Exhibit 14
              CODE OF ETHICS FOR CEO AND SENIOR FINANCIAL OFFICERS

         The Company has a Code of Business Conduct and Ethics applicable to all
directors and employees of the Company. The CEO and all senior financial
officers, including the CFO and principal accounting officer, are bound by the
provisions set forth therein relating to ethical conduct, conflicts of interest
and compliance with law. In addition to the Code of Business Conduct and Ethics,
the CEO and senior financial officers are subject to the following additional
specific policies:

l.       The CEO and all senior financial officers are responsible for full,
         fair, accurate, timely and understandable disclosure in the periodic
         reports required to be filed by the Company with the U.S. Securities
         and Exchange Commission. Accordingly, it is the responsibility of the
         CEO and each senior financial officer promptly to bring to the
         attention of the Board any material information of which he or she may
         become aware that affects the disclosures made by the Company in its
         public filings or otherwise assist the Board in fulfilling its
         responsibilities.

2.       The CEO and each senior financial officer shall promptly bring to the
         attention of the Board any information he or she may have concerning
         (a) significant deficiencies in the design or operation of internal
         controls which could adversely affect the Company's ability to record,
         process, summarize and report financial data or (b) any fraud, whether
         or not material, that involves management or other employees who have a
         significant role in the Company's financial reporting, disclosures or
         internal controls.

3.       The CEO and each senior financial officer shall promptly bring to the
         attention of the Board any information he or she may have concerning
         any violation of the Company's Code of Business Conduct and 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 financial
         reporting, disclosures or internal controls.

4.       The CEO and each senior financial officer shall promptly bring to the
         attention of the Board any information he or she may have concerning
         evidence of a material violation of the securities or other laws, rules
         or regulations applicable to the Company and the operation of its
         business, by the Company or any agent thereof, or of violation of the
         Code of Business Conduct and Ethics or of these additional procedures.

5.       The  Board  shall  determine,  or  designate  appropriate  persons  to
         determine,  appropriate actions to be taken in the event of violations
         of the Code of  Business  Conduct  and  Ethics or of these  additional
         procedures by the CEO and the  Company's  senior  financial  officers.
         Such actions shall be reasonably  designed to deter  wrongdoing and to
         promote  accountability  for adherence to the Code of Business Conduct
         and  Ethics  and to these  additional  procedures,  and shall  include
         written  notices  to  the  individual  involved  that  the  Board  has
         determined  that  there has been a  violation,  censure  by the Board,
         demotion or re-assignment of the individual involved,  suspension with
         or  without  pay  or  benefits  (as   determined  by  the  Board)  and
         termination of the individual's employment. In determining what action
         is appropriate in a particular  case, the Board or such 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 or not the  individual  in  question  had
         committed other violations in the past.





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