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EXHIBIT
14.1
 NATURAL HEALTH TRENDS CORP.
 WORLDWIDE CODE OF BUSINESS
CONDUCT
 (Effective July 1, 2004, revised March 27, 2007)




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TABLE OF CONTENTS
 I.
    
    Compliance
    
    
    1II.
    
    Legal Matters
    
    
    1A. Compliance With Laws Generally
    
    
    1B. Antitrust and Competition Laws
    
    
    1C. Securities Trading and Non-Public Information
    
    
    3D. The Foreign Corrupt Practices Act
    
    
    4III.
    
    Information and Technology Management
    
    
    5A. Protection of Proprietary Information
    
    
    5B. Electronic Communications Policy
    
    
    5IV.
    
    Finance and Accounting
    
    
    5A. Accuracy of Company Records
    
    
    5B. Authorization Systems
    
    
    6C. Senior Financial Officers
    
    
    6V.
    
    Where to Find More Information
    
    
    6VI.
    
    How to Report Violations
    
    
    6VII.
    
    Acknowledgement of Receipt
    
    
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I.
    
    ComplianceCompliance with this Code of Business Conduct is required of everyone who acts on behalf of
Natural Health Trends Corp. or one of its subsidiaries. That includes directors, officers,
employees and agents. Anyone who violates our Code will be acting outside the scope of his
or her employment (or agency) and will be subject to disciplinary action, up to and
including termination of employment. Our General Counsel, Gary Wallace, has been designated
by the Board of Directors to oversee compliance with our Code and its policies and
procedures. Any questions of applicability or interpretation should be addressed to this
person at 972-241-4080 or Gary.Wallace@NHTGlobal.com.If at any time a Company employee has an ethical concern or becomes aware of any conduct on
the part of any Company employee that violates  or may violate  our high ethical
standards or any company policy, you should report such concern or conduct to your
supervisor or to Mr. Wallace, our Ethics Compliance Officer. See the section entitled How
To Report Violations in Section VI on p. 6 of this Code of Business Conduct for more
detail.Each employee will be asked to complete and submit an Acknowledgment of Receipt that you
have received and read a copy of the Code and agree to comply with its requirements.II.
    
    Legal Matters
 A.
    
    Compliance With Laws GenerallyNatural Health Trends Corp., each of its subsidiaries and its directors, officers,
employees and agents, will abide by the letter and the spirit of all applicable
laws and regulations, and will act in such a manner that the full disclosure of all
facts related to any activity will always reflect favorably upon the Company.The international business operations of Natural Health Trends Corp. may encounter
local laws, customs and social standards that differ widely from U.S. practice. It
is Company policy to abide by the national and local laws of the countries and
markets in which we operate, unless prohibited by U.S. law. When local customs and
business or social practices vary from the standards contained in this Code of
Business Conduct, it is permissible to conform to local customs and practices when
necessary for the proper conduct of Natural Health Trends Corp. business provided
that it does not violate U.S. law, such as the Foreign Corrupt Practices Act
(discussed below) and when approved by the Ethics Compliance Officer.B.
    
    Antitrust and Competition LawsAntitrust laws in the United States are designed to preserve and foster fair and
honest competition within the free enterprise system. To accomplish this goal, the
language of these laws is deliberately broad, prohibiting such activities as unfair
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methods of competition and agreements in restraint of trade. Such language gives
enforcement agencies the right to examine many different business activities to
judge their effect on competition.
 Natural Health Trends Corp. requires all employees to comply with the U.S. antitrust
laws. The failure to do so can result in severe penalties for both the individuals
involved and Natural Health Trends Corp.Outside of the United States, many countries and the European Union have competition
laws that are similar to the U.S. antitrust laws. Natural Health Trends Corp. also
requires strict compliance with these laws.There are two areas in which antitrust or competition violations most frequently
occur  relations with competitors and relations with customers and suppliers.
 1.
    
    Relations with CompetitorsThe greatest danger for violations of the antitrust/competition laws rests
in contacts with competitors. It is illegal to have an understanding with a
competitor, expressed or implied, written or oral, that improperly restricts
competition or interferes with the ability of the free market system to
function properly.A formal agreement with a competitor is not needed to prove a violation of
the antitrust laws. A general discussion followed by common action often is
enough to show that an agreement exists. In an investigation, every
communication, written or oral, is subject to extreme scrutiny.Communications with competitors should be avoided unless they concern a true
customer-supplier relationship, other legitimate business ventures or
permitted trade association activities. You must not engage in any
communications with competitors that could result, or even appear to result,
in price-fixing, allocation of customers or markets, boycotts, or production
limits.The antitrust laws do recognize, however, your need to be aware of market
conditions, and you may discuss these with customers, suppliers, retailers,
wholesalers and brokers, if they are not your competitors.2.
    
    Relations with Customers and SuppliersGenerally speaking, a company has an unrestricted right to choose its
customers and suppliers. However, a company may not improperly restrict a
distributors freedom to establish its own prices or terms of resale. With
respect to suppliers, we must avoid any agreement that sets the minimum
price of resale by Natural Health Trends Corp. You should also avoid
discussions with customers or distributors regarding Natural
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Health Trends Corp.s supplying other customers or distributors or the
prices charged to them.If you have any questions about a specific business activity, consult with
Gary Wallace, our Ethics Compliance Officer. Remember that we want you to
ask questions.
 C.
    
    Securities Trading and Non-Public InformationIn the normal course of business, you may have access to information that would
affect the value of the stock, options or other securities of Natural Health Trends
Corp. or another company. Until this information is publicly disclosed, it is
considered material non-public information and must be kept confidential. Acting on
this information for personal gain or disclosing it to anyone else before it has
been released to the public violates federal law and Natural Health Trends Corp.
policy.Information is material if it would influence a reasonable persons decision to buy,
sell or hold a companys stock, options or other securities. It includes not only
information about earnings and possible dividend changes, but also such things as
stock splits, new stock or bond offerings, significant acquisitions or divestitures,
and major changes in management, corporate structure or policy. You may not trade
while possessing this information, or disclose it to anyone else, including
relatives, friends, co-workers or stockbrokers, until the information has been
released publicly and the public has had time to react to the information.Trading while in possession of material non-public information creates an unfair
advantage over investors who do not have access to this information. Federal
securities laws are designed to protect the investing public by prohibiting anyone
with access to material non-public information from exploiting this advantage.
Penalties for violations are severe and include criminal fines and imprisonment,
payment to damaged investors of any profits made from trading on the information,
and payment of civil penalties of up to three times the amount of profits made or
losses avoided. In addition, Natural Health Trends Corp. may be penalized for
violations by its employees.Although the nature of their duties means that some employees have greater access to
non-public information than others do, the rules apply to anyone who has direct or
indirect access to material non-public information. This includes everyone from
officers and directors to secretaries who may type confidential memoranda or
technical personnel who may work on new projects.The following guidelines are intended to help you comply with the rules regarding
non-public information:
 i)
    
    Material non-public information should be
shared only with Natural Health Trends Corp. employees whose jobs
require them to have the information.
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ii)
    
    Do not disclose sensitive or non-public
information to anyone outside Natural Health Trends Corp. Natural
Health Trends Corp. has standard procedures for the release of
information to the public.iii)
    
    You should not buy or sell stock, options or
other securities of Natural Health Trends Corp. or another company, or
direct someone else to buy or sell these for you, when you possess
material information about Natural Health Trends Corp. or such other
company that has not been made public. After it has been made public,
you cannot act on the information until the public has had time to
react to the information.Please refer to Natural Health Trend Corp.s Blackout Period Policy
for regular blackout periods, special blackout periods and reporting
obligations. Also please refer to Natural Health Trend Corp.s
Insider Trading Policy for additional information.iv)
    
    You should not trade in another companys
stock, options or other securities if you believe Natural Health Trends
Corp.s plans or activities will affect such stocks value.v)
    
    You should immediately notify Gary Wallace, the
Ethics Compliance Officer, if you believe that you or anyone else has
disclosed, even inadvertently, sensitive or non-public information
relating to Natural Health Trends Corp. to anyone outside of Natural
Health Trends Corp. See the section entitled How To Report
Violations in Section VI on p. 6 of this Code of Business Conduct for
more detail.
 D.
    
    The Foreign Corrupt Practices ActIt is a Federal offense under the Foreign Corrupt Practices Act (FCPA) to offer,
pay, promise, or authorize the payment of anything of value to any foreign
government official, political party, or candidate for political office, for the
purpose of influencing an act or decision to obtain, retain or direct business or
securing any improper advantage. Anything of value includes money, debt
forgiveness, gifts, entertainment and other goods or services of value. The FCPA
applies to U.S. individuals, companies and businesses, including their controlled
international subsidiaries. Therefore, foreign agents who represent Natural Health
Trends Corp. must comply with the terms of the FCPA. Any director, officer,
employee or agent of Natural Health Trends Corp., or any stockholder acting on
behalf of Natural Health Trends Corp., who is convicted of violating the FCPA is
subject to substantial fines and/or imprisonment. In addition, Natural Health Trends
Corp. may also be subject to substantial fines.
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Any employee or other agent of Natural Health Trends Corp. who thinks a transaction
may be illegal under the FCPA must report this to Gary Wallace, the Ethics
Compliance Officer. See the section entitled How To Report Violations in Section
VI on p. 6 of this Code of Business Conduct for more detail. All appropriate
persons, including the reporting individual, will be informed as to how the issue is
resolved. If the review procedure results in a favorable decision, the transaction
may proceed.
 III.
    
    Information and Technology Management
 A.
    
    Protection of Proprietary InformationAll Natural Health Trends Corp. employees must respect the proprietary information
and trade secrets of our distributors and suppliers. New employees are not to
divulge or use the proprietary information of their former employers. Natural
Health Trends Corp. employees should not disclose any proprietary information of
distributors or suppliers unless the release or disclosure is properly authorized by
the individual or firm owning the information.B.
    
    Electronic Communications PolicyAll company-provided equipment, software and communication systems, including
without limitation voice mail, e-mail, Internet, file folders and personal computer
systems, are the property of Natural Health Trends Corp. and as such are provided to
employees for business purposes only. The review, transmission, retrieval or
storage of offensive, obscene or other inappropriate material via Natural Health
Trends Corp. computing and communications systems, including the Internet and
electronic mail, is strictly prohibited. The use of Company e-mail to send
offensive or inappropriate statements, make solicitations, or divulge confidential
information is also prohibited.All communications made via Natural Health Trends Corp. property are considered
records and property of the Company. Natural Health Trends Corp. reserves the right,
in compliance with applicable laws, to monitor, access, copy, modify, disclose or
delete the contents of messages sent or received over its systems, including
Internet points of contact.
 IV.
    
    Finance and Accounting
 A.
    
    Accuracy of Company RecordsNatural Health Trends Corp. business transactions worldwide must be properly
authorized and be completely and accurately recorded on the Companys books and
records in accordance with generally accepted accounting practice and established
Natural Health Trends Corp. financial policies and procedures. Budget proposals and
economic evaluations must fairly represent all information relevant to the decision
being requested or recommended. No false, artificial or misleading entries in the
books and records of Natural Health Trends Corp.,
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domestic or foreign, shall be made for any reason and no employee shall engage in
any arrangement that results in such prohibited acts. The retention or proper
disposal of Company records shall be in accordance with established Natural Health
Trends Corp. financial policies and applicable statutory and legal
requirements.
 B.
    
    Authorization SystemsNatural Health Trends Corp. has established a financial approval system in keeping
with approved quarterly budgets that defines and limits the authority of employees
to commit or obligate the Company with respect to any agreement or transaction that
has financial consequences. The Finance Department maintains and monitors compliance
with the system. You are required to understand your financial approval authority
and to ensure that you do not exceed your authority.C.
    
    Senior Financial OfficersThe honesty, integrity and sound judgment of the senior financial officer and the
chief executive officer of Natural Health Trends Corp. (the Senior Financial
Officers) is fundamental to the reputation and success of the Company. Although
all employees, officers, and directors are required to adhere to the Companys Code
of Business Conduct, the professional and ethical conduct of the Senior Financial
Officers is essential to the proper function and success of the Company. Therefore,
the Senior Financial Officers, in addition to complying with all of the other
provisions of this Code of Business Conduct, must also comply with the Companys
Code of Ethics for Senior Financial Officers.
 V.
    
    Where to Find More InformationThe Natural Health Trends Corp. Code of Business Conduct is a summarized version of many
policies and laws and does not cover all situations. Any questions of applicability or
interpretation should be addressed to your local General Manager or Gary Wallace at
972-241-4080 or Gary.Wallace@NHTGlobal.com.VI.
    
    How to Report ViolationsIt is each employees personal responsibility to bring violations or suspected violations of
the Companys Code of Business Conduct to the attention of their local General Manager or to
Gary Wallace, Ethics Compliance Officer. To report conduct you suspect to be unethical or in
violation of any Code of Business Conduct policy or the law, talk to your supervisor or Gary
Wallace. If you wish to disclose such information anonymously, you are free to do so. You
may anonymously report actual or suspected ethics or legal violations to Gary Wallace as the
Ethics Compliance Officer through the following telephone, e-mail, and web-based methods:
 E-mail:
    
    nhtc@openboard.infoWebsite:
    
    http://www.openboard.info/nhtc/
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Telephone:
    
    866-299-8539 (this is a U.S. telephone number)
 You should feel free to make the report to your local General Manager. If for any reason
those persons are not available or you would feel more comfortable making the report to
someone else, then feel free to contact Gary Wallace.The Company encourages its employees to report or question any conduct that may violate the
companys ethical standards. Therefore, no employee will suffer any retribution in
connection with any good faith reporting, and your identity will not be disclosed
without your permission.VII.
    
    Acknowledgement of ReceiptThe following page contains the Acknowledgement of Receipt form that you should read, sign
and return to the attention of Ethics Compliance Officer at 2050 Diplomat Drive, Dallas,
Texas 75234.
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Natural Health Trends Corp. (NHTC) and Subsidiaries
 Acknowledgement of Receipt
of Worldwide Code of Business Conduct
 By signing below, I acknowledge and understand that as an employee of NHTC or one
of its subsidiaries, it is my responsibility to read the Worldwide Code of Business Conduct
(the Code) and familiarize myself with the information contained in it. I understand that
the Code will be periodically updated and revisions and amendments will be made available to
all employees via e-mail. A current version of the Worldwide Code of Business Conduct will
be available in the Human Resources Department in Dallas at all times. I understand that it
is my responsibility to comply with the policies contained in the Code and any revisions to
it and that I should consult my local General Manager or the Ethic Compliance Officer
concerning any questions I may have about the Code.
 I further understand that the Code supersedes any previously issued policies or
procedures. I understand that the policies and procedures described in the Code are subject
to change at the sole discretion of NHTC at any time.
 Employees Signature
    
    
    
    DateEmployees Printed Name
 PLEASE REMOVE THIS PAGE, SIGN IT AND RETURN IT TO:
 Ethics Compliance Officer
Natural Health Trends Corp.
2050 Diplomat Drive
Dallas, Texas 75234
Fax: (972) 243-5428
Gary.Wallace@NHTGlobal.com
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