**EXHIBIT 14.1**

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**OBSIDIAN ENTERPRISES, INC.**

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**CODE OF ETHICSFOR CHIEF EXECUTIVE OFFICER AND SENIOR FINANCIAL OFFICERS**

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THISCODE OF ETHICS (this “**Code**”) of OBSIDIAN ENTERPRISES, INC. (the “**Company**”) applies to the Company’s Chief Executive Officer (“**CEO**”) and Senior Financial Officers.  The term “**Senior Financial Officer**”means the Chief Financial Officer and any other person or persons performingthe functions of principal financial officer and/or principal accountingofficer for the Company.

 

The purpose of the Codeis to deter wrongdoing and promote honest and ethical conduct.  The CEO and Senior Financial Officers aresubject to the following specific policies:

 

1.               The CEO and SeniorFinancial Officers are responsible for full, fair, accurate, timely and understandabledisclosure in the reports and documents the Company files with, or submits to, theSecurities and Exchange Commission and in other public communications.Accordingly, it is the responsibility of the CEO and each Senior FinancialOfficer to promptly bring to the attention of the Chairman of the AuditCommittee any material information of which he or she may become aware thataffects the disclosures made by the Company in its public filings or otherpublic communications or that otherwise may assist the Company in fulfilling itsreporting and disclosure responsibilities.

 

2.               The CEO and eachSenior Financial Officer shall promptly bring to the attention of the ContactPerson any information he or she may have concerning:

 

•                  Significantdeficiencies in the design or operation of internal controls that couldadversely affect the Company’s ability to record, process, summarize and reportfinancial data; or

 

•                  Any fraud,whether or not material, that involves management or other employees who have asignificant role in the Company’s financial reporting, disclosures or internalcontrols.

 

3.               The CEO and eachSenior Financial Officer shall promptly bring to the attention of the ContactPerson any information he or she may have concerning:

 

•                  Any actual or apparentconflicts of interest between personal and professional relationships thatinvolve any management or other employees who have a significant role in theCompany’s financial reporting, disclosures or internal controls;

 

•                  Evidence of amaterial violation of the securities laws, rules or regulations or otherlaws, rules or regulations applicable to the Company and the operation ofits business, by the Company or any agent of the Company; or

 

•                  Any other violationof this Code.

 

4.               After appropriate investigation,the Contact Person shall report violations and potential violations of thisCode to the Audit Committee.  The AuditCommittee shall take all appropriate action to investigate such violations.  If the Audit Committee determines that aviolation of this Code has occurred, it shall notify the Board of

 

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Directors and the Boardof Directors shall take such disciplinary or other action as it deemsappropriate.

 

5.               Any waiver of thisCode may be made only by the Board of Directors or the Audit Committee andshall be promptly disclosed as required by applicable law, rule orregulation.

 

6.               Any amendment ofthis Code may be made only by the Board of Directors and shall be promptlydisclosed as required by applicable law, rule or regulation.

 

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