CODE OF ETHICS
                                       FOR
                               EXECUTIVE OFFICERS
                                       OF
                           CLICKABLE ENTERPRISES, INC.

SECTION I

A.  OVERVIEW

      This Code of  Ethics  and  Business  Conduct  (the  "Code")  embodies  the
commitment of Clickable Enterprises,  Inc. to conduct our business in accordance
with  all  applicable  laws,  rules  and  regulations  and the  highest  ethical
standards.  All Executive  Officers (as defined below) are expected to adhere to
the principles  and  procedures set forth in this Code that apply to them.  (For
purposes  of this Code,  the term  "Executive  Officer"  is defined to  include,
without  limitation,  the Company's  President,  Chief Executive Officer,  Chief
Operating  Officer,  Chief  Financial  Officer,  Controller  or other  principal
accounting  officer  and any  Vice-President  of the  Company  who the board has
determined  is an "Officer"  for  purposes of the rules under  Section 16 of the
Exchange  Act of 1934.  This Code of  Ethics  has been  adopted  by the Board of
Directors  of the  Company  in  compliance  with the rules  adopted  by the U.S.
Securities  and  Exchange  Commission  (the  "Commission")  for the  purpose  of
implementing Section 406 of the Sarbanes-Oxley Act of 2002.

B.  BASIC STANDARD OF ETHICS

      Executive Officers shall observe the highest standards of ethical conduct.
In the  performance of their duties,  they shall protect and foster  shareholder
value through fair dealings, complete honesty and full disclosure in all manners
of  business.  Executive  Officers  shall  maintain  the  highest  standards  of
integrity, both in the workplace and outside the workplace,  fully observing all
laws and applicable regulations. Each Executive Officer is obligated to:

      1.    Engage in honest and ethical  conduct,  including  by  avoiding  any
            actual or apparent  conflicts of interest  between  personal affairs
            and relationships on the one hand and professional  responsibilities
            to the Company on the other hand.

      2.    Promote full, fair, accurate,  timely and understandable  disclosure
            in reports and documents that the Company files with, or submits to,
            the  Securities  and  Exchange  Commission  ("SEC") and in any other
            public communications made by the Company.

      3.    Comply with applicable governmental laws, rules and regulations.

      4.    Promptly  report any  possible  violation  of this Code to the Audit
            Committee of the Board of  Directors of the Company,  or if there is
            no Audit Committee, to the Board of Directors.

      Each Executive  Officer will be accountable to the Audit  Committee (or to
the Board of Directors if the Company h as no Audi Committee) for any failure by
him or her to  observe  any term of this Code.  Failure to observe  the terms of
this Code of Ethics may result in disciplinary  action.  Violations of this Code
also may constitute violation of law.

      No waiver or amendment  of this Code of Ethics  shall be permitted  unless
approved by the Audit  Committee of the Board of  Directors,  or an  independent
director, if there is no Audit Committee.  Any such waiver or amendment shall be
publicly  disclosed  to  the  extent  required  by  the  rules  adopted  by  the
Commission.

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C.  CONFLICTS OF INTEREST

      Executive  Officers shall avoid all conflicts of interest.  A "conflict of
interest"  occurs when an individual's  private interest  improperly  interferes
with the  interests of the Company or when an Executive  Officer  faces a choice
between what is in their best personal interest (financial or otherwise) and the
interest of the Company.  In particular,  an Executive Officer must never use or
attempt  to use his or her  position  at the  Company  to  obtain  any  improper
personal benefit for himself or herself,  for his or her family members,  or for
any other person, including loans or guarantees of obligations,  from any person
or entity.

      An Executive  Officer  should never take any action which would  interfere
with the  Company's  contractual  relationships  or  diminish or  disparage  the
reputation  of the Company.  An Executive  Officer  should not have any personal
financial interest in a person or organization that supplies goods,  property or
services  to the Company or from which the Company  obtains  goods,  property or
services.  This  paragraph  does  not  apply to  ownership  of  publicly  traded
securities.

      Executive  Officers  may not seek or accept  personal  gain,  directly  or
indirectly,  from anyone  soliciting  business from, or doing business with, the
Company.  Executive Officers, and members of their immediate families, shall not
accept gifts from, or have and personal  expenses paid for by, anyone soliciting
business from, or doing  business  with,  the Company,  except for gifts with an
annual value from any source not in excess of $250.

      When a conflict of interest  arises,  it is important  that each Executive
Officer act with great care to avoid even the appearance that their actions were
not in the best interests of the Company.  If an Executive Officer is faced with
a situation in which their  objectivity may be questioned  because of individual
interests  or family or  personal  relationships,  the  Executive  Officer  must
immediately notify an Ethics Contact (as defined in Section III).

      Any  Executive  Officer  who  is  aware  of  a  material   transaction  or
relationship that could reasonably be

expected  to give rise to a  conflict  of  interest  should  discuss  the matter
promptly with an Ethics Contact.

D.  LOANS

      The  Company  doe not make  loans,  in any  form,  of  money to  Executive
Officers. This prohibition includes any guarantee by the Company of a loan to an
Executive Officer from a third party.

E.  PUBLIC DISCLOSURE

      It  is  the  Company's   policy  that  the   information   in  its  public
communications, including all filings and periodic reports submitted to the SEC,
be full, fair, accurate,  timely and understandable.  Executive Officers who are
involved  in the  Company's  disclosure  process are  responsible  for acting in
furtherance of these policies and procedures.  In particular,  these individuals
are required  to: (i)  maintain  familiarity  with the  disclosure  requirements
applicable to the Company;  (ii) oversee the Company's  disclosure  controls and
procedures to ensure that information  required to be disclosed in the Company's
filings to the SEC is identified and processed on a timely basis; and (iii) take

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steps  to  regularly   obtain  and  evaluate   information   in  their  area  of
responsibility.    Executive    Officers   are    prohibited    from   knowingly
misrepresenting,  omitting,  or causing others to misrepresent or omit, material
facts  about the  Company to others,  whether  within or  outside  the  Company,
including the Company's independent auditors. In addition, any Executive Officer
who has a supervisory role in the Company's disclosure process has an obligation
to discharge his or her responsibilities diligently.

F.  COMPLIANCE WITH LAWS, RULES AND REGULATIONS

      It is the Company's  policy to comply with all applicable  laws, rules and
regulations.  It is the personal  responsibility  of each  Executive  Officer to
adhere to the  standards  and  restrictions  imposed  by those  laws,  rules and
regulations.

      Generally, it is both illegal and against Company policy for any Executive
Officer who is aware of material nonpublic  information relating to the Company,
any of the  Company's  clients or any other  private or  governmental  issuer of
securities to buy or sell any  securities of those  issuers,  or recommend  that
another person buy, sell or hold the securities of those issuers.

      Any Executive Officer who is uncertain about the legal rules involving his
or her purchase or sale of any Company  securities or any  securities in issuers
that he or she is  familiar  with by virtue  of his or her work for the  Company
should  consult with the  Company's  outside  counsel that prepares its periodic
reports under the U.S. securities laws before making any such purchase or sale.

G.  PROTECTION AND PROPER USE OF COMPANY ASSETS

      All Executive  Officers  should  protect the  Company's  assets and ensure
their  efficient use. All Company assets should be used for legitimate  business
purposes only. The Company's  Executive  Officers must ensure the maintenance of
internal controls to provide guidance and overall  protection of company assets,
financial integrity and reporting accuracy.

      Executive  Officers may not: (i) make personal use of Company assets which
create any  additional  cost for,  interfere  with work duties or  violates  any
Company policies;  (ii) manipulate  financial  accounts,  records or reports for
personal gain or otherwise; or (iii) maintain off-the-book accounts.

      Executive  Officers  must:  (i) prepare  all  corporate  and  governmental
reports and documents with accurate  information  (such documents shall include,
but shall not be limited to,  periodic  reports and other  filings in connection
with the U.S.  securities laws and documents prepared for the U.S. Food and Drug
Administration  and similar  organizations  in other  countries);  (ii) maintain
books,   accounts  and  records  according  to  generally  accepted   accounting
principles,  using  enough  detail to  reflect  accurately  and  fairly  company
transactions;  (iii)  record  transactions  in  a  timely  manner,  so  that  no
misleading financial information is created (these transactions include, but are
not  limited  to:  income,  expense,  indebtedness,   obligation,  reserves  and
acquisition  or disposition of assets);  and (iv) establish  internal  financial
controls that are  documented and reviewed for their  integrity and  application
quarterly by the appropriate  Executive  Officers before submission of quarterly
SEC filings.

      Should any irregularities, non-compliance with internal controls or abuses
be observed,  the observing  Executive Officer should report such directly to an
Ethics Contact.

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SECTION II

A.  CORPORATE OPPORTUNITIES

      Executive  Officers  owe a duty to the  Company to advance  the  Company's
legitimate  business  interests when the opportunity to do so arises.  Executive
Officers are  prohibited  from taking for  themselves  (or  directing to a third
party) a business  opportunity  that is discovered  through the use of corporate
property,  information or position,  unless the Company has already been offered
the opportunity and declined to accept it. More  generally,  Executive  Officers
are  prohibited  from using  corporate  property,  information  or position  for
personal  gain or  competing  with the Company.  Any use of Company  property or
services  that is not solely for the  benefit of the  Company  must be  approved
beforehand through the Ethics Contact.

B.  CONFIDENTIALITY

      In carrying out the Company's  business,  Executive  Officers  often learn
confidential  or  proprietary  information  about  the  Company  or other  third
parties. Executive Officers must maintain the confidentiality of all information
so entrusted to them,  except when disclosure is authorized or legally mandated.
Confidential  or  proprietary  information  includes,  among other  things,  any
non-public  information  concerning  the  Company,   including  its  businesses,
financial  performance,  results or prospects,  and any  non-public  information
provided by a third party with the expectation that the information will be kept
confidential and used solely for the business purpose for which it was conveyed.

C.  FAIR DEALING

      Each Executive  Officer should  endeavor to deal fairly with the Company's
clients, service providers,  suppliers,  competitors and employees. No Executive
Officer   should  take  unfair   advantage  of  anyone   through   manipulation,
concealment,  abuse of  privileged  information,  misrepresentation  of material
facts, or any unfair dealing  practice.  Executive  Officers shall not engage in
practices or enter into arrangements which would violate anti-trust laws.

SECTION III

A.  INTERPRETATION OF THE CODE

Executive  Officers should strive to identify and raise potential ethical issues
before they lead to problems,  and should ask about the application of this Code
whenever in doubt.  Any  questions  relating to how the policies and  procedures
contained in this Code should be  interpreted  or applied should be addressed to
an Ethics  Contact.  For purposes of this Code, an Ethics  Contact is any of the
following:

      o     any  member  of the  Audit  Committee  of  the  Company's  Board  of
            Directors;
      o     the Company's  outside  counsel that  prepares its periodic  reports
            under the U.S. securities laws;
      o     A meeting of the full Audit Committee; or
      o     A meeting  of the full  Board of  Directors,  provided  at least two
            independent directors are present.

      Decisions  is such a case shall be made by a majority  of the  independent
directors present. Any Ethics Contact may refer any issue to, or seek assistance
on any issue from, the outside  counsel who prepares the periodic  reports under
the U.S. securities laws.

B.  REPORTING VIOLATIONS

      All  Executive  Officers  are duty bound to report any  irregularities  or
breaches of this Code of Ethics to an Ethics  Contact.  To the extent  possible,
such  reports  will be  treated  confidentially.  The  Company  will  take  such

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disciplinary  or  preventive  action  as it deems  appropriate  to  address  any
existing or potential violation of this Code brought to its attention.

      Any  Executive  Officer who ignores or violates any of the  principles  or
procedures  in  this  Code,  or any  Executive  Officer  who  penalizes  another
Executive  Officer or other Company personnel for following these standards will
be subject to  appropriate  disciplinary  action,  which may  include  immediate
dismissal.

C. WAIVERS OF THIS CODE

      From time to time, the Company may waive certain  provisions of this Code.
Any  Executive  Officer or Director who believes that a waiver may be called for
should  discuss the matter with an Ethics  Contact.  Waivers may be made only by
the  Board  of  Directors  with  the  affirmative  vote  of a  majority  of  the
independent  directors,  or by the  Audit  Committee  (if  any) of the  Board of
Directors.