51146, INC.
                            FINANCIAL CODE OF ETHICS

As a public company, it is of critical importance that 51146, Inc. ("51146")
filings with the Securities and Exchange Commission be accurate and timely.
Depending on their position with 51146, employees may be called upon to provide
information to assure that 51146's public reports are complete, fair, and
understandable. 51146 expects all of its employees to take this responsibility
seriously and to provide prompt and accurate answers to inquiries related to
51146's public disclosure requirements.

51146's Finance Department bears a special responsibility for promoting
integrity throughout 51146, with responsibilities to stakeholders both inside
and outside of 51146. The Chief Executive Officer (CEO), Chief Financial Officer
(CFO), and Finance Department personnel have a special role both to adhere to
the principles of integrity and also to ensure that a culture exists throughout
51146 as a whole that ensures the fair and timely reporting of 51146's financial
results and conditions. Because of this special role, the CEO, CFO, and all
members of 51146's Finance Department are bound by 51146's Financial Code of
Ethics, and by accepting the Financial Code of Ethics, each agrees that they
will:

-    Act with honesty and integrity, avoiding actual or actual conflicts of
     interest in personal and professional relationships.

-    Provide information that is accurate, complete, objective, relevant, timely
     and understandable to ensure full, fair, accurate, timely, and
     understandable disclosure in the reports and documents that 51146 files
     with, or submits to, government agencies and in other public
     communications.

-    Comply with the rules and regulations of federal, state and local
     governments, and other appropriate private and public regulatory agencies.

-    Act in good faith, responsibly, with due care, competence and diligence,
     without misrepresenting material facts or allowing one's independent
     judgment to be subordinated.

-    Respect the confidentiality of information acquired in the course of one's
     work, except when authorized or otherwise legally obligated to disclose.
     Confidential information acquired in the course of one's work will not be
     used for personal advantage.

-    Share job knowledge and maintain skills important and relevant to
     stakeholders needs. - Proactively promote and be an example of ethical
     behavior as a responsible partner among peers, in the work environment and
     in the community.

-    Achieve responsible use of, and control over, all 51146 assets and
     resources employed by, or entrusted to yourself, and your department.

-    Receive the full and active support and cooperation of 51146's Officers,
     Sr. Staff, and all employees in the adherence to this Financial Code of
     Ethics.

-    Promptly report to the CEO or CFO any conduct believed to be in violation
     of law or business ethics or in violation of any provision of this Code of
     Ethics, including any transaction or relationship that reasonably could be
     expected to give rise to such a conflict. Further, to promptly report to
     the Chair of 51146's Audit Committee such conduct if by the CEO or CFO or
     if they fail to correct such conduct by others in a reasonable period of
     time.