SOMERSET INTERNATIONAL GROUP, INC.
                            FINANCIAL CODE OF ETHICS

As a public company, it is of critical importance that Somerset International
Group, Inc. ("Somerset") filings with the Securities and Exchange Commission be
accurate and timely. Depending on their position with Somerset, employees may be
called upon to provide information to assure that Somerset's public reports are
complete, fair, and understandable. Somerset expects all of its employees to
take this responsibility seriously and to provide prompt and accurate answers to
inquiries related to Somerset' public disclosure requirements.

Somerset's Finance Department bears a special responsibility for promoting
integrity throughout Somerset, with responsibilities to stakeholders both inside
and outside of Somerset. The Chief Executive Officer (CEO), Chief Financial
Officer (CFO), and Finance Department personnel have a special role both to
adhere to the principles of integrity and also to ensure that a culture exists
throughout Somerset as a whole that ensures the fair and timely reporting of
Somerset's financial results and conditions. Because of this special role, the
CEO, CFO, and all members of Somerset's Finance Department are bound by
Somerset's Financial Code of Ethics, and by accepting the Financial Code of
Ethics, each agrees that they will:

-    Act with honesty and integrity, avoiding actual or actual conflicts of
     interest in personal and professional relationships.

-    Provide information that is accurate, complete, objective, relevant, timely
     and understandable to ensure full, fair, accurate, timely, and
     understandable disclosure in the reports and documents that Capital
     Ventures files with, or submits to, government agencies and in other public
     communications.

-    Comply with the rules and regulations of federal, state and local
     governments, and other appropriate private and public regulatory agencies.

-    Act in good faith, responsibly, with due care, competence and diligence,
     without misrepresenting material facts or allowing one's independent
     judgment to be subordinated.

-    Respect the confidentiality of information acquired in the course of one's
     work, except when authorized or otherwise legally obligated to disclose.
     Confidential information acquired in the course of one's work will not be
     used for personal advantage.

-    Share job knowledge and maintain skills important and relevant to
     stakeholders needs.

-    Proactively promote and be an example of ethical behavior as a responsible
     partner among peers, in the work environment and in the community.

-    Achieve responsible use of, and control over, all Somerset assets and
     resources employed by, or entrusted to yourself, and your department.

-    Receive the full and active support and cooperation of Somerset' Officers,
     Sr. Staff, and all employees in the adherence to this Financial Code of
     Ethics.

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-    Promptly report to the CEO or CFO any conduct believed to be in violation
     of law or business ethics or in violation of any provision of this Code of
     Ethics, including any transaction or relationship that reasonably could be
     expected to give rise to such a conflict. Further, to promptly report to
     the Chair of Somerset's Audit Committee such conduct if by the CEO or CFO
     or if they fail to correct such conduct by others in a reasonable period of
     time.