Exhibit 14.1

I-MANY, INC.

CODE OF BUSINESS CONDUCT AND ETHICS

This Code of Business Conduct and Ethics (the Code) sets forth legal and ethical standards of conduct for directors, officers and employees
of I-many, Inc. (the Company). This Code is intended to deter wrongdoing and to promote the conduct of all Company business in accordance with high standards of integrity and in compliance with all applicable laws and regulations. This
Code applies to the Company and all of its subsidiaries and other business entities controlled by it worldwide.

If you have any questions
regarding this Code or its application to you in any situation, you should contact your supervisor or the General Counsel of the Company.

Compliance with Laws, Rules and Regulations

The Company requires that all employees, officers and directors comply with
all laws, rules and regulations applicable to the Company wherever it does business. You are expected to use good judgment and common sense in seeking to comply with all applicable laws, rules and regulations and to ask for advice when you are
uncertain about them.

If you become aware of the violation of any law, rule or regulation by the Company, whether by its officers,
employees, directors, or any third party doing business on behalf of the Company, it is your responsibility to promptly report the matter to your supervisor or to the General Counsel. While it is the Companys desire to address matters
internally, nothing in this Code should discourage you from reporting any illegal activity, including any violation of the securities laws, antitrust laws, environmental laws or any other federal, state or foreign law, rule or regulation, to the
appropriate regulatory authority. Employees, officers and directors shall not discharge, demote, suspend, threaten, harass or in any other manner discriminate or retaliate against an employee because he or she reports any such violation, unless it
is determined that the report was made with knowledge that it was false. This Code should not be construed to prohibit you from testifying, participating or otherwise assisting in any state or federal administrative, judicial or legislative
proceeding or investigation.

Conflicts of Interest

Employees, officers and directors must act in the best interests of the Company. You must refrain from engaging in any activity or having a personal interest that presents a conflict of interest. A
conflict of interest occurs when your personal interest interferes, or appears to interfere, with the interests of the Company. A conflict of interest can arise whenever you, as an officer, director or employee, take action or have an interest that
prevents you from performing your Company duties and responsibilities honestly, objectively and effectively.

For example:



| |  |  | No employee, officer or director shall perform services as a consultant, employee, officer, director, advisor or in any other capacity for, or have a financial
interest in, a competitor of the Company, other than services performed at the request of the Company and other than a financial interest representing less than one percent (1%) of the outstanding shares of a publicly-held company; and
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| |  |  | No employee, officer or director shall use his or her position with the Company to influence a transaction with a supplier or customer in which such person has any
personal interest, other than a financial interest representing less than one percent (1%) of the outstanding shares of a publicly-held company.
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It is your responsibility to disclose any transaction or relationship that reasonably could be expected to give rise to a conflict of interest to the General Counsel or, if you are an executive officer or director, to
the Board of Directors, who shall be responsible for determining whether such transaction or relationship constitutes a conflict of interest.

Insider Trading

Employees, officers and directors who have material non-public information about the Company or other
companies, including our suppliers and customers, as a result of their relationship with the Company are prohibited by law and Company policy from trading in securities of the Company or such other companies, as well as from communicating such
information to others who might trade on the basis of that information. To help ensure that you do not engage in prohibited insider trading and avoid even the appearance of an improper transaction, the Company has adopted an Insider Trading Policy,
which is available in the Legal section of I-manys Inside2 Intranet.

If you are uncertain about the constraints on your
purchase or sale of any Company securities or the securities of any other company that you are familiar with by virtue of your relationship with the Company, you should consult with the General Counsel before making any such purchase or sale.

Confidentiality

Employees, officers and directors must maintain the confidentiality of confidential information entrusted to them by the Company or other companies, including our suppliers and customers, except when disclosure is authorized by a supervisor
or legally mandated. Unauthorized disclosure of any confidential information is prohibited. Additionally, employees should take appropriate precautions to ensure that confidential or sensitive business information, whether it is proprietary to the
Company or another company, is not communicated within the Company except to employees who have a need to know such information to perform their responsibilities for the Company.

Third parties may ask you for information concerning the Company. Subject to the exceptions noted in the preceding paragraph, employees, officers and
directors (other than the Companys authorized spokespersons) must not discuss internal Company matters with, or disseminate internal Company information to, anyone outside the Company, except as required in the performance of their Company
duties and after an appropriate confidentiality agreement is in place. This prohibition applies particularly to inquiries concerning the Company from the media, market professionals (such as securities analysts, institutional investors, investment
advisers, brokers and dealers) and security holders. All responses to inquiries on behalf of the Company must be made only by the Companys authorized spokespersons. If you receive any inquiries of this nature, you must decline to comment and
refer the inquirer to your supervisor or one of the Companys authorized spokespersons.

You also must abide by any lawful obligations
that you have to your former employer. These obligations may include restrictions on the use and disclosure of confidential information, restrictions on the solicitation of former colleagues to work at the Company and non-competition obligations.



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Honest and Ethical Conduct and Fair Dealing

Employees, officers and directors should deal honestly, ethically and fairly with the Companys suppliers, customers, competitors and employees.
Statements regarding the Companys products and services must not be untrue, misleading, deceptive or fraudulent. You must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation
of material facts or any other unfair-dealing practice.

Protection and Proper Use of Corporate Opportunities

Employees, officers and directors must advance the Companys legitimate interests when the opportunity to do so arises. You must not take for
yourself personal opportunities that are discovered through your position with the Company or the use of property or information of the Company.

Gifts and Gratuities

The use of Company funds or assets for gifts, gratuities or other favors to employees or government
officials is prohibited, except to the extent such gifts are in compliance with applicable law, insignificant in amount and not given in consideration or expectation of any action by the recipient.

Employees, officers and directors must not accept, or permit any member of his or her immediate family to accept, any gifts, gratuities or other favors
from any customer, supplier or other person doing or seeking to do business with the Company, other than items of insignificant value. Any gifts that are of sufficient value to influence the relationship should be returned immediately and reported
to your supervisor. If immediate return is not practical, they should be given to the Company for charitable disposition or such other disposition as the Company, in its sole discretion, believes appropriate.

Common sense and moderation should prevail in business entertainment engaged in on behalf of the Company. Employees, officers and directors should
provide, or accept, business entertainment to or from anyone doing business with the Company only if the entertainment is infrequent, modest and intended to serve legitimate business goals.

Bribes and kickbacks are criminal acts, strictly prohibited by law. You must not offer, give, solicit or receive any form of bribe or kickback anywhere
in the world.

Accuracy of Books and Records and Public Reports

Employees, officers and directors must honestly and accurately report all business transactions. You are responsible for the accuracy of your records and
reports. Accurate information is essential to the Companys ability to meet legal and regulatory obligations.

All Company books,
records and accounts shall be maintained in accordance with all applicable regulations and standards and accurately reflect the true nature of the transactions they record. The financial statements of the Company shall conform to generally accepted
accounting rules and the Companys accounting policies. No undisclosed or unrecorded account or fund shall be established for any purpose. No false or misleading entries shall be made in the Companys books or records for any reason, and
no disbursement of corporate funds or other corporate property shall be made without adequate supporting documentation.

It is the policy
of the Company to provide full, fair, accurate, timely and understandable disclosure in reports and documents filed with, or submitted to, the Securities and Exchange Commission and in other public communications.



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Concerns Regarding Accounting or Auditing Matters

Employees with concerns regarding questionable accounting or auditing matters or complaints regarding accounting, internal accounting controls or
auditing matters may confidentially, and anonymously if they wish, submit such concerns or complaints using the toll-free, anonymous telephone number, 866-291-2946. See Reporting and Compliance Procedures. All such concerns and
complaints will be forwarded to the Audit Committee of the Board of Directors. A record of all complaints and concerns received will be maintained by the Audit Committee.

The Audit Committee will evaluate the merits of any concerns or complaints received by it and authorize such follow-up actions, if any, as it deems necessary or appropriate to address the substance of the concern or
complaint.

The Company will not discipline, discriminate against or retaliate against any employee who reports a complaint or concern,
unless it is determined that the report was made with knowledge that it was false.

Dealings with Independent Auditors

No employee, officer or director shall, directly or indirectly, make or cause to be made a materially false or misleading statement to an accountant in
connection with (or omit to state, or cause another person to omit to state, any material fact necessary in order to make statements made, in light of the circumstances under which such statements were made, not misleading to, an accountant in
connection with) any audit, review or examination of the Companys financial statements or the preparation or filing of any document or report with the SEC. No employee, officer or director shall, directly or indirectly, take any action to
coerce, manipulate, mislead or fraudulently influence any independent public or certified public accountant engaged in the performance of an audit or review of the Companys financial statement.

Waivers of this Code of Business Conduct and Ethics

While some of the policies contained in this Code must be strictly adhered to and no exceptions can be allowed, in other cases exceptions may be appropriate. Any employee or officer who believes that an exception to
any of these policies is appropriate in his or her case should first contact his or her immediate supervisor. If the supervisor agrees that an exception is appropriate, the approval of the General Counsel must be obtained. The General Counsel shall
be responsible for maintaining a record of all requests for exceptions to any of these policies and the disposition of such requests.

Any
executive officer or director who seeks an exception to any of these policies should contact the General Counsel. Any waiver of this Code for executive officers or directors or any change to this Code that applies to executive officers or directors
may be made only by the Board of Directors of the Company and will be disclosed as required by law or Nasdaq regulation.

Reporting and
Compliance Procedures

Every employee, officer and director has the responsibility to ask questions, seek guidance, report suspected
violations and express concerns regarding compliance with this Code. Any employee, officer or director who knows or believes that any other employee or representative of the Company has engaged or is engaging in Company-related conduct that violates
applicable law or this Code should report such information to his or her supervisor or to the General Counsel, as described below. You may report such conduct openly or anonymously without fear of retaliation. The Company will not discipline,
discriminate against or retaliate against any employee who reports such conduct, unless it is determined that the report was made with knowledge that it was false, or who cooperates in any investigation or inquiry regarding such conduct. Any
supervisor who receives a report of a violation of this Code must immediately inform the General Counsel of the Company.



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You may report violations of this Code, on a confidential or anonymous basis, by contacting the
Companys General Counsel by fax, mail or e-mail at:

Robert G. Schwartz, Jr.

Vice President and General Counsel

I-many, Inc.

511 Congress Street

Portland, ME 04101

Fax: (207) 828-0492

e-mail: bschwartz@imany.com

In addition, the Company has established an anonymous, toll-free telephone number accessible only by the Audit Committee, 866-291-2946, where you can leave a message about any violation or suspected violation of this
Code. While we prefer that you identify yourself when reporting violations so that we may follow up with you, as necessary, for additional information, you may leave messages anonymously if you wish.

If the General Counsel receives information regarding an alleged violation of this Code, he or she shall, as appropriate, (a) evaluate such information,
(b) if the alleged violation involves an executive officer or a director, inform the Board of Directors of the alleged violation, (c) determine whether it is necessary to conduct an informal inquiry or a formal investigation and, if so, initiate
such inquiry or investigation and (d) report the results of any such inquiry or investigation, together with a recommendation as to disposition of the matter, to the Chairman of the Audit Committee for action, or if the alleged violation involves an
executive officer or a director, report the results of any such inquiry or investigation to the Board of Directors or a committee thereof. Employees, officers and directors are expected to cooperate fully with any inquiry or investigation by the
Company regarding an alleged violation of this Code. Failure to cooperate with any such inquiry or investigation may result in disciplinary action, up to and including discharge.

The Company shall determine whether violations of this Code have occurred and, if so, shall determine the disciplinary measures to be taken against any
employee who has violated this Code. In the event that the alleged violation involves an executive officer or a director, the Board of Directors shall determine whether a violation of this Code has occurred and, if so, shall determine the
disciplinary measures to be taken against such executive officer or director.

Failure to comply with the standards outlined in this Code
will result in disciplinary action including, but not limited to, reprimands, warnings, probation or suspension without pay, demotions, reductions in salary, discharge and restitution. Certain violations of this Code may require the Company to refer
the matter to the appropriate governmental or regulatory authorities for investigation or prosecution. Moreover, any supervisor who directs or approves of any conduct in violation of this Code, or who has knowledge of such conduct and does not
immediately report it, also will be subject to disciplinary action, up to and including discharge.

Dissemination and Amendment

This Code shall be distributed to each new employee, officer and director of the Company upon commencement of his or her employment or
other relationship with the Company and shall also be distributed periodically to each employee, officer and director of the Company, and each employee, officer and director shall certify that he or she has received, read and understood the Code and
has complied with its terms.



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The Company reserves the right to amend, alter or terminate this Code at any time for any reason. The
most current version of this Code can be found in the Legal section of I-manys Inside2 Intranet.

This document is not an
employment contract between the Company and any of its employees, officers or directors.



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Certification

I,

do hereby certify that:

(Print Name Above)

1. I have received and carefully read the Code of Business Conduct and Ethics of I-many, Inc.

2. I
understand the Code of Business Conduct and Ethics.

3. I have complied and will continue to comply with the terms of the Code of Business
Conduct and Ethics.



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EACH EMPLOYEE, OFFICER AND DIRECTOR IS REQUIRED TO SIGN, DATE AND RETURN THIS CERTIFICATION TO THE HUMAN
RESOURCES DEPARTMENT.