Exhibit 9


                                 CODE OF ETHICS


                                 NEUROCHEM INC.

                                 CODE OF ETHICS

          Neurochem Inc. (the "CORPORATION") expects all of its directors,
officers and employees to comply with the laws and regulations governing its
conduct and further is committed to promoting integrity and maintaining the
highest standard of ethical conduct in all of its activities. The Corporation's
business success is dependent on trusting relationships, which are built on this
foundation of integrity. Our reputation is founded on the personal integrity of
the Corporation's personnel and accordingly this Code of Ethics is applicable to
all of the Corporation's directors, officers and employees.

          Each of us, as part of the Corporation, occupies a position of trust
in our relations with fellow employees, customers, competitors, suppliers,
government authorities, investors and the public. Whatever the area of activity,
we should, of course, be honest and responsible in our relations with others.

          If there are any doubts as to whether a course of action is proper, or
about the application or interpretation of any legal requirement, discuss it
with your immediate supervisor. You may also discuss it with the Corporation's
Chief Financial Officer who, if appropriate, will seek the advice of the
Corporation's legal counsel.

          This is not a complete Code of Ethics. No statement can offer a
complete guide to cover all possible situations that might be encountered. There
are some areas, however, which because of their special importance, deserve
particular attention and these are set out in what follows.

CONFLICT OF INTEREST

          Each director, officer or employee, including in particular senior
financial officers, (collectively the "EMPLOYEES") of the Corporation must avoid
any conflict, or perception of conflict, between his or her personal interests
and the interests of the Corporation in transacting the Corporation's business.
All actions and decisions by Employees in the performance of work must be based
on impartial and objective assessments of the Corporation's interests in the
situation, totally without regard to any gifts, favours, or similar benefits
from outside parties that could affect (or be seen by others to possibly affect)
their judgment. Any gift, loan to or guarantee of obligation of, or benefit of
any kind that has a value in excess of $100 must be approved by the Chief
Financial Officer or, in his absence, the General Counsel.

          No Employee shall have any financial interest or position with any
entity that transacts business with or competes with the Corporation other than
the ownership of a minor percentage of shares in a public company without,
immediately disclosing these interests and obtaining the approval of the Chief
Financial Officer or, in the case of directors or officers, the board of
directors of the Corporation (the "BOARD").





CORPORATE OPPORTUNITIES

          Employees are prohibited from (a) taking for themselves personally
corporate opportunities that are discovered through the use of corporate
property, information or position; (b) using corporate property, information or
position for personal gain; and (c) competing with the Corporation. Employees
owe a duty to the Corporation to advance its legitimate interests when the
opportunity to do so arises.

FAIR DEALING

          Each Employee should endeavour to deal fairly with the Corporation's
customers, suppliers, competitors and employees. No one should take unfair
advantage of anyone through manipulation, concealment, abuse of privileged
information, misrepresentation of material facts, or any other unfair-dealing
practice.

PROTECTION AND PROPER USE OF CORPORATION ASSETS

          All Employees should protect the Corporation's assets and ensure their
efficient use. Theft, carelessness and waste have a direct impact on the
Corporation's profitability. All of the Corporation's assets should be used for
legitimate business purposes.


COMPLIANCE WITH LAWS, RULES AND REGULATIONS (INCLUDING INSIDER TRADING LAWS)

          The Corporation will proactively promote compliance with laws, rules
and regulations, including insider trading laws. The Corporation views insider
trading as both unethical and illegal and will deal with it decisively. In this
regard, Employees are referred to the Corporation's Disclosure and Trading
Policy


CONFIDENTIALITY

          Employees will be required to maintain the confidentiality of
information entrusted to them by the Corporation or its trading partners as
required by the Corporation's Disclosure and Trading Policy. Confidential
information includes all non-public information that might be of use to
competitors, or harmful to the Corporation or its trading partners, if
disclosed.

FAIR FINANCIAL REPORTING AND PUBLIC COMMUNICATIONS

          Information in the Corporation's public communications, including
periodic financial reports required to be filed by the Corporation and
communications with shareholders, must be full, fair, accurate, timely and
understandable. All Employees who are involved in the Corporation's disclosure
process, including the senior financial officers (which include the Chief
Executive Officer, the Chief Financial Officer and the Corporate Controller) are
expected to act in furtherance of this Policy. In particular, these individuals
are required to be familiar with the disclosure requirements for the Corporation
and are prohibited from knowingly misrepresenting, omitting, or causing others
to misrepresent or omit, material facts about the Corporation to others, whether
within or outside the Corporation, including the Corporation's independent


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auditors. Additionally, any Employee with a supervisory role in the
Corporation's disclosure process is required to discharge his or her
responsibilities diligently.

SEXUAL HARASSMENT

          Sexual harassment by an individual, regardless of seniority, is
regarded as unacceptable conduct, and all Employees must comply with applicable
legislation.

DISCLOSURE

          In the event that a breach of this Policy has occurred or if an
Employee is concerned that a breach has or may occur, the Employee has an
obligation to immediately disclose the situation and facts to his supervisor,
the Chief Financial Officer or to the General Counsel for their counsel and
direction. Potential conflicts of Board members shall be disclosed to the Board
itself in accordance with Board guidelines and obligations. Every Employee has
an obligation to provide full and complete disclosure. An undisclosed breach is
a more serious violation of trust than an early and full disclosure of the
situation.

          If any Employee believes that he or she may have a personal interest
which could be construed or perceived by others to be in conflict with their
position as an Employee they have an obligation to make full and complete
disclosure as noted above.

          The Chief Executive Officer, the Chief Financial Officer or the Board
may, if a conflict is disclosed fully and in advance, permit the conflict in
certain instances, if deemed reasonable.


WAIVER

          Any waiver of this Policy for executive officers or directors of the
Corporation may be made only by the Board or a committee of the Board and must
be promptly disclosed to the Corporation's shareholders.

COMPLIANCE

          A violation of this Policy will result in disciplinary action and
could result in dismissal for cause or removal from the Board of Directors, as
the case may be.



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