EXHIBIT 14.1
**CODE OF ETHICS**
This Code of Ethics (the “Code”) has been adopted by the Board of Directors ofSina Corporation (the “Company”). Pursuant to the Sarbanes-Oxley Act of 2002,and the rules of the SEC and the Nasdaq Stock Market, this Code containsstandards for the ethical handling of actual or apparent conflicts of interestbetween personal and professional relationships; compliance with applicablelaws, and accurate and timely public disclosure. It is applicable to allemployees, officer and directors of the Company.
This Code does not summarize all laws, rules, regulations, and Company policieswhich may be applicable to the Company and its employees, officers anddirectors. Please refer to the Company’s Code of Conduct and other guidelinesand policies for information on matters not addressed in this Code.
The Company has designated the General Counsel as Compliance Officer toadminister this Code. You may, at your discretion, make any report orcomplaint provided for in this Code to the Compliance Officer. The ComplianceOfficer will refer complaints submitted, as appropriate, to the Board ofDirectors or an appropriate Committee of the Board.
**1. Conflicts Of Interest**
While it is not possible to identify every activity that might give rise to aconflict of interest, a conflict of interest may exist whenever a relationshipof an employee, officer or director, or one of their family members, isinconsistent with the Company’s best interests or could cause a conflict withjob responsibilities.
Conflicts of interest may not always be clear-cut, so if you have a question,you should consult with your immediate supervisor or the Compliance Officer.If you become aware of a conflict or potential conflict, you should bring it tothe attention of your immediate supervisor or the Compliance Officer.
**2. Compliance With Applicable Laws**
All employees, officers and directors of the Company should comply with allgovernmental laws, rules and regulations applicable to the Company.
**3. Public Company Reporting**
As a public company, it is of critical importance that the Company’s filingswith the SEC, and other public communications, contain full, fair, accurate,timely and understandable disclosure. Depending on their respective positionswith the Company, employees, officers or directors may be called upon toprovide information necessary to assure that the Company’s public reports arecomplete, fair and understandable. The Company expects employees, officers anddirectors to take this responsibility seriously and to provide prompt andaccurate answers to inquiries related to the Company’s public disclosurerequirements.
 

 

**4. Reporting Any Illegal Or Unethical Behavior**
Employees are encouraged to talk to supervisors, managers or other appropriatepersonnel about observed illegal or unethical behavior and, when in doubt,about the best course of action in a particular situation. Anyone who believesthat a violation of this Code or other illegal or unethical conduct by anyemployee, officers or director has occurred or may occur should promptlycontact a supervisor, a corporate officer, or the Compliance Officer. Suchreports may be made confidentially or anonymously. Confidentiality will beprotected, subject to applicable law, regulation or legal proceedings.
**5. No Retaliation**
The Company will not permit retaliation of any kind by or on behalf of theCompany and its employees, officers and directors against good faith reports orcomplaints of violations of this Code or other illegal or unethical conduct.
**6. Amendment, Modification And Waiver**
Any request for a waiver of any provision of this Code must be in writing andaddressed to the Compliance Officer. If you are a director or executiveofficer of the Company, the request may be addressed directly to the Chairmanof the Audit Committee.
With regard to executive officers and directors, the Board will have the soleand absolute discretionary authority, to approve any waiver from this Code. Anywaiver of the Code with respect to executive officers and directors will bepromptly publicly disclosed to shareholders, together with the reason to thewaiver by a method selected by the Board of Directors in conformity withapplicable SEC and Nasdaq rules.
This Code may be amended, modified or waived by the Board of Directors, subjectto disclosure requirements and other applicable SEC and Nasdaq rules.
**7. Accountability**
You will be held accountable for your adherence to this Code. If you are anemployee, your failure to observe the terms of this Code may result indisciplinary action, up to and including immediate termination of employment.