EXHIBIR 14.1

                                 WaterChef, Inc.

                                  ETHICS POLICY

It is the policy of WaterChef, Inc. that its employees and board members uphold
the highest standards of ethical, professional behavior. To that end, these
employees and board members shall dedicate themselves to carrying out the
mission of this organization and shall:

     Hold paramount the safety, health and welfare of the public in
     the performance of professional duties.

     Conduct our business in accordance with all applicable laws and
     regulations. Compliance with the law does not comprise our entire
     ethical responsibility, rather, it defines our minimum absolutely
     essential performance of our duties.

     Act in such a manner as to uphold and enhance personal and
     professional honor, integrity and the dignity of the Company..

     Treat with respect and consideration all persons, regardless of
     race, color, religion, gender, national origin, age, disability,
     ancestry, marital status, veteran status, citizenship status,
     sexual orientation, or any other protected status.

     Engage in carrying out WaterChef's mission in a professional
     manner.

     Collaborate with and support other professionals in carrying out
     WaterChef's mission.

     Commit to fair competition and the sense of responsibility
     required of a good customer and teammate in regards to our
     suppliers and partners.

     Build professional reputations on the merit of services and
     refrain from competing unfairly with others.

     Recognize the chief function of WaterChef at all times is to
     serve the best interests of its constituency. To this end,
     WaterChef is committed to pursuing sound growth and earnings
     objectives and to exercising prudence in the use of our assets
     and resources.

     Accept as a personal duty the responsibility to keep up to date
     on emerging issues and to conduct ourselves with professional
     competence, fairness, impartiality, efficiency and effectiveness.

     Respect the structure and responsibilities of the board of
     directors, provide them with facts and advice as a basis for
     their making policy decisions, and uphold and implement policies
     adopted by the board.

     Keep the community informed about issues affecting it.

     Conduct organizational and operational duties with positive
     leadership exemplified by open communication, creativity,
     dedication and compassion.

     Maintain accurate and complete company records. Transactions
     between the company and outside individuals and organizations
     must be promptly and accurately entered in our books in
     accordance with GAAP and principles. No one should rationalize or
     even consider misrepresenting facts or falsifying records. It
     will not be tolerated and will result in disciplinary action,
     including the possibility of immediate termination of employment.

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     Exercise whatever discretionary authority they have under the law
     to carry out the mission of the organization.

     Serve with respect, concern, courtesy and responsiveness in
     carrying out the organization's mission.

     Demonstrate the highest standards of personal integrity,
     truthfulness, honesty and fortitude in all activities in order to
     inspire confidence and trust in such activities.

     Avoid any interest or activity that is in conflict with the
     conduct of their official duties. If a potential conflict of
     interest exists or arises, the company must be made immediately
     aware.

     Respect and protect privileged information to which they have
     access in the course of their official duties. This includes
     abiding by the privacy legislation governing the collection,
     holding, use, correction, disclosure or transfer of personal
     information obtained through any dealing with WaterChef. Any
     breach of the security of WaterChef's personal or confidential
     information must be immediately reported.

     Strive for personal and professional excellence and encourage the
     professional development of others.