EXHIBIT 14.1

                                    LMIC, INC

                       CODE OF BUSINESS CONDUCT AND ETHICS

             FOR EMPLOYEES, FINANCIAL OFFICERS AND SENIOR EXECUTIVES

INTRODUCTION

From its  inception,  LMIC,  Inc. and its employees  have been committed to high
standards of ethical behavior. Daily business decisions are made on the basis of
LMIC's five stated Values:  Integrity,  Compassion,  Teamwork,  Excellence,  and
Innovation. Because of its placement first, Integrity takes precedence should it
ever be in conflict with any of the other Values.

USE AND DISCLOSURE OF INSIDE INFORMATION

Company  policy and  applicable  laws  prohibit  disclosure  of material  inside
information to anyone outside the Company without a specific business reason for
them to know. It is unlawful and against  Company  policy for anyone  possessing
inside information to use such information for personal gain.

CONFIDENTIAL OR PROPRIETARY INFORMATION

Company policy prohibits  employees from disclosing  confidential or proprietary
information  outside the Company,  either  during or after  employment,  without
Company authorization to do so.

CONFLICTS OF INTEREST

Company policy  prohibits  conflicts  between the interests of its employees and
the Company. A conflict of interest exists when an employee's  personal interest
interferes  or may  interfere  with the  interests of the Company.  Conflicts of
interest  may not  always  be clear,  so if an  employee  has a  concern  that a
conflict  of  interest  may exist,  they should  consult  with higher  levels of
management,  the  company's  internal  auditor,  or the  Chairman  of the  Audit
Committee.

WAIVERS

When  it  is  deemed  to be  in  the  best  interests  of  LMIC,  Inc.  and  its
shareholders,  the Audit  Committee  may grant  waivers  to  employees  who have
disclosed an actual or potential conflict of interest.  Such waivers are subject
to approval by the Board of Directors.

COMMERCIAL BRIBERY

Company policy prohibits commercial bribes,  kickbacks and other similar payoffs
and benefits paid to any suppliers or customers.

FRAUD

Company policy prohibits fraud of any type or description.

ACCOUNTING CONTROLS, PROCEDURES & RECORDS

Applicable laws and Company policy require the Company to keep books and records
that accurately and fairly reflect its  transactions and the dispositions of its
assets. In this regard, the Company's financial executives shall:

           o          Act with honesty and integrity, avoiding actual or
                      apparent conflicts of interest in personal and
                      professional relationships.


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           o          Provide constituents with information that is accurate,
                      complete, objective, relevant, timely and understandable.

           o          Comply with rules and regulations of federal, state,
                      provincial and local governments, and other appropriate
                      private and public regulatory agencies.

           o          Act in good faith, responsibly, with due care, competence
                      and diligence, without misrepresenting material facts or
                      allowing independent judgment to be subordinated.

           o          Share knowledge and maintain skills important and relevant
                      to constituents' needs.

           o          Actively promote ethical behavior as a responsible partner
                      among peers in the work environment.

           o          Achieve responsible use of, and control over, all assets
                      and resources for which responsible.

PROTECTION FOR EMPLOYEES WHO PROVIDE EVIDENCE OF FRAUD OR OTHER BREACHES OF THIS
CODE

Employees who have evidence of fraud or other breaches of this code are
encouraged and expected to report them to their supervisor, any Leadership Team
member, a member of the Board of Directors, or a member of the Audit Committee
in accordance with the Company's Whistleblower policy if applicable. Such
reports will be investigated in reference to applicable laws and Company policy
and Values. It is unlawful and against Company policy to institute reprisal or
recrimination against employees for reporting such concerns.

Breaches to this code or any other unlawful acts by the Company's officers,
directors or employees may be subject to dismissal from employment and/or fines,
imprisonment and civil litigation according to applicable laws.

Approved By The Board of Directors
April 2, 2004


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