Exhibit 14.1

CODE OF ETHICS FOR CHIEF EXECUTIVE OFFICER AND SENIOR FINANCIAL OFFICERS

      Attached hereto is the Code of Conduct and Ethics applicable to all
directors, officers and employees of the Company. The CEO and all senior
financial officers, including the CFO and principal accounting officer, are
bound by the provisions set forth therein relating to ethical conduct, conflicts
of interest, and compliance with law. In addition to the Code of Conduct and
Ethics, the CEO and senior financial officers are subject to the following
additional specific policies:

      1. Act with honesty and integrity, avoiding actual or apparent conflicts
between personal, private interests and the interests of the Company, including
receiving improper personal benefits as a result of his or her position.

      2. Disclose to the CEO and the Board of Directors of the Company any
material transaction or relationship that reasonably could be expected to give
rise to a conflict of interest.

      3. Perform responsibilities with a view to causing periodic reports and
documents filed with or submitted to the SEC and all other public communications
made by the Company to contain information that is accurate, full, fair, timely
and understandable, including full review of all annual and quarterly reports.

      4. Comply with laws, rules and regulations of federal, state and local
governments applicable to the Company and with the rules and regulations of
private and public regulatory agencies having jurisdiction over the Company.

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

      6. Respect the confidentiality of information acquired in the course of
performance of his or her responsibilities except when authorized or otherwise
legally obligated to disclose any such information; not use confidential
information acquired in the course of performing his or her responsibilities for
personal advantage.

      7. Share knowledge and maintain skills important and relevant to the needs
of the Company, its stockholders and other constituencies and the general
public.

      8. Proactively promote ethical behavior among subordinates and peers in
his or her work environment and community.

      9. Use and control all corporate assets and resources employed by or
entrusted to him or her in a responsible manner.

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      10. Not use corporate information, corporate assets, corporate
opportunities or his or her position with the Company for personal gain; not
compete directly or indirectly with the Company.

      11. Comply in all respects with the Company's Code of Conduct and Ethics.

      12. Report promptly violations of this Code of Ethics to the Chairperson
of the Board, Chief Executive Officer, Chief Financial Officer or Chairperson of
the Audit Committee (if any) of the Board of Directors, as appropriate. The
Board of Directors will investigate any reported violations and will oversee an
appropriate response, including corrective action and preventative measures. Any
officer who violates this Code will face appropriate, case specific disciplinary
action, which may include demotion or discharge.

      Any request for a waiver of any provision of this Code must be in writing
and addressed to the Chairman of the Board of Directors of the Company. Any
waiver of this Code will be disclosed promptly on Form 8-K or any other means
approved by the Securities and Exchange Commission.

      It is the policy of the Company that each officer covered by this Code
shall acknowledge and certify to the foregoing annually and file a copy of such
certification with the Chairman of the Board of Directors.