CODE OF ETHICS
                      FOR CEO AND SENIOR FINANCIAL OFFICERS
                          GLOBETECH ENVIRONMENTAL, INC.


Globetech Environmental,  Inc. (GENV) has a Code of Ethics applicable to all its
employees.  In addition to the Code of Ethics the CEO, and all senior  financial
officers are subject to the following terms and policies.

1.   The CEO and all senior  financial  officers are responsible for full, fair,
     accurate,  timely and  understandable  disclosure  in the periodic  reports
     required to be filed by GENV with the Securities  and Exchange  Commission.
     Accordingly,  it is the responsibility of the CEO and each senior financial
     officer to promptly  bring to the  attention of the  appropriate  officers,
     agents and  employees  involved  in the  preparation  and  approval of each
     report filed with the SEC (the "Disclosure Team") any material  information
     which may affect the disclosures made by GENV in its public filings.  It is
     also the burden of the CEO and each senior financial  officer to assist the
     Disclosure Team in fulfilling its  responsibilities  in connection with the
     preparation  and filing of reports  that  comply  fully with SEC  reporting
     requirements.

2.   The CEO and each  senior  financial  officer  shall  promptly  bring to the
     attention  of the  Audit  Committee  (or the  Disclosure  Team and Board of
     Directors, if there is no acting Audit Committee) any information he or she
     may have concerning (a) significant deficiencies in the design or operation
     of internal controls which could adversely affect GENV's ability to record,
     process,  summarize and/or report  financial data or (b) fraud,  whether or
     not  material,  that  involves  management  or  other  employees  who  have
     significant  role in GENV's  financial  reporting,  disclosures or internal
     control.

3.   The CEO and each  senior  financial  officer  shall  promptly  bring to the
     attention of the CEO and to the Audit Committee (or the Disclosure Team and
     Board of Directors,  if there is no acting Audit Committee) any information
     he or she may have  concerning  any  violation  of GENV's  Code of  Ethics,
     including any actual or apparent conflicts of interest between personal and
     professional relationships, involving any management or other employees who
     have a  significant  role in GENV's  financial  reporting,  disclosures  or
     internal controls.

4.   The CEO and each  senior  financial  officer  shall  promptly  bring to the
     attention of the CEO and to the Audit Committee (or the Disclosure Team and
     Board of Directors,  if there is no acting Audit Committee) any information
     he or she may have  concerning  evidence  of a  material  violation  of the
     securities or other laws,  rules or regulations  applicable to GENV and the
     operation of its business, by GENV or any agent thereof, or of violation of
     the Code of Ethics or of these additional policies and procedures.

5.   The Board of Directors shall determine, or designate appropriate persons to
     determine, appropriate action to be taken in the event of violations of the
     Code of Ethics or of these  additional terms and policies by the CEO and/or
     any of the senior  financial  officers.  Such actions  shall be  reasonably
     designed to deter wrongdoing and to promote accountability for adherence to
     the Code of Ethics and to these  additional  terms and policies,  and shall
     include  written  notices  to the  individual  involved  that the Board has
     determined that there has been a violation,  censure by the Board, demotion
     or re-assignment of the individual involved, 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 of Directors or such designee  shall take into
     account all relevant information, including that nature and severity of the
     violation,  whether  the  violation  was a single  occurrence  or  repeated
     occurrences  whether  the  violation  appears  to  have  been  intentional,
     inadvertent,  whether the  individual in question had been advised prior to
     the  violation  as to the proper  course of action  and  whether or not the
     individual in question had committed or violations in the past.