**Java
        Detour, Inc.**
  **Code
        of Business Conduct and Ethics**
  **I.**  **Statement
        of Policy**
  This
        Code
        of Business Conduct and Ethics (the “Code”) summarizes the legal, ethical and
        regulatory standards that the Company must follow and is a reminder to our
        directors, officers and employees of the seriousness of that commitment.
        This
        Code has been adopted by the Board of Directors of Java Detour, Inc. (the
        “Company”) to promote honest and ethical conduct, proper disclosure of financial
        information in the Company's periodic reports, and compliance with applicable
        laws, rules, and regulations by the Company's Financial Employees who have
        financial responsibilities. As used in this Code, the term Financial Employees
        means executives and all managers with accounting or financial reporting
        responsibilities or related disclosure responsibilities, including but not
        limited to the Company's Chief Executive Officer, Chief Financial Officer,
        other
        executive officers, directors, controller, general managers and other similar
        positions hereafter created and filled. The Code should also be provided
        to and
        followed by all of the Company’s agents and representatives, including its
        consultants, to the same extent required of directors, certain of its officers
        and employees of the Company.
  Our
        business is becoming increasingly complex, both in terms of the geographies
        in
        which we function and the laws with which we must comply. To help our Financial
        Employees understand what is expected of them and to carry out their
        responsibilities, we have created this Code of Business Conduct and Ethics.
        While this Code covers a wide range of business practices and procedures,
        it is
        not intended to be a comprehensive guide to all of our policies or to all
        of
        your responsibilities under the applicable laws or regulations. Rather, this
        Code sets out basic principles to help you resolve the ethical and legal
        issues
        that you may encounter in conducting our business. As such, this Code functions
        as a guideline, or a minimum requirement, that must always be followed.
  We
        expect
        each of our Financial Employees to read and become familiar with the ethical
        standards described in this Code. Violations of the law, our corporate policies
        or this Code may lead to disciplinary action, including termination of
        employment or service with the Company.
  **II.** **We
        Insist on Honest and Ethical Conduct**
  We
        place
        the highest value on the integrity of our Financial Employees, and demand
        this
        level of integrity in all our dealings. We insist on not only ethical dealings
        with others, but on the ethical handling of actual or apparent conflicts
        of
        interest between personal and professional relationships.
  Competition
        and Fair
        Dealing
 
 All
        Financial Employees are required to deal honestly and fairly with our customers,
        suppliers, competitors, other employees and other third parties. We seek
        to
        outperform our competition fairly and honestly. Stealing proprietary
        information, possessing trade secret information that was obtained without
        the
        owner’s consent, or inducing such disclosures by past or present employees of
        other companies is prohibited. No employee should take unfair advantage of
        anyone through manipulation, concealment, abuse of privileged information,
        misrepresentation of material facts or any other intentional unfair practice,
        and our Financial Employees should be diligent in preventing or terminating
        any
        such activity by the employees reporting to them.
  
  **Conflicts
        of Interest; Corporate Opportunities**
  Our
        Financial Employees should not be involved in any activity that creates or
        gives
        the appearance of a conflict of interest between their personal interests
        and
        the interests of the Company. A conflict of interest occurs when an individual’s
        private interest interferes in any way or may appear to interfere with the
        interests of the Company as a whole. A conflict situation can arise when
        a
        director, officer or employee takes actions or has interests that may make
        it
        difficult to perform his or her work for the Company objectively and
        effectively. Conflicts of interest may also arise when a director, officer
        or
        employee, or a member of his or her family, receives an improper personal
        benefit as a result of his or her position with the Company. It may be a
        conflict of interest for a director, officer or employee to work simultaneously
        for a competitor, customer or supplier. The best policy is to avoid any direct
        or indirect business connection with our customers, suppliers or competitors,
        except on our behalf. Loans to, or guarantees of obligations of, employees
        and
        their family members may create conflicts of interest.
  In
        addition, without limiting the generality of this Code’s prohibition on
        conflicts of interest by Financial Employees, examples of conflicts of interest
        include, but are not limited to:
  ·
            Accepting,
                directly or indirectly, gifts, loans, services or entertainment of
                more
                than nominal value, from a competitor, customer, supplier, or other
                party
                doing or seeking to do business with the
                Company;  ·
            Acquiring
                any interest or asset of any kind for the purpose of selling or leasing
                it
                to the Company; and  ·
            Doing
                business with close relatives on behalf of the Company unless authorized
                after the relationship has been fully
                disclosed.  Financial
        Employees must notify the Chairman of our Board of Directors, or audit
        committee, if such committee is hereafter created, of the existence of any
        actual or potential conflict of interest including any actual or potential
        conflicts of interest involving their subordinate employees of which they
        become
        aware. The Board of Directors or audit committee, may make a determination
        that
        a particular transaction or relationship will not result in a conflict of
        interest covered by this policy. Any waivers of this policy may only be approved
        by the Board of Directors or audit committee. If you are not sure whether
        a
        potential matter constitutes a conflict of interest, please contact the Chairman
        of the Board of Directors or audit committee who will assist you in the
        determination or refer you to the Company’s outside counsel.
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  **Confidentiality**
  Our
        Financial Employees are entrusted with our confidential information and with
        the
        confidential information of our suppliers, customers or other business partners.
        This information includes all non-public information that might be of use
        to
        competitors, or harmful to the Company or its customers, if disclosed, and
        may
        include (a) technical or scientific information about current and future
        products, services or research, (b) business or marketing plans or projections,
        (c) earnings and other internal financial data, (d) personnel information,
        (e)
        supply and customer lists and (f) other non-public information that, if
        disclosed, might be of use to our competitors, or harmful to our suppliers,
        customers or other business partners. This information is our property, or
        the
        property of our suppliers, customers or business partners, and in many cases
        was
        developed at great expense.
  Our
        Financial Employees must maintain the confidentiality of confidential
        information entrusted to them by the Company, its suppliers, customers or
        other
        business partners, except when disclosure is authorized by the Board of
        Directors, or general counsel, if such position is hereafter filled, or is
        otherwise required by applicable laws or regulations. This obligation to
        preserve confidential information continues even after your appointment and/or
        employment, as applicable, ends. In connection with this obligation, you
        may
        have executed a confidentiality agreement when you began employment with
        the
        Company. Please see your confidentiality agreement, if any, and the Company’s
        employee handbook for further information regarding your responsibilities
        in
        this area.
  **Protection
        and Proper Use of Corporation Assets**
  All
        Financial Employees should endeavor to protect the Company’s assets and ensure
        their efficient use. Theft, carelessness and waste have a direct impact on
        the
        Company’s profitability. Any suspected incident of fraud or theft should be
        immediately reported for investigation. Company equipment should not be used
        for
        non-Company business, though incidental personal use may be
        permitted.
  The
        obligation to protect the Company’s assets includes its proprietary information.
        Proprietary information includes intellectual property such as trade secrets,
        patents, trademarks, and copyrights, as well as business, marketing and service
        plans, engineering and manufacturing ideas, designs, databases, records,
        salary
        information and any unpublished financial data and reports. Unauthorized
        use or
        distribution of this information would violate Company policy, could be illegal
        and may result in civil or even criminal penalties.
  **Corporate
        Opportunities**
  Financial
        Employees are prohibited from taking for themselves personally opportunities
        that are discovered through the use of corporate property, information or
        position without the consent of the Board of Directors. No employee may use
        corporate property, information or position for improper personal gain, and
        no
        employee may compete with the Company directly or indirectly. Employees,
        officers and directors owe a duty to the Company to advance its legitimate
        interests when the opportunity to do so arises.
  **III.**
            **Provide
                Full, Fair, Accurate, Timely and Understandable Disclosure**  3
  We
        are
        committed to providing our stockholders and investors with full, fair, accurate,
        timely and understandable disclosure in the reports that we file with the
        Securities and Exchange Commission. You must take all steps available to
        assist
        the Company in these responsibilities. To this end, our Financial Employees
        shall:
  ·
            not
                make false or misleading entries in our books and records for any
                reason;  ·
            notify
                our Chief Financial Officer if they become aware of an unreported
                or
                questionable transaction;  ·
            maintain
                a system of internal accounting controls that will provide reasonable
                assurances to management that all transactions are properly
                recorded;  ·
            prohibit
                the establishment of any undisclosed or unrecorded funds or
                assets;  ·
            maintain
                a system of internal controls that will provide reasonable assurances
                to
                our management that material information about the Company is made
                known
                to management, particularly during the periods in which our periodic
                reports are being prepared; and  ·
            present
                information in a clear and orderly manner and avoid the use of unnecessary
                legal and financial language in our periodic
                reports.  **IV.**
            **Special
                Ethical Obligations for Employees with Financial Reporting
                Responsibilities**  In
        performing their duties, our Financial Employees must adhere to and advocate
        to
        the best of their ability the following principles governing their professional
        and ethical conduct:
 
 ·
            Act
                with honesty and integrity, including the ethical handling of actual or
                apparent conflicts of interests between personal and professional
                relationships; 
 ·
            Comply
                with all applicable laws, rules and regulations of federal, state,
                provincial and local governments, and other appropriate private and
                public
                regulatory agencies applicable to the performance of his or her duties
                with the Company;  ·
              Comply
                    with the Company’s established accounting procedures, system of internal
                    controls and generally accepted accounting
                    principles;
  ·
            Promptly
                disclose to the Board of Directors, or audit committee, if such committee
                is hereafter created, any significant deficiencies in the design
                or
                operation of the Company’s internal controls impacting the collection and
                reporting of financial data and any fraud involving management or
                other
                employees who play a significant role in the Company’s internal controls;
                and 
 ·
            Provide
                information that is accurate, complete, objective, relevant, timely
                and
                understandable to ensure full, fair, accurate, timely and understandable
                disclosure in reports and documents that the Company files with,
                or
                submits to, governmental agencies, including the Securities and Exchange
                Commission, and in other public communications made by the
                Company.  4
  **V.**  **Compliance
        with all Laws, Rules and Regulations**
  We
        are
        committed to full compliance with the laws and regulations of the cities,
        states
        and countries in which we operate, including, but not limited to:
  ·
            Conducting
                our activities in full compliance with all applicable environmental
                laws;  ·
            prohibiting
                any illegal payments, gifts or gratuities to any government or government
                employee;  ·
            prohibiting
                the unauthorized use, reproduction, or distribution of any third
                party’s
                trade secrets, copyrighted information or confidential information;
                and  ·
            complying
                with all applicable securities laws.  Our
        Financial Employees who have access to material, nonpublic information about
        the
        Company are not permitted to use or share that information for stock trading
        purposes or for any other purpose except in the conduct of our business.
        All
        non-public information about the Company should be considered confidential
        information. To use non-public information for personal financial benefit
        or to
“tip” others who might make an investment decision on the basis of this
        information is not only unethical but also illegal.
  Any
        Financial Employee who violates the law or this Code may be subject to immediate
        disciplinary action, including possible termination of employment or affiliation
        with the Company.
  **VI.**  **Compliance
        Procedures; Reporting Violations; and Effect of
        Violations**
  Compliance
        with this Code, first and foremost, is the individual responsibility of every
        Financial Employee. We attempt to foster a work environment in which ethical
        issues and concerns may be raised and discussed with supervisors or with
        others
        without the fear of retribution.
  **Reporting
        Violations and Questions**
  Financial
        Employees must promptly report, in person or in writing, any known or suspected
        violations of laws, governmental regulations or this Code to the Chairman
        of the
        Company’s Board of Directors, or audit committee, is such committee is hereafter
        created, at mike@javadetour.com. Any questions or violation reports will
        be
        addressed immediately and seriously.
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  **No
        Retaliation; Internal Investigation**
  We
        will
        not allow any retaliation against a Financial Employee who acts in good faith
        in
        reporting any violation. When an alleged violation of the Code is reported,
        we
        shall take prompt and appropriate action in accordance with the law and
        regulations otherwise consistent with good business practices. Our Board
        of
        Directors, or audit committee, if such committee is hereafter created, will
        investigate any reported violations and will determine an appropriate response,
        including corrective action and preventative measures, involving the Chief
        Executive Officer when required. All reports will be treated confidentially
        to
        every extent possible.
  **Consequences
        of a Violation**
  Financial
        Employees that violate any laws, governmental regulations or this Code will
        face
        appropriate, case specific disciplinary action, which may include demotion
        or
        immediate discharge.
  **At
        Will Employment**
  Nothing
        in this Code shall confer upon employees any right to continue in the employment
        of the Company for any period of specific duration or interfere with or
        otherwise restrict in any way the rights of the Company (or any parent or
        subsidiary of the Company employing or retaining the employee) or of the
        employee, which rights are hereby expressly reserved by each, to terminate
        the
        employee’s service with the Company at any time for any reason, with or without
        cause.
  **VII.**  **Waivers
        of the Code of Ethics**
  Any
        waiver of this Code for Financial Employees may be made only by the Board
        of
        Directors, or audit committee, if such committee is hereafter created, and
        will
        be promptly disclosed as required by law. Requests for waivers must be made
        in
        writing to the Board of Directors or audit committee prior to the occurrence
        of
        the violation of the Code.
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