Code of Ethics for Managing Directors and Senior Financial Officers

This code of ethics for the Managing Directors and the Senior Financial Officers ("the code") of Coastal South Properties, CSP Construction, and subsidiary per-project corporations ("the Company") applies to the Company's principal executive officers, principal financial officers, principal accounting officers, controller and persons performing similar functions designated by the Company's Board of Directors (collectively, the "Senior Officers"). The Senior officers must conduct themselves in accordance with the principles and responsibilities set forth in their Code. Senior Financial Officers who violate this Code may be subject to disciplinary action. The Code has been adopted by management unanimously.

Each of the Senior Officers shall:

1. Act with honesty and integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships.

2. Avoid transactions that involve potential conflicts of interest, which have not been appropriately processed in accordance with Company policy or reviewed and approved by the Board of Directors or the appropriate Board committee; disclose to one of individuals designated in item 11, below, any material transaction or relationship that reasonably could be expected to give rise to such a conflict.

3. Provide full, fair, accurate, timely and understandable disclosure in reports and documents filed with, or submitted to, the SEC and in other public communications made by the Company.

4. Comply in good faith with applicable laws, rules, and regulations of federal, state, provincial and local governments, and other appropriate private and public regulatory agencies.

5. Act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing his or her independent judgment to be subordinated.

6. Respect the confidentiality of information acquired in the course of their work except when authorized or otherwise legally obligated to disclose. Confidential information acquired in the course of his or her work shall not be used for personal advantage.

7. Maintain skills important to his or her constituents' needs.

8. Promote ethical behavior as a responsible partner among peers in his or her work environment.

9. Achieve responsible use of and control over all assets and resources employed or entrusted to him or her.

10. Be accountable for adherence to this Code.

11. Promptly report any violations of their Code to one for the following persons: Chief Executive Officer, General Counsel, Chairman of the Audit Committee.