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Exhibit 14.1

                           GREEN IRONS HOLDINGS CORP.
                                 CODE OF ETHICS


                                     TOPICS
                                     ------

1.   Statement of Policy 2. Implementation and Enforcement
3.   Relations with Competitors and Other Third Parties
4.   Insider Trading, Securities Compliance and Public Statements
5.   Financial Reporting
6.   Human Resources
7.   Environmental, Health and Safety
8.   Conflicts of Interest
9.   International Trade
10.  Government Relations
11.  Contractors, Consultants, and Temporary Workers
12.  Conclusion

1.   STATEMENT OF POLICY

The Company has adopted eight Corporate Values (Focus, Respect, Excellence,
Accountability, Teamwork, Integrity, Very Open Communications and Enjoying Our
Work) to provide a framework for all employees in conducting ourselves in our
jobs. These policies are not intended to substitute for those Values, but will
serve as guidelines in helping you to conduct the Company's business in
accordance with our Values. Compliance requires meeting the spirit, as well as
the literal meaning, of the law, the policies and the Values. It is expected
that you will use common sense, good judgment, high ethical standards and
integrity in all your business dealings.

If you encounter a situation you are not able to resolve by reference to these
policies, ask for help. Contact Andrew Couvell, Chief Executive Officer, who has
been identified as responsible for overseeing compliance with these policies.

Violations of the law or the Company's policies will subject employees to
disciplinary action, up to and including termination of employment. In addition,
individuals involved may subject themselves and the Company to severe penalties
including fines and possible imprisonment. Compliance with the law and high
ethical standards in the conduct of Company business should be a top priority
for each employee, officer and director.

2.   IMPLEMENTATION AND ENFORCEMENT.

Andrew Couvell, our Chief Executive Officer, has been appointed as Compliance
Officer of the Company, responsible for overseeing compliance with, and
enforcement of, all Company policies.

Employees are expected to be familiar with these policies as they apply to their
duties. They should consult with their managers if they need assistance in
understanding or interpreting these policies. Each employee is required to
follow these policies and to comply with their terms. A refusal by any employee
to agree to be bound by these policies shall be grounds for discipline up to and
including dismissal.

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Any employee who, in good faith, has reason to believe a Company operation or
activity is in violation of the law or of these policies must call the matter to
the attention of Andrew Couvell, our Chief Executive Officer. All reports will
be reviewed and investigated and as necessary under the circumstances, and the
reporting employee should provide sufficient information to enable a complete
investigation to be undertaken.

ANY EMPLOYEE WHO MAKES AN ALLEGATION IN GOOD FAITH REASONABLY BELIEVING THAT A
PERSON HAS VIOLATED THESE POLICIES OR THE LAW, WILL BE PROTECTED AGAINST
RETALIATION.

3.   RELATIONS WITH COMPETITORS AND OTHER THIRD PARTIES.

The Company's policy is to comply fully with competition and antitrust laws
throughout the world. These laws generally prohibit companies from using illegal
means to maintain, obtain or attempt to obtain a monopoly in a market. They also
prohibit companies from engaging in unfair trade practices. "UNFAIR TRADE
practices" include fixing prices, dividing markets, agreeing with competitors
not to compete, or agreeing to boycott certain customers. It is advised that you
consult with the Andrew Couvell before attending a meeting with a party who may
be viewed as a competitor.

4.   INSIDER TRADING, SECURITIES COMPLIANCE AND PUBLIC STATEMENTS.

Securities laws prohibit anyone who is in possession of material, non-public
information ("Insider Information") about a company from purchasing or selling
stock of that company, or communicating the information to others. Information
is considered "material" if a reasonable investor would consider it to be
important in making a decision to buy or sell that stock. Some examples include
financial results and projections, new products, acquisitions, major new
contracts or alliances prior to the time that they are publicly announced.
Employees who become aware of such Inside Information about the Company must
refrain from trading in the shares of the Company until the Inside Information
is publicly announced.

Employees must also refrain from disclosing that information to persons who do
not have a Company need to know, whether they are inside the Company or outside,
such as spouses, relatives or friends.

The Company makes regular formal disclosures of its financial performance and
results of operations to the investment community. We also regularly issue press
releases. Other than those public statements, which go through official Company
channels, employees are prohibited from communicating outside the Company about
the Company's business, financial performance or future prospects. Such
communications include questions from securities analysts, reporters or other
news media, but also include seemingly innocent discussions with family,
friends, neighbors or acquaintances.

5.   FINANCIAL REPORTING.

The Company is required to maintain a variety of records for purposes of
reporting to the government. The Company requires all employees to maintain full
compliance with applicable laws and regulations requiring that its books of
account and records be accurately maintained. Specifics of these requirements
are available from Andrew Couvell.

6.   HUMAN RESOURCES.

The Company is committed to providing a work environment that is free from
unlawful harassment and discrimination, and respects the dignity of its
employees. The Company has policies covering various aspects of its relationship
with its employees, as well as employees' relationships with each other. For
more detailed information, you should consult Andrew Couvell. Each employee is
expected to be familiar with these policies and to abide by them.

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7.   ENVIRONMENTAL, HEALTH AND SAFETY.

The Company is committed to protecting the health and safety of our employees,
as well as the environment in general. The Company expects employees to obey all
laws and regulations designed to protect the environment, and the health and
safety of our employees, and to obtain and fully observe all permits necessary
to do business.

At the very least, all employees should be familiar with and comply with safety
regulations applicable to their work areas. The Company will make, to the extent
possible, reasonable accommodations for the known physical or mental limitations
of our employees. Employees who require an accommodation should contact Andrew
Couvell. The Company will then engage in an interactive process to determine
what reasonable accommodations may exist.

8.   CONFLICTS OF INTEREST.

Each employee is expected to avoid any activity, investment or association that
interferes with the independent exercise of his or her judgment in the Company's
best interests ("Conflicts of Interest"). Conflicts of Interest can arise in
many situations. They occur most often in cases where the employee or the
employee's family obtains some personal benefit at the expense of the Company's
best interests.

No employee, or any member of employee's immediate family, shall accept money,
gifts of other than nominal value, unusual entertainment, loans, or any other
preferential treatment from any customer or supplier of the Company where any
obligation may be incurred or implied on the giver or the receiver or where the
intent is to prejudice the recipient in favor of the provider. Likewise, no
employee shall give money, gifts of other than nominal value, unusual
entertainment or preferential treatment to any customer or supplier of the
Company, or any employee or family members thereof, where any obligation might
be incurred or implied, or where the intent is to prejudice the recipient in
favor of the Company. No such persons shall solicit or accept kickbacks, whether
in the form of money, goods, services or otherwise, as a means of influencing or
rewarding any decision or action taken by a foreign or domestic vendor,
customer, business partner, government employee or other person whose position
may affect the Company's business.

No employee shall use Company property, services, equipment or business for
personal gain or benefit.

Employees may not: (1) act on behalf of, or own a substantial interest in, any
company or firm that does business, or competes, with the Company; (2) conduct
business on behalf of the Company with any company or firm in which the employee
or a family member has a substantial interest or affiliation. Exceptions require
advance written approval from the Company's Attorney.

Employees should not create the appearance that they are personally benefiting
in any outside endeavor as a result of their employment by the Company, or that
the Company is benefiting by reason of their outside interests. Any employee who
is not sure whether a proposed action would present a conflict of interest or
appear unethical should consult with Andrew Couvell.

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9.   INTERNATIONAL TRADE.

The Company must comply with a variety of laws around the world regarding its
activities. In some cases, the law prohibits the disclosure of information,
whether the disclosure occurs within the U.S. or elsewhere, and whether or not
the disclosure is in writing.
Payments or gifts to non-U.S. government officials are prohibited by law and by
Company policy. The Foreign Corrupt Practices Act precludes payments to non-U.S.
government officials for the purpose of obtaining or retaining business, even if
the payment is customary in that country. This law applies anywhere in the world
to U.S. citizens, nationals, residents, businesses or employees of U.S.
businesses. Because GREEN IRONS HOLDINGS CORP. is a U.S. company, this law
applies to the Company and all of its subsidiaries. Any questions on this policy
should be directed to Andrew Couvell.

10.  GOVERNMENT RELATIONS.

The Company is prohibited by law from making any contributions or expenditures
in connection with any U.S. national election. This includes virtually any
activity that furnishes something of value to an election campaign for a federal
office. Use of the Company's name in supporting any political position or ballot
measure, or in seeking the assistance of any elected representative, requires
the specific approval of the Chief Executive Officer of the Company. Political
contributions or expenditures are not to be made out of Company funds in any
foreign country, even if permitted by local law, without the consent of the
Company's Chief Executive Officer.

U.S. law also prohibits giving, offering, or promising anything of value to any
public official in the U.S. or any foreign country to influence any official
act, or to cause an official to commit or omit any act in violation of his or
her lawful duty. Company employees are expected to comply with these laws.

11.  VENDORS, CONTRACTORS, CONSULTANTS AND TEMPORARY WORKERS.

Vendors, contractors, consultants or temporary workers who are acting on the
Company's behalf, or on Company property, are expected to follow the law,
Company policies and honor Company Values. Violations will subject the person or
firm to sanctions up to and including loss of the contract, contracting or
consulting agreement, or discharge from temporary assignment.

12.  CONCLUSION.

This Code of Ethics is not intended to cover every possible situation in which
you may find yourself. It is meant to give you the boundaries within which the
Company expects you to conduct yourself while representing GREEN IRONS HOLDINGS
CORP. You may find yourself in a situation where there is no clear guidance
given by this Code of Ethics. If that occurs, return to the foundations stated
earlier: common sense, good judgment, high ethical standards and integrity. And
refer to the Company's Values. In addition, there are many resources upon which
you may rely: your management chain, Human Resources, Legal or other GREEN IRONS
HOLDINGS CORP. departments, and the CEO. Together we can continue to make GREEN
IRONS HOLDINGS CORP. a company that sets a standard for managing high-tech
companies.


_____________________________________
Employee


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                           GREEN IRONS HOLDINGS CORP.

                                     VALUES

FOCUS We exist only because we are involved in accounts receivable management.

RESPECT We value all people, treating them with dignity at all times.

EXCELLENCE We strive for "Best in Class" in everything we do.

ACCOUNTABILITY We do what we say we will do and expect the same from others.

TEAMWORK We believe that cooperative action produces superior results.

INTEGRITY We are honest with ourselves, each other, our customers, our partners
and our shareholders

VERY OPEN COMMUNICATION We share information, ask for feedback, acknowledge good
work, and encourage diverse ideas.

ENJOYING OUR WORK We work hard, are rewarded for it, and maintain a good sense
of perspective, humor and enthusiasm.


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REPORTABLE VIOLATIONS - ANONYMOUS REPORTING PROGRAM

Accounting Error
Accounting Omissions
Accounting Misrepresentations
Auditing Matters
Compliance/Regulation Violations
Corporate Scandal
Domestic Violence
Discrimination
Embezzlement
Environmental Damage
Ethics Violation
Fraud
Harassment
Industrial Accidents
Misconduct
Mistreatment
Poor Customer Service
Poor Housekeeping
Sabotage
Securities
Violation
Sexual Harassment
Substance Abuse
Theft
Threat of Violence
Unfair Labor Practice
Unsafe Working Conditions
Vandalism
Waste Waste of Time and Resources
Workplace Violence

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