**Exhibit 14.1**

 

**UNITED WISCONSIN GRAIN PRODUCERS, L.L.C.**

# **CODE OF ETHICS FORCHIEF EXECUTIVE AND SENIOR FINANCIAL OFFICERS**

 

We are honest and ethical in all of our business dealings and the Codeof Ethics for Chief Executive and Senior Financial Officers (the “Code ofEthics”) embodies principles to which we are expected to adhere andadvocate.  We have adopted the followingCode of Ethics specifically for our Chief Executive and senior financialofficers.  Any violations of the Code ofEthics may result in disciplinary action, up to and including termination ofemployment.

 

1.     Youare responsible for full, fair, accurate, timely and understandable financialdisclosure in reports and documents filed by the Company with the Securitiesand Exchange Commission and in other public communications made by theCompany.  The Company’s accountingrecords must be maintained in accordance with all applicable laws, must beproper, supported, and classified, and must not contain any false or misleadingentries.

 

2.     Youare responsible for the Company’s system of internal financial controls.  You shall promptly bring to the attention ofWilliam Hanigan at Brown, Winick, Graves, Gross, Baskerville, and Schoenebaum,P.L.C. (the “Company’s Legal Counsel”) and the Audit Committee any informationyou may have concerning (a) significant deficiencies in the design or operationof internal controls which could adversely affect the Company’s ability torecord, process, summarize, and report financial data, or (b) any fraud,whether or not material, that involves management or other employees who have asignificant role in the Company’s financial reporting, disclosures, or internalcontrols.

 

3.     Youmust act honestly and ethically.  Youmay not compete with the Company and may never let business dealings on behalfof the Company be influenced – or even appear to be influenced – by personal orfamily interests.  You shall promptlybring to the attention of the Company’s Legal Counsel and the Audit Committeeany information you may have concerning any actual or apparent conflicts ofinterest between personal and professional relationships, involving anymanagement or other employees who have a significant role in the Company’sfinancial reporting, disclosures, or internal controls.

 

4.     TheCompany is committed to complying with both the letter and the spirit of allapplicable laws, rules, and regulations. You shall promptly bring to the attention of the Company’s legal counseland the Audit Committee any information you may have concerning evidence of amaterial violation of the securities or other laws, rules, or regulationsapplicable to the Company or its employees or agents.  You shall promptly bring to the attention of the Company’s LegalCounsel and Audit Committee any information you may have concerning anyviolation of this Code of Ethics.  TheBoard of Directors may determine, or designate appropriate persons todetermine, appropriate additional disciplinary or other actions to be taken inthe event of violations of this Code of Ethics by the Company’s Chief Executiveor senior financial officers and a procedure for granting any waivers of thisCode of Ethics.

 

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5.     TheCompany will not retaliate against a director, officer or employee who providesinformation to the federal government or a supervisor or testifies about anymatter than an employee reasonably believes constitutes a violation of federalsecurities law or any provision of federal law relating to fraud againstshareholders.

 

 

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