EXHIBIT 99.1

                            TORPEDO SPORTS USA, INC.

                 CODE OF ETHICS FOR SENIOR FINANCIAL MANAGEMENT


     Torpedo Sports, Inc. (the "Company") has adopted this Code of Ethics for
Senior Financial Management to promote honest and ethical conduct and to deter
wrongdoing. This Code applies to the Company's Chief Executive Officer, Chief
Financial Officer, Controller, Principal Accounting Officer and other employees
performing similar functions (the "Senior Financial Management"). The
obligations of this Code supplement, but do not replace, any other code of
conduct or ethics policy applicable to employees of the Company generally.

     Any person who has information concerning any violation of this Code by any
member of the Senior Financial Management shall promptly bring such information
to the attention of the General Counsel or Chief Executive Officer of the
Company. If the Chief Executive Officer determines that a conflict of interest
exists, he or she will refer the matter to the Audit Committee of the Board of
Directors for resolution. Violations of this Code may subject the employee to
appropriate actions, such as censure, suspension or termination. Such actions
shall be reasonably designed to deter wrongdoing and to promote accountability
for adherence to this Code. The Audit Committee of the Board of Directors shall
consider any request for a waiver of this Code and any amendments to this Code
and all such waivers or amendments shall be disclosed promptly as required by
law or SEC regulation.

     All members of the Senior Financial Management shall:

     o Act honestly and ethically in the performance of their duties at the
       Company.

     o Avoid actual or apparent conflicts of interest between personal and
       professional relationships.

     o Provide full, fair, accurate, timely and understandable disclosure in
       reports and documents that the Company files with, or submits to, the SEC
       and in other public communications by the Company.

     o Comply with rules and regulations of federal, state and local governments
       and other private and public regulatory agencies that affect the conduct
       of the Company's business and the Company's financial reporting. o Act in
       good faith, responsibly, with due care, competence and diligence, without
       misrepresenting material facts or allowing the member's independent
       judgment to be subordinated.

     o Respect the confidentiality of information acquired in the course of
       work, except when authorized or legally obtained to disclosure such
       information.

     o Share knowledge and maintain skills relevant to carrying out the member's
       duties within the Company. o Proactively promote ethical behavior as a
       responsible partner among peers and colleagues in the work environment
       and community.

     o Achieve responsible use of and control over all assets and resources of
       the Company entrusted to the member.

     o Promptly bring to the attention of the Chief Executive Officer any
information concerning (a) significant deficiencies in the design or operating
of internal controls which could adversely affect the Company's ability to
record, process, summarize and report financial date or (b) any fraud, whether
or not material, that involves management or other employees who have a
significant role in the Company's financial reporting or internal controls.


Acknowledged:


______________________________
Employee: