EXHIBIT 14

                             SIGA TECHNOLOGIES, INC.
                       Code of Ethics and Business Conduct

                                  Introduction

      All of us at SIGA have important roles to play in upholding our Company's
commitment to conduct our business-related activities in a legal and ethical
manner. Maintaining high levels of legal and ethical compliance is simply the
right thing to do and will also maximize the long-term success of our Company.
The purpose of this Code of Ethics and Business Conduct is to promote a culture
of honesty, integrity and respect for law and the people with whom we work. It
applies to SIGA Technologies, Inc. and its subsidiaries (which this Code
collectively calls the "Company").

      We expect each employee to use sound judgment to help us maintain
appropriate compliance procedures and to carry out our business legally and
ethically. No Code can address all of the issues that its personnel may face, so
please apply this Code with common sense. If you are not sure what to do, ask
your supervisor or Thomas N. Konatich, who serves as our Company's Compliance
Officer. Each employee of our Company must read this Code and demonstrate a
personal commitment to its standards. (References in this Code to "employees"
also include non-employee officers and members of the Board of Directors.)

      Our officers and other supervising employees must be leaders in
demonstrating this personal commitment to the standards outlined in this Code.
They must also insure that the employees they supervise adhere to its standards.

      An employee who does not comply with this Code may be subject to
discipline, including termination of employment where appropriate.

      The Code of Ethics and Business Conduct is not a contract. It is not
intended to and does not create an employment contract, does not create any
contractual right between our Company and its employees, does not alter or amend
any existing or future contractual relationship between our Company and any
employee and does not create any express or implied promise for specific
treatment in any specific situation. Further, is not intended as a detailed
guide for all situations you may face or to detract from the importance of
applicable laws and regulations not detailed herein.

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                        The Rules That Guide Our Business

Our Commitment to Our Stockholders

      We expect you to share a commitment to protect our assets and manage our
business in the best interests of our stockholders.

>     Accuracy of our records and reporting: All employees must accurately
      record financial and other business information pertaining to our Company,
      all financial records and transactions must adhere to our system of
      internal controls and accounting requirements, and no one shall enter any
      false or artificial information in our records or reporting systems. These
      requirements apply to all Company information, including personnel,
      workplace and safety records and information we release to the public or
      file with governmental agencies.

>     Disclosure Controls and Procedures. The U.S. Securities and Exchange
      Commission (the "SEC") requires that we maintain effective "disclosure
      controls and procedures" so that financial and non-financial information
      we report in our SEC filings is timely and accurate. All employees must,
      within the scope of their employment duties, support the effectiveness of
      our disclosure controls and procedures and comply with disclosure
      requirements in accordance with applicable laws.

>     Stock Trading and Confidential Information Policy. Our Company's Insider
      Trading Policy prohibits any employee from buying or selling stock or
      other securities of our Company, its affiliates or third parties with whom
      we do business using "material" non-public information concerning our
      Company or concerning those third parties (until after the material
      information has been fully disclosed to the public). As the Policy
      explains in more detail, "material" information is any information that a
      shareholder would consider important when deciding whether to buy, sell or
      hold our stock. Employees must also not disclose or "tip" any of this
      material non-public information to family, friends or others outside the
      Company. These practices are sometimes called "insider trading." The
      insider trading rules can be quite complex, so, if you need more
      information, please refer to our Company's Insider Trading Policy or
      contact the Compliance Officer.

      *     No Selective Disclosure. In addition, applicable securities rules
            also prohibit selective disclosure of material non-public
            information to those outside the Company in most circumstances.
            Therefore, all employees must assist the Company in keeping all
            material non-public information about our Company strictly
            confidential unless and until our Company makes an authorized press
            release or other authorized public communication or filing.

      *     Information to the Public. Our policy is to provide public
            dissemination of material information about our business only
            through our employees authorized for this purpose. You may not under
            any circumstance discuss our Company's financial, business or other
            information with the press (except if the Company has expressly
            authorized you to do so for this purpose) or on any Internet or
            other "discussion board," "chat room," or similar forum. If you
            receive a request from the media, an analyst or a stockholder about
            our Company, you must forward it to our Chief Executive Officer,
            Chief Financial Officer or the Compliance Officer.

>     Protection of Company Assets. You are personally responsible to use our
      Company's assets only for lawful, corporate purposes approved by
      management. All employees should help our Company protect its assets from
      misuse, theft, damage or other loss. You may not make improper or
      unauthorized personal use of Company assets.

>     Intellectual Property. Our Company considers its "intellectual property" -
      including its inventions, processes, patents, trademarks, licenses,
      customer lists and trade secrets - to be valuable assets. Employees must
      maintain the value of our Company's intellectual property by using care to
      keep our trade secrets and other non-public information confidential, and
      limiting access to non-public information to those authorized to use it in
      their duties in connection with our Company's business. If customers or
      suppliers

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      provide non-public information to us in their dealings with us, we must
      protect that information in the same manner as our Company's property.

>     Communications. You must use appropriate judgment and discretion in your
      email, memos, notes and other formal and informal communications relating
      to our business. Communications relating to our business must avoid
      inappropriate or derogatory comments about other individuals or companies,
      unprofessional language and unauthorized financial, legal or business
      statements.

>     Retention of Records. You must preserve Company records for which you are
      responsible in a manner consistent with the business needs of the Company
      and all legal requirements. You must familiarize yourself with special
      retention rules applicable to specific categories of documents (e.g.,
      personnel files, tax records) for which you are responsible. It is our
      Company's policy not to destroy or alter our records or documents (whether
      in paper form, emails or otherwise) in response to or in anticipation of
      any legal proceeding or governmental inquiry or investigation. You may
      also subject yourself to criminal liability if you:

      *     corruptly alter, destroy, mutilate or conceal a record, document or
            other object, or attempt to do so, with the intent to impair its
            availability for use in an official proceeding, or

      *     knowingly alter, cover up, falsify or make a false entry in any
            record, document or tangible object with the intent to impede or
            obstruct the investigation or administration of any matter by a
            governmental agency or bankruptcy court.

Our Commitment to Customers and Business Partners

      We are committed to excellence in service and performance for our
customers, and building mutually advantageous alliances with our business
partners.

>     Customer Relationships. Our policy is to build lasting relationships with
      our customers through superior delivery and execution, and honest sales
      and marketing. We will comply with applicable advertising laws and
      standards. Our policy also prohibits making false or deceptive statements
      about our competitors, and giving or accepting kickbacks, bribes,
      inappropriate gifts and other matters prohibited under the conflict of
      interest topic in this Code.

>     Protecting Information about Others. We are committed to treating
      confidential information of our customers and business partners with at
      least the care we use to protect our own proprietary or confidential
      information. All employees are expected to use sound judgment in limiting
      access to confidential information about our customers and business
      partners to those individuals in our Company who need to know this
      information to carry out their jobs.

>     Commitment to Quality. Our long-term reputation and business success
      depend upon our continued maintenance of high quality in the products and
      services we provide. We are committed to deliver our products and services
      only in accordance with the documentation, safety, quality control and
      other procedures we maintain from time to time.

>     Special Concerns with Governmental Customers. Special legal and
      contracting rules may apply to our dealings with domestic and foreign
      governmental agencies. Many national, state or other local governmental
      agencies impose bidding or procurement requirements, special billing and
      accounting rules and restrictions on the subcontractors or agents we may
      engage. Domestic or foreign laws or regulations may also impose strict
      limits on any kind of benefit or gift offered to officials, including
      limitations on hiring former government officials or their family members.
      If you deal with domestic or foreign governmental agencies, you must be
      familiar with the laws applicable to these business activities and use
      sound judgment to avoid any violation of the letter or spirit of the laws
      prohibiting corrupt practices in connection with governmental contracting.

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>     Suppliers. We must base our contracts with suppliers of products and
      services exclusively on the best interests of our Company and its
      business. These contracts must reflect a fair price for the deliverables
      provided to us and be recorded in accordance with appropriate approval,
      contracting and internal control procedures.

>     Business with Third Parties. We expect our consultants, agents, resellers,
      distributors, subcontractors and other business partners to adhere to
      lawful and ethical business practices. It is important to our Company's
      reputation that we avoid doing business with companies that violate
      applicable laws or have reputations that could harm our business. Our
      policy prohibits engaging agents or other third parties to do indirectly
      what we as a Company should not do under our own policies.

Our Commitment to Each Other

      Each employee must do his or her part to promote a positive working
environment for all.

>     Respect for Our Employees. Our Company's employment decisions will be
      based on reasons related to our business, such as job performance,
      individual skills and talents, and other business-related factors. Our
      Company policy requires adherence to all national, state and local
      employment laws. Our Company policy prohibits discrimination in any aspect
      of employment based on race, color, religion, sex, sexual preference,
      marital status, national origin, disability or age, within the meaning of
      applicable laws.

>     Abusive or Harassing Conduct Prohibited. Our Company policy prohibits
      abusive or harassing conduct by our employees toward others, such as
      unwelcome sexual advances, comments based on ethnic, religious or racial
      aspects, or other non-business, personal comment or conduct that makes
      others uncomfortable in their employment with us. Our Company's policy is
      to provide to its employees a protective and pleasant work environment
      free from harassment, sexual or otherwise, and to prevent harmful
      exploitation of authority and to promote gender equality at work. We
      encourage employees to report harassment or other inappropriate conduct as
      soon as it occurs. We are committed to taking prompt and appropriate
      action as soon as we are aware of or receive any report of harassment or
      inappropriate conduct of any kind, and we will neither take nor permit
      retaliatory action against any employee who reports alleged harassment.
      Sexual harassment impinges upon a person's dignity, privacy and sense of
      equality between the sexes, makes the work relationship more difficult and
      contradicts our Company's policy. In addition to harm caused to the work
      environment, sexual harassment can be a criminal offense. Employees must
      adhere to our Company's policy in this matter and the prevailing laws and
      regulations.

>     Health and Safety. All employees must help us to maintain a healthy,
      hygienic and safe working environment and to report promptly any unsafe or
      hazardous condition or material, injury or accident connected with our
      business. Our Company is committed to adhering to safety laws and
      regulations, including fire protection and other building regulations, and
      laws and regulations that promote cleanliness and hygiene in the
      workplace. You may not work under the influence of any substance that
      would impair the safety of others. All threats or acts of physical
      violence or intimidation are prohibited.

Competition

      We are committed to competing effectively, but lawfully, in our business
markets.

>     Compliance with Antitrust Laws. Our Company and its employees must comply
      with the antitrust and unfair competition laws of the countries in which
      our Company engages in business. These laws vary by country and can be
      complex. If you have a role that may implicate the antitrust laws - such
      as a sales and marketing executive position - you are responsible for
      knowing the laws that apply to these business activities, and should speak
      to our Compliance Officer if any question arises. Generally, these laws
      prohibit or regulate mergers and acquisitions, attempts to monopolize or
      otherwise restrain trade, selling products below cost, price
      discrimination, price fixing or other agreements with competitors that
      would divide or allocate customers or otherwise harm customers, certain
      kinds of "tying" arrangements that require a customer who wishes to buy a
      given product to buy other products or services, artificially

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      maintaining prices, and certain other restrictive agreements or
      arrangements. Our employees may not exchange non-public sales information
      with competitors for the purpose of affecting sales prices or levels.

>     Fair Methods of Competition. Our Company is committed to competition on a
      lawful and ethical basis. You may not use improper or illegal means of
      gaining competitive information that is confidential or proprietary
      information owned by others. You may not use or disclose confidential or
      proprietary information that you may have from past employment with other
      employers.

Conflicts of Interest

      We expect all of our employees to avoid allowing their private interests
to interfere, or appear to interfere, with the interests of our Company as a
whole.

>     Generally. You must make or participate in business decisions and actions
      in the course of your employment with us based on the best interests of
      our Company as a whole, and not based on personal relationships or
      benefits. Although this Code contains some general guidelines, you must
      apply sound judgment to avoid conflicts of interest that could negatively
      affect our Company or its business, whether or not we have specific rules
      for that particular situation. You must disclose to us any situation that
      may involve inappropriate or improper conflicts of interest affecting you
      personally or affecting other employees or those with whom we do business,
      as described under "How to Report Your Concerns."

>     Business Referrals. You may not personally attempt to give or steer our
      Company's business transactions to companies in which a family relative or
      personal friend has a financial or other interest unless you first fully
      inform the Compliance Officer about such transaction and relationship and
      have received the appropriate approvals from unconflicted and sufficiently
      senior personnel.

>     Personal Investments. Generally, you must avoid investments in other
      companies with which our Company does business if these investments could
      create the fact or appearance of a conflict of interest, unless such
      investments received the appropriate Company approvals after full
      disclosure of the relevant circumstances. Investing in relatively small
      positions in publicly traded securities of other companies is generally
      not prohibited so long as there is no violation of our Company policy
      relating to trading while in possession of material non-public information
      about other companies. You must notify the Compliance Officer in advance
      of any proposed personal investment you wish to make in other companies
      with which our Company does business. The Compliance Officer shall advise
      on the appropriate approvals, if any, required in such circumstances.

>     Corporate Opportunities. You must also refrain from purchasing property or
      otherwise taking for yourself personally a business opportunity that you
      learn about through your employment with us. You may not use our Company's
      information for personal gain.

>     Prohibited Competition. You may not compete with us during the term of
      your employment and may not initiate any step to compete with us while
      still in our employ.

>     Outside Compensation and Activities. While employed by us, you may not
      work for or seek or accept personal payments from any customer, supplier,
      competitor, distributor, reseller or other business partner of our
      Company, except as approved in writing by an authorized officer or manager
      of our Company. You may not use trade secrets or other non-public know-how
      or information learned at our Company in activities outside our Company or
      in other ways that could harm our business.

>     Outside Board Service. You must obtain prior written authorization from
      the Compliance Officer for service as a director, general partner,
      manager, officer or similar position with any privately held or public
      business entity or as an appointee to any kind of governmental or
      quasi-governmental agency or body. Service solely as a director or trustee
      of nonprofit corporations engaged in charitable activities does not
      require approval unless that activity could involve improper conflicts of
      interest.

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>     Gifts and Gratuities. You may not seek or accept gifts or gratuities in
      the form of services or other items of value from our customers, other
      business partners or other parties with whom our Company contracts. You
      may not offer or give anything of value that could be or appear to be a
      bribe or otherwise illegal payment. These prohibitions do not apply to
      items of truly nominal value such as generally free promotional items,
      assuming these items are not otherwise prohibited by applicable law or
      custom. Employees should never accept anything that would appear to create
      a conflict of interest. In the unusual situation where refusal to accept a
      true gift might hurt our business, be sure to consult the appropriate
      officer or manager of our Company concerning the proper means of resolving
      the situation.

>     Business Entertainment. You must adhere to our Company's policies as in
      effect from time to time with respect to costs of entertainment. Extending
      or accepting invitations to reasonable meals, public events and similar
      business activities incurred for bona fide business purposes is generally
      acceptable, assuming the costs are not disproportionate to the business
      purpose and otherwise do not create the fact or appearance of a conflict
      of interest. You should not attend entertainment events that may appear
      contrary to professional standards of conduct.

>     Travel. You must comply with Company travel policies in effect from time
      to time. All travel-related expenses must actually be incurred, accurately
      reported and recorded in compliance with these policies.

>     Other Corporate Policies. In addition to the above, employees must comply
      with all other Company policies in effect from time to time.

Legal Compliance Generally

      We expect our employees to be committed to pro-active compliance with all
applicable laws and regulations affecting our Company and its business. In
addition to the laws discussed elsewhere in this code:

>     General Standard of Compliance. You must comply with all applicable laws
      and regulations and national and local governmental authority rules and
      procedures in every location in which we conduct our business. Competitive
      factors, personal goals, and pressure from supervisors, customers or
      others shall never be an acceptable excuse for violating the law.

>     Prohibited Corrupt Practices. Our Company must comply with anti-corruption
      laws, including the Foreign Corrupt Practices Act ("FCPA"), that apply in
      the places where we do business. Our employees and agents must not
      directly or indirectly offer or make a corrupt payment to any domestic or
      foreign governmental official, any foreign political party, candidate or
      official, or employees of enterprises owned or controlled by a
      governmental agency. You may not engage in any form of fraud, including,
      but not limited to, bribery, embezzlement, theft, hiding or misuse of
      Company assets or falsification of records.

>     Prohibited Political Contributions. Political activity represents another
      area where the rules on permissible activities are complex and you could
      inadvertently run afoul of such rules. As a result, you may not contribute
      in our Company's name or on our Company's behalf any cash, services or
      property of any kind for or in support of any political candidate,
      committee, initiative or activity without the prior express approval of
      the Compliance Officer or appropriate legal counsel. No lobbying effort or
      contract shall be undertaken in our Company's name or on our Company's
      behalf without the prior approval of our Board of Directors.

>     Prohibited Loans to Executive Officers and Directors. It is unlawful for
      our Company, directly or indirectly, to extend or maintain credit, to
      arrange for the extension of credit, or to renew an extension of credit,
      in the form of a personal loan to or for any director or executive officer
      of our Company. However, we may continue in effect an extension of credit
      in existence on July 30, 2002, provided that there is no material
      modification, or any renewal, of the extension of credit after that date.

>     Import and Export Restrictions. Our Company and its employees must comply
      with applicable restrictions under domestic and foreign laws relating to
      importing or exporting technology, products, services or

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      regulated information. Employees who conduct Company business involving
      foreign countries must be familiar with and abide by applicable
      import/export and similar restrictions.

>     Environmental Laws. Our Company is committed to protecting the
      environment. We respect the policies and requirements of domestic and
      foreign laws aimed at protecting the environment. We expect a commitment
      from our employees to report appropriately any violation of environmental
      laws and any exposure to hazardous materials or substances that are not
      being handled or disposed of properly.

Our Communities

      We respect our employees' involvement in the community, charitable and
political activities and causes they may choose, so long as these activities do
not interfere with job responsibilities to us. You may not represent that your
views or activities speak for our Company. You may not engage in any unwanted
solicitation or pressure toward other employees relating to charitable,
religious or political causes.

                           How to Report Your Concerns

>     Where to Direct Questions. If you have questions about this Code or
      concerns about any of the matters listed here, please first consider
      speaking with your immediate manager or supervisor if that person was not
      involved in the matter giving rise to your questions. If you do not wish
      to communicate with that person on the matter, please feel free to contact
      Thomas N. Konatich, who serves as our Compliance Officer, or any other
      member of our management. If you wish to communicate any matter
      anonymously, you are free to do so (although we encourage you to identify
      yourself in case we need to follow up on any aspect of your report with
      you), and we will maintain the confidentiality of your communication to
      the extent reasonably possible under the circumstances. You may send
      communications intended to be confidential to the Company's address,
      Attention: Chairman of the Audit Committee.

>     Good Faith Concerns Are Protected. We encourage each of our employees to
      report any concern regarding possible illegal or unethical conduct
      relating to our business. We do not discriminate, retaliate or permit
      discrimination or retaliation against any employee who reports in good
      faith a concern to us. In addition, Company policy prohibits the discharge
      of, other adverse employment action in any manner against, or threat to or
      harassment of an employee for any lawful, good faith act by the employee
      to provide information or assist in an investigation by us or any
      governmental authority or agency, of violations of applicable laws.

>     False Claims Are Prohibited. It is a violation of our standards for any
      employee to communicate a report claiming illegal or unethical conduct
      that the employee knows or reasonably believes to be false.

>     Audit Committee Available to Hear About Accounting Matters. In addition to
      the above, if you have concerns about accounting, internal accounting
      controls or auditing matters relating to our Company, you are also free to
      contact the audit committee of our board of directors directly. Inquiries
      or communications intended to be anonymous should be mailed in writing
      without indicating your name or address to the Audit Committee as noted in
      the first paragraph of this section.

>     Procedures for Investigating and Resolving Concerns. The individual or
      Committee that receives a report under this Code may, in his, her or its
      discretion, assume responsibility for evaluating any possible violation
      and directing or conducting any investigation or may delegate any portion
      of such responsibility to the Compliance Officer, our Board of Directors,
      another committee of the Board whose charge includes the matter at issue
      or another person or entity, either inside or outside the Company. If the
      Audit Committee chooses to assume responsibility for evaluating any
      possible violation or directing or conducting any investigation where the
      investigation concerns a possible violation by a member of the Board, the
      Audit Committee, not including that member, shall assume such
      responsibility. If the Audit Committee is conducting the investigation, it
      shall have the authority to engage independent counsel and other advisers,
      as it deems necessary, to assist in its investigation and decision
      process. After conducting the investigation, the results will be evaluated
      and the Company shall authorize such prompt response,

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      follow-up and preventive actions, if any, as are deemed necessary and
      appropriate to address the substance of the reported possible violation.
      The Company reserves the right to take whatever action it believes
      appropriate, up to and including discharge, if appropriate and permissible
      under law and this Code, of any employee determined to have engaged in
      improper conduct.

                 Waivers Requested by Our Officers and Directors

      As noted at the outset, this Code applies to our officers and directors as
well as to our employees generally. Any waiver of a specific provision of this
Code for any individual officer or director of our Company must be approved, if
at all, in advance by a majority of the independent directors serving on our
board of directors. Any such waiver that may be granted and is required to be
disclosed by applicable law will be publicly disclosed by appropriate means.