Exhibit 14.1

                           RUBICON MEDICAL CORPORATION

              CODE OF ETHICS FOR CEO AND SENIOR FINANCIAL OFFICERS

         Rubicon Medical Corporation (the "Company") has policies and procedures
applicable to all directors and employees of the Company (the "Policies and
Procedures"). The CEO and all senior financial officers, including the CFO and
principal accounting officer, are bound by the provisions set forth therein. In
addition to the Policies and Procedures, the CEO and senior financial officers
are subject to the following additional specific policies:

         1.       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 SEC. Accordingly, it is the responsibility of the CEO and
                  each senior financial officer promptly to bring to the
                  attention of the Board of Directors any material information
                  of which he or she may become aware that affects the
                  disclosures made by the Company in its public filings.

         2.       The CEO and each senior financial officer shall promptly bring
                  to the attention of the Board of Directors 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 CEO and to the Board of Directors any
                  information he or she may have concerning any violation of the
                  Policies and Procedures, 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 CEO and to the Board of Directors 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 Policies and Procedures or of these additional
                  procedures.

         5.       The Board of Directors shall determine, or designate
                  appropriate persons to determine, appropriate actions to be
                  taken in the event of violations of the Policies and

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                  Procedures 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 Policies and Procedures
                  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 of Directors 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.