CODE OF BUSINESS CONDUCT



INTRODUCTION



The Plastipak Holdings, Inc. Code of Business Conduct ("Code") applies to all

representatives, Associates (defined as any person who is employed by the

Company), including but not limited to supervisors, managers, consultants,

directors, officers and any other persons whose business activities are

conducted for Plastipak Holdings, Inc. and/or any of its subsidiaries

(collectively, the "Company"). The Code requires all Associates of the Company

to act ethically when conducting the business of the Company. This Code provides

a summary of the conduct required from all Associates of the Company, and is a

source for guidance, modification, accountability for, and enforcement of its

provisions; and is hereby incorporated into the Company handbooks.



The integrity of the Company must not ever be compromised for the personal

benefit of an Associate, Customer or Supplier. Early identification and

resolution of ethical issues are critical to maintaining our commitment to

ethical business practices. If you are unsure of what to do in any situation,

seek additional guidance and information from the Company's designated Chief

Compliance Officer identified on the Company's website. You may remain

anonymous.



You are responsible to know and comply with the provisions of the Code. Failure

to comply with the Code could result in disciplinary action, up to and including

termination of employment. In addition, violation of the Code may also be a

violation of either civil or criminal law and may result in civil or criminal

penalties for you, your supervisor, and the Company. Company policy and the law

prohibit retaliatory action against any Associate for reporting suspected

violations of the Code or for raising legitimate concerns or questions regarding

ethics matters.



This Code does not constitute a contract of employment for a definite term or a

guarantee of continued employment.



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                                                                      Exhibit 14



CONFLICTS OF INTEREST



It is fundamental to this Code that the conduct of all business dealings of the

Company be carried out in the best interest of the Company and within

appropriate ethical and legal boundaries. Associates should not have personal

interests that conflict with the interests of the Company.



Financial Interests and Investments in Suppliers, Customers and Competitors



THIS CODE PROHIBITS FINANCIAL CONFLICTS OF INTEREST RELATED TO INVESTMENTS IN OR

OTHER INTERESTS IN SUPPLIERS, CUSTOMERS AND COMPETITORS. THE PROHIBITIONS

CONTAINED IN THE CODE IN THIS RESPECT APPLY NOT ONLY TO THE ASSOCIATE, BUT ALSO

APPLY TO ANY IMMEDIATE FAMILY MEMBERS LIVING IN THE SAME HOUSEHOLD AS THE

ASSOCIATE. THE CODE PROHIBITS A CONFLICT OF INTEREST OR THE APPEARANCE OF A

CONFLICT OF INTEREST. AN ASSOCIATE MUST SUBMIT TO THE CHIEF COMPLIANCE OFFICER

ANY FACT SITUATION THAT IS, OR POTENTIALLY CONSTITUTES, A CONFLICT OF INTEREST

OR THE APPEARANCE OF A CONFLICT OF INTEREST. THE COMPLIANCE OFFICER WILL

DETERMINE THE COURSE OF ACTION REQUIRED BY THIS CODE.



Some examples of a financial interest prohibited by this Code are a financial

interest or investment in any entity (by an officer of the Company, or an

Associate that is involved in the procurement of goods and services, or who

influences the decisions made regarding the selection of a particular vendor or

supplier of goods or services) that (a) competes with; (b) is a supplier to; or

(c) is a customer of the Company. This does not include investments that are (a)

held through a publicly traded mutual fund; or (b) equal to or less than

$25,000, provided that any changes in value above the limit during the year are

not the result of additional investment by the Associate. Associates in the

category described in this paragraph must disclose to the Chief Compliance

Officer any investments or financial interests of this nature annually by

October 1st of each year. For other Associates, there is no limit to the

investment or financial interest in the publicly traded securities of suppliers

or customers and no disclosure requirement under the Code.



Any investments made prior to the Associate becoming employed by the Company may

be retained provided the Associate registers the investment with the Chief

Compliance Officer at the time this policy is effective and provided no

additional investment is made during the time the Associate is employed by the

Company.



In instances where the application of this policy results in extreme hardship,

the Associate may request the Chief Compliance Officer seek a waiver from the

Board of Directors of the Company.



All officers of the Company and Associates that are paid on the executive

payroll are required to disclose annually (prior October 1st of each year) all

of their investments (whether or not they are competitors, suppliers, or

customers) by name, but not by amount. All Associates must disclose all

investments that are or may be prohibited by this Code (competitor, supplier or

customer) annually by furnishing a list to the Chief Compliance Officer of the

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