GLOBAL GOLD CORPORATION
                       CODE OF BUSINESS CONDUCT AND ETHICS

                  This Code of Business Conduct and Ethics (this "Code")
consists of three parts: Business Ethics, Legal Compliance and Making It Work.
This Code is not intended to cover every applicable law, address all possible
business dealings or potential dilemmas, nor does it provide answers to all
questions that may arise in connection with the issues raised.

Business Ethics

>>       General Standards. The Company is committed to operating with the
         highest ethical principles guiding our business philosophy and personal
         business behavior at all times. All employees, officers and directors
         are expected to behave honestly and with integrity at all times,
         whether in dealing with fellow employees, the general public, the
         business community, civic organizations, stockholders, customers,
         suppliers, or governmental and regulatory authorities.

>>       Books and Records and Internal Controls. The accuracy and reliability
         of the Company's business records are critical to the Company's
         business decisions and compliance with the Company's financial and
         legal reporting requirements. Employees, officers and directors shall
         be familiar with and follow the Company's policies, accounting controls
         and procedures. Applicable laws and Company policy require the Company
         to keep books and records that accurately and fairly reflect its
         transactions and the dispositions of its assets and to maintain a
         system of internal accounting controls which ensure the reliability and
         adequacy of its books and records. No employee, officer or director is
         authorized to depart from this requirement or to condone a departure by
         anyone else.

>>       Alteration of Documents. There will be times when destruction of
         documents no longer needed for business or legal purposes may be a
         perfectly legitimate exercise of a proper business decision (i.e., for
         reasons of cost, logistics, space, etc.). However, the knowing
         destruction, alteration, concealment, or falsification of paper or
         electronic documents with the intent to impede, obstruct, or wrongly
         influence official investigations or proceedings is not only unethical,
         it is a crime punishable by fines and imprisonment of up to 20 years.
         Employees, officers and directors must cooperate with duly constituted
         official investigations that are conducted by both sides in a legally
         correct fashion.

>>       Business Communications. At all times, the Company shall promote full,
         fair, accurate, timely and understandable disclosures in every report
         and public communication made by the Company, which includes, of
         course, any document that it files with or submits to the Securities
         and Exchange Commission (the "SEC"). Employees, officers and directors
         are required to comply with these standards in the preparation of any
         disclosure or communication of the Company. Good judgment must be used
         when writing about our Company and its business. Written business
         records may be subject to compulsory disclosure to the government or
         private parties in litigation, or may be wrongly leaked to or
         interpreted by the news media.

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>>       Conflict of Interest. Company business must be conducted solely on the
         basis of merit and open competition. Employees, officers and directors
         must refrain from actions that might impair their independent judgment
         or provide unfair advantage to another, or might represent a conflict
         of interest. A "conflict of interest" occurs when an individual's
         private interest interferes in any way, or even appears to interfere in
         any way, with the interests of the Company as a whole. A conflict
         situation can arise when an employee, officer or director takes actions
         or has interests that may make it difficult to perform his or her work
         for the Company in an objective and effective fashion. Conflicts of
         interest also arise when an employee, officer or director, or a member
         of his or her family, receives improper personal benefits as a result
         of his or her position in the Company. Personal loans to, or guarantees
         of obligations of, such persons are of special concern. Personal loans
         to officers and directors are not only unethical but also illegal.

>>       Confidential Information. Employees, officers and directors should
         maintain the confidentiality of information entrusted to them by the
         Company or other companies or persons, except when disclosure is duly
         authorized or legally mandated. Confidential information includes
         various kinds of information, including internal, confidential,
         proprietary or secret information related to the Company's business,
         operations and research. It includes trade secrets (such as our
         technology, know-how and experience) and in general all non-public
         information that might be of use to competitors, or harmful to the
         Company or its customers if disclosed. Selected human resource and
         personnel information must be kept strictly confidential and used only
         for the purposes for which it is intended. Confidential information
         also includes information entrusted to the Company by other companies
         or persons, such as customers, suppliers, vendors or service-providers.
         The obligation to preserve confidential information continues even
         after association with the Company ends.

>>       Corporate Opportunities. Employees, officers and directors owe a duty
         to the Company to advance its legitimate interests when the opportunity
         to do so arises. Employees, officers and directors should not: (i) take
         for themselves personally opportunities that are discovered through the
         use of Company property, information or position (ii) use Company
         property, information or position for personal gain or (iii) compete
         with the Company.

>>       Fair Dealing. Employees, officers and directors should endeavor to deal
         fairly with the Company's customers, suppliers, competitors and
         employees. No employee, officer or director should take unfair
         advantage of anyone through manipulation, concealment, abuse of
         privileged information, misrepresentation of material facts or any
         other unfair-dealing practice.

>>       Protection and Proper Use of Company Assets. Carelessness, misuse,
         waste, destruction or theft has a direct impact on the Company's
         profitability. Employees, officers and directors should safeguard the
         Company's assets and ensure their efficient use. All Company assets
         should be used only for legitimate business purposes.

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Legal Compliance

>>       General Standard.  The Company requires compliance with all applicable
         laws, rules and regulations, as well as compliance with this Code.

>>       Discrimination and Harassment. The Company's legal compliance
         requirement includes all federal and state regulations prohibiting
         discrimination against any employee or applicant for employment because
         of race, color, religion, ethnic or national origin, gender, sexual
         orientation, age, disability or veteran status. This applies to
         recruitment, compensation, training, promotion and other employment
         practices. The Company is also committed to providing its employees
         with a work environment free of any type of harassment, including any
         deliberate discrimination or harassment, in word or action, against a
         fellow employee or applicant for employment on the basis of any of the
         classifications above.

>>       Fraud. The Company's legal compliance requirement includes all laws
         related to wire fraud, mail fraud, bank fraud, securities fraud, any
         SEC rule or regulation, or any federal rules relating to fraud against
         shareholders.

>>       Securities Laws and Insider Trading. The Company's stock is owned and
         traded by the general public, and for this reason various laws require
         the Company to make full, fair, accurate, timely and understandable
         disclosure of material information. It is the Company's goal to protect
         all shareholder investments in our Company through strict enforcement
         of the prohibition against insider trading set forth in federal
         securities laws and regulations. Employees, officers and directors who
         have access to inside information are not permitted to use or share
         that information for stock trading purposes or for any other purpose
         except to conduct Company business. Inside information includes any
         financial, technical or other information about the Company that is not
         available to the public and might influence an investor's decision to
         buy, sell or hold stock of the Company. To use inside information for
         personal financial benefit or to "tip" others who might make an
         investment decision on the basis of this information is not only
         unethical but also illegal.

>>       Bribes, Kickbacks, and Other Unlawful Payments. The Company's legal
         compliance requirement includes the U.S. Foreign Corrupt Practices Act,
         international anti-bribery conventions and any state or local
         anti-corruption or bribery laws. No payment to government officials,
         bribes, kickbacks or other similar unlawful payments designed to secure
         favored or preferential treatment for or from the Company or any
         individual associated with the Company is to be given or received.

>>       International Operations Policy. The Company's legal compliance
         includes all governmental laws, rules, and regulations applicable to
         its operation s outside the United States and to conduct those
         operations to the highest ethical standards. Where feasible, locally
         sourced engineering work, construction crews, and supplies will be
         preferentially used. Laws that apply to operations outside the United
         States include those of the countries where the operations occur, and
         may also include certain United States laws which govern international
         operations of United States companies and United States persons,
         broadly defined. Accordingly, directors, officers, and employees of the
         Company who are involved with the Company's operations outside the
         United States should consult with the General Counsel for advice on
         applicable United States laws, especially laws regarding boycotts,
         trade sanctions, export controls, and foreign corrupt practices, and
         are expected to comply with those laws.

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>>       Environmental Policy. The Company's legal compliance requires that the
         Company conduct its business in a manner that is compatible with the
         balanced environmental and economic needs of the communities in which
         it operates. The Company is committed to continuous efforts to improve
         environmental performance throughout its operations. Accordingly, the
         Company's policy is to: comply with international standards as
         developed by the World Bank; comply with all applicable environmental
         laws and regulations and apply responsible standards where laws and
         regulations do not exist; assess all projects which will include a
         review of the environmental issues associated with project development.
         This assessment will be made available to the appropriate government
         agencies for review and approval; encourage concern and respect for the
         environment, emphasize every employee's responsibility in environmental
         performance, and foster appropriate operating practices and training;
         manage its business with the goal of preventing incidents and of
         controlling emissions and wastes to below harmful levels; design,
         operate, and maintain facilities to this end; respond quickly and
         effectively to incidents resulting from its operations, in cooperation
         with industry organizations and authorized government agencies; and
         undertake appropriate reviews and evaluations of its operations to
         measure progress and to foster compliance with this policy.

Making It Work

>>       Compliance and Reporting Required. Employees, officers and directors
         are required to report or cause to be reported, on a named or anonymous
         basis, any act or practice or other information which may constitute a
         violation of law, rules, regulations or this Code (or may otherwise be
         considered unethical) to their immediate supervisor, personnel manager,
         or facility director. However, any employee, officer or director who
         suspects questionable accounting, internal control or auditing, or has
         any information to report on an issue described in this Code under the
         headings "Business Communications" or "Fraud" above, must make a report
         directly to the Chairman of the Audit Committee of the Board of
         Directors in accordance with the procedures set forth below. Any
         employee, officer or director who has any questions related to an
         interpretation of any part of this Code is encouraged to contact the
         General Counsel. There is no right to privacy through the use of the
         Company's telephone, e-mail, Internet and computers. However, the
         Company will make every effort to respect your anonymity if you choose
         to use the procedures for anonymous reporting set forth below. In any
         event, the Company cannot guarantee the eventual anonymity or
         confidentiality of a person making a report, as more fully described
         below.

>>       Procedure for Anonymous Reports to Supervisors, Etc. or the General
         Counsel. The procedure for anonymous reporting of complaints to the
         applicable immediate supervisor, personnel manager, facility director
         or the General Counsel of the Company is for information to be sent by
         any of the following means: (i) using non-Company telephones, by
         immediately faxing a letter to the applicable individual at his or her
         office number, (ii) using non-Company telephones, by calling the
         applicable individual at his or her office number, (iii) using
         non-Company computers, by e-mailing the applicable individual at his or
         her work e-mail address, or (iv) using non-Company mail facilities, by
         sending a letter to the applicable individual at his or her work
         address.

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>>       Procedure for Reports to Audit Committee. The procedure for anonymous
         reporting of complaints to the Audit Committee is for information to be
         sent directly to the Audit Committee, which is composed entirely of
         independent outside directors, by any of the following means: (i) using
         non-Company telephones, by immediately faxing information to the
         Chairman of the Audit Committee concerning any such complaint at
         212-941-1041, attn: Mr. Nicholas Aynilian (ii) using non-Company
         telephones, by calling the Chairman of the Audit Committee at
         212-431-9785 (please leave a message if your call is not immediately
         answered), (iii) using non-Company computers, by e-mailing the Chairman
         of the Audit Committee at Nick@Aynilian.com, or (iv) using non-Company
         mail facilities, by sending a letter to Nicholas J. Aynilian, Chairman,
         Audit Committee of the Board of Directors of Global Gold Corporation,
         104 Field Point Road, Greenwich Connecticut 06830. The procedure for
         named reporting of complaints to the Audit Committee is the same,
         except that Company telephones, computers or mail facilities may be
         used. Such reporting mechanisms are available 24 hours a day, 7 days a
         week. All reasonable and appropriate expenses incurred by any employee,
         officer or director in making a report to the Audit Committee in
         accordance with this Code will be reimbursed at any time upon request.

>>       Full Information. It will be helpful to the Company's investigation of
         any such suspected violations if your communication is as specific as
         possible with regard to: (i) the nature of the suspected conduct, (ii)
         the persons involved or who may have knowledge of it, (iii) the dates
         upon which such suspected activity occurred, (iv) where it allegedly
         took place, (v) why you believe this conduct to be unethical, irregular
         or fraudulent and (vi) how such suspected conduct has allegedly
         occurred or is presently occurring.

>>       No Guarantee of Anonymity or Confidentiality. The Company shall always
         try to maintain the anonymity and confidentiality of the reports and of
         those furnishing the information. The Company cannot, however,
         guarantee the eventual anonymity or confidentiality of any complaint in
         the event that an effective investigation requires otherwise.

>>       No Retaliation. In no event will any action or retaliation be taken
         against any employee, officer or director for making a report regarding
         suspected violations of any law, regulation or this Code, or against
         any person who testifies, participates in, or otherwise assists in a
         proceeding filed or about to be filed that relates to any such
         violation. Employees, officers and directors should immediately report
         to the Chairman of the Audit Committee, in the manner as set forth
         above, any irregular situation regarding this issue.

>>       Application of this Code; Disciplinary Measures. All reports will be
         investigated and appropriate actions will be taken. The Company shall
         continuously enforce this Code through appropriate means of discipline.
         In instances where the proper and ethical course of action is unclear,
         employees, officers and directors should seek counsel from their
         immediate supervisor, personnel manager, facility director or the
         General Counsel. If necessary, the applicable immediate supervisor,
         personnel manager, facility director, the General Counsel or the Audit
         Committee, as appropriate, shall determine whether violations of law or
         this Code have occurred and, if so, shall determine the measures to be
         taken against the corresponding person. The disciplinary measures shall
         include counseling, oral or written reprimands, warnings, probation or
         suspension without pay, demotions and termination of employment or
         other association with the Company. The Company's General Counsel and
         the Audit Committee, as appropriate, shall respond to questions and
         issues of interpretation of this Code.

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>>       Changes to or Waivers of this Code. Any change to or waiver of this
         Code involving a director or the Company's principal executive officer,
         principal financial officer, principal accounting officer or
         controller, or persons performing similar functions, may be made only
         by the Board of Directors or a committee of the Board of Directors and
         will be promptly disclosed as required by law.

>>       Questions and Comments. If anyone has any questions concerning the
         ethical propriety of any business dealings or other conduct while at
         work, or any suggestions to make regarding this Code, they should feel
         free to consult with their immediate supervisor, personnel manager,
         facility director, the General Counsel or any other officers of the
         Company.

                                   May 4, 2005

































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Distribution:     All Directors
                  All Officers
                  All Employees
                  All Personnel & Human Resource Directors
                  All Managers & Supervisors
                  All Outside Vendors & Suppliers
                  All Providers of Professional Services
                  Company Website

































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