**Exhibit
      14.1**




**ROYAL
      EQUINE ALLIANCE CORPORATION**


**FINANCIAL
      CODE OF ETHICS**





As
      a
      public company, it is of critical importance that ROYAL EQUINE ALLIANCE
      CORPORATION (ROYAL EQUINE) filings with the Securities and Exchange Commission
      be accurate and timely. Depending on their position with ROYAL EQUINE, employees
      may be called upon to provide information to assure that ROYAL EQUINE's public
      reports are complete, fair, and understandable. ROYAL EQUINE expects all of
      its
      employees to take this responsibility seriously and to provide prompt and
      accurate answers to inquiries related to ROYAL EQUINE's public disclosure
      requirements.




ROYAL
      EQUINE's Finance Department bears a special responsibility for promoting
      integrity throughout ROYAL EQUINE, with responsibilities to stakeholders both
      inside and outside of ROYAL EQUINE. The Chief Executive Officer (CEO), Chief
      Financial Officer (CFO), and Finance Department personnel have a special role
      both to adhere to the principles of integrity and also to ensure that a culture
      exists throughout ROYAL EQUINE as a whole that ensures the fair and timely
      reporting of ROYAL EQUINE's financial results and conditions. Because of this
      special role, the CEO, CFO, and all members of ROYAL EQUINE's Finance Department
      are bound by ROYAL EQUINE's Financial Code of Ethics, and by accepting the
      Financial Code of Ethics, each agrees that they will:




-
      Act
      with honesty and integrity, avoiding actual or Royal Equine conflicts of
      interest in personal and professional relationships.




-
      Provide
      information that is accurate, complete, objective, relevant, timely and
      understandable to ensure full, fair, accurate, timely, and understandable
      disclosure in the reports and documents that ROYAL EQUINE files with, or submits
      to, government agencies and in other public communications.




-
      Comply
      with the rules and regulations of federal, state and local governments, and
      other appropriate private and public regulatory agencies.




-
      Act in
      good faith, responsibly, with due care, competence and diligence, without
      misrepresenting material facts or allowing one's independent judgment to be
      subordinated.




-
      Respect
      the confidentiality of information acquired in the course of one's work, except
      when authorized or otherwise legally obligated to disclose. Confidential
      information acquired in the course of one's work will not be used for personal
      advantage.




-
      Share
      job knowledge and maintain skills important and relevant to stakeholders needs.




-
      Proactively promote and be an example of ethical behavior as a responsible
      partner among peers, in the work environment and in the community.




-
      Achieve
      responsible use of, and control over, all ROYAL EQUINE assets and resources
      employed by, or entrusted to yourself, and your department.




-
      Receive
      the full and active support and cooperation of ROYAL EQUINE's Officers, Sr.
      Staff, and all employees in the adherence to this Financial Code of Ethics.




-
      Promptly report to the CEO or CFO any conduct believed to be in violation of
      law
      or business ethics or in violation of any provision of this Code of Ethics,
      including any transaction or relationship that reasonably could be expected
      to
      give rise to such a conflict. Further, to promptly report to the Chair of ROYAL
      EQUINE's Audit Committee or the Board of Directors prior to the formation of
      the
      Audit Committee, such conduct if by the CEO or CFO or if they fail to correct
      such conduct by others in a reasonable period of time.