EXHIBIT
14.01




SANDSTON
CORPORATION


SENIOR
FINANCIAL OFFICERS


CODE
OF ETHICS




General
Philosophy


The
honesty, integrity and sound judgment of each director, officer or employee
involved in the Company’s disclosure process, including the Chief Executive
Officer, the Chief Financial Officer, the Chief Accounting Officer and any other
officer serving a similar function (the “Senior Financial Officers”) is
fundamental to the reputation and success of the Company.





Senior
Financial Officers Code of Ethics





To the
best of their knowledge and ability, the Senior Financial Officers of the
Company performing accounting, auditing, financial management or similar
functions must:




·
            Familiarize
      himself or herself with the disclosure requirements applicable to the
      Company as well as the business and financial operations of the
      Company.




·
            Act
      in good faith, with due care, competence and diligence, without
      misrepresenting material facts or allowing independent judgment to be
      subordinated, and not knowingly misrepresent, or cause others to
      misrepresent, facts about the Company to others, whether within or outside
      the Company, including the Company’s independent auditors, government
      regulators and self-regulatory
organizations.




·
            Provide
      colleagues with information that is accurate, complete, objective,
      relevant, timely and understandable, and properly review and critically
      analyze proposed disclosures for accuracy and completeness (or, where
      appropriate, delegate this task to
others).




·
            Promptly
      bring to the attention of the Board of Directors any material information
      of which they become aware that may affect the Company’s disclosures in
      its filings with the Securities and Exchange Commission (the “SEC”) and
      other public regulatory authorities and in its public
      communications.




·
            Act
      with honesty and integrity, and avoid actual or apparent conflicts of
      interest in personal and professional
  relationships.




·
            Comply
      with applicable laws, rules and regulations of federal, state, and local
      governments (both United States and foreign) and other appropriate private
      and public regulatory agencies.




·
            Respect
      the confidentiality of information acquired in the course of
      employment.




·
            Share
      knowledge and maintain skills necessary and relevant to the Company’s
      needs.




·
            Proactively
      promote ethical and honest behavior within the
  Company.







·
            Assure
      responsible use of and control of all assets, resources and information of
      the Company.





All
Senior Financial Officers must be familiar with and must comply with the
Company’s disclosure controls and procedures and internal control over financial
reporting, to the extent relevant to his or her area of responsibility, so that
the Company’s public reports and documents filed with the SEC comply in all
material respects with the applicable federal securities laws and SEC
rules.  In addition, each such person having direct or supervisory
authority regarding these SEC filings or the Company’s other public
communications concerning its general business, results, financial condition and
prospects should, to the extent appropriate within his or her area of
responsibility, consult with the other Company officers and employees and take
other appropriate steps regarding these disclosures with the goal of making
full, fair, accurate, timely and understandable disclosure.





All
Senior Financial Officers will promptly bring to the attention of the Board of
Directors any information they may have regarding (i) significant deficiencies
in the design or operation of the Company’s internal controls or its disclosure
controls and procedures, (ii) any violation of this Code of Ethics, or (iii) any
evidence of a material violation of the securities or other laws applicable to
the Company and its operations by the Company or any agent of the
Company.





All
Senior Financial Officers are expected to adhere to this Code of Ethics for
Senior Financial Officers at all times.





The board
of directors shall have the sole and absolute discretionary authority to approve
any deviation or waiver from this Code of Ethics for Senior Financial
Officers.  Any waiver and the grounds for such waiver for a Senior
Financial Officer shall be promptly disclosed through a filing with the SEC on
Form 8-K. Additionally, any change of this Code of Ethics for Senior Financial
Officers shall be promptly disclosed to the Company’s
securityholders.