**Exhibit14.1**

 

**JASMINE’SGARDENCODE OF ETHICS**

 

Conflicts of Interest Policy Overview

 

Jasmine’s Garden (“JASG”) recognizes andrespects that officers and employees may take part in legitimate financial,business and other activities outside their jobs. However, those activitiesmust be lawful and free of conflicts with their responsibilities as JASGemployees.

 

**Employees must not misuse JASG resources or discredit JASG‘s name and reputation. The effectiveness of this policy depends on thecooperation of all employees in disclosing any situations that may be contraryto the intent of the policy and the ethical standards that it expresses.**

** **

Core Ethical Requirements

 
| • |   | Disclose outside activities,  financial interests or relationships that may present a possible conflict of  interest or the appearance of a conflict. Make your disclosures in writing to  your supervisor as well as to company legal counsel.  When in doubt as to whether a possible  conflict of interest exists, err on the side of disclosure. |
|--------|--------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|   |   |                                                                                                                                                                                                                                                                                                                                                      |
| • |   | In addition to complying with  the law and JASG policies, exercise your own good judgment in all personal  and business dealings outside your JASG job.                                                                                                                                                                                                   |
|   |   |                                                                                                                                                                                                                                                                                                                                                      |
| • |   | Avoid actions or  relationships which might conflict or appear to conflict with your job  responsibilities or the interests of JASG.                                                                                                                                                                                                                      |
|   |   |                                                                                                                                                                                                                                                                                                                                                      |
| • |   | Do not misuse JASG resources,  intellectual property, time or facilities (including office equipment,  e-mail, and computer applications).                                                                                                                                                                                                                |
|   |   |                                                                                                                                                                                                                                                                                                                                                      |
| • |   | Obtain necessary approvals  before accepting any position as an officer or director of an outside  business concern.                                                                                                                                                                                                                                      |

 

What JASG Officers and Employees Are Urged ToWatch For

 
| • |   | Holding a financial interest  in a company where you could personally affect JASG ‘s business with that  company                                                                                       |
|--------|--------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|   |   |                                                                                                                                                                                                        |
| • |   | Taking a part-time job where  you may be tempted to spend time on that job during your normal JASG working  hours or to use JASG equipment or materials                                                     |
|   |   |                                                                                                                                                                                                        |
| • |   | Receiving gifts of greater  than nominal value from suppliers, customers or competitors while you are in  a position to influence JASG decisions that might affect or appear to affect  the outside concern |
|   |   |                                                                                                                                                                                                        |
| • |   | Receiving personal discounts  or other benefits from suppliers, service providers or customers not  available to the general public or similarly situated JASG employees                                    |
|   |   |                                                                                                                                                                                                        |
| • |   | Directing business to a  supplier that is owned or managed by a relative or close friend                                                                                                                    |
|   |   |                                                                                                                                                                                                        |
| • |   | Misusing JASG resources, your  position or influence to promote or assist an outside business or  not-for-profit activity                                                                                   |
|   |   |                                                                                                                                                                                                        |
| • |   | Preferential hiring of,  direct supervision of, or making a promotion decision about a spouse,  relative or close personal friend                                                                           |
|   |   |                                                                                                                                                                                                        |
| • |   | A romantic or other personal  relationship that may create a conflict of interest with the employee’s JASG  responsibilities or compromise company interests                                           |

 

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