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Exhibit 14
  HORIZON
  LINES
  Code
  of
  Business
  Conduct
  and
  Ethics
  This Code is
    being distributed electronically
    to all officers, employees and directors of
    Horizon Lines, Inc. and its subsidiaries.
    Each officer, employee and director
    should read it carefully.
  Any questions
    should be directed to the Law
    Department.
  Opening the
    electronic message will signify
    your agreement
    to comply with this Code.
  NOTE: and/or




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I.


INTRODUCTION


3II.


ADMINISTRATION


3III.


ANTITRUST AND SHIPPING LAWS


4a. U.S.A. Antitrust Laws


4b. Other Anti-Monopoly and Fair Trade
    Laws


5c. U.S.A. Shipping Laws


5IV.


U.S. SECURITIES LAW


6a. Insider Trading Laws


6b. Disclosure


7c. Personal Loans


7V.


CONFLICTS OF INTEREST


7VI.


FORMER GOVERNMENT EMPLOYEES


9VII.


CORRUPTION AND BRIBERY


9VIII.


THE FOREIGN CORRUPT PRACTICES ACT (FCPA)


11IX.


CONFIDENTIALITY


11X.


POLITICAL AND LOBBYING ACTIVITIES


12XI.


DISCRIMINATION, HARASSMENT, AND RETALIATION


13XII.


POLICY ON A DRUG FREE WORKPLACE


15XIII.


SAFETY AND ENVIRONMENTAL CONCERNS


15XIV.


COPYRIGHTS, TRADEMARKS, AND PATENTS


16XV.


INVESTIGATIONS


16XVI.


ACCOUNTING AND FINANCIAL REPORTING


16XVII.


COMMUNICATIONS WITH MEDIA AND PUBLIC


17XVIII.


RESPONSIBILITIES OF MANAGEMENT


17XIX.


USE OF AGENTS AND NON-EMPLOYEES


17XX.


PROTECTION AND PROPER USE OF HORIZON PROPERTY


17XXI.


FAIR DEALING


18XXII.


LIMITS ON AUTHORITY


18XXIII.


REPORTING VIOLATIONS


18XXIV.


ADMINISTRATION AND WAIVER OF CODE


18XXV.


CONCLUSION


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I.
    INTRODUCTION  Purpose of
    Code of Business Conduct and Ethics
        
    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
    reports and documents that the Company files with, or submits
    to, governmental and regulatory agencies 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 of
    violations of this Code; and
    accountability for adherence to this Code.            II.
    ADMINISTRATION




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III.
    ANTITRUST
    AND SHIPPING LAWS  a.
    U.S.A.
    Antitrust Laws.                 4




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Price Fixing.
            Division of Markets.
  Tying Devices.
  Reciprocity.
  b.
    Other
    Anti-Monopoly and Fair Trade Laws.  40-50%
  c.
    U.S.A.
    Shipping Laws   5




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IV.
    U.S.
    SECURITIES LAW  a.
    Insider
    Trading Laws   6




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b.
    Disclosure    c.
    Personal
    Loans    V.
    CONFLICTS
    OF INTEREST  1
              1
 7




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his/her
            his/her
   8




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VI.
    FORMER
    GOVERNMENT EMPLOYEES   VII.  CORRUPTION
    AND BRIBERY              With regard to U.S. government personnel:
    any
     9




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In commercial situations
      and
  and
  and
               10




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VIII.  THE
    FOREIGN CORRUPT PRACTICES ACT (FCPA)                    IX.
    CONFIDENTIALITY       11




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X.
    POLITICAL
    AND LOBBYING ACTIVITIES    Political.
        Lobbying and Public Issues.
     12




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XI.
    DISCRIMINATION,
    HARASSMENT, AND RETALIATION  expressly prohibited
  or
  1. Discrimination
  because of
  2. Harassment
               13




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3. Retaliation
  because of
  4. Discipline
  any and/or
  5. Complaints
    of Discrimination, Harassment or Retaliation
  First Second
  (866) 850-2115.
  must
  6. Who Is
    Covered
   14




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7. Confidentiality
    8. Your
    Policy
  please you may lose your legal rights or
 XII.  POLICY
    ON A DRUG FREE WORKPLACE       XIII.  SAFETY
    AND ENVIRONMENTAL CONCERNS         15




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XIV.  COPYRIGHTS,
    TRADEMARKS, AND PATENTS      back-up
  XV.
    INVESTIGATIONS       XVI.  ACCOUNTING
    AND FINANCIAL REPORTING       16




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XVII.  COMMUNICATIONS
    WITH MEDIA AND PUBLIC   XVIII.  RESPONSIBILITIES
    OF MANAGEMENT     XIX.  USE
    OF AGENTS AND NON-EMPLOYEES    XX.
    PROTECTION
    AND PROPER USE OF HORIZON PROPERTY        e-mail
 17




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E-mail E-mail e-mail,
     XXI.  FAIR
    DEALING   XXII.  LIMITS
    ON AUTHORITY   XXIII.  REPORTING
    VIOLATIONS   XXIV.  ADMINISTRATION
    AND WAIVER OF CODE    case-by-case
 18




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XXV.  CONCLUSION


HORIZON LINES,
    INC. AND ITS SUBSIDIARY COMPANIES CODE OF
    BUSINESS CONDUCT
  ­
    ­
 (Print or type name)
       (Signature)                                                      (Date)
   (Location)


19