EXHIBIT 14
                                 CODE OF ETHICS
                               AVENUE GROUP, INC.

         CODE OF ETHICS

         FOR PRINCIPAL EXECUTIVE OFFICERS AND SENIOR FINANCIAL OFFICERS


         Avenue Group, Inc. (the "Company") expects the highest possible ethical
conduct from its principal executive officers and senior financial officers.
Your full compliance with this Code is mandatory. You are expected (i) to foster
a culture of transparency, integrity and honesty, and (ii) to take actions that
result in the Company's compliance with laws and regulations.

         In accordance with the rules of the U.S. Securities and Exchange
Commission, any amendment to, or waiver of, this Code must be immediately
publicly disclosed by the Company in a Report on Form 8-K within four (4)
business days after the adoption of any amendment or grant of any waiver.

         This Code of Ethics has been adopted by the Board of Directors of the
Company, and may only be amended by the Board of Directors or, at such time as
applicable, a committee of the Board of Directors consisting solely of directors
who are not the principal executive officers or senior financial officers of the
Company. Any waiver of this Code of Ethics may only be approved by: (i) the
Board of Directors, with any affected member thereof abstaining or (ii) at such
time as the Company has formed an Audit Committee of the Board of Directors,
such Audit Committee or, if any Audit Committee has not been formed, another
committee designated by the Board of Directors consisting solely of directors
who are not the principal executive officers or senior financial officers of the
Company. For purposes of this Code of Ethics, all references hereinafter to the
"Board" shall mean the Board of Directors as described in (i) above, and all
references hereinafter to the "Committee" shall mean a committee of the Board as
described in (ii) above.

         Statement of Purpose

         This Code of Ethics is adopted to deter wrongdoing and to 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 reports
         and documents that the Company files with, or submits to the Securities
         and Exchange Commission and in other public communications made by the
         Company;
     o   Compliance with governmental laws, rules and regulations;
     o   The prompt internal  reporting of violations of the Code to an
         appropriate  person or persons identified in the Code; and
     o   Accountability for adherence to the Code.

         Conflicts of Interest

         You must avoid any personal activity, investment or association that
could appear to interfere with good judgment concerning the Company's best
interests. You may not exploit your position or relationship with the Company
for personal gain at the expense of the Company. You should utilize your best
efforts to avoid even the appearance of such a conflict. For example, there is a
likely conflict of interest if you:

     o   cause the Company to engage in business transactions with relatives or
         friends, without the prior approval, after the full disclosure thereof,
         by the Board of Directors;
     o   use nonpublic information concerning the Company, vendors or
         competitors for personal gain by you, your relatives or friends
         (including securities transactions based on such information);
     o   financial interest in the Company's vendors or competitors, other than
         1% or less of their publicly traded stock, unless your interest is
         fully disclosed to and approved by the Board or the Committee;
     o   receive a loan,  or  guarantee  of  obligations,  from any third
         party as a result of your  position at the
         Company; or
     o   compete with the Company while still employed by the Company.

         There are other situations in which a conflict of interest may arise.
You are expected to be aware of potential conflicts of interest that may arise
under various circumstances. When you become aware of a conflict of interest or
the appearance of a conflict of interest, you are expected to take actions
necessary to avoid the conflict of interest. Alternatively, if you believe it
appropriate, you are expected to advise the Board and/or the Committee, as the
case may be, of the conflict and seek their approval.

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         Accurate Periodic Reports

         As you are aware, full, fair, accurate, timely and understandable
disclosures in the Company's periodic reports is legally required and is
essential to the success of its business. You are expected to exercise the
highest standard of care in preparing such reports in accordance with the
following guidelines:

         All Company accounting records, as well as reports produced from those
records, must be in accordance with the laws of each applicable jurisdiction.

         All records must fairly and accurately reflect the transactions or
occurrences to which they relate.

         All records must fairly and accurately reflect, in reasonable detail,
the Company's assets, liabilities, revenues and expenses.

         The Company's accounting records must not contain any false or
intentionally misleading entries.

         No transactions should be intentionally misclassified as to accounts,
departments or accounting periods.

         All transactions must be supported by accurate documentation in
reasonable detail and recorded in the proper account and in the proper
accounting period.

         No information should be concealed from the internal auditors or the
independent auditors.

         Compliance with the Company's system of internal accounting controls is
required.

         Compliance

         You are expected to comply with both the letter and spirit of all
applicable governmental laws, rules and regulations.

         If you fail to comply with this Code, with the Company's Code of
Business Conduct, and/or with any applicable laws, you will be subject to
disciplinary measures, up to and including immediate discharge from the Company.

         Reporting Violations

         Your conduct can reinforce an ethical atmosphere and positively
influence the conduct of fellow associates. If you are powerless to stop
suspected misconduct or discover it after it has occurred, you must report it to
the appropriate level of management. If you are the senior financial officer,
the appropriate reporting level is the Chief Executive Officer. If the Chief
Executive Officer does not respond in a timely manner to your concern, you
should report the matter to the Board or the Committee, as the case may be. If
you are the Chief Executive Officer, the appropriate reporting level is the
Board or the Committee, as the case may be.

         Conclusion

         You, as the principal executive officers and senior financial officers
of the Company, are primarily responsible for ensuring that the Company complies
with all applicable laws and regulations. You are primarily responsible for
ensuring that the Company's public reports are full, fair, accurate, timely and
understandable, and the Company looks to you to set the standards under which
these objectives will be fulfilled. You are expected to exercise your best
business judgment in good faith as to all matters that may be covered by this
Code of Ethics.

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