Exhibit 14


              CODE OF ETHICS FOR CEO AND SENIOR FINANCIAL OFFICERS
                         (as amended February 13, 2004)

The Company has Standard Policies and Practices that establish controls over,
among other things, business conduct, improper payments and financial reporting.
These Standard Policies and Practices are applicable to all employees. In
addition to the Standard Policies and Practices, the CEO and senior financial
officers are subject to the following specific code of ethics:

1.   The CEO and all senior financial officers shall act with honesty and
     integrity, avoiding actual or apparent conflicts of interest in personal
     and professional relationships. They will achieve responsible use of and
     control over all Company assets and resources employed by or entrusted to
     them, and provide information that is accurate, complete, objective,
     relevant, timely and understandable. They will respect the confidentiality
     of information acquired in the course of work except when authorized or
     otherwise legally obligated to disclose. They will promptly bring to the
     attention of the Audit Committee any material information that affects the
     disclosures made by the Company in its public filings.

2.   The CEO and all senior financial officers shall comply with rules and
     regulations of federal, state, provincial and local governments, and other
     appropriate private and public regulatory agencies. They will promptly
     bring to the attention of the General Counsel or the CEO and to the Audit
     Committee any information concerning a material violation of any of these
     laws, rules or regulations applicable to the Company and the operation of
     its business, by the Company or any agent thereof, or of violation of the
     Company's Standard Policies and Practices, or of these additional policies.

3.   The CEO and all senior financial officers shall promptly bring to the
     attention of the Audit Committee any information he or she may have
     concerning (a) 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 or (b) any 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.

4.   The Board of Directors or Committee thereof shall determine appropriate
     actions to be taken in the event of violations of the Company's Standard
     Policies and Practices or of this Code of Ethics by the CEO and the
     Company's senior financial officers. Such actions shall be reasonably
     designed to deter wrongdoing and to promote accountability for adherence to
     the Company's Standard Policies and Practices and to this Code of Ethics.