EXHIBIT 99.1

                                 HUSKER AG, LLC

      CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND SENIOR FINANCIAL OFFICERS

I. COVERED OFFICERS/PURPOSE OF THE CODE

      This Code of  Ethics of Husker  Ag,  LLC (the  "Company")  applies  to the
principal executive officer,  principal financial officer,  principal accounting
officer or controller,  and all persons performing similar functions,  and shall
include the  Company's  President,  Treasurer,  General  Manager,  and principal
accounting  officer and controller of the Company (each a "Covered Officer") for
the purpose of promoting:

      o     honest and ethical conduct, including the ethical handling of actual
            or apparent  conflict of interest  between personal and professional
            relationships;

      o     full,  fair,  accurate,  timely  and  understandable  disclosure  in
            reports and documents  that a registrant  files with, or submits to,
            the Securities and Exchange  Commission  ("SEC") and in other public
            communications made by the Company;

      o     compliance  with  applicable   laws  and   governmental   rules  and
            regulations;

      o     the  prompt  internal  reporting  of  violations  of the  Code to an
            appropriate person or persons identified in the Code; and

      o     accountability for adherence to the Code.

      It is the policy of the Company that its  employees,  directors and agents
are held to the highest  standards of honest and ethical conduct when conducting
the affairs of the  company.  Because  Husker Ag, LLC is a public  company,  the
Covered Officers are held to an especially high set of ethical standards,  which
are set out in this Code of Ethics.  Those officers and employees of the Company
who are Covered  Officers  will not commit acts  contrary to these  standards of
ethical  conduct,  nor shall they condone the  commission of such acts by others
within the Company.

      This  Code of  Ethics  covers  a wide  range  of  business  practices  and
procedures.  It does not cover every issue that may arise, but it sets out basic
principles to guide the Covered  Officer.  If a law  conflicts  with a policy in
this Code,  the Covered  Officer must comply with the law;  however,  if a local
custom or policy  conflicts with this Code, the Covered Officer must comply with
the Code.

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All  references  to the  masculine  gender in this Code  shall also apply to the
feminine gender, as applicable, and all references to singular shall include the
plural, and references to plural include the singular, as applicable.

II.   COVERED OFFICERS SHOULD HANDLE ETHICALLY ACTUAL AND APPARENT  CONFLICTS OF
      INTEREST

      A "conflict of interest" occurs when a Covered  Officer's private interest
interferes with the interests of, or his service to, the Company. For example, a
conflict  of  interest  would  arise if a  Covered  Officer,  or a member of his
family, receives improper personal benefits as a result of his position with the
Company.

      Certain  conflicts  of  interest  arise out of the  relationships  between
Covered Officers and the Company and already are subject to conflict of interest
provisions in the Company's  Affiliated  Transactions Policy, and this Code does
not, and is not intended to, repeat or replace this Policy,  and conflicts which
are conducted in compliance with the Affiliated Transactions Policy, as approved
by the  Company  Board of  Directors  from  time to time,  fall  outside  of the
parameters of this Code.

      The following  list provides  examples of conflicts of interest  under the
Code,  but  Covered  Officers  should keep in mind that these  examples  are not
exhaustive. The overarching principle is that the personal interest of a Covered
Officer should not be placed improperly before the interest of the Company.

      Each Covered Officer must:

      o     not use his personal influence or personal relationships  improperly
            to  influence  business  decisions  or  financial  reporting  by the
            Company whereby the Covered Officer would benefit  personally to the
            detriment of the Company;

      o     not cause the Company to take action,  or fail to take  action,  for
            the individual  personal  benefit of the Covered Officer rather than
            the benefit the Company;

      o     not  use  material  non-public  knowledge  of  Company  business  or
            transactions to benefit personally to the detriment of the Company.

      There are some  conflict of interest  situations  that should be discussed
with  outside  legal  counsel  for the  Company  (referred  to  herein as "Legal
Counsel") if material. Examples of these include:


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      o     service as a  director  on the board or as an officer of any other
public company;

      o     the receipt of any gifts in excess of $100;

      o     the receipt of any  entertainment  from any  company  with which the
            Company has current or  prospective  business  dealings  unless such
            entertainment is business-related,  reasonable in cost,  appropriate
            as to time and place,  and not so frequent as to raise any  question
            of impropriety; or

      o     any  ownership   interest  in,  or  any   consulting  or  employment
            relationship with, any of the Company's service providers.

      Legal  Counsel may, in his  discretion,  review such  conflict of interest
situations  with one or more  independent  directors of the Company,  and/or the
Audit Committee of the Company.

III. DISCLOSURE AND COMPLIANCE

      o     Each Covered Officer should familiarize  himself with the disclosure
            requirements generally applicable to the Company;

      o     each Covered  Officer  should not knowingly  misrepresent,  or cause
            others to misrepresent,  facts about the Company,  whether within or
            outside  the  Company,  including  to the  Company's  directors  and
            auditors,   and  to  governmental   regulators  and  self-regulatory
            organizations;

      o     each Covered Officer should,  to the extent  appropriate  within his
            area of responsibility, consult with other officers and employees of
            the Company with the goal of promoting full, fair, accurate,  timely
            and  understandable  disclosure  in the  reports and  documents  the
            Company  files  with,  or  submit  to,  the SEC and in other  public
            communications made by the Company;

      o     it  is  the  responsibility  of  each  Covered  Officer  to  promote
            compliance with the standards and restrictions imposed by applicable
            laws, rules and regulations; and

      o     each Covered  Officer  shall become  familiar with and comply in all
            respects with the Company's Dissemination of Company Information and
            Insider Trading Policy.



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IV. REPORTING AND ACCOUNTABILITY

      Each Covered Officer must;

      o     upon  adoption  of the  Code  (or  thereafter  as  applicable,  upon
            becoming a Covered Officer),  affirm in writing to the Board that he
            has received, read, and understands the Code;

      o     annually  thereafter  affirm to the Board that he has complied  with
            the requirements of the Code;

      o     not retaliate  against any other Covered  Officer or any employee of
            the Company or their  affiliated  persons  for reports of  potential
            violations that are made in good faith; and

      o     notify Legal  Counsel  promptly if he knows of any violation of this
            Code. Failure to do so is itself a violation of this Code.

      Legal Counsel is responsible for applying this Code to specific situations
in which  questions  are  presented  under it and has the authority to interpret
this Code in any particular situation.  However, a Covered Officer may also meet
his obligation to notify Legal Counsel  promptly if he knows of any violation of
the  Code,  by  notifying  two or more  independent  directors  of the  Board of
Directors,  or any member of the Company Audit  Committee.  In such event,  such
independent  directors,  or member of the Audit Committee may consult with Legal
Counsel,  or, upon approval of a majority of the members of the Company's  Audit
Committee  or approval of a majority of  independent  directors  of the Board of
Directors who are not  implicated  in the  situation in question,  special legal
counsel ("Special Counsel"),  who is independent of the Company, and any Covered
Officer.

      The Company will follow these  procedures in  investigating  and enforcing
this Code:

      o     Legal Counsel or Special Counsel, as appropriate  (referred to below
            as  "Investigating  Counsel"),  will take all appropriate  action to
            investigate any potential violations reported to him;

      o     if, after such investigation, Investigating Counsel believes that no
            violation  has  occurred,  Investigating  Counsel is not required to
            take any further action;

      o     any matter that  Investigating  Counsel believes is a violation will
            be reported to the Audit  Committee,  or, if so  established  as set
            forth  below,  a  Qualified  Legal  Compliance   Committee   ("Legal
            Compliance Committee");

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      o     if the Audit Committee or Legal Compliance  Committee concurs that a
            violation has occurred,  it will inform and make a recommendation to
            the Board of  Directors,  which will  consider  appropriate  action,
            which may include, but is not limited to, review of, and appropriate
            modifications to, applicable  policies and procedures;  notification
            to  appropriate  personnel of the Company,  or a  recommendation  to
            dismiss the Covered Officer;

      o     the Audit  Committee,  or,  if  established,  the  Legal  Compliance
            Committee,  will be responsible for granting  waivers from this Code
            of Ethics, as appropriate, or in its discretion, the Audit Committee
            or Legal Compliance  Committee,  may forward the issue of a grant of
            waiver to the Company  Board of  Directors,  where  approval  may be
            granted  upon a majority  vote of the  independent  directors of the
            Company; and

      o     any changes to or waivers of this Code will, to the extent required,
            be disclosed as provided by SEC rules.

            In its discretion,  with respect to any specific investigation,  the
Company Board of Directors, upon a majority vote of the independent directors of
the  Company,  may direct the Audit  Committee  functions  set forth herein to a
Qualified  Legal  Compliance  Committee  (as  described  in  17  CFR  Part  205,
implementing  Section 307 of the  Sarbanes-Oxley  Act),  which  Qualified  Legal
Compliance  Committee shall have all the rights and  obligations  established in
this Code for the Audit Committee, and as granted by applicable law.

V. AMENDMENTS

      Any  amendments  to this Code must be  approved  or ratified by a majority
vote of the Board, including a majority of independent directors.

VI. CONFIDENTIALITY

      All reports and records prepared or maintained  pursuant to this Code will
be considered  confidential  and shall be maintained and protected  accordingly.
Except as  otherwise  required  by law or this Code,  or unless  approved by the
Board of Directors, Audit Committee, or Legal Compliance Committee, such matters
shall not be disclosed  to anyone other than members of the Board of  Directors,
legal counsel, and state and federal regulatory authorities,  in accordance with
applicable statutes and regulations.

VII. FILING AND AVAILABILITY

      The Code shall be filed with the SEC in accordance  with SEC  regulations,
and the  Company  shall  undertake  in its annual  report  filed with the SEC to
provide to any person without charge, upon request, a copy of such Code, as well
as the manner in which such request may be made.

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Adopted by the Husker Ag, LLC Board of Directors on March 26, 2004.










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