Attached files

Exhibit 14.  Transtech Industries, Inc. Code Of Ethics.
Introduction
     In keeping with our commitment to honest business practices,
Transtech Industries, Inc., (the "Company") has adopted this company-wide
Code of Ethics to assist our directors, officers, and employees in
complying with both our corporate policies and with the law.
	Although this Code of Ethics covers many different business practices
and procedures, it does not cover every issue that may arise. Instead, our
code sets forth the clear principles and standards that our directors,
officers, and employees are accustomed to following. This Code also
explains how we enforce our Code. At Transtech Industries, our goal is to
conduct ourselves in a manner that avoids even the appearance of
impropriety.
	This Code should be read in conjunction with our other corporate
policies. If a law conflicts with a policy in this Code, you must comply
with the law. If you have questions about this Code, other Company
policies, or how to comply with the law in a certain situation, it is
important that you immediately bring your questions to one of the
Company's officers. If you are in or observe a situation that you believe
may violate or lead to a violation of this Code, you should refer to
Section D of our Code for guidance on how to report questionable behavior.
	Anyone who violates the standards of this Code will be subject to
disciplinary action. Such action may include termination of employment.
A. Compliance with All Laws, Rules and Regulations
     The Company requires that all its directors, officers, and employees
strictly adhere to local, state, and federal laws, as well as the laws of
the other countries in which we conduct business. If you have questions
about what laws we are subject to, or about how to comply with certain
laws, it is important that you alert an officer of the Company to your
question. We rely on you not only to act ethically, but also to assist
your fellow employees and management in following the law.
     When appropriate, the Company will provide information and training
to promote compliance with laws, rules, and regulations, including
insider-trading laws.
B. Ethical Conduct and Conflicts of Interest
     The Company's employees, officers, and directors are expected to make
or participate in business decisions and actions based on the best
interests of the Company as a whole, and not based on personal
relationships or personal gain. As we define it, a conflict of interest
exists when a person's private interest interferes in any way with the
interest of the Company, or creates an appearance of impropriety. A
conflict situation can arise when you have interests that make it
difficult for you to perform your work objectively, or when a director,
officer, or employee receives improper personal benefits as a result of
his or her position with the Company.
     It is almost always a conflict of interest for a Company employee to
work simultaneously for a competitor, customer, or supplier. You should
avoid any relationship that would cause a conflict of interest with your
duties and responsibilities at the Company. All directors, officers, and
employees are expected to disclose to management any situations that may
involve inappropriate or improper conflicts of interest affecting them
personally or affecting other employees or those with whom we conduct
business.
     Members of our Board of Directors have a special responsibility to
our Company and to our shareholders. To avoid conflicts of interest,
Directors are required to disclose to their fellow directors any personal
interest they may have in a transaction being considered by the Board and,
when appropriate, to recuse themselves from any decision involving a
conflict of interest. Waivers of a conflict of interest or this Code
involving executive officers and directors require approval by the Board
of Directors.
     Any discovery of a potential or existing conflict of interest should
be immediately disclosed to management in accordance with the procedures
set forth in Section D of our Code.
C. Our Commitment to Full, Fair, Accurate, Timely and Plain English
Disclosure
     As a respected public company, it is critical that the Company's
filings with the Securities and Exchange Commission be complete, timely
and accurate in all material respects. At the Company, all our employees,
officers and directors are charged with the responsibility of providing
management with accurate and complete information to assure we are
complying with our public disclosure requirements and our commitment to
our shareholders.
     Commensurate with these special duties, all members of Senior
Financial Management and other employees each agree that he or she will:
1. Act honestly and ethically in the performance of their duties at the
Company, avoiding actual or apparent conflicts of interest in personal and
professional relationships.
2. Provide information that is accurate, complete, objective, relevant,
timely and understandable to ensure full, fair, accurate, timely, and
understandable disclosure in reports and documents filed with or submitted
to the SEC or used in other public communications by the Company.
3. Comply with rules and regulations of federal, state, provincial, local
and overseas governments, as well as those of other appropriate private
and public regulatory agencies that affect the conduct of the Company's
business and the Company's financial reporting.
4. Act in good faith, responsibly, with due care, competence and
diligence, without misrepresenting material facts or allowing one's
independent judgment to be subordinated.
5. Respect the confidentiality of information acquired in the course of
one's work, except when authorized or otherwise legally obligated to
disclose such information. Further, confidential information acquired in
the course of performing one's duties for the Company will not be used for
personal advantage.
6. Share knowledge and maintain skills relevant to carrying out the
member's duties within the Company.
7. Proactively promote and set an example of ethical behavior as a
responsible partner among peers and colleagues in the work environment and
community.
8. Achieve responsible use of and control over all assets and resources of
the Company to which they are entrusted.
9. Promptly bring to the attention of the board of directors any
information concerning (a) any conduct believed to be a violation of law
or business ethics, or this Code, including any transaction or
relationship that reasonably could be expected to give rise to such a
conflict, (b) significant deficiencies in the design or operation of
internal controls which could adversely affect the Company's ability to
record, process, summarize and report financial data or (c) 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.
D. Reporting and Treatment of Violations
Persons who become aware of suspected violations of this Code should
report such suspected violations promptly to any member of the Company's
Board of Directors. To assist in the response to or investigation of the
alleged violation, the report should contain as much specific information
as possible to allow for proper assessment of the nature, extent and
urgency of the alleged violation. Without limiting the foregoing, the
report should, to the extent possible, contain the following information:

*	the alleged event, matter or issue that is the subject
	of the alleged violation;

*	the name of each person involved;

*	if the alleged violation involves a specific event or events, the
approximate date and location of each event;

*	and any additional information, documentation or other evidence
available relating to the alleged violation.

The Board of Directors has the power to monitor, investigate, make
determinations and take action with respect to violations of this Code. In
determining whether a violation of this Code has occurred, the Board of
Directors may take into account:

1.	The nature and severity of the violation;

2.	Whether the violation was a single occurrence or involved repeated
occurrences;

3.	Whether the violation appears to have been intentional or inadvertent;

4.	Whether the person in question had been advised prior to the violation
as to the proper course of action;

5.	Whether the person in question had committed other violations in the
past; and

6.	Such other facts and circumstances as the Board of Directors shall deem
advisable in the context of the alleged violation.