Exhibit 14


                        JAVA EXPRESS INC.
                          CODE OF ETHICS

Introduction

     This Code of Ethics (the "Code") embodies the commitment of Java Express,
Inc. to conduct our business in accordance with all applicable laws, rules and
regulations and the highest ethical standards.  All Senior Financial Officers
(as hereinafter defined) are expected to adhere to the principles and
procedures set forth in this Code.  For purposes of Section 406 of the
Sarbanes-Oxley Act of 2002 and the rules promulgated there under, this Code
shall be our code of ethics for our principal executive officer, principal
financial officer, principal accounting officer or controller, or persons
performing similar functions  (collectively,  "Senior Financial Officers").
This Code is separate and apart from, and in addition to, any policies our
company may have in effect, from time to time, relating to our employees,
officers and Board of Directors.

A.   Code Compliance and Reporting

     Our Senior Financial Officers should strive to identify and raise
potential issues before they lead to problems, and should ask about the
application of this Code whenever in doubt. Any Senior Financial Officer who
becomes aware of any existing or potential violation of this Code should
promptly notify the Audit Committee of our Board of Directors. We will take
such disciplinary or preventive action, as we deem appropriate to address any
existing or potential violation of this Code brought to our attention.

B.   Personal Conflicts of Interest

     A "personal conflict of interest" occurs when an individual's private
interest improperly interferes with the interests of the Company. Personal
conflicts of interest, whether actual or apparent, are prohibited as a matter
of company policy, unless they have been approved or waived by the company. In
particular, a Senior Financial Officer must never use or attempt to use his or
her position at the Company to obtain any improper personal benefit for
himself or herself, for his or her family members, or for any other person,
including loans or guarantees of obligations, from any person or entity.

C.   Public Disclosure

     It is Company policy that the information in our public communications,
including our filings made with the United States Securities and Exchange
Commission, be full, fair, accurate, timely and understandable. Our Senior
Financial Officers, who are involved in the company's disclosure process, are
responsible for acting in furtherance of this policy. In particular, these
individuals are required to maintain familiarity with the disclosure
requirements applicable to the company and are prohibited from knowingly
misrepresenting, omitting, or causing others to misrepresent or omit, material
facts about the company to others, whether within or outside the Company,
including the company's independent auditors.

D.   Compliance with Laws, Rules and Regulations

     It is Company policy to comply with all applicable laws, rules and
regulations. It is the personal responsibility of each Senior Financial
Officer to adhere to the standards and restrictions imposed by those laws,
rules and regulations.

     Generally, it is both illegal and against company policy for any Senior
Financial Officer who is aware of material nonpublic information relating to
the Company, to buy or sell securities or recommend that another person buy,
sell or hold the securities of the Company.

E.   Amendment, Modification and Waiver

     This Code may be amended or modified by the Board of Directors. Waivers
of this Code may only be granted by the Board of Directors or a committee of
the Board with specific delegated authority. Waivers will be disclosed as
required by the Securities Exchange Act of 1934, as amended, and the rules
promulgated there under and any applicable rules relating to the maintenance
of the listing of our securities on any stock exchange.