EXHIBIT 14.1

                          PENINSULA GAMING COMPANY, LLC

              CEO AND SENIOR FINANCIAL OFFICERS' CODE OF ETHICS

General Philosophy

The honesty,  integrity and sound judgment of the chief  executive  officer (the
"CEO") and senior  financial  officers  is  fundamental  to the  reputation  and
success of Peninsula Gaming Company,  LLC (the "Company").  The professional and
ethical  conduct of the CEO and senior  financial  officers is  essential to the
proper  function  and  success of the  Company as a leading  hardware  wholesale
cooperative.

Senior Financial Officers Code of Ethics

Pursuant  to the  mandate  of the  Sarbanes-Oxley  Act of 2002 (the  "Act")  and
regulations  of the  Securities  and  Exchange  Commission  ("SEC")  promulgated
pursuant to the  authority  and mandate of the Act, this Code of Ethics has been
adopted for our CEO, chief financial officer,  controller or officers performing
a similar function of the Company (the "Senior Financial Officers").

To the  best of  their  knowledge  and  ability,  the CEO and  Senior  Financial
Officers of the Company performing accounting, auditing, financial management or
similar functions must:

|_|  Act with  honesty and  integrity,  avoid  actual or apparent  conflicts  of
     interest in personal and professional relationships.

|_|  Provide  colleagues,  the SEC  and  the  public  with  information  that is
     accurate, complete, objective, relevant, timely and understandable.

|_|  Comply with applicable laws,  rules and regulations of federal,  state, and
     local  governments  and other  appropriate  private  and public  regulatory
     agencies.

|_|  Act in good  faith,  with  due  care,  competence  and  diligence,  without
     misrepresenting  material  facts or  allowing  independent  judgment  to be
     subordinated.

|_|  Respect  the  confidentiality  of  information  acquired  in the  course of
     employment.

|_|  Share knowledge and maintain skills necessary and relevant to the Company's
     needs.

|_|  Proactively  promote  ethical  and honest  behavior  within  the  Company's
     environment.

|_|  Assure  responsible  use  of  and  control  of all  assets,  resources  and
     information of the Company.

|_|  Report  violations of this Code of Ethics the Audit  Committee of the board
     of managers of the Company promptly after learning of any such violation.

All Senior  Financial  Officers are expected to adhere to the Company's  Code of
Ethics  for the CEO and Senior  Financial  Officers  at all times.  The board of
managers shall have the sole and absolute discretionary authority to approve any
deviation  or waiver  from the Code of Ethics for the CEO and  Senior  Financial
Officers.  Any change of this Code of Ethics or waiver and the  grounds for such
waiver for a Senior  Financial  Officer  shall be promptly  disclosed  through a
filing with the SEC on Form 8-K.