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                                                                      EXHIBIT 99

AQUATIC CELLULOSE INTERNATIONAL CORPORATION CODE OF ETHICS FOR CHIEF EXECUTIVE
OFFICER AND SENIOR FINANCIAL OFFICERS

The Board of Directors of Aquatic Cellulose International Corporation (the
"Company") has adopted the following Code of Ethics (the "Code") to apply to
each of the Company's Chief Executive Officers, Chief Financial Officer,
principal accounting officer or controller, and persons performing similar
functions (collectively, "Senior Financial Officers"). This Code is intended to
focus Senior Financial Officers on areas of ethical risk, provide guidance to
help them recognize and deal with ethical issues, provide a mechanism to report
unethical conduct, foster a culture of honesty and accountability, deter
wrongdoing and promote fair and accurate disclosure and financial reporting,
deal with conflicts of interest, and compliance with law.

The Senior Financial Officers each owe a duty to the Company to adhere to a high
standard of ethical conduct.

This Code is intended to serve as a source of guiding principles. Senior
Financial Officers are encouraged to raise questions about particular
circumstances that may involve one or more provisions of this Code to the
attention of the Audit Committee (or in the absence thereof, to the Company's
Board of Directors), who may consult with legal counsel.

1. The Senior Financial Officers are responsible for full, fair, accurate,
timely and understandable disclosure in the periodic reports and other filings
made by the Company with the Securities and Exchange Commission ("SEC"). The
Senior Financial Officers are required to familiarize themselves with disclosure
requirements applicable to the Company as well as the business and financial
operations of the Company. In the performance of their duties, the Senior
Financial Officers are prohibited from knowingly misrepresenting facts.

2. It is the Company's policy to comply with all applicable laws, rules and
regulations relating to its business and operations. It is the responsibility of
the Senior Financial Officers to adhere to the standards and restrictions
imposed by such laws, rules and regulations.

3. The Senior Financial Officers shall encourage open communication and full
disclosure of financial information by providing well understood processes under
which management is kept informed of financial information of importance,
including any departures from sound policy, practice or accounting norms.
However, such officers should refrain from disclosing confidential information
acquired in the course of their work except where authorized, unless legally
obligated to do so. They should also refrain from using confidential information
acquired in the course of their work for unethical or illegal advantage, either
personally or through others.

4. The Senior Financial Officers, among other things, have a supervisory role
over the preparation of financial disclosure to be included in the Company's
periodic reports to be filed with the SEC.

5. It is the responsibility of the Senior Financial Officers to bring to the
attention of the Board of Directors ("Board") and the Audit Committee (upon the
formation thereof by the Board) any material information of which he or she may
become aware that affects the disclosures made by the Company in its filings
with the SEC or otherwise assist the Board and Audit Committee (upon the
formation thereof by the Board) in fulfilling their responsibilities.

6. The Senior Financial Officers shall promptly bring to the attention of the
Board and the Audit Committee (upon the formation thereof by the Board) any
information he or she may have concerning (a) a significant deficiency 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.

7. The Senior Financial Officers shall promptly bring to the attention of the
CEO or Audit Committee (or in the absence thereof, to the Board) any information
he or she may have concerning any violation of these procedures, including any
actual or apparent conflict of interest between personal and professional
relationships, involving any management or other employee who has a significant
role in the Company's financial reporting, disclosures or internal controls.

8. The Senior Financial Officers shall promptly bring to the attention of the
CEO or Audit Committee (or in the absence thereof, to the Board) any information
he or she may have concerning evidence of a violation of the securities or other
laws, rules or regulations applicable to the Company and the operations of its
business, by the Company or any agent thereof, or of violation of these
procedures.


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9. The Board shall determine, or designate an appropriate person to determine,
appropriate actions to be taken in the event of violations of these procedures
by the Senior Financial Officers. Such actions shall be reasonably designed to
deter wrongdoing and to promote accountability for adherence to these
procedures, and shall include written notices to the individual involved that
the Board has determined there has been a violation, censure of the Board,
demotion or re-assignment of the individual, 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 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 or whether or
not the individual in question had committed other violations in the past.

Approved by the Sole Board of Director,

March 11, 2005.


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