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Exhibit 14.1

Banyan Corporation 
  Code of Business Conduct and Ethics

THE BANYAN CODE OF BUSINESS CONDUCT AND ETHICS makes compliance
  with high standards of business conduct mandatory for every Banyan director,
  officer, manager and employee. Adherence to the principles in this Code and
  the Banyan Compliance Program is essential to the efforts of Banyan to gain
  and keep the confidence and support of all of its stakeholders. Most important
  of all, compliance is simply the right thing to do.(1)

The business of Banyan and its various subsidiaries and ventures
  is far more complex today than it was when Banyan was established. These complexities
  create new ethical challenges as we adapt ourselves and our business to new
  situations. In light of these challenges, we need a central set of guiding standards
  to act as a legal and ethical compass for our directors, officers, managers
  and employees ("you"). This Code and Banyan's Compliance Program provide that
  compass.

Banyan's Compliance Program is composed of three sections:

|1. | This Code of Business Conduct and Ethics,
        which establishes Banyan's guiding standards for conducting business and
        applies to all employees and the Banyan Board of Directors;       
|-- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|   |                                                                                                                                                                                                      
|2. | The Finance Code of Ethics which applies
        to the Banyan's Chief Executive Officer, Chief Financial Officer, Corporate
        Controller, and all of Banyan's worldwide finance employees; and
|   |                                                                                                                                                                                                      
|3. | The Banyan Corporate Policies and Practices
        (CPPs), as adopted from time to time and set forth in writing, which apply
        to all employees.(2)                                          

While each section has a specific purpose, together they provide
  an integrated approach to the way Banyan conducts business.

Our Compliance Program reflects Banyan's commitment to do
  what is legal and what is ethical. It is also necessary both to manage the business
  of Banyan effectively and to meet the constantly changing needs of the marketplace.
  It is a critical part of the way we do business. We expect you to understand
  and follow the applicable requirements of Banyan's Compliance Program, as well
  as all applicable laws and rules.

This part of the Compliance Program, the Code of Business
  Conduct and Ethics, provides guidance to recognize and deal with ethical issues,
  provides mechanisms to report unethical conduct and fosters a culture of honesty
  and accountability. It provides general standards for the operation of our business
  and reaffirms Banyan's obligation to meet legal requirements.

We Comply with All Laws, Regulations & Rules

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You must follow the applicable laws, regulations, rules and
  regulatory orders of every jurisdiction in which Banyan operates, including
  all insider trading laws and regulations. Insider trading is unethical and illegal
  and will be dealt with decisively. You are charged with the responsibility to
  acquire appropriate knowledge of the requirements relating to your duties sufficient
  to enable you to recognize potential dangers and to know when to seek legal
  advice or other advice on the Banyan Compliance Program. Banyan understands
  that the insider trading rules are complex, so the Corporate Policies and Practices
  shall provide more detail as to how to handle and avoid particular situations.

We Protect our Shareholders' Assets

Banyan is dedicated to creating value for its shareholders.
  Our shareholders have shown confidence in us by investing in Banyan. We are
  obligated to enhance and protect Banyan's assets and ensure their efficient
  use. That means you must vigilantly protect Banyan's physical property, as well
  as tangible, intangible intellectual, and other proprietary property or information,
  including trade secrets. In addition, you must use Banyan's assets for only
  legitimate business purposes.

We Avoid Even the Appearance of a Conflict of Interest

You should ensure that your private activities and interests
  do not interfere with your responsibilities or the interests of Banyan.

Many situations may arise where your personal interest conflicts,
  either actually or in appearance, with the interests of Banyan or your loyalty
  to Banyan. A conflict of interest occurs when one's personal interest interferes
  in any way - or even appears to interfere - with the interests of Banyan as
  a whole. Conflicts of interest can arise if you take actions or have interests
  that make it difficult to perform your duty objectively or efficiently. Conflicts
  of interest can also arise when you or a member of your family, receives improper
  personal benefits due to your position at Banyan. In all instances you should
  not enter into situations that could result in even the appearance of a conflict
  of interest.

You may not take for yourself personally opportunities that
  are discovered through the use of Banyan property, information or your position
  with Banyan. You also may not use Banyan property, information or your position
  for personal gain, other than through proper employment activities, and you
  may not compete with Banyan as an employee. Your obligation is to advance Banyan's
  legitimate interests when the opportunity arises.

Sometimes the evolving nature of Banyan's business changes
  a previously acceptable situation into a potential conflict of interest. In
  these situations you may be required to discontinue an activity which was previously
  acceptable.

We Maintain Accurate Books and Records

The Banyan books and records must accurately and fairly reflect
  all transactions. Banyan will

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maintain a system of internal accounting controls to ensure
  that: assets are safeguarded; transactions conform to management's authorizations;
  and accounting records are accurate and comply with all applicable laws. You
  must not falsely report transactions, or fail to report the existence of any
  known false reports in Banyan's accounting records. Furthermore, you are prohibited
  from circumventing any policies and procedures that represent an element of
  our internal controls.

We Value Our Employees and their Workplace

Banyan does not engage in discriminatory conduct based on
  the legally protected classes outlined in our corporate policies. Our goal is
  to provide employment and promotional opportunities for all employees and applicants
  for employment on a nondiscriminatory basis. Banyan and applicable law prohibit
  unlawful discrimination or harassment, including sexual harassment or the creation
  of a hostile working environment based on any protected class. This paragraph
  does not expand any rights or privileges that exist under applicable laws, but
  reflects Banyan's commitment to complying with these laws.

Recognizing the importance of providing Banyan employees with
  a safe and healthful workplace free of recognized hazards, you are responsible
  for helping to ensure the safety of Banyan's workplace through personal action
  and through the prompt reporting of unsafe conditions. In addition, you may
  not use violence or threats of violence at work.

We Value our Customers

If your job puts you in contact with customers or potential
  customers, it is critical for you to remember that you are Banyan to these people.
  You represent not only Banyan, but all other Banyan employees as well. Banyan
  and its employees have provided data storage products and services for many
  years and have built up significant goodwill over that time. This goodwill is
  one of our most important assets, and you must act to preserve and enhance our
  reputation. You may not misrepresent Banyan products or services.

We Value our Suppliers and Contractors

Our suppliers, contractors, partners and affiliates make significant
  contributions to Banyan's success. To create an environment where they have
  an incentive to work with Banyan, they must be confident that we will treat
  them lawfully. If Banyan cannot legally do something directly, it will not do
  it indirectly through agents, consultants or other third parties. Banyan's policy
  is to purchase supplies based on need, quality, service, price, applicable legal
  requirements and other relevant factors.

We Compete Vigorously and Fairly

You must observe high standards of ethical conduct in all
  relationships with our competitors. Banyan will compete vigorously and effectively,
  but fairly. Banyan must and will comply with all applicable antitrust laws and
  requirements relating to fair competition, including the Foreign

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Corrupt Practices Act and other laws relating to international
  competition. Fair competition is competition that is based on the value and
  quality of the products and services which Banyan has to offer to its customers.

There are many other types of conduct that the antitrust,
  trade regulation or competition laws may prohibit under certain circumstances.
  Banyan understands that these rules are complex, so the Corporate Policies and
  Practices provide details as to how to deal with particular situations.

We Protect Confidential Information

Others must be able to interact with us in the knowledge that
  the content of their communications and records will be kept confidential and
  private when appropriate. We must ensure that the confidential and proprietary
  information is protected and that information which Banyan discloses is accurate.
  You must maintain the confidentiality of information entrusted to you by Banyan
  and its customers, except where disclosure is authorized or legally mandated.

You may not use confidential information in violation of the
  terms under which it was disclosed for any reason and you may not allow any
  third-party to obtain such information in violation of such terms. Improper
  acquisition, possession and use of confidential information of a third party
  is also improper and can under certain circumstances be illegal. If you know
  or have reason to know that confidential information was wrongfully obtained
  from the owner of the information or was obtained from a third party who was
  under a confidentiality obligation to the owner you cannot use such information.

We are Good Corporate Citizens in our Communities

Banyan will apply uniformly high standards of ethics and business
  conduct in every country in which it operates, and in every business relationship
  or affiliation it has worldwide. In our active pursuit of international business
  in an increasingly global economy, Banyan will be guided both by the laws and
  regulations of the United States and the laws and regulations of the countries
  within which we do business. In some circumstances, of course, that will mean
  that Banyan is subject to different laws and regulations, and thus will do business
  somewhat differently from country to country. Additionally, laws may conflict,
  however, one thing is constant: wherever we do business; we are committed to
  doing business ethically and within the law.

Banyan is committed to being a responsible corporate citizen
  within the communities in which it operates. You must assist these efforts by
  obeying all applicable environmental laws.

Reporting and Compliance with this Code

You must comply, as applicable, with the standards and principles
  contained or referenced, directly or indirectly, in this Code, the Finance Code
  of Ethics, and the Corporate Policies and Practices. In addition, you have an
  obligation to behave according to high ethical standards. Any potential violations
  should be reviewed or reported for legal action, discipline or other corrective
  steps.

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Part of your job and your ethical responsibility to Banyan
  is to help Banyan enforce its Compliance Program. You should be alert to possible
  violations of the Compliance Program anywhere in Banyan. We expect you to report
  possible violations promptly. This self-policing is encouraged. You should report
  potential violations to your manager, an officer of Banyan or one of Banyan's
  Hotlines (which permit complaints and concerns regarding employment, accounting
  and audit matters be raised on a confidential and anonymous basis without fear
  of reprisal), as appropriate. You should review Banyan's Open Door policy for
  guidance in this area. We expect you to cooperate in any Banyan legal or regulatory
  investigation of violations, suspected violations and compliance review. It
  is a serious violation for any employee to knowingly raise a false allegation
  and/or initiate or encourage reprisal action against any person who in good
  faith reports known or potential violations.

Banyan will promptly investigate any reported matter and will
  take appropriate corrective and/or disciplinary action. Violations of the law,
  this Code, the Finance Code of Ethics, the Corporate Policies and Practices
  or other Banyan policies, procedures, standards, instructions, practices or
  the like can lead to disciplinary action up to and including termination of
  your employment and if warranted, the initiation of legal proceedings. Disciplinary
  action may also be taken against managers or officers who condone, permit or
  fail to take appropriate preventive, corrective or other action against illegal,
  unethical or other improper conduct.

Modifications and Waivers of this Code

Banyan may modify this Code and this Code supersedes and replaces
  all other codes, policies or verbal representations to the extent they are inconsistent.
  Only the Banyan Board of Directors or a Board Committee may waive this Code
  of Business Conduct and Ethics for executive officers or Directors and any such
  waiver must be promptly disclosed in writing to shareholders.

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1 Throughout this Code, the term "Banyan" refers to Banyan
  Corporation or any business unit, subsidiary or majority-owned venture of Banyan.

2 For employees, this Code does not modify the "at-will" employment
  policies of Banyan as set forth in the Banyan Corporate Policies and Practices.

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