Exhibit 14.1
 OMNI BIO PHARMACEUTICAL, INC.
 CODE OF BUSINESS CONDUCT AND ETHICS
 Adopted by the Board of Directors
on March 10, 2010
 Introduction
   If you are in a situation which you believe may violate or
lead to a violation of this Code, follow the guidelines described in Section 16 of this Code
 1. Compliance with Laws, Rules and Regulations
   2. Conflicts of Interest




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3. Insider Trading
  4. Corporate Opportunities
  5. Competition and Fair Dealing
    2




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6. Discrimination and Harassment
  7. Health and Safety
   8. Record-Keeping
      3




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9. Confidentiality
  10. Protection and Proper Use of Company Assets
   11. Payments to Government Personnel
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12. Responsibilities of Senior Financial Management
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    Act honestly and ethically in the performance of their duties at the
Company.
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    Avoid actual or apparent conflicts of interest between personal and
professional relationships.
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    Provide full, fair, accurate, timely and understandable disclosure in
reports and documents that the Company files with, or submits to, the SEC and
in other public communications by the Company.
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    Comply with rules and regulations of federal, state and local governments
and other private and public regulatory agencies that affect the conduct of the
Companys business and the Companys financial reporting.
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    Act in good faith, responsibly, with due care, competence and diligence,
without misrepresenting material facts or allowing the members independent
judgment to be subordinated.
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    Respect the confidentiality of information acquired in the course of work,
except when authorized or legally obligated to disclose such information.
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    Share knowledge and maintain skills relevant to carrying out the members
duties within the Company.
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    Proactively promote ethical behavior as a responsible partner among peers
and colleagues in the work environment and community.
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
    
    Achieve responsible use of and control over all assets and resources of the
Company entrusted to the member.
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    Promptly bring to the attention of the Chief Executive Officer any
information concerning (a) significant deficiencies in the design or operation
of internal controls which could adversely affect the Companys ability to
record, process, summarize and report financial data or (b) any fraud, whether
or not material, that involves management or other employees who have a
significant role in the Companys financial reporting, disclosures or internal
controls.
 13. Waivers of the Code of Business Conduct and Ethics
  14. Reporting any Illegal or Unethical Behavior
  15. Complaint Procedures for Financial, Accounting and Audit Matters
    6




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Investigation and Response
  Confidentiality and Non-retaliation
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16. Compliance Procedures
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    Make sure you have all the facts. In order to reach the right
solutions, we must be as fully informed as possible.
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    Ask yourself: What specifically am I being asked to do? Does it seem
unethical or improper? This will enable you to focus on the specific
question you are faced with, and the alternatives you have. Use your judgment
and common sense; if something seems unethical or improper, it probably is.
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    Clarify your responsibility and role. In most situations, there is
shared responsibility. Are your colleagues informed? It may help to get
others involved and discuss the problem.
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    Discuss the problem with your supervisor. This is the basic
guidance for all situations. In many cases, your supervisor will be more
knowledgeable about the question, and will appreciate being brought into the
decision-making process. Remember that it is your supervisors responsibility
to help solve problems.
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    Seek help from Company resources. In the rare case where it may not
be appropriate to discuss an issue with your supervisor or where you do not
feel comfortable approaching your supervisor with your question, discuss it
locally with your office manager or your Human Resources manager.
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    You may report ethical violations in confidence and without fear of
retaliation. If your situation requires that your identity be kept secret,
your anonymity will be protected. The Company does not permit retaliation of
any kind against employees for good faith reports of ethical violations.
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    Always ask first, act later: If you are unsure of what to do in any
situation, seek guidance before you act.
  8