Exhibit 14.01


                 RUVANE INVESTMENT CORPORATION CODE OF ETHICS

Purpose

To establish standards that promote:

        o   Honest and ethical conduct, including the ethical handling
            of actual or apparent conflicts of interest between personal
            and professional relationships;

        o   Full, fair, accurate, timely, and understandable disclosure
            in the filings with or submissions to the Securities and
            Exchange Commission (the "SEC") on behalf of The
            Willowbridge Fund, L.P. (the "Pool"), an investment pool
            operated by Ruvane Investment Corporation (the "Company")
            that is subject to the reporting requirement of the
            Securities Exchange Act of 1934, and in other public
            communications made by the Company concerning the Pool;

        o   Compliance with all applicable governmental laws, rules, and
            regulations;

        o   Prompt internal reporting of violations of the Company's Code
            of Ethics (this "Code"); and

        o   Accountability for adherence to this Code

Applicability

This Code applies to the Company's principal executive officer, principal
financial officer, principal accounting officer and persons performing similar
functions (collectively, the "Covered Officers").

General Responsibilities

The Company expects the Covered Officers to know and follow the policies
outlined in this Code. Any Covered Officer who violates the letter or spirit
of these policies is subject to disciplinary action, up to and including
termination.

Honest and Ethical Conduct

Every Covered Officer has the responsibility to be honest and ethical. All of
a Covered Officer's responsibilities should be performed with the highest
sense of integrity. Integrity accommodates the inadvertent error and the
honest difference of opinion, but it cannot accommodate deceit or
subordination of principle.

Honesty and integrity require that each Covered Officer ethically handle
actual or apparent conflicts of interest between personal and professional
relationships. A conflict of interest is any situation in which a Covered
Officer's personal interest is inconsistent with, or contrary to, the
legitimate interests of the Company, or an investment pool operated by the
Company. A conflict of interest situation can arise when a Covered Officer
takes action or has interests (financial or other) that may make it difficult

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to fulfill duties owed to the Company or any investment pool operated by the
Company. Conflicts of interest also may arise when a Covered Officer or a
member of a Covered Officer's family receives improper personal benefits as a
result of the Covered Officer's affiliation with the Company, regardless of
whether such benefits are received from the Company or a third party.

Full, Fair, Accurate, Timely, and Understandable Disclosure

As a result of the Pool being a reporting company under the Securities
Exchange Act of 1934, the Company is required, on behalf of the Pool, to file
periodic and other reports with the SEC. In that regard, each Covered Officer
must (1) take all reasonable steps to ensure that these reports and other
public communications represent full, fair, accurate, timely and
understandable disclosure regarding the financial and business condition of
the Pool; (2) promptly bring to the attention of the board of directors of the
Company any material information of which a Covered Officer may become aware
that affects the disclosures made by the Company in the public filings made on
behalf of the Pool or otherwise would assist the board of directors in
fulfilling its responsibilities to the Pool; and (3) must promptly bring to
the attention of the Compliance Officer and the board of directors of the
Company any information he or she may have concerning (i) significant
deficiencies in the design or operation of internal controls that could
adversely affect the Company's ability to record, process, summarize and
report financial data, including on behalf of the Pool or (ii) any fraud,
whether or not material, involving management or other employees who have a
significant role in the Company's financial reporting, including on behalf of
the Pool, disclosures or internal controls.

Compliance with All Applicable Governmental Laws, Rules, and Regulations

Each Covered Officer must comply with all applicable governmental laws, rules,
and regulations. This requirement applies to all federal, foreign, state and
local laws.

Prompt Internal Reporting of Violations of the Code

If a Covered Officer is unsure whether a situation violates any applicable
law, rule, regulation, or Company policy, the Covered Officer should discuss
the situation promptly with the Compliance Officer. Failure to do so is itself
a violation of the Code. The Company will not allow retaliation for reports
made in good faith.

Violations of or interpretive matters related to the Code should immediately
be brought to the attention of the Compliance Officer.

Waivers of or Amendments to the Code

Any waivers of or amendments to this Code must be granted by the Company's
board of directors. If a Covered Officer would like to request a waiver or
amendment to this Code, he should contact the Compliance Officer.