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EXHIBIT 14

                                 CODE OF ETHICS
                     FOR CHIEF EXECUTIVE AND SENIOR OFFICERS

The Company is committed to conducting our business in accordance with
applicable laws, rules and regulations and the highest standards of business
conduct, and to full and accurate financial disclosure in compliance with
applicable law. This Code of Ethics, applicable to the Company's Chief Executive
Officer, Chief Operating Officer, Chief Financial Officer and Controller (or
persons performing similar functions) (together, "Senior Officers"), sets forth
specific policies to guide you in the performance of your duties.

As a Senior Officer, you must not only comply with applicable law. You also must
engage in and promote honest and ethical conduct and abide by the Code of
Business Conduct and other Company policies and procedures that govern the
conduct of our business. Your leadership responsibilities include creating a
culture of ethical business conduct and commitment to compliance, maintaining a
work environment that encourages employees to raise concerns, and promptly
addressing employee compliance concerns.

COMPLIANCE WITH LAWS, RULES AND REGULATIONS

You are required to comply with the laws, rules and regulations that govern the
conduct of our business and to report any suspected violations in accordance
with the section below entitled "Compliance With Code Of Ethics."

CONFLICTS OF INTEREST

Your obligation to conduct the Company's business in an honest and ethical
manner includes the ethical handling of actual or apparent conflicts of interest
between personal and professional relationships. No Senior Officer shall make
any investment, accept any position or benefits, participate in any transaction
or business arrangement or otherwise act in a manner that creates or appears to
create a conflict of interest unless the Senior Officer makes full disclosure of
all facts and circumstances to, and obtains the prior written approval of, the
Audit Committee of the Board of Directors.

DISCLOSURES

It is Company policy to make full, fair, accurate, timely and understandable
disclosure in compliance with all applicable laws and regulations in all reports
and documents that the Company files with, or submits to, the Securities and
Exchange Commission and in all other public communications made by the Company.
As a Senior Officer, you are required to promote compliance with this policy and
to abide by Company standards, policies and procedures designed to promote
compliance with this policy.

COMPLIANCE WITH CODE OF ETHICS

If you know of or suspect a violation of applicable laws, rules or regulations
or this Code of Ethics, you must immediately report that information to any
member of the Audit Committee of the Board of Directors. No one will be subject
to retaliation because of a good faith report of a suspected violation.

Violations of this Code of Ethics may result in disciplinary action, up to and
including discharge. The Audit Committee of the Board of Directors shall
determine, or shall designate appropriate persons to determine, appropriate
action in response to violations of this Code.

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WAIVERS OF CODE OF ETHICS

If you would like to seek a waiver of the Code of Ethics you must make full
disclosure of your particular circumstances to the Audit Committee of the Board
of Directors. Amendments to and waivers of this Code of Ethics will be publicly
disclosed as required by applicable law and regulations.

NO RIGHTS CREATED

This Code of Ethics is a statement of certain fundamental principles, policies
and procedures that govern the Company's Senior Officers in the conduct of the
Company's business. It is not intended to and does not create any rights in any
employee, customer/client, supplier, competitor, shareholder or any other person
or entity.

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