**Exhibit 14.1**

 

**CODE OF ETHICS**

 

KUBLA KHAN recognizes and respects that officers andemployees may take part in legitimate financial, business and other activitiesoutside their jobs. However, those activities must be lawful and free ofconflicts with their responsibilities as KUBLA KHAN employees.

** **

**Employees must not misuse KUBLA KHAN resources or discreditKUBLA KHAN’s name and reputation. The effectiveness of this policy depends onthe cooperation 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 KUBLA KHAN policies, exercise your own good judgment in all  personal and business dealings outside your KUBLA KHAN job.                                                                                                                                                                                       |
|   |   |                                                                                                                                                                                                                                                                                                                                                      |
| • |   | Avoid actions or  relationships which might conflict or appear to conflict with your job  responsibilities or the interests of KUBLA KHAN.                                                                                                                                                                                                                |
|   |   |                                                                                                                                                                                                                                                                                                                                                      |
| • |   | Do not misuse KUBLA KHAN  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 KUBLA KHAN Officers and Employees AreUrged To Watch For

 
| • |   | Holding a financial interest  in a company where you could personally affect KUBLA KHAN’s business with  that company                                                                                        |
|--------|--------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|   |   |                                                                                                                                                                                                              |
| • |   | Taking a part-time job where  you may be tempted to spend time on that job during your normal KUBLA KHAN  working hours or to use KUBLA KHAN equipment or materials                                               |
|   |   |                                                                                                                                                                                                              |
| • |   | Receiving gifts of greater  than nominal value from suppliers, customers or competitors while you are in  a position to influence KUBLA KHAN 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 KUBLA KHAN employees                                    |
|   |   |                                                                                                                                                                                                              |
| • |   | Directing business to a  supplier that is owned or managed by a relative or close friend                                                                                                                          |
|   |   |                                                                                                                                                                                                              |
| • |   | Misusing KUBLA KHAN  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 KUBLA  KHAN responsibilities or compromise company interests                                           |

 

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