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Exhibit 14.1

SE Global Equities Corp.Code of Ethics

Adopted __________

It is the policy of SE Global Equities Corp. (together with
  its wholly-owned subsidiaries and affiliates worldwide, the "Company") that
  all directors, officers and employees of the Company shall, to the best of
  their knowledge and ability, adhere to, comply with and advocate the
  principles set out in this code of ethics (the "Code") governing their
  professional and ethical conduct in the fulfillment of their responsibilities.

This Code is not intended to supercede the Company's
  Employee Handbook or to otherwise alter employee obligations to comply with
  the Handbook.

The purposes of the Code are to promote:

- 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 the U.S. Securities and
  Exchange Commission and in other public communications made by the Company;
- compliance with applicable governmental laws, rules and regulations;
- the prompt internal reporting of violations of the Code to appropriate
  persons of authority within the Company; and
- accountability for adherence to the Code.

The Code embodies principles to which all directors,
  officers and employees are expected to adhere and advocate. Any violations of
  the Code may result in disciplinary action, up to and including termination or
  removal, as applicable.

All directors, officers and employees of the Company will:

1. Act with honesty and integrity, avoiding actual or apparent conflicts
  between personal and private interests and the interests of the Company,
  including refraining from receiving improper personal benefits as a result of
  holding a particular position with the Company;
2. Not solicit or accept, for personal or other benefit, business or similar
  opportunities that could reasonably be expected to otherwise accrue to the
  benefit of the Company;

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1. Use corporate assets entrusted to them in a responsible manner and refrain
  from competing directly or indirectly with the Company or using corporate
  information or opportunities for personal gain;
2. Where applicable, provide the U.S. Securities and Exchange Commission, the
  Company's stockholders, the investing public and other relevant constituencies
  with full, fair, accurate, timely and understandable reports and information;
3. Endeavor to comply with applicable laws and regulations of federal, state,
  local and foreign governments and government agencies having jurisdiction over
  the Company, including the U.S. Food and Drug Administration, and with
  applicable regulations of private or self-regulatory authorities having
  jurisdiction over the Company;
4. Act in good faith, responsibly with due care and diligence and without
  misrepresentation or omission of material facts and strive to maintain
  independent judgment in the performance and fulfillment of their duties and
  responsibilities;
5. Promote ethical behavior among subordinates and peers at the Company;
6. Respect the confidentiality of information acquired or obtained in the
  course of performance of their responsibilities, never use confidential
  information for personal advantage, and disclose confidential information of
  the Company or third parties only when such disclosure is legally required or
  is otherwise authorized.
7. Not fraudulently influence, coerce, manipulate or mislead any auditor
  engaged in the performance of an audit for the purpose of rendering the
  financial statements materially misleading.
8. Comply with other policies and procedures of the Company applicable to
  their positions and employment, including the Company's Insider Trading Policy
  and the policies and procedures of the Company set forth in the Company's
  Employee Handbook.

Any waiver of this Code of Ethics may be made only by the
  Company's Board of Directors (the "Board"). Any waiver of the code for any
  director or executive officer of the Company must be disclosed on Form 8-K
  within five days, or such shorter period as may be required under applicable
  regulation.

It is the duty of each director, officer and employee of
  the Company to report violations of the Code promptly to the attention of the
  Company's Chief Executive Officer, General Counsel or to any member of the
  Audit Committee of the Board (the "Audit Committee").

If you have a concern about a questionable accounting or
  auditing matter, or any other violation of this Code, the Company's Insider
  Trading Policy or the Company's Employee Handbook, and wish to submit the
  concern confidentially or anonymously, you may do so though our Employee
  Hotline by calling (800) 518-4535. Your communication will be kept
  confidential to the extent permitted by law.

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The Company will handle all inquiries discretely and make
  every effort to maintain, within the limits allowed by law, the
  confidentiality of anyone requesting guidance or reporting questionable
  behavior or other matters of concern under the Code.

The Board shall promptly determine, or designate
  appropriate persons (including, if so determined by the Board, the Audit
  Committee) promptly to determine appropriate actions to be taken in the event
  of violations of the Code by any director, officer or employee. In determining
  what actions are appropriate in a particular case, the Board (or its designee)
  shall act consistently and take into account relevant information including
  the nature and severity of the violation, whether the violation was a single
  occurrence or a series of 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 director, officer or employee in question had committed
  other violations in the past.

If the Board or the Audit Committee believes that standards
  for compliance with the Code are not objective, or that the process for
  determining violations is not fair or that the Code is not conducive to prompt
  and consistent enforcement, or that the protection for persons reporting
  questionable behavior pursuant to the Code is inadequate (either under the
  Code or under the Company's other policies), the Board shall adopt, or the
  Audit Committee shall recommend to the Board for adoption appropriate changes
  to the Code or other Company policies.

It is the Company's intention that the Code be the
  Company's written code of ethics under Section 406 of the Sarbanes-Oxley Act
  of 2002 complying with the standards set forth in Securities and Exchange
  Commission Regulation S-K Item 406.





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ACKNOWLEDGEMENT OF ADHERENCE TO CODE OF ETHICS

In my role as an executive and/or a financial executive of SE Global Equities
Corp., I certify to you that I adhere to and advocate the principles and
responsibilities outlined in SE Global Equities Corp.'s attached Code of Ethics.

I agree to report to SE Global Equities Corp. and all other applicable
parties including regulators of any failure on my part to adhere to this Code of
Ethics. I fully understand that violation of this code may lead to penalties to
myself personally and to SE Global Equities Corp.



|______________________________ |  | Date for reference:
|------------------------------ |  | -------------------
|Name:Position:                 |  |                    
|                               |  |                    





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