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                                   EXHIBIT 14

                                 GENELINK, INC.
                                 CODE OF CONDUCT

                                  January 2004

         GeneLink, Inc. (the "Company") is committed to uphold the highest
standards of ethics in the conduct of our business affairs. We have a duty to
carry out our responsibilities in accordance with both the letter and the spirit
of the law. We will strictly comply with the laws, rules and regulations that
apply to our Company and with the corporate policies, procedures and guidelines
established by our Company.

         The Company acts only through its employees and therefore every
employee is responsible for carrying out our commitment to these high standards.
We expect every employee to act with honesty and integrity in every aspect of
daily business and to follow the principles set out in this Code of Conduct in
all business matters.

         Failure to comply with the standards contained in the Code can damage
the Company's good name, trade and client relations and business opportunities.
In addition, conduct which violates applicable laws or regulations can subject
the individuals involved and the Company and its officers to civil liabilities
and in many cases to prosecution, imprisonment and fines.

         For convenience, the Code is drafted to refer to Company employees, but
"employees" should be read to include also every director, officer, consultant
and agent of the Company, unless the context clearly otherwise indicates. Copies
of the Code, available from the President of the Company, should be provided to
consultants and agents retained to provide services to which the Code is
applicable.

A.       DISSEMINATION OF CONFIDENTIAL INFORMATION

Company employees will learn confidential information in the course of their
employment about the Company's business or about the business of our present and
prospective clients. Confidential information may include business, financial,
pricing and marketing data, supplier and customer information and personnel
information such as salary data.

The Company is committed to protecting confidential information to the maximum
extent reasonable and possible. Every employee must keep such information
confidential and not disclose it to anyone who does not have a legitimate need
to know, including others within the Company. Employees may not use confidential
information except in connection with the Company's business.

Former employees remain bound by the rules of confidentiality. An employee who
leaves a job at the Company may not use confidential information learned while
employed here, nor may such information be given to anyone else to use.

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Employees have a special obligation not to buy or sell the Company's or any
client company's securities when they have knowledge of any important
information regarding the Company or the client company which is not generally
known to the public. Please see the discussion under the heading "Securities
Trading" for additional guidelines.

B.       SECURITIES TRADING

The Company's stock is traded publicly, and the Company has a commitment to
compliance with applicable United States federal and state and foreign
securities laws and regulations. In the course of business operations, you may
become aware of nonpublic information regarding important business affairs of
the Company or other firms. The securities laws prohibit trading securities on
the basis of such information if it is material. Under the securities laws,
information is deemed to be material if an investor would consider it important
in deciding whether to buy, sell or hold securities. Examples of some types of
material information are financial results, financial forecasts, possible
mergers, acquisitions, joint ventures and other purchases and sales of or
investments in companies, obtaining or losing important contracts, significant
discoveries, important product developments, major litigation developments and
major changes in business direction.

Employees may not (i) direct someone else to buy or sell on their behalf if they
have knowledge of any material nonpublic information or (ii) pass material
nonpublic information on to outsiders ("tipping") who may then trade on it. Do
not give advice or recommendations to others concerning an investment in Company
securities or the securities of another company about which you have heard
through your employment with the Company. This restriction applies to your
family and friends.

C.       CONFLICT OF INTEREST

No officer, employee or member of his or her immediate family shall have a
conflict of interest with the business of the Company. A conflict of interest
can exist where an employee or a member of his immediate family:

         -        Has an interest in, or a position with a supplier, customer or
                  competitor of our Company, or such other financial interest as
                  could affect the employee's judgment (the exception being
                  ownership of a listed company's stock).

         -        Gains personal enrichment through access to confidential
                  information, whether in connection with the trading in the
                  Company stock or otherwise.

         -        Gains personal enrichment through misuse of his or her
                  position in the Company.

D.       MAKING AND ACCEPTING GIFTS

Employees of the Company shall not make, nor accept gifts of more than $75 in
value from:

         -        Customers, prospective customers, suppliers or prospective
                  suppliers of the Company.

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         -        Employees of any customer, prospective customer, supplier or
                  prospective supplier of the Company.

In addition, employees shall not make, or accept from the above, any
entertainment or social invitations involving more than reasonable cost. Should
an employee have questions whether a gift may be contrary to this Code, then
advance written approval should be sought from their supervisor and each
supervisor should make a report to the President of the Company regarding the
circumstances if the gift is accepted.

E.       POLITICAL CONTRIBUTIONS, PAYMENT TO UNRELATED PARTIES AND OUTSIDE
         ACTIVITIES

No political contributions shall be made by the Company unless permitted by
local and United States law and made with the prior written consent of the
President of the Company.

No employee shall be reimbursed directly or indirectly for any political
contribution made by such employee.

An employee must obtain written permission in advance from their immediate
supervisor before serving as a director, trustee, officer, owner, partner or
employee of any other organization, or before entering self-employment,
consulting, writing, speaking, teaching or any other individual employment
activity.

Employees may serve as volunteers, without compensation, in the capacity of
director, trustee, officer, member or representative of non-profit organizations
such as school boards, hospitals, churches and social organizations without
obtaining prior approval of their immediate supervisor, provided there are no
points of conflict with the Company and with their employment with the Company.

No Employee shall accept individual compensation for making an oral
presentation, writing, teaching, lecturing, rendering charitable or professional
services or for performing any other activity prepared or carried out using the
time or facilities of the Company. Any amounts received for activities of this
type must be approved in writing by the employee's immediate supervisor and any
amounts received remitted to the Company.

If no company time or facilities are used in the preparation or delivery of the
non-company activity, individual compensation received may be retained by the
individual, subject to the aforementioned Conflict of Interest rules. This
permission does not extend to books or articles subject of which is related to
the types of business conducted by the Company as to which prior written
approval is required.

E.       TRADE, TECHNICAL SECRETS AND COMPETITION

Trade and technical secrets shall not be disclosed by any employee to anyone
except with prior approval by the President of the Company and when accompanied
by appropriate legal documents to protect these valuable assets.

In its business activities the Company engages in vigorous, but fair and ethical
competition. The Company excludes all practices which are anti-competitive,
illegal or unethical. Discussions and

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agreements, oral or written, with competitors concerning pricing or other
competitive policies are prohibited. Employees must take special care to ensure
that in meetings of trade associations and other business groups, competitive
policies and practices are not discussed.

G.       BRIBES, ILLEGAL PAYMENTS AND KICKBACKS

No payments by the Company shall be approved or made with the intention or
understanding that any part or all of such payment is to be used for any purpose
other than described by the supporting documents.

No employee is to use funds, assets, or services of the Company for an unlawful
purpose.

H.       ACCOUNTING ACCURACY

No undisclosed or unrecorded fund or asset of the Company shall be established
or maintained.

No false or misleading entries shall be made in the books and records of the
Company.

No employee shall knowingly make a false or misleading statement to the
Company's independent auditors.

Any employee having information or knowledge of an unrecorded fund or asset or
any prohibited act shall promptly report such matter to the President of the
Company.

I.       COMPLIANCE WITH TRADE LAWS

Compliance with government trade laws in spirit and in letter is a fundamental
Company policy.

No employee may directly, or indirectly, engage in agreements to limit
production or services, unjustified and undocumented preferential prices, trade
reciprocity or other activities contrary to the Company pricing policies.

J.       GENERAL

The President of the Company shall be responsible for the administration of and
compliance with the Code of Conduct. Periodic distribution and reinforcement to
ensure employee knowledge and compliance is required of all employees.
Exceptions to this Code may only be granted by the President of the Company or
his designee.

Employees will annually be required to complete an acknowledgement and
compliance with the Code of Conduct.

All employees are required to keep their supervisory officers fully informed on
all matters pertinent to the Company's affairs and business activities with the
aim of ensuring that senior management will be fully informed on a timely basis
as to all such matters. If any employee believes there may be conflicts of
interest in reporting to senior management any acts which fail to comply with
this Code, or the employee believes senior management acts may be contrary to
the Code, then the employee is directed to contact the President of the Company.

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K.       LABOR AND EMPLOYMENT LAW

The Company is committed to cultivating a safe and fair work environment. All
employees must comply with all applicable United States and foreign laws
concerning labor and employment. The Company is bound by these laws and has
established policies and programs, including equal employment opportunity
policies, safety and health programs and wage and hour procedures, to ensure
compliance with legal requirements, certain of which are described below.

Equal Employment Opportunity. The Company is dedicated to the goal of providing
equal opportunity for all employees. We have a duty to ensure that everyone has
a fair and equal opportunity not only of being hired, but also of being promoted
and enjoying all of the opportunities offered by the Company. It is therefore
Company policy to recruit, hire and promote without discrimination based on any
impermissible classification including, but not limited to, race, color, creed,
religion, sex, national origin, citizenship, age, disability, marital status,
veteran status or sexual orientation. As an equal employment opportunity
employer, the Company is dedicated to the principles of affirmative action and
requires all employees to implement steps to achieve those principles.

         Consistent with this policy, the Company will not tolerate
discrimination against its employees by any employee or any individual or firm
with which the Company does business based upon any impermissible
classification. The Company will not tolerate racist or bigoted remarks or
treating fellow employees with disrespect. If you believe you have been
subjected to unlawful employment discrimination, you should immediately contact
the President of the Company. All complaints of employment discrimination will
be investigated swiftly and in as confidential a manner as possible, and, if
appropriate, corrective and disciplinary action will be taken.

Sexual Harassment. As part of the Company's equal employment opportunity policy,
the Company is committed to protecting the right of its employees to work in an
environment that is free from all forms of discrimination, including sexual
harassment. No form of sexual harassment will be tolerated. Sexual harassment
may include unwelcome sexual advances, requests for sexual favors, and verbal,
physical or visual conduct or conditions of a sexual nature that have the effect
of unreasonably interfering with an employee's work performance or which create
an intimidating, hostile or offensive work environment. If you believe you have
been the victim of sexual harassment, you should immediately contact the
President of the Company. All allegations of sexual harassment will be
investigated promptly in as confidential a manner as possible, and, if
appropriate, corrective and disciplinary action will be taken.

Safety and Health. The Company is committed to providing its employees with a
safe and healthy work environment and complying with all applicable occupational
safety and health laws and standards. Employees are required to report any
adverse health or safety incidents or conditions, including broken equipment or
machinery and accidents, to the President of the Company. All such reports will
be investigated promptly and corrective action will be taken as appropriate.

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Other activities which are prohibited because they are not conducive to a good
work environment include: (i) harassment, threats and violent behavior; (ii)
possession of weapons; and (iii) possession, use, sale or distribution of
illegal drugs. If employees are under the influence of illegal drugs or alcohol,
they may not be present on Company premises.

L.       RESPONDING TO INQUIRIES FROM THE PRESS AND OTHERS

Requests for financial or business information about the Company from any member
of the investment community, including securities analysts, fund and portfolio
managers, directors of research and brokers, or any member of the business or
financial press or other news media, should be referred to the President of the
Company to ensure appropriate and timely response. Requests for information or
other contacts from the Securities and Exchange Commission, the National
Association of Securities Dealers, Inc. or other securities regulators must also
be referred to the President of the Company. It is critical that employees not
respond to any such inquiries or contacts themselves because any inappropriate
or inaccurate response, even a disclaimer of information, may result in adverse
publicity and could otherwise seriously affect the Company's legal position.
This policy does not apply to requests for published financial information, such
as Annual and Quarterly Reports, or to requests concerning normal marketing,
product or promotional publicity activities of the Company.

Requests for proposed interviews with any Company employee by the financial
community or news media, and the issuance of any press release by any Company
employee, must be reviewed and approved in advance by the President of the
Company. Company-initiated interviews similarly must be approved before they may
be scheduled with the media.

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