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                                                                    EXHIBIT 14.1
                       CODE OF BUSINESS CONDUCT AND ETHICS

1. LEGAL COMPLIANCE

All employees, officers, and directors of Triple-S Management Corporation and
those of its subsidiaries, ("the Corporation") should respect and comply with
all laws, rules, and regulations of the Commonwealth of Puerto Rico as well as
those of the Federal, state and municipal jurisdictions.

Such legal compliance should include, without limitation, strict observance with
the "insider trading" prohibiting transactions made based on confidential or
non-public information from or about the Company. This restriction involves
revealing or sharing said information with others. Corporate employees,
officers, and directors are encouraged to seek information at the Triple-S
Management Corporation's Corporate Affairs Office if they have any question
regarding the application of the aforesaid prohibition.

This Code of Business Conduct and Ethics does not summarize all the laws, rules
and regulations applicable to the Corporation and its employees, officers, and
directors. If any question arises or for additional information, please consult
with the Corporate Affairs Office (or Legal Compliance Office) and the various
guidelines, which the Corporation has prepared on specific laws, rules and
regulations.

2. CONFLICTS OF INTEREST

All employees, officers, and directors of the Corporation must be scrupulous in
avoiding a conflict of interests in regard to the Corporation's interests. A
"conflict of interest" exists whenever an individual's private interests
interfere or diverge in any way (or even appear to interfere or diverge) with
those of the Corporation. A conflictive situation can arise when employees,
officers, or directors undertake some action or have interests that affect the
objective and effective performance of their duties in the Corporation. Another
possible conflict could emerge upon an employee, officer, or director, or some
member of their family, receiving improper personal benefits as a result of
their position in the Corporation, whether the benefit is received from the
Corporation or from a third party.

Loans to, or guarantees of obligations of, employees, officers, and directors,
and their respective family members could possibly create a conflict of
interest. Federal law prohibits loans to directors and executive officers.
Conflicts of interest are prohibited as a matter of corporate policy.

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Such conflicts may not always be clear-cut; therefore, any question should be
consulted with the highest managerial levels or with the Corporate Affairs
Office, where the legal compliance office is ascribed. Any employee, officer, or
director that notices a conflict or a potential conflict should inform a
supervisor, manager, or consult the procedures described in this code.

3. CORPORATE OPPORTUNITY

Employees, officers, and directors are prohibited from:

      a)    Making personal use of opportunities that in truth belong to the
            Corporation, or which are discovered through corporate property,
            information, or position;

      b)    Using corporate property, information or position for personal
            benefit;

      c)    Competing with the Corporation.

Employees, officers, and directors are under the obligation to promote the
Corporation's legitimate interests when the opportunity to do so arises.

4. CONFIDENTIALITY

Employees, officers, and directors should not disclose confidential information
entrusted to them by the Corporation, its suppliers, clients, or any other
person, except when disclosure is authorized by the Legal Compliance Office or
required by law, regulations or legal proceedings. If an employee, officer, or
director understands there is a legal obligation to disclose such information,
they must consult with the Legal Compliance Office. Confidential information
includes all non-public information which could be strategically useful to the
Corporation's competition, or harmful to the Corporation or its clients if it
were divulged.

5. FAIR DEALING

Every employee, officer, and director should endeavor to deal fairly with the
Corporation's clients, suppliers, competitors, officers and directors in a fair
manner. No one should take unfair advantage of any of the above-mentioned
through manipulation, cover-up, concealment, the abuse of privileged
information, fraudulent representation of material facts, or any other unfair
business practice.

6. PROTECTION AND PROPER USE OF THE CORPORATION'S ASSETS

All employees, officers, and directors must protect the Corporation's assets and
ensure their efficient use. Theft, carelessness, waste and alterations, all have
a

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direct impact on the Corporation's assets. All of the Corporation's assets must
be used for legitimate business purposes.

7. ACCOUNTING COMPLAINTS

It is corporate policy to comply with all rules and regulations regarding
financial and accounting reports that apply to the Corporation. If any of the
Corporation's employees, officers, and directors have any concerns or complaints
regarding questionable Corporate accounting or auditing practices, the person
should submit those concerns or complaints (anonymously or confidentially if
desired) to the Audit Committee of the Board of Directors or any member of the
Committee.

8. INFORMING OF ANY ILLEGAL OR UNETHICAL BEHAVIOR

Employees are encouraged to speak to their supervisor, manager or other
appropriate officer regarding any illegal or unethical behavior observed or upon
questions about the best course of action to follow regarding a particular
situation whose legal or ethical nature is unclear. Employees, officers, and
directors concerned about violations to this Code or that other illegal or
unethical conducts have occurred or may occur should contact their supervisors
or superiors. If informing the supervisors or superiors about their concerns or
complaints is an inappropriate or uncomfortable option, they may contact the
Legal Compliance Office, the Nomination and Compensation Committee, the Audit
Committee, or the Triple-S Management Corporation's Board of Directors. If the
concerns or complaints require confidentiality, including maintaining the
informant's identity anonymous, this confidentiality will be protected, subject
to applicable laws, regulations and/or legal proceedings that apply.

All of the Corporation's legal advisors should inform the Corporate Affairs
Office and the Audit Committee regarding any violation to the Securities and
Exchange Commission Regulations. Any other lack of compliance with fiduciary
obligations or other similar obligations to the Corporation or its agents should
be informed to the Vice-President of Legal Affairs in the Corporate Affairs
Office. If he/she does not act upon the evidence presented (adopting, as
necessary, the corresponding preventive measures or sanctions), the legal
advisor could present said evidence to the Main Executive Officer or to the
Corporation's Board of Directors' Audit Committee.

The Corporation will not allow any retaliation from or on behalf of the
Corporation or its employees, officers, and directors because of reports or
complaints, made in good faith, of violations to this Code or of any other
unethical or illegal behavior.

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9. REPORT FROM LISTED CORPORATIONS

As a Corporation listed in the Securities and Exchange Commission (SEC), it is
important that reports submitted to the SEC be accurate and on time. Depending
on their position with the Corporation, employees, officers, and directors may
be called upon to provide necessary information in order to ensure that the
Corporation's public reports are complete, fair, and understandable. The
Corporation expects its employees, officers, and directors to take this
responsibility very seriously, providing correct and rapid responses to
questions regarding the Corporation's public disclosure requirements.

10. AMENDMENTS, MODIFICATIONS AND WAIVER

This Code may be amended, modified or suspended by the Board of Directors, who
can also grant suspensions or waivers, subject to disclosure and other
provisions of the Securities and Exchange Act of 1934, its rules, and the rules
that apply to the New York Stock Exchange.