Exhibit 14.1 SANTO PITA CORP.CODE OF ETHICS TOPICS 1.
 Statement of Policy2.
 Implementation and Enforcement3.
 Relations with Competitors and Other
  Third Parties4.
 Insider Trading, Securities Compliance
  and Public Statements5.
 Financial Reporting6.
 Human Resources7.
 Environmental, Health and Safety8.
 Conflicts of Interest9.
 International Trade10.
 Government Relations11.
 Contractors, Consultants, and
  Temporary Workers12.
 Conclusion
 1.   STATEMENT OF POLICY The
Company has adopted eight Corporate Values (Focus, Respect, Excellence,
Accountability, Teamwork, Integrity, Very Open Communications and Enjoying Our
Work) to provide a framework for all employees in conducting ourselves in our
jobs. These policies are not intended to substitute for those Values, but will
serve as guidelines in helping you to conduct the Company's business in
accordance with our Values. Compliance requires meeting the spirit, as well as
the literal meaning, of the law, the policies and the Values. It is expected
that you will use common sense, good judgment, high ethical standards and
integrity in all your business dealings. If you
encounter a situation you are not able to resolve by reference to these
policies, ask for help. Contact Rosa Ruiz, Chairman and Chief Executive
Officer, who has been identified as responsible for overseeing compliance with
these policies.


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Violations of the law or the Company's policies will subject employees to disciplinary action, up to and including termination of employment. In addition, individuals involved may subject themselves and the Company to severe penalties including fines and possible imprisonment. Compliance with the law and high ethical standards in the conduct of Company business should be a top priority for each employee, officer and director.  2.    IMPLEMENTATION AND ENFORCEMENT. Rosa Ruiz, our Chairman and Chief Executive Officer, has been appointed as Compliance Officer of the Company, responsible for overseeing compliance with, and enforcement of, all Company policies. Employees are expected to be familiar with these policies as they apply to their duties. They should consult with their managers if they need assistance in understanding or interpreting these policies. Each employee is required to follow these policies and to comply with their terms. A refusal by any employee to agree to be bound by these policies shall be grounds for discipline up to and including dismissal. Any employee who, in good faith, has reason to believe a Company operation or activity is in violation of the law or of these policies must call the matter to the attention of Rosa Ruiz, our Chairman and Chief Executive Officer. All reports will be reviewed and investigated and as necessary under the circumstances, and the reporting employee should provide sufficient information to enable a complete investigation to be undertaken. Any employee who makes an allegation in good faith reasonably believing that a person has violated these policies or the law, will be protected against retaliation. 3.  RELATIONS WITH COMPETITORS AND OTHER THIRD PARTIES. The Company's policy is to comply fully with competition and antitrust laws throughout the world. These laws generally prohibit companies from using illegal means to maintain, obtain or attempt to obtain a monopoly in a market. They also prohibit companies from engaging in unfair trade practices."Unfair tradepractices" include fixing prices, dividing markets, agreeing with competitors not to compete, or agreeing to boycott certain customers. It is advised that you consult with the Rosa Ruiz before attending a meeting with a party who may be viewed as a competitor. 4.  INSIDER TRADING, SECURITIES COMPLIANCE AND PUBLIC STATEMENTS. Securities laws prohibit anyone who is in possession of material, non-public information ("Insider Information") about a company from purchasing or selling stock of that company, or communicating the information to others. Information is considered "material" if a reasonable investor would consider it to be important in making a decision to buy or sell that stock. Some examples include financial results and projections, new products, acquisitions, major new contracts or alliances prior to the time that they are publicly announced. Employees who become aware of such Inside Information about the Company must refrain from trading in the shares of the Company until the Inside Information is publicly announced.  2


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Employees
must also refrain from disclosing that information to persons who do not have a
Company need to know, whether they are inside the Company or outside, such as
spouses, relatives or friends. The
Company makes regular formal disclosures of its financial performance and
results of operations to the investment community. We also regularly issue
press releases. Other than those public statements, which go through official
Company channels, employees are prohibited from communicating outside the
Company about the Company's business, financial performance or future
prospects. Such communications include questions from securities analysts,
reporters or other news media, but also include seemingly innocent discussions
with family, friends, neighbors or acquaintances. 5.  FINANCIAL REPORTING. The
Company is required to maintain a variety of records for purposes of reporting
to the government. The Company requires all employees to maintain full
compliance with applicable laws and regulations requiring that its books of
account and records be accurately maintained. Specifics of these requirements
are available from Rosa Ruiz. 6.  HUMAN RESOURCES. The
Company is committed to providing a work environment that is free from unlawful
harassment and discrimination, and respects the dignity of its employees. The
Company has policies covering various aspects of its relationship with its
employees, as well as employees’ relationships with each other. For more
detailed information, you should consult Rosa Ruiz. Each employee is expected
to be familiar with these policies and to abide by them. 7.  ENVIRONMENTAL, HEALTH AND
SAFETY. The
Company is committed to protecting the health and safety of our employees, as
well as the environment in general. The Company expects employees to obey all
laws and regulations designed to protect the environment, and the health and
safety of our employees, and to obtain and fully observe all permits necessary
to do business. At the
very least, all employees should be familiar with and comply with safety
regulations applicable to their work areas. The Company will make, to the
extent possible, reasonable accommodations for the known physical or mental
limitations of our employees. Employees who require an accommodation should
contact Rosa Ruiz. The Company will then engage in an interactive process to
determine what reasonable accommodations may exist. 8.  CONFLICTS OF INTEREST. Each
employee is expected to avoid any activity, investment or association that
interferes with the independent exercise of his or her judgment in the
Company's best interests ("Conflicts of Interest"). Conflicts of
Interest can arise in many situations. They occur most often in cases where the
employee or the employee's family obtains some personal benefit at the expense
of the Company's best interests.  3


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No
employee, or any member of employee's immediate family, shall accept money,
gifts of other than nominal value, unusual entertainment, loans, or any other
preferential treatment from any customer or supplier of the Company where any
obligation may be incurred or implied on the giver or the receiver or where the
intent is to prejudice the recipient in favor of the provider. Likewise, no
employee shall give money, gifts of other than nominal value, unusual
entertainment or preferential treatment to any customer or supplier of the
Company, or any employee or family members thereof, where any obligation might
be incurred or implied, or where the intent is to prejudice the recipient in
favor of the Company. No such persons shall solicit or accept kickbacks,
whether in the form of money, goods, services or otherwise, as a means of
influencing or rewarding any decision or action taken by a foreign or domestic
vendor, customer, business partner, government employee or other person whose
position may affect the Company's business. No
employee shall use Company property, services, equipment or business for
personal gain or benefit. Employees
may not: (1) act on behalf of, or own a substantial interest in, any company or
firm that does business, or competes, with the Company; (2) conduct business on
behalf of the Company with any company or firm in which the employee or a
family member has a substantial interest or affiliation. Exceptions require
advance written approval from the Legal Department. Employees
should not create the appearance that they are personally benefitting in any
outside endeavor as a result of their employment by the Company, or that the
Company is benefitting by reason of their outside interests. Any employee who
is not sure whether a proposed action would present a conflict of interest or
appear unethical should consult with Rosa Ruiz . 9.  INTERNATIONAL TRADE. The
Company must comply with a variety of laws around the world regarding its
activities. In some cases, the law prohibits the disclosure of information,
whether the disclosure occurs within the U.S. or elsewhere, and whether or not
the disclosure is in writing. Payments
or gifts to non-U.S. government officials are prohibited by law and by Company
policy. The Foreign Corrupt Practices Act precludes payments to non-U.S.
government officials for the purpose of obtaining or retaining business, even
if the payment is customary in that country. This law applies anywhere in the
world to U.S. citizens, nationals, residents, businesses or employees of U.S.
businesses. Because SANTO PITA CORP is a U.S. company, this law applies to the
Company and all of its subsidiaries. Any questions on this policy should be
directed to Rosa Ruiz. 10.  GOVERNMENT RELATIONS. The
Company is prohibited by law from making any contributions or expenditures in
connection with any U.S. national election. This includes virtually any
activity that furnishes something of value to an election campaign for a
federal office. Use of the Company's name in supporting any political position
or ballot measure, or in seeking the assistance of any elected representative,
requires the specific approval of the Chairman and Chief Executive Officer of
the Company. Political contributions or expenditures are not to be made out of
Company funds in any foreign country, even if permitted by local law, without
the consent of the Company's Chairman and Chief Executive Officer.  4


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U.S. law also prohibits giving, offering, or promising anything of value to any public official in the U.S. or any foreign country to influence any official act, or to cause an official to commit or omit any act in violation of his or her lawful duty. Company employees are expected to comply with these laws. 11.  VENDORS, CONTRACTORS, CONSULTANTS AND TEMPORARY WORKERS. Vendors, contractors, consultants or temporary workers who are acting on the Company's behalf, or on Company property, are expected to follow the law, Company policies and honor Company Values. Violations will subject the person or firm to sanctions up to and including loss of the contract, contracting or consulting agreement, or discharge from temporary assignment. 12.  CONCLUSION. This Code of Ethics is not intended to cover every possible situation in which you may find yourself. It is meant to give you the boundaries within which the Company expects you to conduct yourself while representing SANTO PITA CORP. You may find yourself in a situation where there is no clear guidance given by this Code of Ethics. If that occurs, return to the foundations stated earlier: common sense, good judgment, high ethical standards and integrity. And refer to the Company's Values. In addition, there are many resources upon which you may rely: your management chain, Human Resources, Legal or other SANTO PITA CORP. departments, and the CEO. Together we can continue to make SANTO PITA CORP. a company that sets a standard for managing real estate companies.   ______________________________________                                                                     Employee           5


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SANTO
PITA CORP.
VALUES  FOCUSWe exist only
because we are involved in managing real estate companies.RESPECTWe value all people, treating them with dignity at all
times.EXCELLENCEWe strive for "Best in Class" in everything
we do. ACCOUNTABILITYWe do what we
say we will do and expect the same from others. TEAMWORKWe believe that
cooperative action produces superior results. INTEGRITYWe are honest
with ourselves, each other, our customers, our partners and our shareholders VERY OPEN COMMUNICATIONWe share
information, ask for feedback, acknowledge good work, and encourage diverse
ideas. ENJOYING OUR WORKWe work hard,
are rewarded for it, and maintain a good sense of perspective, humor and
enthusiasm.         6


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Reportable
Violations - Anonymous Reporting Program Accounting Error
Accounting Omissions
Accounting Misrepresentations
Auditing Matters
Compliance/Regulation Violations
Corporate Scandal
Domestic Violence
Discrimination
Embezzlement
Environmental Damage
Ethics Violation
Fraud
Harassment
Industrial Accidents
Misconduct
Mistreatment
Poor Customer Service
Poor Housekeeping
Sabotage
Securities Violation
Sexual Harassment
Substance Abuse
Theft
Threat of Violence
Unfair Labor Practice
Unsafe Working Conditions
Vandalism
Waste
Waste of Time and Resources
Workplace Violence    7


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