Exhibit
      10.4


**Satellite
      Newspapers**


**Code
      of Business Ethics**





The
      Vision of Satellite Newspapers is a world class, multi-million dollar
      organization that provides its people with awesome opportunities to grow and
      develop.  It is an organization that is not afraid to value its people and
      take chances in which the end result will be a great brand that people will
      love
      and value for a long time.




The
      Company is committed to uphold the highest standards of ethical conduct,
      business practices, principles and applicable laws and regulations. We want
      to
      ensure our dedication to maintaining the fundamental principles of fairness,
      integrity, honesty and common sense towards our relationships with employees,
      customers, partners, competitors, suppliers and vendors around the world.
      Without these standards, we could be undermining our global business reputation
      for integrity, standards of excellence, and ultimately our success as a
      Company.




The
      Code
      was written to ensure the guidelines of our business practices are made public
      and provide a brief explanation of what the Company expects of those associated
      with Satellite Newspapers. The signee is held accountable for adherence to
      this
      Code, in all markets around the world. Violations of this Code will result
      in
      immediate corrective action by Satellite Newspapers included but not limited
      to
      termination of the relationship between the violator and Satellite Newspapers,
      legal action and etc.




**CONDUCT
      AND BEHAVIOR STANDARDS**


Satellite
      Newspapers provides an environment free from any form of hostile work
      environment, unlawful discrimination or harassment (regardless of race, color,
      gender, age, religion, national origin, disability, veteran status or any other
      protected status). For the Company’s success, each must respect and value its
      diverse population.




It
      is
      policy to deal fairly with, employees, Company customers, partners, competitors,
      suppliers and vendors. The success of the Company is only achieved and
      maintained by performing jobs as required in a professional manner consistent
      with the Company's business philosophy, values and standards of business
      conduct. Honesty and integrity are essential to ethical business
      practices.




Any
      type
      of harassment is not tolerated and should be reported to the leadership of
      Satellite Newspapers immediately. All incidents will be immediately investigated
      and the appropriate action taken.




**CONDUCT
      AND BEHAVIOR STANDARDS**


The
      following list includes, but is not limited to, unacceptable conduct that is
      considered detrimental to the Company's best interests will result in immediate
      corrective action by Satellite Newspapers included but not limited to
      termination of the relationship between the violator and Satellite Newspapers,
      legal action and etc.


·
            Falsify
                or mislead facts, not limited to, company records and financial
                reports;


·
            Making
                misrepresentations or dishonest statements to anyone inside or outside
                the
                Company;


·
            Unethical,
                immoral, indecent or illegal
                conduct;














·
            Harassment
                (which includes, but is not limited to, sexual harassment, indecent
                gestures, demeaning comments, physical fighting, or other abusive
                conduct
                creating an intimidating, hostile or offensive work environment);


·
            Discrimination
                due to race, religion, color, national origin, gender, sexual orientation,
                age, disability, veteran or marital
                status;


·
            Deliberate
                destruction of company or other’s property;


·
            Deliberate
                work stoppage or slowdown;


·
            Theft,
                misappropriation, or unauthorized personal use of company property
                or
                property of others;


·
            Any
                conduct that poses a serious threat to the health or safety of
                others


·
            Any
                action which seriously impacts the company business or image in a
                negative
                or destructive way




**CONFLICTS
      OF INTEREST**


A
      conflict of interest generally exist when private interests conflicts or appears
      to conflict, with the best business interests of the Company. A conflict also
      arises when working simultaneously for customers, partners, competitors,
      suppliers or vendors. If you are in doubt about any situation regarding conflict
      of interests, discuss with the leadership of Satellite Newspapers.




There
      are
      many forms of conflict, below is a listing of conflicts, but are not limited
      to,
      the following examples.


·
            Having
                any financial interest in any company where that interest might conflict
                with our Company business;


·
            Participating
                in any activity that is competitive while being employed by the
                Company;


·
            Working
                part-time or full-time that would interfere with fulfilling your
                job
                responsibilities;


·
            Serving
                as a Board Member or Director for a customers, partners, competitors,
                suppliers or vendors of the Company without prior written approval
                by the
                Legal Department;


·
            Obtaining
                or giving any cash, kickbacks or bribes


·
            Asking
                customers, partners, competitors, suppliers or vendors for personal
                gifts,
                favors or donations for personal, family or significant relationship
                use
                or gain;


·
            Provide
                purchasing conditions of Company products or services that are not
                legitimate;


Accepting
      inappropriate expenses paid from customers, partners, competitors, suppliers
      or
      vendor’s event.


This
      is
      not an all-inclusive listing therefore you are responsible for ensuring to
      avoid
      any conflicts of interests. Contact Satellite Newspapers if there are any
      questions concerning this matter.




**PROTECTING
      COMPANY CONFIDENTIAL INFORMATION**


Be
      sensitive to the potential compromise of the Company’s confidential and
      proprietary information and the appearance of divided loyalty that can occur
      when family members or others work for the Company’s customers, partners,
      competitors, suppliers or vendors.




Disclosing
      the Company’s confidential information could give the competition an advantage,
      weaken the quality of our products and services, increase the risk of
      litigation, or damage the Company.













Confidential
      information includes, but not limited to technology, trade secrets, non-public
      business plans/strategies, financial data, pricing, marketing or sales programs,
      product information, lists or information related to our customers, partners,
      competitors, suppliers or vendor’s businesses, company training, operations,
      changes in executive management.




Confidential
      and insider information must not be shared with anyone outside the Company
      or
      who does not need to know. Be mindful when having social conversations not
      to
      disclose any Company information that should not be shared with others. It
      is
      your responsibility to safeguard Company information from unauthorized access
      or
      use. If there is a doubt about confidential information, contact the Legal
      Department.




It
      is not
      appropriate to use another company's confidential or proprietary information
      for
      their or the Company’s benefit.




**PROTECTION
      AND APPROPRIATE USE OF COMPANY RESOURCES**


The
      Company provides equipment and resources for the purpose to be used for
      conducing business. From time to time personal uses of these resources are
      allowed; however misapplication of these equipment or resources is a violation
      of the Code.




**FINANCIAL
      REPORTING**


The
      Company maintains and complies with all applicable financial reporting and
      accounting principles applicable to the Company. All financial matters must
      be
      recorded and in a timely and accurately manner. Inaccurate or misleading entries
      or sign or disseminate, or ask another to sign such documents known to be
      inaccurate, untrue or misleading is not an acceptable practice. Concerns or
      issues regarding questionable financial practices must discuss the situation
      immediately with the leadership of Satellite Newspapers’
leadership.




**BUSINESS
      RELATED ENTERTAINMENT**


Gifts
      could be given or received as long as they not being made in return for special
      consideration. The amount of a gift given or received should not exceed the
      appropriate amount defined by local law and business governance.




Local
      custom in some countries may call for the exchange of gifts having more than
      nominal value as part of the business relationship. Such gifts may only be
      accepted on behalf of the Company (not an employee). In all cases, the exchange
      of gifts must be conducted so there is no appearance of impropriety.




**GLOBAL
      TRADE REGULATIONS**


Globally,
      trade laws and regulations are intended to promote ethical competition in the
      marketplace and to limit activities that restrain trade. Never talk about or
      enter into any arrangement (written or verbal) or understanding with a
      competitor regarding confidential information, pricing of products, favoring
      or
      withholding business from particular customers, partners, competitors, suppliers
      or vendors, or any other activity that may have antitrust or anti-competition
      implications.





Any
      questions regarding trade or competition laws or how they might affect the
      Company conducts its business, should be referred to the leadership of Satellite
      Newspapers.




**ASSOCATION**


Associates
      with Satellite Newspapers or any of its’ related companies will be held to the
      Code of Business Ethics and asked to sign.




**COMMUNICATION
      WITH THE MEDIA OR OUTSIDE CONTACTS**


Contact
      with the media or other outside contacts are not authorized to provide
      information regarding the Company without prior approval. All calls should
      be
      referred to the leadership of Satellite Newspapers.




**REPORTING
      VIOLATIONS**


Any
      questions or concerns about the Code, business standards or if you think or
      observe what you believe to be inappropriate, unethical, or unlawful ethical
      standards by employees, customers, partners, competitors, suppliers or vendors
      please contact the leadership of Satellite Newspapers.




Any
      information provided during an investigation will be shared only with those
      who
      have a need to know. All reports will be taken seriously and acted upon as
      deemed appropriate by the Company.




**RESPONSIBILITY**


Should
      be
      familiar with the Code of Business Ethics and how it applies to them and to
      those they manage. No one has authority to require or influence another to
      violate this Code, and any attempt to do so may result in immediate action
      by
      Satellite Newspapers.




Knowledge
      of a violation or questionable behavior related to this Code, means that it
      should be reported immediately to Satellite Newspapers’ leadership for
      investigation and corrective action.




**AMENDMENTS
      and MODIFICATIONS**


This
      Code
      may be amended or modified, as needed by the Company.




**COMPLIANCE
      REPORTING**


After
      reading the Code of Business Ethics submit a Code acknowledgement that states
      you have read, understand and, to the best of your knowledge, are complying
      with
      the various provisions of this Code.




Acknowledgement
      of the Code of Business Ethics




I,
      (print
      name) _____________________________________________, being associated with
      Satellite Newspapers, do hereby acknowledge to have received a copy of the
      Code
      of Business Ethics and have read and reviewed this Code and understand its
      contents and understand that I am subject to all of its provisions. I further
      certify that I am not aware of any violations of this Code





of
      Business Ethics that have not been duly reported pursuant to the provisions
      of
      this Code as of this date.




_______________________________________
            ___________________Signature
            Date








_______________________________________


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