Exh. 14
                 Hebei Aoxing Pharmaceutical Group Co., Ltd

                           CODE OF CONDUCT POLICY

Hebei Aoxing Pharmaceutical Group Co., Ltd ("the Company") is dedicated
to conducting its business in accordance with the applicable laws,
regulations and with highest standards of business ethics. This code is
intended to provide guidance in identifying ethical issues, offer
mechanisms to report unethical conduct, and to help foster a culture of
honesty and accountability.

Each officer, director, and employees is expected to comply with the
letter and spirit of this Code. The Directors and employees of the
Company mentioned above must not only comply with the applicable
regulations but should also actively advance the promotion of honest
and ethical conduct of the business. They must abide by the policies
and procedures that govern the conduct of the Company's business.

This Code illustrates some of the potential problem areas that could
develop below:

CONFLICTS OF INTEREST - A conflict situation can arise:

a. When an employee or Director takes action or has interests that may
make it difficult to perform his or her work, objectively and
effectively,

b. The receipt of improper personal benefits by a member of his or her
family as a result of one's position in the Company,

c. Any outside business activity that detracts an individual's ability
to devote appropriate time and attention to his or her responsibilities
with the Company,

d. The receipt of non-nominal gifts or excessive entertainment from any
person/company with which the Company has current or prospective
business dealings,

e. Any significant ownership interest in any supplier, customer,
development partner or competitor of the Company,

f. Any consulting or employment relationship with any supplier,
customer, business associate or competitor of the Company.
The Directors and employees should be scrupulous in avoiding "conflicts
of interest" with the Company. In case there is likely to be a conflict
of interest, he/she should make full disclosure of all facts and
circumstances thereof to the Board of Directors or any
Committee/officer nominated for this purpose by the Board and a prior
written approval should be obtained.

HONEST AND ETHICAL CONDUCT: The Directors and employees shall act in
accordance with the highest standards of personal and professional
integrity, honesty and ethical conduct not only on Company's premises
and off site but also at Company sponsored business, social events as
well as any places. They shall act and conduct free from fraud and
deception. Their conduct shall conform to the best-accepted
professional standards of conduct.



CORPORATE OPPORTUNITIES: Directors and employees owe a duty to the
Company to advance its legitimate interests when the opportunity to do
so arises. Directors and employees are expressly prohibited from:

a. Taking for themselves, personally, opportunities that are discovered
through the use of Company's property, information, or position;

b. Competing directly with the business of the Company or with any
business that the Company is considering.

c. Using Company's property, information, or position for personal
gain.  If the Company has finally decided not to pursue an opportunity that
relates to the Company's business activity, he/she may pursue such activity
only after disclosing the same to the Board of directors or the nominated
person/committee.

CONFIDENTIALITY: The Directors and employees shall maintain the
confidentiality of confidential information of the Company or that of
any customer, supplier or business associate of the Company to which
Company has a duty to maintain confidentiality, except when disclosure
is authorized or legally mandated. The Confidential information
includes all non-public information (including private, proprietary and
other) that might be of use to competitors or harmful to the Company or
its associates. The use of confidential information for his/her own
advantage or profit is also prohibited.

FAIR DEALING: Each Director and employee should deal fairly with
customers, suppliers, competitors and employees of group companies,
They should not take unfair advantage of anyone through manipulation,
concealment, abuse of confidential proprietary or trade secret
information, misrepresentation of material facts, or any other unfair
dealing practices.

PROTECTION AND PROPER USE OF COMPANY'S ASSETS: All Directors and
employees should protect Company's assets and property and ensure its
efficient use. Theft, carelessness, and waste of the Company's assets
and property have a direct impact on the Company's profitability.
Company's assets should be used only for legitimate business purposes.

COMPLIANCE WITH LAWS, RULES AND REGULATIONS: The Directors and
employees shall comply with all applicable laws, rules and regulations
Transactions, directly or indirectly, involving securities of the
Company should not be undertaken without pre-clearance from the
Company's Compliance Officer. Any Director or employee who is
unfamiliar or uncertain about the legal rules involving Company
business conducted by him/her should consult the Legal Department of
the Company before taking any action that may jeopardize the Company or
that individual.

COMPLIANCE WITH CODE OF CONDUCT: If any director or employee who knows
of or suspects of a violation of applicable laws, rules or regulations
or this Code of Conduct, he/she must immediately report the same to the
Board of Directors or any designated person/committee thereof. Such
person should as far as possible provide the details of suspected
violations with all known particulars relating to the issue. The
Company recognizes that resolving such problems or concerns will



advance the overall interests of the Company that will help to
safeguard the Company's assets, financial integrity and reputation.
Violations of this Code of Ethics will result in disciplinary action,
which may even include termination of services of the employee. The
Company's Board or any Committee/person designated by the Board for
this purpose shall determine appropriate action in response to
violations of this Code of Ethics.

INTERPRETATION OF CODE: Any question or interpretation under this Code
of Ethics and Business Conduct will be handled by the Board or any person/
Committee authorized by the Board of the Company. The Board of Directors or
any designated person/committee has the authority to waive compliance with
this Code of business conduct for any Director or employee of the
Company. The person-seeking waiver of this Code shall make full
disclosure of the particular circumstances to the Board or the
designated person/committee