EXHIBIT 20.1
CODE OF ETHICAL CONDUCT

                             CODE OF ETHICAL CONDUCT

                          Sailtech International, Inc.

OVERVIEW  Sailtech  International,  Inc.,  ("the Company") has adopted a code of
ethical  conduct that is applicable  to every  officer,  director,  employee and
consultant of the company and its  affiliates  (collectively  the  "Employee" or
"Employees"). The Code reaffirms the high standards of business conduct required
of all  Employees.  The Code is part of the Company's  continuing  effort to (1)
ensure that it complies with all applicable laws, (2) have an effective  program
in place to prevent and detect  violations of law, and (3) educate and train its
Employees  to be  aware  and  understand  ethical  business  practices.  In most
circumstances,  the Code sets  standards  that are higher than the law requires.
OBJECTIVE One of the Company's  objectives is to conduct all business operations
in  the  utmost  ethical   manner.   Communicate   cares  about  its  Employees,
shareholders,  clients,  suppliers, and the communities in which it conducts its
business  operations.   In  the  course  of  meeting  its  business  objectives,
Communicate considers it essential that all Employees understand and comply with
the Code and therefore  share and participate in the Company's way of conducting
business.  STANDARD  OF CONDUCT  The  Company  insists  that all  aspects of its
business operations are conducted with honesty, integrity and fairness, and with
respect for the interests of those affected by its business and activities.  The
Company also expects the same in its  relationships  with all those with whom it
does business.  Each Employee must maintain and foster  integrity and honesty in
all dealings  with clients and all business  transactions.  Each  Employee  must
commit to act  according  to the highest  ethical  standards  and is expected to
apply ethical business  practices in administrative and financial aspects of the
business  operations  of the  Company.  No code of conduct  can hope to lay down
appropriate  behavior  for every  situation,  nor should it seek to do so.  Each
Employee is required to make a careful and considered judgement of what is right
and proper in any particular  situation.  It is the obligation of every Employee
in conducting the business operations of the Company to be responsible,  honest,
trustworthy,  conscientious,  and dedicated to the highest  standards of ethical

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business  practices.  Accordingly,  all Employees are required to avoid not only
impropriety,  but also the  appearance of impropriety in conducting the business
operations of the Company.  ACCURACY OF RECORDS The Company's accounting records
and  supporting  documents must  accurately  describe and reflect the nature and
result of the Company's business  operations.  All activities and results of the
Company's  business  operations must be presented in a fair and balanced manner.
All business  transactions must be properly authorized as well as completely and
accurately recorded on the Company's books.  Procedures for doing so must comply
with the  Company's  financial  policy  and  follow  the  Company's  policy  for
authorization and documentation, as well as follow generally accepted accounting
practices.  Budget proposals and other financial  evaluations and forecasts must
fairly  represent  all  information  relevant to the  business  transaction.  In
addition,  no unrecorded  cash funds or other asset accounts will be established
or maintained  for any purpose.  Misapplication  or improper use of corporate or
property or false entry to records by officers,  directors,  employees or others
must be  reported to Board of the  Company.  COMMUNICATING  ACCURATE  AND TIMELY
INFORMATION In all interactions and  communications,  whether with shareholders,
the public,  clients,  government  agencies,  or others inside or outside of the
Company, each Employee is expected to be truthful and forthright.  This includes
making accurate  statements,  not  misrepresentations  or statements intended to
mislead  or  misinform;  and  responding  promptly,  accurately,  and with  full
disclosure to requests from governmental  agencies for information or documents.
RECORD  KEEPING AND  RETENTION To help  maintain the  integrity of the Company's
record-keeping and reporting systems,  each Employee must know his or her area's
records retention procedures,  including how data is stored and retrieved. It is
that person's responsibility to know how to document and transact any entries or
records that he or she is responsible  for. All Employees are expected to comply
fully and accurately with all audits,  including  responding in a timely fashion
to requests  for records or other  material  from or on behalf of the  Company's
auditors  or  management.  OBEYING  THE LAW All  Employees  of the  Company  are
required to comply with (1) the letter and the spirit of laws and regulations of
the  countries  in which  the  Company  conducts  business  operations,  (2) the
accepted business practices in commercial markets, and (3) any contractual terms
and conditions applicable to any business transaction. Each Employee must commit
to know and abide by all applicable laws and  regulations.  A breach of any law,
regulation  or ethical  standard by any  Employee  will not be  justified by the
pursuit of profit or the  departure  from  acceptable  practice by  competitors.
INSIDER TRADING The applicable laws prohibit any Employee from buying or selling
the Company's  stock or any other kind of public  security as a result of inside
information.  It is also illegal and unethical to provide such information about
the  Company  to other  individuals  or  companies  so that they may gain.  As a
result, every Employee is prohibited under the Code from trading in stock of the
Company, clients or suppliers as a result of any inside information.

ENVIRONMENTAL  ISSUES The Company is  committed  to running  its  business in an
environmentally  sound and  sustainable  manner.  The Company's  objective is to
ensure  that its  business  operations  have the minimum  adverse  environmental
impact  commensurate  with  the  legitimate  needs of its  business  operations.
DECLARATION  OF  INTEREST  Each  Employee  is  required  to reveal any  personal
interest that may impinge or might  reasonably be deemed by others to impinge on
the  Employee's  business  dealings  with  industry.  The  Company  expects  its
Employees to avoid (1) personal  activities  and financial  interests that could
conflict with their  responsibilities  and obligations and (2) giving assistance
to competitors,  which could be in conflict with the interests of the Company or
its clients.  All  Employees  are required to seek the consent of the  Company's
management  if they  intend to become  partners  or  shareholders  in  companies
outside of the Company's  corporate  structure.  CONFIDENTIALITY  Employees must
respect the  confidentiality  of information  received in the course of business
dealings  and must never use such  information  for personal  gain.  Information
given by Employees in the course of business  dealings must be true and fair and
never designed to mislead.  Confidential  information  can only be revealed upon
written  authorization  of  management.  Employees  must not use or disclose the
Company's trade secrets,  proprietary, or confidential information, or any other
confidential  information  gained in the  performance  of their  duties  for the
Company  as a means of  making  private  profit,  gain or  benefit.  In today 's
electronic  age,  posting  information  on  Internet  bulletin  boards  or  even
communicating  in chat rooms is the same as "speaking  to the media".  Employees
must not use these forums to discuss matters or opinions  related to the Company
or any of its businesses,  or to respond to comments about the Company.  PRODUCT
AND SERVICE QUALITY ASSURANCE The Company is committed to providing products and
services  that  consistently  offer value in terms of price and quality  that is
equivalent to or greater than accepted industry standards.  FAIR COMPETITION The

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Company  is  committed  to  vigorous  yet  fair  competition  and  supports  the
development  of  appropriate  competition  laws.  Each  Employee  must avoid any
business  arrangement  that  might  prevent  the  effective  operation  of  fair
competition.

COMPLIANCE WITH THE CODE It is the responsibility of the Board of the Company to
ensure that the  standards  embodied in the Code are the Company to,  understood
and  observed  by all  Employees.  The Board of the Company  will not  criticize
management  for any loss of  business  resulting  from  adherence  to the  Code.
Equally,  the Board of the Company  undertakes that no Employee will suffer as a
consequence  of bringing to their  attention,  or that of senior  management,  a
breach  or  suspected  breach  of the Code.  The  standards  set out in the Code
directly reflects the Company's high ethical standards.  The Company expects and
requires each and every Employee, as a representative of the Company, to fulfill
the Company's  ethical  commitment in a way that is visible to the outside world
with which the  Company  conducts  its  business  operations.  Each  Employee is
responsible for complying with the standards set out in the Code and must ensure
that their personal  conduct is above reproach.  Each Employee has an obligation
to assure that the conduct of others  around him or her complies  with the Code.
All Employees  have a legal,  moral,  and ethical duty to report to the Board of
the Company and the appropriate authorities any known or suspected violations of
law,  regulations  or corporate  policy,  including  the Code.  Breaches of law,
regulations  and the  standards  of  conduct  listed  above may lead to  serious
consequences  for the Employee  concerned.  ENFORCEMENT OF CODE The Code will be
enforced at all levels fairly and without prejudice.  Any breach of any standard
of the Code may result in disciplinary action, up to and including  termination.
ANNUAL  ACKNOWLEDGMENT  Each  Employee  will be  required  to  sign a  statement
annually that he or she has read and  understands  the Company's Code of Ethics.
This  statement  will also require that the Employee  state that he or she is in
full compliance with the Code.

ACKNOWLEDGMENT  AND CERTIFICATION I acknowledge and certify that I have read and
understand  the  information  set forth in the Code of Ethics of the Company and
will comply with these principles in my daily work activities. I am not aware of
any violation of the standards of the Company's Code of Ethics.

Date:____________________________________________________
Name (print):____________________________________________
Position:________________________________________________
Address:_________________________________________________
Signature:_______________________________________________