Code of Ethics
Hemophilia Options

Hemophilia Options. (the "Company") is adopting this Code of Ethics (the "Code") to formalize the Company's continuing expectations regarding ethical conduct. The Code applies to the directors, officers and employees of the Company and each of its subsidiaries.

This Code is intended to satisfy the requirements of Section 406 of the Sarbanes-Oxley Act of 2002 regarding the adoption of a code of ethics for senior officers and the rules of the NASDAQ Stock Market regarding the adoption of a code of conduct for directors, officers and employees.

Honest and Ethical Conduct

The Company is committed to conducting its business in accordance with the highest ethical principles. This Code is designed to accomplish this goal by setting forth the ethical standards which will govern the conduct of our directors, officers, and employees.

Conflicts of Interest

Directors, officers and employees have a duty to act in the best interests of the Company and its stockholders at all times. As part of this duty, directors, officers and employees should identify and disclose apparent conflicts of interest.

A "conflict of interest" exists where a person has a private or personal interest sufficient to influence the exercise of his or her duties to the Company. A conflict of interest is apparent where a reasonable person would think that the director, officer or employee's professional judgment is likely to be compromised by his or her personal or private interest. Conflicts of interest may also arise when a director, officer or employee, or members of his or her family, receives personal benefits as a result of his or her position in the Company.

While not all conflicts of interest are necessarily harmful to the Company, all apparent conflicts of interest must be identified as soon as possible and promptly disclosed to the Company's General Counsel and Corporate Compliance Officer, Joseph Bonaccorsi, for independent review.

Corporate Opportunities

Directors, officers and employees owe a duty to the Company to advance our legitimate business interests when the opportunity to do so arises. Directors, officers and employees are prohibited from taking for themselves (or directing to a third party) a business opportunity that is discovered through the use of corporate property, information or position, without the consent of the Board of Directors. No director, officer or employee may use corporate property, information or position for improper personal gain, and no director, officer or employee may compete with the Company directly or indirectly.

Any use of Company property or services that is not solely for the benefit of the Company must be approved in advance by the Company's General Counsel.

Business Entertainment and Gifts

The purpose of business entertainment and gifts in a commercial setting is to create good will and sound working relationships, not to gain unfair advantage with customers. Directors, officers and employees of the Company may not accept gifts from persons or entities where any such gift is being made in order to influence their actions in their position with the Company, or where acceptance of the gifts could create the appearance of a conflict of interest.