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Exhibit 14.01

# CIS Investments, Inc.
                                                            Code of Ethics

Introduction
Cargill,  Incorporated  has adopted the  "Cargill  Guiding  Principles"  to provide  Cargill  employees a framework in which to examine
problems  arising out of Cargill's  global business and to assist Cargill  employees to act in a fair,  ethical and lawful manner.  CIS
Investments,  Inc.  (the  "Company")  is an  indirect  subsidiary  of  Cargill,  Incorporated  and is  subject to the  Cargill  Guiding
Principles.   In addition, the Company has adopted this Code of Ethics to address certain specific issues relating to its business.

The Company acts as the managing  owner and/or  general  partner of several  commodity  pools (the "Pools")  that are public  reporting
issuers  under the  Securities  Exchange  Act of 1934,  as amended.  As the  managing  owner  and/or  general  partner,  the Company is
responsible for the management and administration of the Pools.

The Company expects its principal executive officer,  principal financial officer,  principal accounting officer and persons performing
similar functions  (collectively,  the "Covered  Officers") to know and follow the policies outlined the Cargill Guiding  Principles as
well as this Code of Ethics.  Any  Covered  Officer who  violates  the letter or spirit of these  policies  is subject to  disciplinary
action, up to and including termination.

Every Covered  Officer has the  responsibility  to obey the law and act honestly and  ethically.  To that end, this Code of Ethics is a
guide that is intended to make Covered  Officers  sensitive to some of the significant  legal and ethical issues that arise  frequently
in connection  with the  operation of the Pools and to the  mechanisms  available to report  illegal or unethical  conduct.  It is not,
however,  a comprehensive  document that addresses every legal or ethical issue that you may confront,  nor is it a summary of all laws
and policies  that apply to the business  activities  of the Company or the Pools.  For  additional  information  regarding the Company
policies,  you should  refer to the  Company's  Chief  Compliance  Officer.  Ultimately,  no code of ethics can replace the  thoughtful
behavior of an ethical officer.

If you have any questions  about this Code of Ethics or are  concerned  about  conduct you believe  violates  this Code of Ethics,  the
Company's  policies or applicable  laws,  rules or  regulations,  you should consult with the Company's Chief  Compliance  Officer or a
member of the Board of Directors at (312)  460-4027.  No one at the Company has the  authority to make  exceptions  to these  policies,
other than the Company's Board of Directors (or a committee thereof).

Compliance with Laws, Rules and Regulations
The Covered Officers must comply fully with all applicable  foreign,  federal,  state and local laws, rules and regulations that govern
the Company's or the Pool's  business  conduct.  Failure to comply with such laws,  rules and  regulations  may result in  disciplinary
action (in addition to those imposed by any governmental, regulatory or self-regulatory body), up to and including termination.

Conflicts of Interest
Business  decisions  must be made in the best interest of the Company,  not motivated by personal  interest or gain. The same principle
applies  to  business  decisions  made by the  Company  in respect of the  investors  in the Pools.  Therefore,  as a matter of Company
policy, all Covered Officers must avoid any actual or perceived conflict of interest.

A "conflict  of  interest"  occurs when a Covered  Officer's  personal  interests  interfere  or conflict in any way (or even appear to
interfere or conflict)  with the interests of the Company or, as applicable,  those of the Pools. A conflict of interest  situation can
arise when a Covered  Officer takes actions or has interests  (financial or other) that may make it difficult to fulfill duties owed to
the  equity  owners of the Pools.  Conflicts  of  interest  also may arise  when a Covered  Officer or a member of a Covered  Officer's
family receives improper personal  benefits as a result of the Covered  Officer's  affiliation with the Company,  regardless of whether
such  benefits are received  from the Company or a third party.  Loans by the Company or the Pools to, or  guarantees by the Company or
the Pools of obligations of, Covered Officers and their family members are of special concern and are prohibited.

It is difficult to identify  exhaustively  what  constitutes a conflict of interest.  For this reason,  the Covered Officers must avoid
any situation in which their  independent  business  judgment might appear to be compromised.  Questions  about potential  conflicts of
interest  situations,  and  disclosure  of these  situations  as they arise,  should be promptly  addressed  and  reported to the Chief
Compliance Officer at (312) 460-4027.

Corporate Opportunities
The Covered Officers are prohibited from:  (a) taking for themselves  personally  opportunities  that properly belong to the Company or
are discovered through the use of corporate property,  information or position;  (b) using corporate property,  information or position
for personal  gain;  and  (c) competing  with the  Company.  The Covered  Officers owe a duty to the Company to advance its  legitimate
interests when the opportunity to do so arises.

Public Company Reporting
As a result of the Pools' status as "public  reporting  companies,"  the Company is required,  on behalf of the Pools, to file periodic
and other reports with the  Securities and Exchange  Commission.  The Company takes its  obligations  with respect to the Pools' public
disclosure seriously.  To that end:

|A. | each Covered Officer must take all reasonable steps to ensure that these reports and other public  communications  represent full,
     fair, accurate, timely and understandable disclosure regarding the financial and business condition of the Pools;                                                                                                                                                                                                                                                                                                                                                                                               
|-- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|B. | each Covered  Officer must promptly  bring to the attention of the Board of Directors any material  information of which a Covered
     Officer may become aware that  affects the  disclosures  made by the Company in the public  filings made on behalf of the Pools or
     otherwise would assist the Board of Directors in fulfilling its responsibilities to the Pools; and                                                                                                                                                                                                                                                                      
|C. | each  Cover  Officer  must  promptly  bring to the  attention  of the Chief  Compliance  Officer  and the Board of  Directors  any
     information he or she may have concerning (i) significant  deficiencies in the design or operation of internal controls that could
     adversely affect the Company's ability to record, process,  summarize and report financial data, including on behalf of the Pools,
     or (ii) any fraud,  whether or not material,  involving management or other employees who have a significant role in the Company's
     financial reporting, including on behalf of the Pools, disclosures or internal controls.

Reporting Illegal or Unethical Behavior
Each Covered  Officer has a duty to adhere to this Code of Ethics.  Each Covered  Officer must also promptly  bring to the attention of
the Chief  Compliance  Officer or the CEO and to the Board of  Directors  any  information  the  Covered  Officer  may have  concerning
evidence of a material  violation of the  securities or other laws,  rules or regulations  applicable to the Company or the Pools,  and
the operation of its or their  businesses,  by the Company or any agent  thereof,  or of a violation of this Code of Ethics,  including
any actual or apparent  conflicts of interest  between  personal and  professional  relationships,  involving  any  management or other
employees  who have a  significant  role in the  Company's  or the  Pools'  financial  reporting,  disclosures  or  internal  controls.
Confidentiality will be maintained to the fullest extent possible.

A Covered  Officer  will not be penalized  for making a  good-faith  report of  violations  of this Code of Ethics or other  illegal or
unethical  conduct,  nor will the Company  tolerate  retaliation  of any kind against anyone who makes a good-faith  report.  A Covered
Officer who submits a false report of a violation,  however,  will be subject to disciplinary  action. If you report a violation and in
some way also are involved in the violation, the fact that you stepped forward will be considered.

If the result of an  investigation  indicates that  corrective  action is required,  the Board of Directors  will decide,  or designate
appropriate persons to decide, what actions to take, including,  when appropriate,  legal proceedings and disciplinary action up to and
including  termination,  to rectify the problem and avoid the likelihood of its recurrence.  Such actions shall be reasonably  designed
to deter  wrongdoing  and to promote  accountability  for adherence to this Code of Ethics,  and shall include  written  notices to the
individual  indicating  any action taken.  In determining  what action is  appropriate in a particular  case, the Board of Directors or
its  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 the
individual in question had committed other violations in the past.

Amendment, Modification and Waiver
This Code of Ethics may be amended,  modified or waived by the Board of  Directors of the  Company.  Any change to, or waiver  (whether
explicit or implicit) of, this Code of Ethics must be disclosed  promptly to the Pools that are public reporting  companies by filing a
Form 8-K on behalf of each affected Pool or by another permitted means.

Acknowledgment
Each  Covered  Officer is  accountable  for knowing  and  abiding by the  policies  contained  in this Code of Ethics.  The Company may
require that the Covered Officers sign an  acknowledgment  confirming that they have received,  read and understand this Code of Ethics
and are complying with them.