Exhibit 14

              CODE OF ETHICS FOR CEO AND SENIOR FINANCIAL OFFICERS

      The Chief  Executive  Officer ("CEO") and all senior  financial  officers,
including the chief financial officer and principal accounting officer of Summit
Environmental  Corporation,  Inc., and of any subsidiary that becomes subject to
the periodic reporting  requirements under Section 13(a) or Section 15(d) of the
Securities  Exchange Act of 1934, as amended,  are bound by the  provisions  set
forth in this Code of Ethics relating to ethical conduct, conflicts of interest,
compliance  with law and  standards  designed to deter  wrongdoing.  The CEO and
senior financial officers are subject to the following specific policies:

      1. The CEO and all senior  financial  officers are  responsible  for full,
fair,  accurate,  timely and  understandable  disclosure in the periodic reports
required  to be  filed by the  Company  with  the  SEC.  Accordingly,  it is the
responsibility of the CEO and each senior financial officer promptly to bring to
the attention of the Audit Committee of Summit Environmental  Corporation,  Inc.
any  material  information  of which he or she may become aware that affects the
disclosures  made by the Company in its public  filings or otherwise  assist the
Audit Committee in fulfilling its responsibilities as specified in the Company's
financial reporting policies and applicable law.

      2. The CEO and each senior  financial  officer shall promptly bring to the
attention of the Audit  Committee any information he or she may have which he or
she reasonably  believes  reflects or indicates (a) significant  deficiencies in
the design or operation of internal  controls which could  adversely  affect the
Company's ability to record, process, summarize and report financial data 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,  audits or
internal controls or (c) any attempt to improperly influence,  coerce or mislead
the  Company's  independent  auditors  in  violation  of  Section  303(a) of the
Sarbanes-Oxley Act of 2002 and the rules of the SEC passed thereunder.

      3. The CEO and each senior  financial  officer shall promptly bring to the
attention  of the  General  Counsel  or the CEO and to the Audit  Committee  any
information he or she may have which he or she reasonably  believes  reflects or
indicates a violation of this Code of Ethics or any actual or apparent conflicts
of interest  between  personal and  professional  relationships,  involving  any
management  or other  employees  who have a  significant  role in the  Company's
financial reporting, audits or internal controls.

      4. The CEO and each senior  financial  officer shall promptly bring to the
attention  of the  General  Counsel  or the CEO and to the Audit  Committee  any
information he or she may have which he or she reasonably  believes  indicates a
material  violation  of the  securities  or other  laws,  rules  or  regulations
applicable to the Company and the  operation of its business,  by the Company or
any agent thereof.

      5. The  Board of  Directors  shall  determine,  or  designate  appropriate
persons to determine, appropriate actions to be taken in the event of violations
of the Code of  Ethics  or of  these  additional  procedures  by the CEO and the
Company's senior financial  officers.  Such actions shall be reasonably designed
to deter wrongdoing and to promote  accountability for adherence to this Code of
Ethics and to these additional procedures,  and shall include written notices to
the  individual  involved  that the Board has  determined  that there has been a
violation  and the action to be taken,  which action may include  censure by the
Board, demotion or re-assignment of the individual involved,  suspension with or
without pay or  benefits  (as  determined  by the Board) or  termination  of the
individual's  employment.  In  determining  what  action  is  appropriate  in  a
particular case, the Board of Directors or such designee shall take into account
all relevant  information,  including without limitation the nature and severity
of the  violation,  whether the  violation  was a single  occurrence or repeated
occurrences,   whether  the  violation  appears  to  have  been  intentional  or
inadvertent,  whether the  individual  in question had been advised prior to the
violation as to the proper course of action and whether or not the individual in
question had committed other violations in the past.

      6. Any  waiver  of this  Code of  Ethics  may be made only by the Board of
Directors  of the  Company and shall be  disclosed  to the persons in the manner
provided by applicable  law and by any regulatory  agency having  authority over
the Company.

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