**Exhibit14.1**

 

**Code of Ethicsfor Senior Financial Officersandthe Principal Executive OfficerofEarle M. Jorgensen Company**

 

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Earle M. JorgensenCompany (the “Company”) is committed to conducting its business in compliancewith all the applicable laws and regulations of the countries in which itoperates and in accordance with high standards of business conduct.  The Company strives to maintain the higheststandard of accuracy, completeness and disclosure in its financial dealings,records and reports.  These standardsserve as the basis for managing the Company’s business, for meeting theCompany’s duties to its shareholders and for maintaining compliance withfinancial reporting requirements.  Allof the Company’s financial executives must execute the following certification,and the Chief Executive Officer, in his or her capacity as the Company’sprincipal executive officer, to whom all senior financial officers ultimatelyreport, will promote and support this Code of Ethics, and, to the extent consistentwith his or her duties and responsibilities, comply with the followingprinciples:

 

Each seniorfinancial officer of the Company will adhere to and advocate the followingprincipals and responsibilities governing his or her professional and ethicalconduct, each to the best of his or her knowledge and ability:

 

1.                                       Actwith honesty and integrity and in an ethical manner, avoiding actual orapparent conflicts of interest in personal and professional relationships.

 

2.                                       Promptlydisclose to the Company**,**throughthe Audit Committee, any material transaction or relationship that reasonablycould be expected to give rise to a conflict of interest between personal andprofessional relationships.

 

3.                                       Provideconstituents with information that is accurate, complete, objective, relevant,timely and understandable.

 

4.                                       Complywith rules and regulations of federal, state, provincial and local governmentsand other appropriate private and public regulatory agencies.

 

5.                                       Actin good faith, responsibly, with due care, competence and diligence, withoutmisrepresenting material facts or allowing his or her independent judgment tobe subordinated.

 

6.                                       Usegood business judgment in the processing and recording of all financialtransactions.

 

7.                                       Respectthe confidentiality of information acquired in the course of the Company’sbusiness, except when authorized or otherwise legally obligated to disclosesuch information, and not use confidential information acquired in the courseof work for personal advantage.

 

8.                                       Shareknowledge and maintain skills important and relevant to his or herconstituents’ needs.

 

9.                                       Promoteethical behavior among constituents in his or her work environment.

 

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10.                                 Achieveresponsible use of and control over all assets and resources employed orentrusted to him or her.

 

11.                                 Complywith generally accepted accounting standards and practices, rules, regulationsand controls.

 

12.                                 Ensurethat accounting entries are promptly and accurately recorded and properlydocumented and that no accounting entry intentionally distorts or disguises thetrue nature of any business transaction.

 

13.                                 Maintainbooks and records that fairly and accurately reflect the Company’s businesstransactions.

 

14.                                 Signonly those documents that he or she believes to be accurate and truthful.

 

15.                                 Devise,implement and maintain sufficient internal controls to assure that financialrecord-keeping objectives are met.

 

16.                                 Prohibitthe establishment of any undisclosed or unrecorded funds or assets for anypurpose and provide for the proper and prompt recording of all disbursements offunds and all receipts.

 

17.                                 Notknowingly be a party to any illegal activity or engage in acts that arediscreditable to his or her profession or the Company.

 

18.                                 Respectand contribute to the legitimate and ethical objectives of the Company.

 

19.                                 Engagein only those services for which he or she has the necessary knowledge, skilland expertise.

 

20.                                 Notmake, or tolerate to be made, false or artificial statements or entries for anypurpose in the books and records of the Company or in any internal or externalcorrespondence, memoranda, or communication of any type, including telephone orwire communications.

 

21.                                 Reportto the Company, through the Audit Committee, any situation where this Code ofEthics, the Company’s standards or the laws are being violated.

 

Those required tocomply with this Code of Ethics understand that failure to comply with thisCode of Ethics will not be tolerated by the Company and that deviationstherefrom or violations thereof will result in serious consequences, which mayinclude, but may not be limited to, serious reprimand, dismissal or other legalactions.

 

The parties subject tothis Code of Ethics will acknowledge in writing that they agree to comply withthese requirements.

 

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