident and Corporate Counsel with questions about the proposeduse of another party's intellectual property and for appropriatecontracts.

> 
**C. Compliance with Internal Controls**

Oppenheimer maintains and enforces a strong, effective systemof internal controls to safeguard and preserve its informationand assets, its clients, and its shareholders. These controls aredesigned to ensure that business transactions are properlyauthorized and carried out, and that all reporting is truthfuland accurate. These administrative and accounting control systemsare the responsibility of each group in the Oppenheimerorganization. All business transactions require authorization atan appropriate management level. Any employee who is responsiblefor the acquisition or disposition of assets for Oppenheimer, orwho is authorized to incur liabilities on Oppenheimer's behalf,must act prudently in exercising this authority and must becareful not to exceed his or her authority. Equally important,every employee must help ensure that all business transactionsare executed as authorized. Transactions must be properlyreflected on Oppenheimer's books and records. Every employee isinvolved, if not in the authorization or execution of businesstransactions, in some level of reporting. This may includereporting travel and entertainment expenses or recording workhours on a timecard. It is important that all reporting be donehonestly and accurately and that employees cooperate fully withboth internal and independent audits.

**10. OPPENHEIMER WRITTEN AND ELECTRONICCOMMUNICATIONS**

You must use Oppenheimer's information and communicationsystems properly and judiciously. Oppenheimer has strict policieson use of the Internet and on written and electroniccommunications which you must comply with.

> 
**A. Access to the Internet**

Oppenheimer has strict policies on Internet access. Onlyauthorized connections are permitted, and access to the Internetmust be accomplished via an approved security gateway.Furthermore, you are not permitted to link to the Internet fromOppenheimer offices via modem dial-up services or other externalservice providers without the express approval of the Director ofCompliance. Additionally, you should exercise good judgment whenusing the Internet during business hours for personal andnon-business purposes. You may not do any of the following:

> 
transmit, copy, or download any material, including        sexually explicit images or messages and materials        containing racial, ethnic, or other slurs, that may        defame, embarrass, threaten, offend, or harm an        Oppenheimer employee or client or the general public;

transmit or post non-public corporate information        about Oppenheimer or any company to any organization or        individual not authorized to receive or possess it;

attempt to gain access to any computer, database, or        network without authorization or wilfully propagate        computer viruses or other disruptive or destructive        programs;

distribute unsolicited e-mail messages,        advertisements, or postings to multiple newsgroups,        individuals, or organizations (e.g.,        "spamming"); and

use electronic means for the purpose of gambling or to        send or forward chain letters.

You may not establish e-mail addresses or domain names thatattempt to trade on, or are derived from, the Oppenheimer name orany corporate, brand names or domain names used within theOppenheimer Group; if such use is identified, immediaterelinquishment will be requested. You should not register domainnames on behalf of Oppenheimer and may not establish Internetwebsites related to Oppenheimer business without approval fromyour Manager and the Director of Compliance and Director ofInformation Technology. You are reminded to be sure that yoursystem passwords are secure. Inappropriate conduct in respect ofthe usage of Oppenheimer's communications systems will lead todisciplinary action, including revocation of privileges,immediate termination, and referral to regulatory authorities.

> 
**B. Written and E-Mail Communications**

Electronic communications should be treated with the same careas any other business communication. Any communication relatingto Oppenheimer business must be of an appropriate nature, mustnot violate the legal rights of Oppenheimer, any Oppenheimeremployee, or third party, and must be transmitted, stored, andaccessed in the manner that safeguards confidentiality andcomplies with applicable law. All written communications,including those electronically delivered, should be clear,concise, and professional in tone and content. Communications forpersonal, non-business purposes should be kept to a minimum.

> 
**C. Communications Monitoring**

All electronic communications relating to Oppenheimer businessmust be made through the Oppenheimer network unless the Directorof Compliance and Director of Information Technology hasexpressly authorized another means. Electronic communications,including connections to Internet and Intranet websites usingOppenheimer computing or network resources, as the property ofOppenheimer and are subject to monitoring and surveillance.Communications by certain Oppenheimer personnel are subject todetailed supervisory requirements.

**11. Report Problems or Irregularities**

If you believe that you may have breached the Code or asupplemental code or guideline that applies to you, or haveobserved:

> 
a breach of the Code or a supplemental code or        guideline by another Oppenheimer employee; or 

a serious weakness or deficiency in Oppenheimer's        policies, procedures or controls which might enable        breaches to occur or go undetected;

you have a responsibility to Oppenheimer, your fellowOppenheimer employees and yourself to report it to your Manager,that employee's Manager or the Senior Vice President andCorporate Counsel.

Failure to report a known breach of the Code may result inserious consequences. If a problem or irregularity has beenreferred to you, you must resolve the issue or refer itappropriately using the chain of communication referred to below.

Oppenheimer recognizes that, from time to time, you may beuncertain about an appropriate course of action. In all suchcases, immediately seek the advice of your Manager, a more seniorofficer or the Senior Vice President and Corporate Counsel.Consult a still more senior officer or one of the personsreferred to below if you do not receive what you consider to be areasonable response from any such person.

If you are not satisfied with the resulting response oraction, you should contact or write without fear of reprisal tothe Chief Executive Officer of Oppenheimer or the Senior VicePresident and Corporate Counsel. You will be protected byOppenheimer from retaliation or reprisal if you, in good faith,report actual, suspected or perceived breaches of the Code, orsupplemental codes or guidelines or problems with Oppenheimerpolicies, procedures or controls.

**12. BREACHES OF THE CODE**

Breaches of the Code (and supplemental codes or guidelines) orreported problems with Oppenheimer policies, procedures orcontrols will be dealt with promptly and fairly. Any breach ofthe Code (and supplemental codes or guidelines) is a seriousmatter, and can result in action up to and including terminationof employment. Oppenheimer may be required to report certaintypes of breaches to regulatory authorities, in which case thedirector, officer or employee may be subject to civil or criminalproceedings and penalties.

**13. Sources of Assistance**

You are expected to know and understand this Code. If you havequestions or concerns consult your supervisor or your Manager. Ifthis is not appropriate or if you need further guidance, you mayconsult any of the following as you believe appropriate:

> 
Ms. Lenore Denys        Director of Human Resources        Oppenheimer & Co. Inc.        300 River Place, Suite 4000        Detroit, MI 48207        Tel: (313) 566-2309        Fax: (313) 259-7853        Email: Lenore.denys@opco.com

Mr. Allen Holeman        Director of Compliance        Oppenheimer & Co. Inc.        125 Broad Street, 16th Floor        New York, NY 10004        Tel: (212) 668-8944        Fax: (212) 668-5896        Email: Allen.Holeman@opco.com

Dennis P. McNamara, Esq.        Senior Vice President and Corporate Counsel,        Oppenheimer & Co. Inc.        125 Broad Street, 16th Floor        New York, NY 10004 U.S.A.        Tel: (212) 668-5771        Fax: (212) 425-8627        E-mail: dennis.mcnamara@opco.com 

> 
Eric Shames, Esq.        Office of the General Counsel        Oppenheimer & Co. Inc.        125 Broad Street, 16th Floor        New York, NY 10004 U.S.A.        Tel: (212) 668-8073        Fax: (212) 785-1918        Email: eric.shames@opco.com

> 
Ms. Elaine K. Roberts,        President and Treasurer        Oppenheimer Holdings Inc.        20 Eglinton Avenue West        Suite 1110, P.O. Box 2015        Toronto, Ontario M4R 1K8        Tel: (416) 322-1515        Fax: (416) 322-7007        E-mail: eroberts@opy.ca

> 
Mr. Albert G. Lowenthal        Chairman and CEO        Oppenheimer Holdings Inc. and Oppenheimer & Co. Inc.        125 Broad Street        16th Floor         New York, N.Y. 10004 U.S.A.        Tel: (212) 668-5782        Fax: (212) 943-8728        E-mail: albert.lowenthal@opco.com

Mr. Kenneth W. McArthur         Lead Director         Oppenheimer Holdings Inc.         93 Riverwood Parkway        Toronto, Ontario M8Y 4E4        Tel: (416) 233-0218        Fax: (416) 233-7870

or

Gulf Harbor Golf and Country Club        14335 Harbor Links Ct., Unit 20B        Fort Meyers Florida 33908 USA        Tel: (239) 481-0249        Fax: (239) 481-0249

 

 

C:\DOCUME~1\nhaile\LOCALS~1\Temp\MetaSave\OppenheimerCode of Conduct.doc