EXHIBIT 14.0 - Code of Ethics

                                PPOL, INC.
                              CODE OF ETHICS

I.       INTRODUCTION, PURPOSE AND APPLICATION
         This Code of Ethics (the "Code") is adopted by the Board of Directors
         of PPOL, Inc. and its subsidiary (the "Company") to help us to ensure
         compliance with legal requirements, specifically Section 406 of the
         Sarbanes-Oxley Act of 2002 and the Securities and Exchange Commission
         (the "SEC") rules promulgated thereunder, and is applicable to the
         actions and conduct of all employees, officers and directors of the
         Company in carrying out the business of the Company. The purpose of
         this Code is to provide guidance to our employees, officers and
         directors in order to help the Company to maintain the highest possible
         standards of ethical, moral and legal business conduct. It also
         provides a framework for ethical business conduct, recognizing that it
         is not possible to establish rules governing every possible instance
         that could potentially affect the reputation and business of the
         Company.

II.      ETHICAL CONDUCT
         It is the policy of the Company that each employee, officer and
         director will:
         1.       Act with honesty and integrity.
         2.       Avoid actual conflicts of interest between personal and
                  professional relations and disclose to senior management, a
                  member of the Company's Audit Committee or Board of Directors
                  any material transaction or relationship that reasonably could
                  be expected to give rise to an actual or apparent conflict of
                  interest;
         3.       Promote full, fair, accurate, timely, and understandable
                  disclosure in reports and documents that the Company files
                  with, or submits to, the Securities Exchange Commission or
                  other public communications made by the Company;
         4.       Comply with applicable governmental laws, rules and
                  regulations;
         5.       Report promptly any conduct that the individual believes to be
                  a violation of this Code to senior management, a member of the
                  Company's Audit Committee or Board of Directors. It is against
                  the Company's policy to retaliate in any way against an
                  employee for good faith reporting of violations or suspected
                  violations of this Code;
         6.       Promote accountability for adherence to the Code.

III.     ACCOUNTABILITY
         Actual violations of this Code, including failures to report potential
         violations by others, can lead to disciplinary action at the Company's
         discretion, up to and including employment termination or removal from
         the Board of Directors.

IV.      WAIVER AND AMENDMENT
         The Company is committed to continuously reviewing and updating its
         policies and procedures. Therefore, this Code is subject to
         modification. Any amendment or waiver of any provision of this Code
         must be approved in writing by the Company's Board of Directors and
         promptly disclosed pursuant to applicable laws and regulations. Any
         waiver of the Code for executive officers or directors may be made only
         by independent members of the Board of Directors and must promptly be
         disclosed to stockholders.