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EXHIBIT 14.1 Caneum, Inc.
Code of Ethics
Formally Adopted March 10, 2004 Caneum, Inc. (the Company) is formally establishing, although it
believes it has complied with the tenants of such a document during its
existence, a Code of Ethics (the Code) pursuant to Section 406 of the
Sarbanes-Oxley Act, and Item 406 of Regulation S-B, which is designed to deter
wrongdoing and to promote:  
    
    Honest and ethical conduct, including the ethical handling of
actual or apparent conflicts of interest between personal and
professional relationships;
    
    Full, fair, accurate, timely, and understandable disclosure in
reports and documents that the Company files with, or submits to, the
Securities and Exchange Commission, and in other public communications
made by the Company;
    
    Compliance with applicable government laws, rules, and regulations;
    
    The prompt internal reporting of violations of the Code to the
appropriate person or persons identified in the Code; and
    
    Accountability for adherence to the Code. The Code of Ethics expects the highest standard of ethical conduct and
fair dealing of its senior financial and accounting officers, defined as the
principal executive officer, principal financial officer, principal accounting
officer or controller, or persons performing similar functions. While this
policy is intended to only cover the actions of the senior financial officers,
the Company expects its other officers, directors and employees will also
review this Code and abide by its provisions. The Companys reputation is a
valuable asset and as such must continually be guarded by all associated with
the Company so as to earn the trust, confidence and respect of our suppliers,
customers and shareholders. The Companys senior financial and accounting officers are committed to
conducting business in accordance with the highest ethical standards. The
senior financial and accounting officers must comply with all applicable laws,
rules and regulations. Furthermore, senior financial and accounting officers
must not commit an illegal or unethical act or instruct or authorize others to
do so. Conflicts of Interest The senior financial and accounting officers must act in the best
interests of the Company, and should avoid any situation that presents an
actual, potential, or apparent conflict between their personal interests and
the interests of the Company.




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The senior financial and accounting officers have a conflict when their
personal interests, relationships, or activities, or those of a member of their
immediate family, interfere or conflict, or even appear to interfere or
conflict, with the interests of the Company. A conflict of interest prevents
one from acting objectively with the best interests of the Company in mind, or
prevents one from exercising sound, ethical business judgment. Public Communications The Company is committed to providing Company information to the public in
a manner that complies with all applicable legal and regulatory requirements
and that promotes investor confidence by facilitating fair, orderly and
efficient behavior. The reports and documents filed by the Company with the
Securities and Exchange Commission, as well as any other public communications,
must be complete, fair, accurate and timely. The senior financial and
accounting officers must do everything in their power to comply with these
standards. Gifts The senior financial and accounting officers may not give or receive
kickbacks, rebates, gifts, services, or any other benefits, other than gifts of
nominal value from a supplier, competitor, government official, customer or any
other person with which the Company does, or expects to do, business. Amounts
would be considered in excess of nominal value if they create the appearance of
impropriety or actually influence the Company to give preferential, versus
arms-length, treatment to the provider. Loans Senior financial and accounting officers may not accept loans, or loan
guarantees, from the Company, or from any persons or entities, either doing
business with, or seeking business with the Company. The Company will not make
any loans to senior financial and accounting officers, other officers,
directors, employees, or any outside parties doing business with, or seeking
business with, the Company. Confidential Information Senior financial and accounting officers, as well as other officers,
directors and employees, are to respect the confidentiality of Company,
employee, supplier, customer, competitor and any other person or entitys
information that is not a matter of public record. Confidential information
must not be used for personal gain. Compliance with the Code Senior financial and accounting officers are expected to fully comply with
this Code. This Code will be strictly enforced and any violations will be
dealt with immediately. Depending on the severity of noncompliance, such
violations could lead to disciplinary action, including termination.
Furthermore, violations involving material unlawful behavior will be reported
to appropriate outside authorities. If anyone is unclear as to the possibility
of a 2




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violation of this Code, he should seek the opinion of the President of the
Company, the Audit Committee, and/or outside legal counsel. If senior financial and accounting officers, or other officers, directors
and employees, have knowledge or are suspicious of any non-compliance with this
Code, or are concerned that circumstances could lead to a violation of this
Code, they should discuss this with their immediate supervisor, the President
of the Company, the Audit Committee, and/or outside legal counsel. The Company will not allow any retaliation against an employee, officer,
or director who acts in good faith in reporting any actual or suspected
violation. Open communication of issues and concerns without fear of
retribution or retaliation is vital to the success of this Code. Adherence to the Code The President will have primary authority and responsibility for the
enforcement of this Code, subject to the supervision of the Audit Committee of
the Board of Directors, and shall promptly notify the Audit Committee of any
violation of this Code. 3