Exhibit 99.16

                  INSIDER TRADING AND CONFIDENTIALITY POLICY


INTRODUCTION

As a reporting issuer, Empire Global Corp is subject to various federal and
state laws and regulations governing trading in its securities. It is the policy
of Empire Global Corp and its subsidiaries (the "Company") to comply fully, and
to assist its employees in complying fully, with these laws and regulations.
This Insider Trading Policy ("Policy") applies to all members of the Company's
Board of Directors, director emeriti and employees, as well as members of such
persons' immediate families and households. All references in this Policy to
employees of the Company should be read to include all such persons listed in
the preceding sentence.

The Company depends upon the conduct and diligence of its employees, in both
their professional and personal capacities, to ensure full compliance with this
Policy. This Policy provides procedures and guidelines with respect to
transactions in the Company's securities, the protection of material, non-public
information and the standard of conduct expected of the Company's employees in
this highly sensitive area. It is the personal obligation and responsibility of
each employee to act in a manner consistent with this Policy.


I. LEGAL BACKGROUND

"Insider trading" is a top enforcement priority of the Securities and Exchange
Commission ("SEC"), the NASDAQ Global Select Market ("NASDAQ") and the
Department of Justice. Criminal prosecutions for insider trading are commonplace
and may result in fines and/or imprisonment.

What is insider trading? The prohibition against such trading generally is
understood to prohibit (1) trading on the basis of material, non-public
information, (2) disclosing or "tipping" material, non-public information to
others or recommending the purchase or sale of securities on the basis of such
information or (3) assisting someone who is engaged in any of the above
activities.

Who is an insider? The term "insider" applies to anyone who, by virtue of a
special relationship with the Company, possesses material, non-public
information regarding the business of the Company.

An individual can be considered an insider for a limited time with respect to
certain material, non-public information even though he or she is not a director
or officer. For example, an assistant who knows that an acquisition is about to
occur may be regarded as an insider with respect to that information until the
news of such acquisition has been fully disclosed to the public.

What is material, non-public information? Information is generally deemed to be
"material" if there is a substantial likelihood a "reasonable investor" would
rely on it in deciding to purchase, sell or hold a security to which the
information relates. As a practical matter, materiality often is determined
after the fact, when it is known that someone has traded on the information and
after the information itself has been made public and its effects upon the
market are more certain. Examples of information that is generally regarded as
material are:

    * Financial results;




    * Projections that significantly differ from external expectations;

    * Major proposed or pending acquisitions, investments or divestitures;

    * Significant project or product developments;

    * Changes in key personnel;

    * Changes in dividends;

    * Stock splits;

    * Stock buy-backs;

    * New equity or debt offerings;

    * Positive or negative developments in outstanding significant litigation;

    * Events that may result in the creation of a significant reserve or
    write-off or other significant adjustments to the financial statements;

    * Actual or threatened significant litigation or inquiry by a governmental
    or regulatory authority; and

    * Any other facts which might cause the Company's financial results to be
    substantially affected.

"Non-public" information is any information that has not been previously
disclosed and is not otherwise available to investors generally. Filings with
the SEC and press releases are generally regarded as public information.
Information about undisclosed financial results or a possible merger,
acquisition or other material development, whether concerning the Company or
otherwise, and obtained in the normal course of employment or through a rumor,
tip or just "loose talk", is not public information. Information should be
considered "non-public" until the beginning of the third (3rd) Trading Day (as
defined below) after such information has been disseminated widely to the
general public through press releases, news tickers, newspaper items, quarterly
or annual reports or other widely disseminated means.

For purposes of this Policy, a "Trading Day" shall mean a day on which the
NASDAQ is open for trading.

Potential Criminal and Civil Liability and/or Disciplinary Action. The
Securities Exchange Act of 1934, as amended (the "Exchange Act"), and
specifically Rule 10b-5 of the Exchange Act, makes it unlawful for any person to
make false statements or omit to state material facts in connection with the
purchase or sale of any security. There are no limits on the size of a
transaction that will trigger insider trading liability. In the past, relatively
small trades have resulted in SEC investigations and lawsuits.

Individuals found liable for insider trading face penalties of up to three (3)
times the profit gained or loss avoided, a criminal fine of up to $5 million and
up to twenty (20) years in jail. In addition to the potential criminal and civil
liabilities mentioned above, in certain circumstances the Company may be able to
recover all profits made by an insider who traded illegally, plus collect other
damages. In addition, the Company (and its executive officers and directors)
could itself face penalties of the greater of $1 million or three (3) times the
profit gained or loss avoided as a result of an employee's violation and/or a
criminal penalty of up to $25 million for failing to take steps to prevent
insider trading.





Without regard to the civil or criminal penalties that may be imposed by others,
willful violation of this Policy and its procedures may constitute grounds for
dismissal.

The procedures regarding securities trading outlined below are designed to deter
and, where possible, to prevent such improper trading.


POLICIES REGARDING TRANSACTIONS IN THE COMPANY'S SECURITIES

The following policies apply to all transactions, direct or indirect, in all of
the Company's securities, including, but not limited to, the Company's Common
Stock (including those shares of common stock that may be held in any retirement
savings plan, pension plan, retirement plan, other similar plan or any such
similar plan that the Company may adopt in the future), Warrants to purchase
Common Stock and derivative securities (including stock options, put or call
options and other similar securities).


Prohibitions for All Employees:

No Trading on Material, Non-Public Information. No employee who is aware of any
material, non- public information concerning the Company or a third-party with
whom the Company does business, shall engage in any transaction in the Company's
or such third-party's securities, including any offer to purchase or sell,
during any period commencing with the date that he or she obtains such material,
non-public information and ending at the beginning of the third (3rd) Trading
Day following the date of public disclosure of that information. After
termination of employment, any employee who is in possession of material,
non-public information is prohibited from trading in Company securities until
that information has become public or is no longer material.

No Tipping. No employee shall disclose ("tip") material, non-public information
to any other person where such information may be used by such person to his or
her benefit by trading in the securities of the company to which such
information relates, nor shall an employee make any recommendations or express
any opinions as to trading in the Company's securities to any other person on
the basis of material, non- public information.

No Short Sales. No employee shall engage in the short sale of the Company's
securities. A short sale is a sale of securities not owned by the seller or, if
owned, not delivered against such sale within twenty (20) days thereafter (a
"short against the box").

Short sales of the Company's securities evidence an expectation on the part of
the seller that the securities will decline in value, and, therefore, signal to
the market that the seller has no confidence in the Company or its short-term
prospects. In addition, short sales may reduce the seller's incentive to improve
the Company's performance.

No Investments in Derivatives of the Company's Securities. No employee shall
invest in Company- based derivative securities. "Derivative Securities" are
options, warrants, stock appreciation rights or similar rights whose value is
derived from the value of an equity security, such as the Company's common
stock. This prohibition includes, but is not limited to, trading in
Company-based put or call option contracts, trading in straddles and the like.
However, holding and exercising stock options, restricted stock units or other
derivative securities granted under the Company's equity compensation plans is
not prohibited by this Policy.




No Margin Purchases. No employee shall purchase the Company's securities on
margin. This means such persons are prohibited from borrowing from a brokerage
firm, bank or other entity in order to purchase the Company's securities (other
than in connection with "cashless" exercises of stock options under the
Company's equity compensation plans).

Retirement Savings Plan. This Policy does not apply to purchases of Company
stock in its retirement plan resulting from periodic contributions of money
pursuant to a payroll deduction election. The Policy does apply, however, to
certain elections made under the Company's retirement plan, including (a) an
election to increase or decrease the percentage of periodic contributions that
will be allocated to the Company stock fund, (b) an election to make an
intra-plan transfer of an existing account balance into or out of the Company
stock fund, (c) an election to borrow money against a retirement plan account if
the loan will result in a liquidation of some or all of the Company stock fund
balance and (d) an election to pre-pay a plan loan if the pre- payment will
result in allocation of loan proceeds to the Company stock fund.

Prohibitions and Procedures for Section 16 Reporting Persons and Designated
Individuals: The following prohibitions and procedures apply to Section 16
Reporting Persons (as defined below) and certain other employees that may be
designated by the Company from time to time ("Designated Individuals"). "Section
16 Reporting Persons" are members of the Company's Board of Directors, director
emeriti and certain executive officers, who are subject to the reporting and
"short-swing profit" liability provisions of Section 16 of the Exchange Act.
Section 16 Reporting Persons and Designated Individuals will be informed of
their status by the Empire Global Corp General Counsel.

Under special circumstances, certain employees who are not Section 16 Reporting
Persons or Designated Individuals may gain access to material, non-public
information and the Company, in its discretion, may determine that such
employees may also be subject to the below listed prohibitions and procedures.
Such employees will be notified of such status and will be subject to the below
listed prohibitions and procedures for such period of time as the Company deems
appropriate.

No Trading During Black-Out Periods. Section 16 Reporting Persons, Designated
Individuals, as well as members of their immediate families and households are
subject to black-out periods during which they are prohibited from conducting
any transactions involving the Company's securities. Each black-out period
begins at the close of the market on the fourteenth (14th) day prior to the
close of any fiscal quarter and ends at the open of the market on the third
(3rd) Trading Day following the release of the Company's quarterly or annual
financial results for that particular quarter (the "Black-Out Period"). The
prohibition against trading during the Black-Out Period also prohibits the
fulfillment of "limit orders" by any broker for such Section 16 Reporting
Person, Designated Individual or member of such person's immediate family or
household, and the brokers with whom any such "limit order" is placed must be
informed of such prohibition at the time such "limit order" is placed.

Notwithstanding the foregoing, a transaction may be exempt from this prohibition
if it is made pursuant to a written trading plan that has been approved in
writing in advance of a Black-Out Period while the employee was not in
possession of material non-public information by the Empire Global Corp General
Counsel and that meets all of the requirements of the SEC's rules and
regulations, including Rule 10b5-1 of the Exchange Act.

The Black-Out Period restriction may be waived in individual cases at the
discretion of the Empire Global Corp General Counsel. Additional black-out
periods may be implemented with regard to certain employees or groups from time



to time who are in possession of non-public information regarding potentially
significant matters.

No Trading in the Company's Securities on a Short-Term Basis. Any Company
securities purchased on the open market by a Section 16 Reporting Person,
Designated Individual or member of such individuals' immediate family or
household must be held for a minimum of six (6) months. Note that the SEC's
short swing profit rules already penalize Section 16 Reporting Persons who sell
any Company securities within six (6) months of a purchase by requiring such
person to disgorge all profits to the Company whether or not such person had
knowledge of any material, non-public information.

Same day "cashless" exercises of stock options are not subject to this
prohibition, provided that there were no previous purchase transactions on the
open market within six (6) months of the exercise date.

Pre-Clearance of Trading by Section 16 Reporting Persons and Designated
Individuals

If a Section 16 Reporting Person, Designated Individual or member of such
person's immediate family or household is contemplating a transaction in the
Company's securities, the proposed transaction must be pre-cleared with either
the Empire Global Corp General Counsel or his or her designee, even if the
proposed transaction is to take place outside of the Black-Out Period. If the
transaction is cleared to proceed, the Empire Global Corp Legal Department will
assist a Section 16 Reporting Person in complying with Section 16 and, where
applicable, Rule 144 of the Securities Act of 1933, as amended.


IT SHOULD BE NOTED THAT ANY PERSON WHO POSSESSES MATERIAL, NON-PUBLIC
INFORMATION, REGARDLESS OF WHETHER OR NOT IT IS WITHIN THE BLACK-OUT PERIOD OR
NOT, SHOULD NOT ENGAGE IN ANY TRANSACTION INVOLVING THE COMPANY'S SECURITIES.

Exceptions to the Prohibitions on Trading

The only exceptions to this Policy's prohibitions of trading in the Company's
securities as outlined above are the following:

    1. Stock Option Exercises - Exercises in stock options granted under the
    Company's equity compensation plans for cash; however, this exception does
    not include the subsequent sale of the shares acquired pursuant to the
    exercise of a stock option; and

    2. Bona Fide Gifts - Bona fide gifts of securities are not deemed to be
    transactions for the purposes of this Policy. Whether a gift is truly bona
    fide will depend on the circumstances surrounding a specific gift. The more
    unrelated the donee is to the donor, the more likely the gift would be
    considered "bona fide" and not a "transaction." For example, gifts to
    charities, churches or non-profit organizations would not be deemed to be
    "transactions." However, gifts to dependent children followed by a sale of
    the "gifted securities" in close proximity to the time of the gift may imply
    some economic benefit to the donor and, therefore, may be deemed to be a
    "transaction" and not a "bona fide gift."

While these transactions are exceptions to this Policy's prohibitions on trading
in the Company's securities, a Section 16 Reporting Person, Designated
Individual or member of such person's immediate family or household
contemplating such a transaction should still pre-clear the proposed transaction
with either the Empire Global Corp General Counsel or his or her designee.




POLICIES REGARDING THE USE, DISCLOSURE AND PROTECTION OF MATERIAL,
NON-PUBLIC INFORMATION

All employees of the Company have ethical and legal responsibilities to
maintain the confidentiality of material, non-public information.

Use and Disclosure of Material, Non-Public Information. As explained previously,
under no circumstances may an employee use material, non-public information
about the Company for his or her personal benefit. Moreover, except as
specifically authorized or in the performance of regular corporate duties, under
no circumstances may an employee release to others information that might affect
the Company's securities. Therefore, it is important that an employee not
disclose material, non-public information to anyone, including other employees
of the Company, unless the other employee needs to know such information in
order to fulfill his or her job responsibilities. Under no other circumstances
should such information be disclosed to anyone, including family, relatives or
business or social acquaintances. In maintaining the confidentiality of the
information, the individual in possession of such information shall not affirm
or deny statements made by others, either directly or through electronic means,
if such affirmation or denial would result in the disclosure of material,
non-public information.

If an employee has any doubt about whether certain information is non-public or
material, such doubt should be resolved in favor of not communicating such
information or trading without discussing with the assigned compliance officer
or raising with in-house counsel. Questions concerning what is or is not
material, non-public information should be directed to the Company's Legal
Department.

Material, Non-Public Information Regarding Other Companies. In the ordinary
course of doing business, employees may come into possession of material,
non-public information with respect to other companies. An individual receiving
material, non-public information in such a manner has the same duty not to
disclose the information to others or to use that information in connection with
securities transactions of such other company as such individual has with
respect to material, non-public information about the Company.

If the Company is in the process of negotiating a significant transaction with
another company, employees are cautioned not to trade in the stock of that
company if they are in possession of material, non-public information concerning
such company.

If an employee is not certain whether it is permissible to trade in the stock of
such company, the employee should contact the Company's Legal Department before
making any trades.

Unauthorized Disclosure of Internal Information. Unauthorized disclosure of
internal information about the Company may create serious problems for the
Company whether or not the information is used to facilitate improper trading in
securities of the Company. Therefore, it shall be the duty of each person
employed or affiliated with the Company to maintain the confidentiality of
information relating to the Company or obtained through a relationship of
confidence. Company personnel should not discuss internal Company matters or
developments with anyone outside the Company, except in the performance of
regular corporate duties.

Precautions to Prevent Misuse or Unauthorized Disclosure of Sensitive
Information. When an employee is involved in a matter or transaction which is
sensitive and, if disclosed, could reasonably be expected to have an effect on
the market price of the securities of the Company or any other company involved



in the transaction, that individual should consider taking extraordinary
precautions to prevent misuse or unauthorized disclosure of such information.
Such measures include the following:

    1. Maintaining files securely and avoiding storing information on computer
    systems that can be accessed by other individuals;

    2. Avoiding the discussion of confidential matters in areas where the
    conversation could possibly be overheard;

    3. Not gossiping about Company affairs; and

    4. Restricting the copying and distribution of sensitive documents within
    the Company.

Internet. Any written or verbal statement that would be prohibited under the law
or under this Policy is equally prohibited if made on the Internet or by social
media.

Inadvertent Disclosure of Material, Non-Public Information. If material,
non-public information regarding the Company is inadvertently disclosed, no
matter what the circumstances, by any employee, the person making or discovering
that disclosure should immediately report the facts to the Empire Global Corp
General Counsel.

Inquiries Regarding Material, Non-public Information. When an inquiry is
received regarding information that may be material, it should be referred,
without comment, to the Company's Investor Relations Department.


Reporting of Violations

Any person who believes that a violation of this policy has taken place shall
report such violation promptly to the General Counsel of Empire Global Corp.

Any questions concerning this Policy should be addressed to the Empire Global
Corp General Counsel.