EXHIBIT 14.00

       Code of Ethics for New Frontier Media, Inc.'s Financial Management

         New Frontier Media, Inc.'s mission includes the promotion of
professional conduct in the practice of its financial management. Those persons
responsible for financial management at New Frontier Media, Inc. hold an
important and elevated role in corporate governance in that they are uniquely
capable and empowered to ensure that the interests of all those involved with
New Frontier Media, Inc. - including shareholders, employees, customers, and the
public - are appropriately balanced, protected and preserved.

         This Code of Ethics provides principles for those persons responsible
for New Frontier Media, Inc.'s financial management. These persons are expected
to adhere to these principles and advocate them. These principles embody rules
regarding individual and peer responsibilities, as well as responsibilities to
other employees, the public and shareholders. Any violations of this Code of
Ethics may result in disciplinary action.

         All those persons responsible for financial management at New Frontier
Media, Inc. will:

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

o    Provide public disclosure of information that is accurate, complete,
     objective, relevant, timely and understandable.

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

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

o    Respect the confidentiality of information acquired in the course of one's
     work except when authorized or otherwise legally obligated to disclose.

o    Confidential information acquired in the course of one's work will not be
     used for personal advantage.

o    Share knowledge and maintain skills important and relevant to New Frontier
     Media, Inc.

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

o    Achieve responsible use of and control over all assets and resources
     employed or entrusted.



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