EXHIBIT 14.1
RENEWABLE ASSETS, INC.
Code of Ethics for
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Principal Executive Officer and Senior Financial Officers
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I. INTRODUCTION
A. Purpose of Code.
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RENEWABLE ASSETS, INC. (the "Corporation") is committed to
the highest standards of legal and ethical conduct, including
providing full and accurate financial disclosure in compliance
with applicable laws, rules and regulations and maintaining its
books and records in accordance with applicable accounting
policies, laws, rules and regulations.
This Code of Ethics for Principal Executive Officer and
Senior Financial Officers (this "Code") is designed to set forth
particular standards of conduct that the Corporation requires its
principal executive officer and its senior financial officers to
follow. Any activity by a principal executive officer or senior
financial officer of the Corporation contrary to this Code is
prohibited and is not within the scope of employment or authority
of such persons.
B. Persons Subject to this Code.
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This Code is applicable to the following Corporation
personnel:
1. Principal executive officer
2. Principal financial officer
3. Principal accounting officer
4. Controller; and
5. Other persons performing similar functions as
persons in the enumerated positions (individually, a "Covered
Person" and collectively, the "Covered Persons").
C. Distribution and Commitment
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All Covered Persons will be given a copy of this Code. Each
Covered Person will be required to certify that each (i) has read
and understands the guidelines contained in this Code and (ii)
will comply with the terms of this Code.
II. COMPLIANCE WITH RULES AND REGULATIONS
The Corporation is committed to conducting its business in
accordance with all applicable laws, rules and regulations and in
accordance with the highest standards of business ethics. As a
Covered Person, you must not only comply with applicable laws,
however. You also have leadership responsibilities that include
creating a culture of high ethical standards and commitment to
compliance; maintaining a work environment that encourages
employees to raise concerns; and promptly addressing employee
compliance concerns.
Exh. 14.1 - Pg. 1
III. CONFLICTS OF INTEREST
A. General Statement.
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All Covered Persons are expected to use good ethical
judgment, and to avoid situations that create an actual or
potential conflict between the Covered Person's personal
interests and the interests of the Corporation. A conflict of
interest also exists where the Covered Person's loyalties or
actions are divided between the Corporation's interests and those
of another, such as a competitor, supplier or customer. Both the
fact and the appearance of a conflict should be avoided.
Before making any investment, accepting any position or
benefits or participating in any transaction or business
arrangement that creates or appears to create a conflict of
interest, Covered Persons must obtain the written approval of the
Board of Directors.
While it is not feasible to describe all possible conflicts
of interest that could develop, the following are some of the
more common examples.
B. Examples of Conflicts.
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1. Financial Interest in Another Business. Covered Persons
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should not have a direct or indirect financial interest in a
customer, supplier, competitor or others with whom the
Corporation does business. The ownership of less than one percent
(1%) of the publicly traded stock of a corporation will not be
considered a conflict.
2. Other Employment and Outside Activities. Covered Persons
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should not work for, become directly or indirectly involved with,
or receive compensation of any sort from, a customer, supplier or
competitor of the Corporation or others with whom the Corporation
does business. Covered Persons should not engage in any activity
which may be competitive with or contrary to the interests of the
Corporation.
3. Corporate Opportunities. Business opportunities of which
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Covered Persons learn as a result of employment with the
Corporation belong to the Corporation, if within the scope of the
Corporation's existing or contemplated business, and should not
be taken advantage of for personal gain.
IV. DISCLOSURE IN REPORTS
The Corporation is committed to providing full, fair,
accurate, timely and understandable disclosure in reports and
documents filed with, or submitted to, the Securities and
Exchange Commission and in other public communications made by
the Corporation.
V. COMPLIANCE WITH THIS CODE
If Covered Persons have questions about this Code, advice
should be sought from the Board of Directors. If a Covered Person
knows of or suspects a conflict of interest or a violation of
applicable laws or regulations or this Code, the Covered Person
must immediately report that information to the Chief Executive
Officer or, if the suspected violation concerns the Chief
Executive Officer, to the President.
VI. ACCOUNTABILITY; WAIVER OF THIS CODE
The Board shall determine, or designate appropriate persons
to determine, appropriate actions to be taken in the event of
violations of this Code. Such actions shall be reasonably
designed to deter wrongdoing and to promote accountability for
adherence to this Code, and may include written notices to the
individual involved that the Board has determined that there has
been a violation, censure by the Board, demotion or re-assignment
Exh. 14.1 - Pg. 2
of the individual involved, suspension with or without pay or
benefits and termination of the individual's employment.
The Corporation will waive application of the policies set
forth in this Code only when circumstances warrant granting a
waiver, and then only in conjunction with any appropriate
monitoring of the particular situation. Changes in and waivers of
this Code may be made only by the Board of Directors and will be
disclosed as required under applicable law and regulations.
Exh. 14.1 - Pg. 3
RENEWABLE ASSETS, INC.
CODE OF ETHICS
FOR
PRINCIPAL EXECUTIVE OFFICER AND
SENIOR FINANCIAL OFFICERS
RECEIPT AND AGREEMENT OF COMPLIANCE NOTICE
OFFICER'S NAME: Alfred M. Schiffrin
I have read and understand the Code of Ethics for Principal
Executive Officer and Senior Financial Officers of RENEWABLE
ASSETS, INC. and hereby acknowledge receipt thereof. I agree to
comply with the requirements of such code.
/s/Alfred M. Schiffrin
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Signature
September 15, 2005
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Date