Exhibit 14.1

                                 CODE OF ETHICS

We, the Employees of Propalms, Inc. in recognition of the importance of our
technologies in affecting the quality of life throughout the world, and in
accepting a personal obligation to our profession, its members and the
communities we serve, do hereby commit ourselves to the highest ethical and
professional conduct and agree:

         1.       For our Clients; To act faithfully in professional matters, To
                  uphold each user's right to privacy and confidentiality and
                  shall respect whatever proprietary rights that belong to them,
                  To accept responsibility in making decisions consistent with
                  their best interests regardless of our monetary impact, and to
                  disclose promptly information they might need to make their
                  best decisions.

         2.       to avoid real or perceived conflicts of interest whenever
                  possible, and to disclose them to affected parties when they
                  do exist;

         3.       to truthfully represent ourselves and to be honest and
                  realistic in stating claims or estimates based on available
                  data;

         4.       to reject bribery in all its forms;

         5.       to improve the understanding of technology, its appropriate
                  application, and potential consequences;

         6.       to maintain and improve our technical competence and to
                  undertake technological tasks for others only if qualified by
                  training or experience, or after full disclosure of pertinent
                  limitations;

         7.       to seek, accept, and offer honest criticism of technical work,
                  to acknowledge and correct errors, and to credit properly the
                  contributions of others;

         8.       to treat fairly all persons regardless of such factors as
                  race, religion, gender, disability, age, or national origin;

         9.       to avoid injuring others, their property, reputation, or
                  employment by false or malicious action;

         10.      to assist colleagues and co-workers in their professional
                  development and to support them in following this code of
                  ethics;

         11.      to undertake assignments for which we are qualified, and for
                  which there is reasonable expectation of meeting requirements
                  in a timely fashion;

         12.      to conduct ourselves in such a manner as to bring credit to
                  our industry and enhance it's reputation;

         13.      to not disparage our competitors by statement or other
                  innuendo to clients or prospective clients.




Propalms Privacy Statement

Information Collection

Propalms deems privacy a central issue of Internet use. Propalms attempts to
have reasonable measures in place to assure the anonymity of visitors to the
Propalms web site. Propalms feels as part of responsible disclosure that
Propalms web site users are aware of what information is being logged.

To maintain and improve site quality and integrity, IP addresses are logged (the
Internet Protocol addresses of computers). This log is a standard method of
reporting to statistically find out which parts of our web site are visited and
how long visitors spend there. We also log the type of browser and operating
system you are using. We do not link IP addresses to personally identifiable
information.

Like many other commercial web sites, the Propalms web site may use a standard
technology called a cookie to collect information about how you use the site.
Cookies were originally designed to help a web site distinguish a user's browser
as a previous visitor and thus save and remember any preferences that may have
been set while the user was browsing the site. A cookie is a small string of
text that a web site can send to your browser. A cookie cannot retrieve any
other data from your hard drive, pass on computer viruses, or capture your
e-mail address. Currently, web sites use cookies to enhance the user's visit; in
general, cookies can securely store a user's ID and password, personalize home
pages, identify which parts of a site have been visited or keep track of
selections in a shopping cart. It is possible to set your browser to inform you
when a cookie is being placed - this way, you have the opportunity to decide
whether to accept the cookie.

At times we may request that you voluntarily supply us with personal
information, such as your e-mail address, for purposes such as corresponding
with us, registering at a site, making a purchase, entering a sweepstakes,
registering a new product, or participating in an online survey.

Information Use

When you supply Propalms with your personal information, we may use the
information to learn more about you so that we can develop better products and
services or use the information, sharing it with our business partners, to
inform you about new products, services and offers that may be of interest to
you.

Declining E-mail Offers

Although most customers tell us they appreciate receiving notice of these
opportunities, we recognize the importance of providing you with choices. At any
time after receiving an e-mail offer from Propalms, you may request to
discontinue receiving these offers. All e-mail offers that you receive from
Propalms will tell you how to decline further e-mail offers. Our partners may
have different policies.

Children

While Propalms' product ad campaigns and marketing materials may be viewed by
children, we do not wish to receive data from children. Propalms encourages
parents and guardians to spend time online with their children and to
participate in the interactive activities offered on the sites their children
visit. No information should be submitted to, or posted at, Propalms's web site
by visitors under 18 years of age without the consent of their parent or
guardian.

Propalms Inc.'s privacy statement is subject to change at any time and without
notice.

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