EXHIBIT 14

                           a21, INC./SUPERSTOCK, INC.


                       CODE OF BUSINESS CONDUCT AND ETHICS


                      For Employees, Officers and Directors


INTRODUCTION


      To further a21, Inc.'s and SuperStock,  Inc.'s  fundamental  principles of
honesty,   loyalty,   fairness  and   forthrightness  we  have  established  the
a21/SuperStock  Code of Business  Conduct and Ethics.  Our Code strives to deter
wrongdoing and promote the following six objectives:

o     Honest and ethical conduct;

o     Avoidance  of  conflicts of interest  between  personal  and  professional
      relationships;

o     Full,  fair,  accurate,  timely and  transparent  disclosure  in  periodic
      reports  required  to be filed by a21 with  the  Securities  and  Exchange
      Commission and in other public communications made by a21;

o     Compliance with the applicable government regulations;

o     Prompt internal reporting of Code violations; and

o     Accountability for compliance with the Code.


ACCOUNTING CONTROLS, PROCEDURES & Records


      Applicable  laws and company  policy  require a21 and  SuperStock  to keep
books and records that accurately and fairly reflect their  transactions and the
dispositions of their assets. In this regard, our financial executives shall:

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

o     Complywith 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.


      All directors,  officers,  employees and other persons are prohibited from
directly  or  indirectly  falsifying  or causing to be false or  misleading  any
financial  or  accounting  book,  record or account.  Furthermore,  no director,
officer or employee of a21 or SuperStock may directly or indirectly:

o     Make or cause to be made a materially false or misleading statement, or

o     Omit to state, or cause another person to omit to state, any material fact
      necessary to make  statements  made not misleading in connection  with the
      audit of financial statements by independent accountants,  the preparation
      of any required reports whether by independent or internal accountants, or
      any other work which  involves or relates to the filing of a document with
      the Securities and Exchange Commission.


BRIBERY

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      The offering, promising, or giving of money, gifts, loans, rewards, favors
or  anything of value to any  supplier,  customer  or  governmental  official is
strictly prohibited.


COMMUNICATIONS


      It is very  important  that the  information  disseminated  about  a21 and
SuperStock  be both  accurate and  consistent.  For this reason,  certain of our
executive officers who have been designated as authorized  spokespersons per our
policy regarding  compliance with Regulation FD are responsible for our internal
and external communications,  including public communications with stockholders,
analysts and other  interested  members of the  financial  community.  Employees
should  refer  all  outside   requests  for   information   to  the   authorized
spokespersons.


COMPUTER AND INFORMATION SYSTEMS


      For business purposes,  officers and employees are provided telephones and
computer  workstations  and  software,  including  network  access to  computing
systems such as the Internet and e-mail, to improve personal productivity and to
efficiently manage proprietary  information in a secure and reliable manner. You
must obtain the permission from our Information  Technology  Services department
to install any software on any company  computer or connect any personal  laptop
to the a21 or SuperStock  network. As with other equipment and assets of a21 and
SuperStock,  we are each  responsible  for the  appropriate use of these assets.
Except  for  limited   personal  use  of  a21  or  SuperStock   telephones   and
computer/e-mail, such equipment may be used only for business purposes. Officers
and employees should not expect a right to privacy of their e-mail.  All e-mails
on company equipment are subject to monitoring by a21 and SuperStock.


CONFIDENTIAL OR PROPRIETARY INFORMATION


      Company  policy  prohibits  employees  from  disclosing   confidential  or
proprietary  information  outside  a21 or  SuperStock,  either  during  or after
employment,  without company  authorization to do so. Unless otherwise agreed to
in  writing,  confidential  and  proprietary  information  includes  any and all
methods, inventions,  improvements or discoveries,  whether or not patentable or
copyrightable,  and any other  information of a similar nature  disclosed to the
directors, officers or employees of a21 or SuperStock or otherwise made known to
us as a  consequence  of or  through  employment  or  association  with  a21  or
SuperStock  (including  information  originated  by  the  director,  officer  or
employee).  This can include,  but is not limited to, information  regarding our
business,  research,   development,   inventions,  trade  secrets,  intellectual
property of any type or description,  data, business plans, marketing strategies
and contract negotiations.


CONFLICTS OF INTEREST


      Company policy prohibits conflicts between the interests of its employees,
officers, directors and a21 or SuperStock. A conflict of interest exists when an
employee,  officer,  or director'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,  and in the case of
officers  and  directors,  they  should  consult  with a  member  of  the  Audit
Committee.  When it is deemed to be in the best  interests of a21 or  SuperStock
and its  shareholders,  the Audit  Committee  may grant  waivers  to  employees,
officers and  directors  who have  disclosed an actual or potential  conflict of
interest. Such waivers are subject to approval by the Board of Directors.


FRAUD


      Company policy prohibits fraud of any type or description.


INSIDE INFORMATION


      Company policy and applicable laws prohibit  disclosure of material inside
information  to anyone outside a21 and  SuperStock  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. a21's
policies  with  respect  to  the  use  and  disclosure  of  material  non-public
information are more particularly set forth in a21's Insider Trading Policy.

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POLITICAL CONTRIBUTIONS


      Company  policy  prohibits the use of company,  personal or other funds or
resources on behalf of a21 or SuperStock  for political or other  purposes which
are improper or prohibited by the applicable  federal,  state,  local or foreign
laws, rules or regulations.  Company contributions or expenditures in connection
with election campaigns will be permitted where allowed by federal, state, local
or foreign election laws, rules and regulations.


REPORTING AND NON-RETALIATION


      Employees who have evidence of any  violations of this code are encouraged
and expected to report them to their supervisor, and in the case of officers and
directors, they should report evidence of any such violations to a member of the
Audit  Committee.  Such reports will be  investigated in reference to applicable
laws and company  policy.  Violations of this Code or any other unlawful acts by
our  officers,  directors or employees  may subject the  individual to dismissal
from employment  and/or fines,  imprisonment and civil  litigation  according to
applicable laws.


      We will not allow retaliation against an employee for reporting a possible
violation  of this  Code in good  faith.  Retaliation  for  reporting  a federal
offense is illegal under federal law and prohibited under this Code. Retaliation
for  reporting any violation of a law, rule or regulation or a provision of this
Code is  prohibited.  Retaliation  will result in discipline up to and including
termination of employment and may also result in criminal prosecution.


WAIVERS


      There  shall be no  waiver of any part of this  Code for any  director  or
officer except by a vote of the Board of Directors of a21 or a designated  board
committee  that will  ascertain  whether a waiver is  appropriate  under all the
circumstances.  In case a  waiver  of this  Code is  granted  to a  director  or
officer,  the notice of such waiver  shall be posted on our website  within five
days of the Board of Director's vote or shall be otherwise disclosed as required
by  applicable  law or  regulation.  Notices  posted on our website shall remain
there for a period of 12 months and shall be  retained  in our files as required
by law.


                                 Approved By The Board of Directors  of a21
                                 and SuperStock
                                 May 4, 2004