EXHIBIT 14.1


                                CODE OF ETHICS

                   FOR SENIOR FINANCIAL OFFICERS, EMPLOYEES,

                   AND THE PRINCIPAL EXECUTIVE OFFICERS OF

                      GREATER ASIA REALTY HOLDINGS, LTD.,

                            A DELAWARE CORPORATION

      (AS ADOPTED BY THE BOARD OF DIRECTORS EFFECTIVE FEBRUARY 18, 2008)

Greater Asia Realty Holdings,  Ltd., a Delaware corporation (the "Company"), is
committed to conducting its business in compliance with all applicable laws and
regulations and in accordance with  high  standards  of  business  conduct. The
Company strives to maintain the highest standard of accuracy, completeness, and
disclosure  in  its  financial  dealings, records, and reports. These standards
serve  as  the  basis for managing the  Company's  business,  for  meeting  the
Company's duties  to  its  stockholders,  and  for  maintaining compliance with
financial  reporting requirements. The Company's principal  executive  officers
and all of the  Company's senior financial executives must agree to comply with
the following principles  and will promote and support this Code of Ethics, and
comply with the following principles.  For  the purpose of this Code of Ethics,
"senior financial officers" means the Company's principal financial officer and
controller  or  principal  accounting officer, or  persons  performing  similar
functions.

The principal executive officer  and  each  senior  financial  officer  of  the
Company   will   adhere   to   and   advocate   the  following  principals  and
responsibilities governing his or her professional and ethical conduct, each to
the best of his or her knowledge and ability:

   1.     Act  with honesty and integrity and in an  ethical  manner,  avoiding
          actual or apparent conflicts of interest in personal and professional
          relationships.

   2.     Promptly  disclose to the Company, through the General Counsel, Chief
          Accounting  Officer,  or Audit Committee, any material transaction or
          relationship that reasonably  could  be  expected  to  give rise to a
          conflict of interest between personal and professional relationships.

   3.     Provide  full, fair, accurate, timely, and understandable  disclosure
          in reports  and documents that the Company files with, or submits to,
          the U.S. Securities  and  Exchange  Commission  and  in  other public
          communications made by the Company.

   4.     Provide  constituents  with  information  that is accurate, complete,
          objective, relevant, timely, and understandable.

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

   6.     Act  in  good  faith,  responsibly,  with  due  care, competence  and
          diligence, without misrepresenting material facts  or allowing his or
          her independent judgment to be subordinated.

   7.     Use  good  business judgment in the processing and recording  of  all
          financial transactions.

   8.     Respect the  confidentiality of information acquired in the course of
          the Company's  business,  except when authorized or otherwise legally
          obligated to disclose such  information,  and  not  use  confidential
          information acquired in the course of work for personal advantage.

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   9.     Share knowledge and maintain skills important and relevant  to his or
          her constituents' needs.

   10.    Promote ethical behavior among constituents in the work environment.

   11.    Achieve  responsible use of and control over all assets and resources
          employed or entrusted to him or her.

   12.    Comply with  generally  accepted  accounting standards and practices,
          rules, regulations and controls.

   13.    Ensure that accounting entries are  promptly  and accurately recorded
          and  properly documented and that no accounting  entry  intentionally
          distorts or disguises the true nature of any business transaction.

   14.    Maintain  books  and  records  that fairly and accurately reflect the
          Company's business transactions.

   15.    Sign only those documents that he  or she believes to be accurate and
          truthful.

   16.    Devise,  implement,  and  maintain sufficient  internal  controls  to
          assure that financial record keeping objectives are met.

   17.    Prohibit the establishment  of any undisclosed or unrecorded funds or
          assets  for  any  purpose  and provide  for  the  proper  and  prompt
          recording of all disbursements of funds and all receipts.

   18.    Not knowingly be a party to  any  illegal  activity or engage in acts
          that are discreditable to his or her profession or the Company.

   19.    Respect and contribute to the legitimate and  ethical  objects of the
          Company.

   20.    Engage  in only those services for which he or she has the  necessary
          knowledge, skill, and expertise.

   21.    Not make,  or  tolerate to be made, false or artificial statements or
          entries for any purpose in the books and records of the Company or in
          any internal or  external correspondence, memoranda, or communication
          of any type, including telephone or wire communications.

   22.    Report to the Company,  through the General Counsel, Chief Accounting
          Officer, or Audit Committee  any  situation where the Code of Ethics,
          the Company's standards, or the laws are being violated.

Those required to comply with this Code of Ethics  understand  that  failure to
comply  with  this  Code  of  Ethics  will not be tolerated by Company and that
deviations  there  from  or  violations  thereof   will   result   in   serious
consequences,  which may include, but may not be limited to, serious reprimand,
dismissal or other legal actions.

The parties subject to this Code of Ethics will acknowledge in writing that
they agree to comply with these requirements.







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