CODE OF ETHICS FOR CHIEF EXECUTIVE OFFICER
                           AND CHIEF FINANCIAL OFFICER
                                       OF
                           VIRILITEC INDUSTRIES, INC.

The Chief Executive Officer and Chief Financial Officer (collectively, the
"Senior Officers") hold an important and elevated role in corporate governance.
As part of the Corporate Leadership Team, Senior Officers are vested with both
the responsibility and authority to protect, balance, and preserve the interests
of all of the enterprise stakeholders, including shareholders, clients,
employees, and citizens of the communities in which business is conducted.
Senior Officers fulfill this responsibility by prescribing and enforcing the
policies and procedures employed in the operation of the enterprise's financial
organization, and by demonstrating the following:

I.    Honest and Ethical Conduct

Senior Officers will exhibit and promote the highest standards of honest and
ethical conduct through the establishment and operation of policies and
procedures that: Encourage and reward professional integrity in all aspects of
the financial organization, by eliminating inhibitions and barriers to
responsible behavior, such as coercion, fear of reprisal, or alienation from the
financial organization or the enterprise itself.

o     Prohibit and eliminate the appearance or occurrence of conflicts between
      what is in the best interest of the enterprise and what could result in
      material personal gain for a member of the financial organization,
      including Senior Officers.

o     Provide a mechanism for members of the finance organization to inform
      senior management of deviations in practice from policies and procedures
      governing honest and ethical behavior.

o     Demonstrate their personal support for such policies and procedures
      through periodic communication reinforcing these ethical standards
      throughout the finance organization.

II.   Financial Records and Periodic Reports

Senior Officers will establish and manage the enterprise transaction and
reporting systems and procedures to ensure that:

o     Business transactions are properly authorized and completely and
      accurately recorded on the Company's books and records in accordance with
      Generally Accepted Accounting Principles (GAAP) and established company
      financial policy.

o     The retention or proper disposal of Company records shall be in accordance
      with established enterprise financial policies and applicable legal and
      regulatory requirements.

o     Periodic financial communications and reports will be delivered in a
      manner that facilitates the highest degree of clarity of content and
      meaning so that readers and users will quickly and accurately determine
      their significance and consequence.

III.  Compliance with Applicable Laws, Rules and Regulations

Senior Officers will establish and maintain mechanisms to: Educate members of
the finance organization about any federal, state or local statute, regulation
or administrative procedure that affects the operation of the finance
organization and the enterprise generally.

o     Monitor the compliance of the finance organization with any applicable
      federal, state or local statute, regulation or administrative rule

o     Identify, report and correct in a swift and certain manner, any detected
      deviations from applicable federal, state or local statute or regulation