EXHIBIT 14    CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS

The chief  executive  officer/chief  financial  officer (the  Company's  "Senior
Financial   Officer")   holds  an  important  and  elevated  role  in  corporate
governance,  vested  with both the  responsibility  and  authority  to  protect,
balance,  and preserve  the  interests  of all of the  enterprise  stakeholders,
including shareholders,  customers,  employees,  suppliers,  and citizens of the
communities in which business is conducted.  Senior  Financial  Officer fulfills
this  responsibility  by  prescribing  and enforcing the policies and procedures
employed in the operation of the Company's financial  organization and by acting
in good  faith  and in the  Company's  best  interests  in  accordance  with the
Company's Code of Business Conduct and Ethics.

1.       Honest and Ethical Conduct
         Senior  Financial  Officers will exhibit and promote honest and ethical
         conduct  through  the  establishment  and  operation  of  policies  and
         procedures that:

o        Encourage  and  reward  professional  integrity  in all  aspects of the
         financial  organization,  by  eliminating  inhibitions  and barriers to
         responsible behavior, such as coercion, fear of reprisal, or alienation
         from the financial organization or the enterprise itself.

o        Promote  the  ethical  handling  of actual  or  apparent  conflicts  of
         interest between personal and professional relationships.

o        Provide a mechanism for members of the finance  organization  to inform
         senior  Management  of  deviations  in the practice  from  policies and
         procedures governing honest and ethical behavior.

o        Respect the  confidentiality  of information  acquired in the course of
         work, except when authorized or otherwise legally obligated to disclose
         such  information,  and  restrict the use of  confidential  information
         acquired in the course of work for personal advantage.

o        Demonstrate  their  personal  support for such policies and  procedures
         through  periodic  communication  reinforcing  these ethical  standards
         throughout the finance organization.

2.       Financial Records and Periodic Reports
         Senior  Financial  Officers will  establish  and manage the  enterprise
         transaction and reporting systems and procedures to provide that:

o        Business transactions are properly authorized and accurately and timely
         recorded  on  the  company's  books  and  records  in  accordance  with
         Generally  Accepted  Accounting  Principles  ("GAAP")  and  established
         company financial policy.

o        No false or  artificial  statements or entries for any purpose are made
         in the company's  books and records,  financial  statements and related
         communications.

o        The  retention  or  proper  disposal  of  company  records  shall be in
         accordance with established  records retention  policies and applicable
         legal and regulatory requirements.




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o        Periodic financial  communications and reports will include full, fair,
         accurate, timely and understandable disclosure.

3.       Compliance  with  Applicable  Laws,   Rules  and  Regulations.   Senior
         Financial Officers will establish and maintain mechanisms to:

o        Educate members of the finance organization about any federal, state or
         local statute,  regulation or administrative procedure that affects the
         operation of the finance organization and the enterprise generally.

o        Monitor the compliance of the finance  organization with any applicable
         federal, state or local statute, regulation or administrative rule.

o        Identify,  report  and  correct  in a swift  and  certain  manner,  any
         detected deviations from applicable federal,  state or local statute or
         regulation.

4.       Reporting of Non-Compliance
         Senior  Financial  Officers will promptly bring to the attention of the
         Audit Committee:

o        Material  information  that affects the disclosures made by the company
         in its public filings.

o        Information  concerning  significant  deficiencies  in  the  design  or
         operation  of  internal   controls  that  could  adversely  affect  the
         company's  ability to record,  process,  summarize and report financial
         data.

         Senior  Financial  Officers will promptly bring to the attention of the
         General Counsel and to the Audit Committee:

o        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.

o        Information  concerning a violation of this Code or the company's  Code
         of  Business  and Ethics  Conduct,  including  any  actual or  apparent
         conflicts of interest between personal and professional  relationships,
         involving  management or other employees who have a significant role in
         the company's financial reporting, disclosures or internal controls.

o        Evidence of a material  violation  by the company or its  employees  or
         agents of applicable laws, rules or regulations.

5.       Disciplinary Action
         In the event of violation by Senior Financial  Officers of this Code or
         the company's Code of Business Conduct and Ethics,  the Audit Committee
         of the Board of Directors shall recommend appropriate  disciplinary and
         remedial actions.