EXHIBIT 14.1



CODE OF ETHICS OF PRIVATE MEDIA GROUP, INC.



Scope and Applicability



This Code of Ethics of Private Media Group, Inc. (the Company), referred to herein as the Code of Ethics, contains
ethical guidelines for its officers, directors and employees (such persons are collectively referred to as employees) and is intended to comply with applicable provisions of the Sarbanes-Oxley Act of 2002 and rules promulgated thereunder
by the U.S. Securities and Exchange Commission (SEC) and Nasdaq. The provisions contained in this Code of Ethics are intended to supplement other policies, practices and procedures as are adopted from time to time by the Company
from time to time which are applicable to all employees or to management level and supervisory personnel.



Standards of Conduct



The honesty and integrity of employees is fundamental to the reputation and success of the Company. Accordingly, each employee shall, in the performance of duties for the Company, to the best of the employees knowledge and ability:



| |  | Act with honesty and integrity, including the ethical handling of any actual or apparent conflicts of interest between personal and professional relationships;
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| |  | Disclose to the Board of Directors any material transaction or relationship that could reasonably be expected to give rise to a personal conflict of interest;
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| |  | Provide, or cause to be provided, full, fair, accurate, timely and understandable disclosure in reports and documents that the Company files with, or submits to, the SEC and in
other public communications made by the Company;
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| |  | Comply with all applicable government laws, rules and regulations; and
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| |  | Promptly report any violations of this Code of Ethics to the Audit Committee, and promote the prompt reporting by others of violations of the Companys Code of Business Conduct
to the Board of Directors.
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Enforcement of Violations and
Waivers



The Board of Directors shall determine, or
designate appropriate persons to determine, remedial actions to be taken in the event of a violation of the Code of Ethics. Such actions shall be reasonably designed to deter wrongdoing and promote accountability for adherence to the Code of Ethics.
The Board of Directors has full and discretionary authority to approve any amendment to or waiver from this Code of Ethics for senior officers; any such amendment or waiver shall be promptly disclosed as required by applicable law or regulation.