EXHIBIT 14.1

                                     [LOGO]

                                 CODE OF ETHICS


BMB Munai will conduct its business honestly and ethically wherever we operate
in the world. We will constantly improve the quality of our services, products
and operations and will create a reputation for honesty, fairness, respect,
responsibility, and integrity, trust and sound business judgment. No illegal or
unethical conduct on the part of officers, directors, employees or affiliates is
in the company's best interest. BMB Munai will not compromise its principles for
short-term advantage. The ethical performance of this company is the sum of the
ethics of the men and women who work here. Thus, we are all expected to adhere
to high standards of personal integrity.

Officers, directors, and employees of the company must never permit their
personal interests to conflict, or appear to conflict, with the interests of the
company, its clients or affiliates. Officers, directors and employees must be
particularly careful to avoid representing BMB Munai in any transaction with
others with whom there is any outside business affiliation or relationship.
Officers, directors, and employees shall avoid using their company contacts to
advance their private business or personal interests at the expense of the
company, its clients or affiliates.

No bribes, kickbacks or other similar remuneration or consideration shall be
given to any person or organization in order to attract or influence business
activity. Officers, directors and employees shall avoid gifts, gratuities, fees,
bonuses or excessive entertainment, in order to attract or influence business
activity.

Officers, directors and employees of BMB Munai will often come into contact
with, or have possession of, proprietary, confidential or business-sensitive
information and must take appropriate steps to assure that such information is
strictly safeguarded. This information - whether it is on behalf of our company
or any of our clients or affiliates - could include strategic business plans,
operating results, marketing strategies, customer lists, personnel records,
upcoming acquisitions and divestitures, new investments, and manufacturing
costs, processes and methods. Proprietary, confidential and sensitive business
information about this company, other companies, individuals and entities should
be treated with sensitivity and discretion and only be disseminated on a
need-to-know basis.

Misuse of material inside information in connection with trading in the
company's securities can expose an individual to civil liability and penalties.
Directors, officers, and employees in possession of material information not
available to the public are "insiders". Spouses, friends, suppliers, brokers,
and others outside the company who may have acquired the information directly or
indirectly from a director, officer or employee are also "insiders." The Act
prohibits insiders from trading in, or recommending the sale or purchase of, the
company's securities, while such inside information is regarded as "material",
or if it is important enough to influence you or any other person in the
purchase or sale of securities of any company with which we do business, which
could be affected by the inside information.

The following guidelines should be followed in dealing with inside information:

[ ]      Until the company has publicly released the material information, an
         employee must not disclose it to anyone except those within the company
         whose positions require use of the information.

--------------------------------------------------------------------------------
BMB Munai * Code of Ethics                                           Page 1 of 2
<PAGE>

[ ]      Employees must not buy or sell the company's securities when they have
         knowledge of material information concerning the company until it has
         been disclosed to the public and the public has had sufficient time to
         absorb the information.

[ ]      Employees shall not buy or sell securities of another corporation, the
         value of which is likely to be affected by an action by the company of
         which the employee is aware and which has not been publicly disclosed.

Officers, directors and employees will seek to report all information accurately
and honestly, and as otherwise required by applicable reporting requirements.

Officers, directors and employees will refrain from gathering competitor
intelligence by illegitimate means and refrain from acting on knowledge, which
has been gathered in such a manner. The officers, directors and employees of BMB
Munai will seek to avoid exaggerating or disparaging comparisons of the services
and competence of their competitors.

Officers, directors and employees will obey all Equal Employment Opportunity
laws and act with respect and responsibility towards others in all of their
dealings.

Officers, directors and employees will remain personally balanced so that their
personal life will not interfere with their ability to deliver quality products
or services to the company and its clients.

Officers, directors and employees agree to disclose unethical, dishonest,
fraudulent and illegal behavior, or the violation of company policies and
procedures, directly to management.

Violation of this Code of Ethics can result in discipline, including possible
termination. The degree of discipline relates in part to whether there was a
voluntary disclosure of any ethical violation and whether or not the violator
cooperated in any subsequent investigation.

Remember that good ethics is good business!


--------------------------------------------------------------------------------
BMB Munai * Code of Ethics                                           Page 2 of 2