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                                                                    Exhibit 14.1

                                  AMINCOR, INC.
                                 CODE OF ETHICS

ADOPTED AS OF 12/31/10

This Code of Conduct and Ethics (this "Code") shall apply to all directors and
officers, or persons performing similar functions, and all employees
(collectively, the "Covered Persons") of Amincor, Inc. (the "Corporation").
Covered Persons have an obligation to the Corporation, its investors and the
investment community in general to maintain the highest standards of honest and
ethical conduct. In recognition of this obligation, the Covered Persons have
adopted the following standards of ethical conduct. Adherence to these standards
is integral to achieving the objectives of the Corporation and its investors.
None of the Covered Persons shall commit acts contrary to these standards nor
shall they condone the commission of such acts by advisors, agents or others
engaged by the Corporation.

GENERAL STANDARDS AND COMPLIANCE WITH LAWS

The Covered Persons have a responsibility to:

     *    Maintain high standards of honest and ethical conduct.

     *    Act in good faith, responsibly and without misrepresenting material
          facts or allowing their independent judgment to be compromised.

     *    Refrain from engaging in any activity that would prejudice their
          ability to carry out their duties ethically.

     *    Refrain from engaging in or supporting any activity that would
          discredit the Corporation.

     *    Comply with rules and regulations of federal, state and local
          governments, and appropriate private and public regulatory agencies or
          organizations.

AVOIDANCE OF CONFLICTS OF INTEREST AND IMPROPER INFLUENCES

The Covered Persons have a responsibility to:

     *    Avoid actual or apparent conflicts of interest between personal and
          Corporation-related relationships. In particular, Covered Persons
          should not participate in a personal business transaction with the
          Corporation in which they will receive a significant profit or gain,
          unless otherwise approved by the board of directors of the Corporation
          (the "Board") in accordance with the Delaware General Corporation Law.
          Covered Persons should advise the Board of any prospective or existing
          potential conflict.

     *    Refuse any gift, favor or hospitality that would influence or would
          appear to influence their actions.

     *    In any dealings with a government official, supplier or other person
          or entity, the Covered Persons shall not request, accept or offer to
          give any significant thing of value, the purpose or result of which
          could be to influence the bona fide business relations between the
          Corporation and such persons or entities.

PROFESSIONAL COMPETENCE

The Covered Persons have a responsibility to:

     *    Maintain an appropriate level of professional competence by continuing
          development of their knowledge and skills.

     *    Perform their professional duties in accordance with relevant laws,
          regulations and technical standards.

     *    Prepare full, fair, accurate, timely and understandable financial
          statements, reports and recommendations after appropriate analyses of
          relevant and reliable information.

CONFIDENTIALITY

The Covered Persons have a responsibility to protect the Corporation by:

     *    Refraining from disclosing to others confidential information acquired
          in the course of their work except when authorized to do so.

     *    Refraining from using or appearing to use confidential information
          acquired in the course of their work for unethical or illegal
          advantage either personally or through third parties.

PROHIBITION OF LOANS

     *    No Covered Persons shall request or accept a loan or advance from the
          Corporation.

REPORTING; ACCOUNTABILITY; DISCIPLINARY ACTION; ANTI-RETALIATION; COMPLIANCE AND
WAIVER

All Covered Persons are expected to read and be familiar with this Code of
Ethics. All Covered Persons will be held accountable for their compliance with
and adherence to this Code of Ethics. Copies of this Code of Ethics will be
supplied to all Covered Persons.

Failure to observe the terms of this Code of Ethics may result in disciplinary
action, up to and including termination of employment. Disciplinary action will
be determined based on the facts and circumstances of each particular situation.
Violations of this Code of Ethics, together with the corresponding disciplinary
action, may be made public by the Corporation. Violation of this Code of Ethics
may also constitute a violation of law and may result in civil and criminal
penalties.

All Covered Persons have a duty and obligation and are required to promptly
notify the Board of any known or suspected violations of this Code of Ethics or
any policies or procedures established pursuant to this Code of Ethics, together
with a full disclosure of the known facts and circumstances of such violation or
suspected violation. Failure to do so may itself constitute a violation of this
Code of Ethics. Covered Persons are expected to identify and report known
potential issues before they lead to problems. Upon the request of the person
reporting any violation or potential violation of this Code of Ethics, the
Corporation will use reasonable efforts to keep all such communication
confidential, subject to any disclosure required by applicable law. Covered
Persons have the right to choose to remain anonymous in reporting any possible
violation of this Code of Ethics. Except to the extent required by applicable
law, any Covered Person reporting any violation or potential violation of this
Code of Ethics must not discuss or disclose any information relating to any
ensuing investigation or the related complaint to any person not involved in
such investigation.

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At no time will there be any retaliation by the Corporation against any Covered
Person who acts in good faith in reporting any violation or suspected violation
of this Code of Ethics or any potential issue with respect to this Code of
Ethics. Additionally, the Corporation strictly prohibits any retaliation against
any Covered Person who reports in good faith any violation or suspected
violation of this Code of Ethics. Any retaliation against any Covered Person
will be subject to disciplinary action, including potential termination of
employment.

Any request for a waiver of any provision of this Code must be in writing and
addressed to the Board. Any waiver of this Code must be disclosed promptly on a
current report on Form 8-K or by any other means approved by the Securities and
Exchange Commission.

If any Covered Person has any questions regarding this Code of Ethics, or the
best course of action in a particular situation, they should promptly contact
the Board.

This Code of Ethics is not intended to and does not constitute a contract of
employment. The Corporation reserves the right, at any time and from time to
time, to amend, supplement, replace or eliminate this Code of Ethics in its sole
and absolute discretion and without any prior notice.

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