Exhibit 14.2  POLICY STATEMENT OF ASIA ATLANIC RESOURCES PROTECTION OF MATERIAL, NONPUBLIC AND OTHER CONFIDENTIAL INFORMATION AND PREVENTION OF INSIDER TRADING AND TIPPING  This
Policy Statement applies to all directors and employees of Asia Atlantic
Resources (the Company) and its subsidiaries.  The term Employees, as
used in this Policy Statement, include not only regular full-time, part-tine and
temporary employees of the Company, but also contract or leased employees whose
legal employer is not the Company and, in some cases, independent contractors
who work closely with the Company and may have access to inside or confidential
information.  The
purpose of this Policy Statement is to reaffirm, in a comprehensive statement,
the Companys long-standing policies with regard to the protection of material,
nonpublic, and other confidential information, the stringent ethical and legal
prohibitions against insider trading and tipping, and the expected standards of
conduct of employees of the Company in these highly sensitive areas.
 Failure to adhere strictly to these policies could both damage the
Companys reputation and otherwise result in serious adverse consequences to the
Company and the employees involved.  The
Company has ethical and legal responsibilities to maintain the confidence of its
shareholders and the public markets generally and to protect as valuable assets
confidential and proprietary information developed by or entrusted to it.
 In addition, violations of the laws against insider trading and tipping by
Company employees can expose such employees and the Company to severe civil and
criminal liability including imprisonment.  Although
the Company respects the right of each of its employees to engage in investment
activities and encourages employees to become and remain shareholders of the
Company, it is important that such practices avoid any appearance of
impropriety, as well as remain in full compliance with the law.
 Accordingly, employees must exercise good judgment when engaging in
securities transactions and when relating to other information obtained as a
result of their employment with the Company.  To
assist in the implementation of this Policy Statement and to deal with other
related matters, the Company has named a Corporate Communications Specialist.
 The Corporate Communications Specialist is also responsible for
communications by the Company with the public.  The present Corporate
Communications Specialist is  Patricia
Cooke President and Chief Executive Officer  If
an employee has any question regarding this Policy Statement, including the need
to maintain confidentiality and whether it is permissible to buy or sell the
stock or other securities of the Company, the Corporate Communications
Specialist should be contacted directly.  The Corporate Communications
Specialist also must be informed of instances that a violation or possible
violation of this Policy Statement is discovered.  In appropriate
circumstances, an employee may first contact his or her supervisor.  If an
employee has any doubt whether a particular situation requires refraining from
making an investment, buying or selling securities of the Company, or sharing
information with others, such doubt should be resolved against taking such
action.  Statement of Policy  It
is the policy of the Company that no director or employee of the Company should
engage in transactions in any securities, whether of the Company or of any
public companies, while in possession of material. nonpublic information, nor
shall any employee communicate such information to any person who might use such
information to purchase or sell securities, so-called tipping.  For
purposes of this Policy Statement, securities includes options or derivative
instruments with respect to such securities and other securities that are
immediately convertible or exchangeable into such securities.  The
question of whether information is rnaterial is not always easily resolved.
 Generally speaking information is deemed material where there is a
substantial likelihood that a reasonable investor could consider the information
important in deciding whether to buy or sell the securities in question, or
where the information, if disclosed, could be viewed by a reasonable investor as
having significantly altered the total mix of information available.
 Where the nonpublic information relates to a possible or contingent event,
materiality depends upon a balancing of both the probability that the event will
occur and the anticipated magnitude of the event in light of the totality of a
companys activities.  Common, but by no means exclusive, examples of
material information include information concerning a companys sales,
earnings, dividends, significant acquisitions, mergers, tender offers, and major
litigation.  Because materiality determinations are often challenged with
the benefit of hindsight, if an employee has any doubt whether certain
information is material, such doubt should be resolved in favor of not trading
or communicating such information,  Information
is nonpublic until it has been made available to investors generally.  In
this respect, one must be able to point to some fact or event to show that the
information is generally public such as widespread public disclosure through a
press release distributed through major news services or inclusion in widely
circulated publications.  Although it may be sufficient if the information
is included in reports fled with the Securities and Exchange Commission, this by
itself may not be sufficient.  In general, information may be presumed to
have been made available to investors after two business days have gone by since
the formal release of such information.  Accordingly,
in the handling of information obtained as a result of employment with the
Company, employees:  · Must
not disclose material, nonpublic, or other confidential information to anyone,
inside or outside of the Company (including family members), except on a strict
need-to-know basis to Company management and under circumstances that make it
reasonable to believe that the information will not be misused or improperly
disclosed by the recipient.  · Must
refrain from recommending or suggesting that any person engage in transactions
in the securities, whether of the Company or any public companies, while in
possession of material, nonpublic information about those securities.  · Must
abstain from engaging in any transactions in securities, whether of the Company
or any public companies, while in possession of material, nonpublic information
regarding those securities.  An
employees actions with respect to matters governed by this Policy Statement are
significant indications of the individuals judgment, ethics, and competence.
 Accordingly, insensitivity to or disregard of the principles of this
Policy Statement may constitute an important element in the evaluation of an
employee for retention, assignment, and promotion. Any actions in violation of
this Policy Statement may be grounds for appropriate disciplinary action and in
addition could expose such employee and the Company to significant civil and
criminal liability.  Responsibility and Authority  Employees
should recognize that certain additional restrictions may be required with
respect to those employees whose responsibilities or functions require or
involve routine access to confidential and material, nonpublic information, or
who are asked to work on sensitive projects or transactions In addition,
managerial employees are responsible for taking appropriate steps, including
communication and explanation of the contents of this Policy Statement, to
assure that the employees whom they supervise understand and comply with the
foregoing policies.  I ACKNOWLEDGE THAT I
HAVE RECEIVED A COMPLETE COPY OF THE FOREGOING POLICY STATEMENT FOR MY OWN USE
AND RETENTION, AND I AGREE TO COMPLY WITH THE POLICY STATEMENT IN ALL
RESPECTS.  Date:Name and
Title   1