EXHIBIT 14
                       Code of Ethics and Business Conduct
                                       for
                        Officers, Directors and Employees
                                       of
                            Bronco Energy Fund, Inc.

1. TREAT IN AN ETHICAL MANNER THOSE TO WHOM THE COMPANY. HAS AN OBLIGATION.

The  officers,  directors  and  employees  of  Bronco  Energy  Fund,  Inc.  (the
"Company") are committed to honesty, just management, fairness, providing a safe
and healthy  environment  free from the fear of retribution,  and respecting the
dignity  due  everyone.  For the  communities  in  which we live and work we are
committed  to  observe  sound  environmental  business  practices  and to act as
concerned and responsible neighbors, reflecting all aspects of good citizenship.

For our  shareholders  we are  committed  to pursuing  sound growth and earnings
objectives and to exercising prudence in the use of our assets and resources.

For our  suppliers  and partners we are  committed to fair  competition  and the
sense of responsibility required of a good customer and teammate.

2. PROMOTE A POSITIVE WORK ENVIRONMENT.

All employees want and deserve a workplace where they feel respected, satisfied,
and appreciated.  We respect cultural diversity and will not tolerate harassment
or  discrimination of any kind -- especially  involving race,  color,  religion,
gender, age, national origin, disability, and veteran or marital status.

Providing an  environment  that supports  honesty,  integrity,  respect,  trust,
responsibility, and citizenship permits us the opportunity to achieve excellence
in our workplace.  While  everyone who works for the Company must  contribute to
the  creation  and  maintenance  of  such an  environment,  our  executives  and
management  personnel  assume  special   responsibility  for  fostering  a  work
environment  that is free from the fear of  retribution  and will  bring out the
best in all of us.  Supervisors  must be careful  in words and  conduct to avoid
placing, or seeming to place,  pressure on subordinates that could cause them to
deviate from acceptable ethical behavior.

3. PROTECT YOURSELF, YOUR FELLOW EMPLOYEES, AND THE WORLD WE LIVE IN.

We are  committed to providing a drug-free,  safe and healthy work  environment,
and to observing  environmentally sound business practices. We will strive, at a
minimum,  to do no harm and where possible,  to make the communities in which we
work a better  place to live.  Each of us is  responsible  for  compliance  with
environmental, health and safety laws and regulations.

4. KEEP ACCURATE AND COMPLETE RECORDS.

We must maintain accurate and complete Company records. Transactions between the
Company  and  outside   individuals  and  organizations  must  be  promptly  and
accurately entered in our books in accordance with generally accepted accounting
practices  and   principles.   No  one  should   rationalize  or  even  consider
misrepresenting  facts or falsifying  records. It will not be tolerated and will
result in disciplinary action.

5. OBEY THE LAW.

We will  conduct  our  business  in  accordance  with  all  applicable  laws and
regulations.  Compliance  with the law  does not  comprise  our  entire  ethical
responsibility.  Rather, it is a. minimum,  absolutely  essential  condition for
performance of our duties. In conducting business, we shall:

a. STRICTLY ADHERE TO ALL ANTITRUST LAWS.

Officer,  directors and employees  must strictly  adhere to all antitrust  laws.
Such laws exist in the  United  States  and in many  other  countries  where the
Company may conduct  business.  These laws  prohibit  practices  in restraint of
trade such as price fixing and boycotting suppliers or customers.  They also bar
pricing   intended  to  run  a   competitor   out  of   business;   disparaging,
misrepresenting, or harassing a competitor; stealing trade secrets; bribery; and
kickbacks.

b. STRICTLY COMPLY WITH ALL SECURITIES LAWS.

In our role as a publicly owned  company,  we must always be alert to and comply
with the security laws and regulations of the United States and other countries.

i. DO NOT ENGAGE IN SPECULATIVE OR INSIDER TRADING.

Federal law and Company  policy  prohibits  officers,  directors and  employees,
directly or indirectly  through  their  families or others,  from  purchasing or
selling   company  stock  while  in  the  possession  of  material,   non-public
information  concerning the Company. This same prohibition applies to trading in
the stock of other publicly held companies on the basis of material,  non-public
information.  To avoid even the appearance of  impropriety,  Company policy also
prohibits  officers,  directors and employees  from trading  options on the open
market in Company stock under any circumstances.

Material,  non-public  information is any information  that could  reasonably be
expected to affect the price of a stock. If an officer,  director or employee is
considering  buying  or  selling a stock  because  of  inside  information  they
possess,  they  should  assume that such  information  is  material.  It is also
important  for the  officer,  director  or  employee to keep in mind that if any
trade they make becomes the subject of an  investigationby  the government,  the
trade will be viewed after-the-fact with the benefit of hindsight. Consequently,
officers,  directors and employees  should always  carefully  consider how their
trades would look from this perspective.

Two simple  rules can help  protect you in this area:  (1) Do not use  nonpublic
information for personal gain. (2) Do not pass along such information to someone
else who has no need to know.

This  guidance also applies to the  securities of other  companies for which you
receive information in the course of your employment at The Company .

ii. BE TIMELY AND ACCURATE IN ALL PUBLIC REPORTS.

As a public company,  the Company must be fair and accurate in all reports filed
with the United States Securities and Exchange Commission.  Officers,  directors
and management of the Company are  responsible for ensuring that all reports are
filed in a timely manner and that they fairly  present the  financial  condition
and operating results of the Company.

Securities  laws are  vigorously  enforced.  Violations  may  result  in  severe
penalties  including forced sales of parts of the business and significant fines
against the Company.  There may also be sanctions against  individual  employees
including substantial fines and prison sentences.

The principal  executive officer and principal financial Officer will certify to
the accuracy of reports filed with the SEC in accordance with the Sarbanes-Oxley
Act of 2002.  Officers and  Directors  who  knowingly  or  willingly  make false
certifications may be subject to criminal penalties or sanctions including fines
and imprisonment.

6. AVOID CONFLICTS OF INTEREST.

Our officers,  directors and employees have an obligation to give their complete
loyalty to the best interests of the Company.  They should avoid any action that
may involve,  or may appear to involve, a conflict of interest with the Company.
Officers,  directors  and  employees  should  not  have any  financial  or other
business  relationships  with  suppliers,  customers or  competitors  that might
impair, or even appear to impair, the independence of any judgment they may need
to make on behalf of the Company.

HERE ARE SOME WAYS A CONFLICT OF INTEREST COULD ARISE:

Employment by a competitor, or potential competitor, regardless of the nature of
the employment,  while employed by the Company. Acceptance of gifts, payment, or
services  from those  seeking to do  business  with the  Company.  Placement  of
business with a firm owned or controlled by an officer,  director or employee or
his/her  family.  Ownership of, or substantial  interest in, a company that is a
competitor,  client  or  supplier.  Acting as a  consultant  to the  Company,  a
customer, client or supplier.
Seeking the  services or advice of an  accountant  or attorney  who has provided
services to the Company.


Officers,  directors and employees are under a continuing obligation to disclose
any  situation  that  presents  the  possibility  of a conflict or  disparity of
interest between the officer,  director or employee and the Company.  Disclosure
of any potential  conflict is the key to remaining in full  compliance with this
policy.

1. COMPETE ETHICALLY AND FAIRLY FOR BUSINESS OPPORTUNITIES.

We must comply with the laws and regulations  that pertain to the acquisition of
goods and  services.  We will  compete  fairly and  ethically  for all  business
opportunities.  In  circumstances  where  there is  reason to  believe  that the
release or receipt of non-public information is unauthorized,  do not attempt to
obtain and do not accept such information from any source.

If you are  involved  in  Company  transactions,  you must be  certain  that all
statements, communications, and representations are accurate and truthful.

2. AVOID ILLEGAL AND QUESTIONABLE GIFTS OR FAVORS.

The sale and  marketing of our products and services  should always be free from
even the perception that favorable treatment was sought,  received,  or given in
exchange  for the  furnishing  or  receipt  of  business  courtesies.  Officers,
directors  and  employees of the Company  will neither give nor accept  business
courtesies that  constitute,  or could be reasonably  perceived as constituting,
unfair business inducements or that would violate law, regulation or policies of
the  Company,  or could  cause  embarrassment  to or reflect  negatively  on the
Company's reputation.

3. MAINTAIN THE INTEGRITY OF CONSULTANTS, AGENTS, AND REPRESENTATIVES.

Business  integrity is a key standard for the  selection  and retention of those
who represent the Company. Agents,  representatives and consultants must certify
their willingness to comply with the Company's  policies and procedures and must
never be retained to  circumvent  our values and  principles.  Paying  bribes or
kickbacks, engaging in industrial espionage, obtaining the proprietary data of a
third party without  authority,  or gaining inside  information or influence are
just a few examples of what could give us an unfair  competitive  advantage  and
could result in violations of law.

4. PROTECT PROPRIETARY INFORMATION.

Proprietary  Company  information  may not be disclosed to anyone without proper
authorization. Keep proprietary documents protected and secure. In the course of
normal business activities,  suppliers,  customers and competitors may sometimes
divulge to you information that is proprietary to their business.  Respect these
confidences.

5. OBTAIN AND USE COMPANY ASSETS WISELY.

Personal use of Company  property  must always be in accordance  with  corporate
policy.  Proper  use  of  Company  property,  information  resources,  material,
facilities and equipment is your  responsibility.  Use and maintain these assets
with the utmost care and respect,  guarding  against waste and abuse,  and never
borrow or remove Company property without management's permission.

6. FOLLOW THE LAW AND USE COMMON SENSE IN POLITIC CONTRIBUTIONS AND ACTIVITIES.

The Company  encourages its employees to become involved in civic affairs and to
participate in the political process.  Employees must understand,  however, that
their involvement and participation must be on an individual basis, on their own
time and at their own  expense.  In the United  States,  federal  law  prohibits
corporations  from donating  corporate  funds,  goods, or services,  directly or
indirectly,  to candidates for federal offices -- this includes  employees' work
time. Local and state laws also govern political contributions and activities as
they apply to their respective jurisdictions.

7. BOARD COMMITTEES.

The Company shall establish an Audit Committee empowered to enforce this Code of
Ethics.  The Audit Committee will report to the Board of Directors at least once
each year regarding the general  effectiveness  of the Company's Code of Ethics,
the Company's  controls and  reporting  procedures  and the  Company's  business
conduct.

8. DISCIPLINARY MEASURES.

The Company shall  consistently  enforce its Code of Ethics and Business Conduct
through  appropriate  means  of  discipline.  Violations  of the  Code  shall be
promptly reported to the Audit Committee.  Pursuant to procedures adopted by it,
the Audit Committee shall determine whether violations of the Code have occurred
and, if so, shall  determine the  disciplinary  measures to be taken against any
employee or agent of the Company who has so violated the Code.

The disciplinary  measures,  which may be invoked at the discretion of the Audit
Committee,  include,  but are  not  limited  to,  counseling,  oral  or  written
reprimands, warnings, probation or suspension without pay, demotions, reductions
in salary, termination of employment and restitution.

Persons  subject to  disciplinary  measures  shall  include,  in addition to the
violator,  others involved in the wrongdoing such as (i) persons who fail to use
reasonable care to detect a violation,  (ii) persons who if requested to divulge
information  withhold  material  information  regarding a  violation,  and (iii)
supervisors  who  approve  or condone  the  violations  or attempt to  retaliate
against employees or agents for reporting violations or violators.