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EXHIBIT 14.1
 True Religion Apparel, Inc.
Corporate Code of Conduct
    I. Compliance with Applicable Laws
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II. Conflicts of Interest
  Personal Business Relationships and Activities:
  Improper Investments
  Improper Gifts and Entertainment
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Outside Employment and Other Affiliations
  Conducting Business With Family Members
   
    
    Acquire a direct or indirect material financial interest in (1) any business or company
with whom True Religion has business dealings, or (2) a True Religion competitor.
    
    Enter into a business relationship on True Religions behalf with an immediate family
member or with a company that the employee, officer or director or such persons immediate
family member has a material financial interest.
    
    Accept, directly or indirectly, anything (including gifts) of a nature or value that
could create the appearance that the person providing the gift is receiving or will receive
favorable prices, terms, and conditions of sale, purchase orders, or other preferential
treatment from True Religion. This extends to any agent, employee, independent contractor,
consultant, manager or director of any competitor, supplier, customer, partner, distributor
or other third party directly or indirectly doing or seeking to do business with True
Religion, or any True Religion subsidiary.
    
    Participate in other employment (including self-employment) or serve as an employee,
officer, manager, director, partner or consultant for other organizations unless such
activity is disclosed to and approved by True Religions Chief Financial Officer. Such
activity is prohibited under any circumstances if it interferes with your
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ability to act in the best interests of True Religion, requires you to use proprietary,
confidential or non-public information, procedures, plans or techniques of True
Religion, or creates an appearance of impropriety.
   Corporate Opportunities:
  III. Communication of False or Derogatory Information
   
    
    Never make dishonest statements, misrepresentations or statements intended to mislead or
misinform.
    
    Always respond promptly and accurately to requests for information or documents from
government agencies. These requests should immediately be brought to the attention of True
Religions management and authorized prior to providing documentation to outside parties.
    
    Direct all media requests for information or statements to True Religion Investor
Relations.
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
    
    Apply the same principles of honesty to all aspects of internal communications and
record keeping. Falsification, alteration, or unauthorized destruction of any document, or
misrepresentation of any information could result in termination of employment, as well as
referral to appropriate authorities.
  IV. Fair Dealing
  
    
    Give or accept anything of value from any current or potential financial institution,
supplier or vendor as an inducement for or in return for business or preferential
treatment; or
    
    Take advantage of any financial institution, supplier, competitor or employee through
manipulation, concealment, abuse of privileged information, misrepresentation of material
facts, or any other unfair business practice.
  V. Confidential Information
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VI. Inside Information and Securities Trading
   disclosing or trading Employees, officers and
directors are expected to have read and be familiar with True Religions Insider Trading Policy,
and to comply fully with its rules and guidelines.
 VII. Financial Reporting and Accuracy of Company Records
   
    
    Business transactions must be properly authorized and be completely and accurately
recorded on True Religions books and records in accordance with generally accepted
accounting practices and established True Religion financial policy.
    
    Each True Religion employee, officer and director must help to maintain the integrity of
True Religions record keeping and reporting systems and is responsible for maintaining
complete and accurate records, accounting entries and classifications.
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
    
    True Religion employees, officers and directors are expected to comply fully and
accurately with all audits, requests for special record keeping or retention of documents,
documents or other material from or on behalf of True Religions auditors, True Religion
management.
    
    Each employee is responsible for maintaining complete and accurate records, accounts,
entries and classifications and for accuracy in expense account vouchers reflecting
legitimate business expenses. Misapplication or improper use of corporate funds or
property or false entry to records by employees or others must be reported to True
Religions management and may result in discipline up to and including termination.
    
    No documents or records may be destroyed without the prior written authorization from
the Chief Financial Officer given in accordance with the Companys document retention
policy.
 VIII. Intellectual Property
    Copyrights
 
    
    Do not copy these materials without first determining that the company has obtained
permission from the copyright holder or that other limited copying is legally permitted.
    
    Consult with True Religions management if you have questions.
    
    Do not copy or distribute software or related documentation without reviewing the
license agreement.
 Trademarks and service marks
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
    
    Requests for use of the name, service marks and trademarks of True Religion or its
subsidiaries are reviewed by True Religions Chief Financial Officer or legal counsel.
    
    Do not use a third partys trademark or service mark without permission.
 Patents
 
    
    Only use inventions patented by third parties within the terms of a license agreement.
 A trade secret
 
    
    Treat as trade secrets and keep confidential all commercially sensitive and important
business information of True Religion and its subsidiaries and all similar information of
other companies and persons that True Religion has received under a confidentiality
agreement.
  IX. Dealings with Public Officials and Government Entities
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X. Use of Company Resources
 Ownership of Company Property:
   
    
    Is limited in duration or extent.
    
    Does not detract from the users attention to or completion of job duties or job
performance.
    
    Does not subject True Religion to any significant incremental cost.
    
    Is not used to unlawfully obtain, copy, download, distribute software, electronic files,
or other materials protected by copyright.
    
    Does not otherwise violate this Code of Conduct, including but not limited to,
provisions related to conflicts of interest and/or disclosure of confidential information.
 Improper Benefit from Company
  Computer Resources
  
    
    Computer software (computer programs, databases and related documentation), whether
purchased from a supplier or developed by True Religion, is protected by copyright and may
also be protected by patent or as a trade secret. Employees are expected to strictly
follow the terms and conditions of the license agreements, including provisions not to
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copy or distribute materials covered by these agreements. These protected materials may not
be reproduced for personal use.
    
    Use of the Internet and electronic mail should be in support of and to advance True
Religions business success. Any personal use of these technologies should not create
additional costs for True Religion, interfere with work duties or violate any Company
policies, including policies related to defamatory, offensive or threatening messages,
gambling, pornography, viruses, chain letters, executable ready to run files, hacking,
etc.
  XI. Media Relations and Public Inquiries
   XII. Reporting
 Reporting Violations and Making Complaints
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No Retaliation
    XIII. Discipline
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XIV. Waivers of the Corporate Code of Conduct
  XV. Acknowledgement
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