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                                                                    Exhibit 14.1

                            NEUTRON ENTERPRISES, INC.

               CODE OF ETHICS FOR THE CHIEF EXECUTIVE OFFICER AND
                            SENIOR FINANCIAL OFFICERS

     The Chief Executive Officer, Chief Financial officer, principal accounting
officer or Controller, and other senior financial officers performing similar
functions (collectively, the "OFFICERS") of NEUTRON ENTERPRISES, INC. (the
"COMPANY") each have an obligation to the Company, its shareholders, the public
investor community, and themselves to maintain the highest standards of ethical
conduct. In recognition of this obligation, the Company has adopted the
following standards of ethical conduct for the purpose of promoting:

     -    Honest and ethical conduct, including the ethical handling of actual
          or apparent conflicts of interest between personal and professional
          relationships;

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

     -    Compliance with applicable governmental laws, rules and regulations;

     -    The prompt internal reporting to an appropriate person or persons
          identified herein of violations of this Code of Ethics; and

     -    Accountability for an adherence to this Code of Ethics.

     The Officers are subject to the specific policies described below.
Adherence to these standards is integral to achieving the objectives of the
Company and its shareholders. The Officers shall not commit acts contrary to
these standards nor shall they condone the commission of such acts by others
within the Company.

COMPETENCE

     The Officers have a responsibility to:

     -    Maintain an appropriate level of professional competence through the
          ongoing development of their knowledge and skills.

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     -    Perform their professional duties in accordance with relevant laws,
          regulations, and technical standards.

     -    Prepare accurate and timely financial statements, reports and
          recommendations after appropriate analyses of relevant and reliable
          information.

CONFIDENTIALITY

     The Officers have a responsibility to protect the Company by:

     -    Refraining from disclosing confidential information (regarding the
          Company or otherwise) acquired in the course of their work except when
          authorized, unless legally obligated to do so.

     -    Informing subordinates as appropriate regarding the confidentiality of
          information acquired in the course of their work and monitoring their
          activities to assure the maintenance of that confidentiality.

     -    Refraining from using or appearing to use confidential information
          acquired in the course of their work for unethical or illegal
          advantage either personally or through third parties.

INTEGRITY

     The Officers have a responsibility to:

     -    Comply with laws, rules and regulations of federal, state and local
          governments, and appropriate private and public regulatory agencies or
          organizations, including insider trading laws.

     -    Act in good faith, responsibility, without misrepresenting material
          facts or allowing their independent judgment to be subordinated.

     -    Protect the Company's assets and insure their efficient use.

     -    Avoid actual or apparent conflicts of interest with respect to
          suppliers, customers and competitors and reports potential conflicts
          as required in the Company's Conflict of Interest Policy.

     -    Refrain from engaging in any activity that would prejudice their
          ability to carry out their duties ethically.

     -    Refrain from either actively or passively subverting the attainment of
          the organization's legitimate and ethical objectives.

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     -    Recognize and communicate professional limitations or other
          constraints that would preclude responsible judgment or successful
          performance of an activity.

     -    Report to senior management and the Audit Committee any significant
          information they may have regarding judgments, deficiencies,
          discrepancies, errors, lapses or any similar matters relating to the
          Company's or its subsidiaries' accounting, auditing or system of
          internal controls. The officers must communicate unfavorable as well
          as favorable information and professional judgments or opinions.

     -    Refrain from engaging in or supporting any activity that would
          discredit their profession or the Company and proactively promote
          ethical behavior within the Company.

OBJECTIVITY

The Officers have a responsibility to:

     -    Communicate information fairly and objectively.

     -    Disclose all material information that could reasonably be expected to
          influence intended user's understanding of the reports, comments and
          recommendations presented.

OVERSIGHT AND DISCLOSURE

     The Officers have a responsibility to:

     -    Ensure the preparation of 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 Officers to promptly bring to the attention of the Audit Committee
          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 of overseeing the Company's financial statements and
          disclosures and internal control systems.

     -    Promptly bring to the attention of the Audit Committee any information
          he or she may have concerning (1) significant deficiencies in the
          design or operation of internal controls which could aversely affect
          the Company's ability to record, process, summarize and report
          financial data or (2) any fraud, whether or not material, that
          involves management or other employees who have a significant role in
          the Company's financial reporting, disclosures or internal controls.

     -    Promptly bring to the attention of the CEO or internal legal counsel,
          if any, and to the Audit Committee any information he or she may have
          concerning evidence of 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, or of violation
          of these procedures.

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ENFORCEMENT

     The Board of Directors shall determine, or designate appropriate persons to
determine, appropriate actions to be taken in the event of violations of these
procedures by the Officers. Such actions shall be reasonably designed to deter
wrongdoing and to promote accountability for adherence to these procedures, and
shall include written notices to the individual involved that the Board has
determined that there has been a violation, censure by the Board, demotion or
re-assignment of the individual involved, suspension with or without pay or
benefits (as determined by the Board) and 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 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.

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     IN WITNESS WHEREOF, the undersigned Officer certifies that he or she has
read the above Code of Ethics and agrees to abide thereby.


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(Signature)

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(Print Name)

Date: ________________, 2007

To be returned to: Rory Olson
                   Chief Executive Officer