Exhibit 14.1

ICG GROUP, INC.

CORPORATE CODE OF CONDUCT

This Corporate Code of Conduct (this “Code”) sets forth the basic principles that guide the conduct of the officers, directors and employees of ICG Group, Inc. (f/k/a Internet Capital Group, Inc.) (the “Company”) and its wholly-owned or wholly-controlled subsidiaries (such subsidiaries, together with the Company, “ICG”). ICG requires each of its consolidated partner companies to adopt a corporate code of conduct that is acceptable to ICG. This Code was adopted on February 7, 2001 and was amended and restated on February 13, 2004 and February 27, 2009, each time to clarify and supplement existing Code guidance in light of developments in applicable law and best corporate governance practices, as well as ICG’s organizational development. This Code was also amended and restated on June 20, 2011 in order to reflect the Company’s corporate name change.

Every ICG officer, director and employee is expected at all times to comply with both the letter and the spirit of all applicable laws and regulations and to adhere to the highest standards of ethics, morality and honesty in the performance of his or her duties at ICG. Each ICG officer, director and employee also has a duty of loyalty to further ICG’s aims and goals and to work on behalf of ICG’s best interests. To that end, ICG’s officers, directors and employees must comply in all respects with this Code and all current and future ICG policies, including those set forth on Appendix A to this Code.

Violations and waivers of, and amendments to, this Code will be disclosed as required by applicable laws, rules and regulations. Those who violate this code will be subject to disciplinary action, including termination, as described in Section 14 of this Code.

Obeying the law, both in letter and spirit, is the foundation on which ICG’s ethical standards are built. All ICG officers, directors and employees must respect and obey the laws, rules and regulations of the countries, states and municipalities in which ICG operates. If an applicable local law, rule or regulation conflicts with a policy of this Code, ICG officers, directors and employees must comply with the applicable law, rule or regulation; however, if an applicable law, rule or regulation requires standards that are less stringent than this Code or ICG policy, they must comply with this Code or such ICG policy in addition to complying with the applicable law, rule or regulation. Although not all officers, directors and employees are expected to know the details of all applicable laws, rules and regulations, it is important that they know when to seek advice from supervisors, managers or other appropriate ICG personnel. If any officer, director or employee has any question regarding the applicability or content of any law, rule or regulation as it pertains to his or her duties at ICG, that person should consult with the Company’s Legal Department.

From time to time, ICG may be involved in various types of litigation or legal action. ICG may first receive notice of actual or threatened legal action in the form of a letter or in the form of a summons and complaint. If any ICG officer, director or employee receives any such notification or threat of a lawsuit against ICG or against such ICG officer, director or employee acting in his or her capacity as such, that person must immediately report such notification to the Company’s General Counsel.

All ICG officers, directors and employees, and specifically the Company’s Chief Executive Officer, Chief Financial Officer, Controller and other similar financial and accounting officers (the “Senior Financial Officers”) must comply with this Code, the other ICG policies listed in Appendix A to this Code and all applicable rules and standards of the U.S. Securities and Exchange Commission (the “SEC”), the Financial Accounting Standards Board, the NASDAQ Stock Market LLC and other regulatory bodies.

In particular, the Senior Financial Officers are responsible for full, fair, accurate, timely and understandable disclosure in the periodic reports that the Company files with the SEC and will promptly bring to the attention of the Company’s Disclosure Committee any material information of which he or she becomes aware that could affect such disclosures. The Senior Financial Officers must promptly bring to the attention of the Audit Committee of the Company’s Board of Directors (the “Board”) any information that he or she may have regarding:

ICG requires honest and accurate recording and reporting of financial and other information in order to make responsible business decisions and full, fair, accurate, timely and understandable financial and other disclosures to regulatory agencies and the public. ICG must maintain internal controls to ensure that transactions are properly authorized, that assets are safeguarded, that operations are conducted in accordance with Board and management directives and that financial records are reliable. All of ICG’s books, records, accounts and financial statements must be maintained in reasonable detail, must be supported by adequate

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documentation, must accurately and appropriately reflect ICG’s transactions and must conform both to applicable legal requirements and to ICG’s system of internal controls. Unrecorded funds or assets, such as “slush funds,” may not be maintained. No false or fictitious entries may be made on ICG’s books and records. If an ICG officer, director or employee is not sure (a) whether a certain expense or transaction is legitimate or (b) how to properly account for an expense or transaction, he or she must ask his or her supervisor or the Company’s Chief Financial Officer. In addition to the obligations of the Senior Financial Officers contained in Section 3 of this Code, any officer, director or employee who becomes aware of any questionable accounting or auditing matters, or of the reporting of fraudulent information to ICG stockholders, the government or financial markets, must promptly report the situation in accordance with the Company’s separate, more detailed Financial Information Integrity Policy.

ICG must maintain disclosure controls to ensure that required information is timely recorded, processed, summarized and reported as required by applicable laws and regulations. Required information must be communicated to management in a timely manner in order to allow timely decisions regarding disclosure. Financial statements for external purposes must be fairly presented in conformity with generally accepted accounting principles accepted in the United States or other applicable standards required by applicable laws and regulations. Public statements and filings regarding ICG’s business and financial status must be true, accurate, complete, timely and not misleading.

It is critically important that all employees carefully read and understand the Company’s Financial Information Integrity Policy and Company Information Disclosure Policy. Any ICG officer, director or employee who has any questions regarding either of these policies should contact the Company’s General Counsel or Chief Financial Officer.

ICG officers, directors and employees have a duty to advance ICG’s legitimate interests when the opportunity to do so arises. A conflict of interest exists when the private interests of an officer, director or employee interfere with that person’s ability to advance ICG’s legitimate interests. Conflict situations often arise when an officer, director or employee takes actions or has interests that may make it difficult to perform his or her duties objectively and effectively. Conflicts of interest could also arise in the context of an officer, director or employee, or members of his or her family, receiving improper personal benefits as a result of his or her position at ICG. Potential and actual conflicts of interest should be avoided where reasonably practicable. If a conflict cannot be reasonably avoided, it must be disclosed and managed in an ethical and responsible manner. To that end, ICG’s officers, directors and employees are prohibited from knowingly engaging in any transaction or relationship that may reasonably be expected to give rise to a conflict of interest without disclosing such transaction or relationship to the Company’s General Counsel in a timely manner.

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Because ICG acquires and holds stakes in a number of companies, potential and actual conflicts of interest can arise in connection with investments made by directors, officers and employees for their personal benefit. Set forth in the following list are certain prohibitions and guidelines with respect to the investment activities of officers, directors and employees of ICG:

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Set forth in the following list are a number of prohibitions relating to other typical conflict of interest situations.

The foregoing lists do not address every possible conflict of interest situation that an ICG director, officer or employee may face. If an officer, director or employee has any question relating to a specific situation or ICG’s conflict of interest policy in general, he or she should consult the Company’s General Counsel. Also, officers, directors and employees should consult the Company’s separate, more detailed Policies and Procedures for Related Party Transactions and should keep in mind the guidelines set forth in Section 16 of this Code.

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Disclosure of potential and actual conflicts of interest is extremely important. Any ICG officer, director or employee who becomes aware of any transaction or relationship that may reasonably be expected to give rise to a conflict of interest, including, but not limited to, any of the activities described above (including any Permitted Activity) must promptly bring it to the attention of the Company’s General Counsel. The Company’s General Counsel must promptly inform the Company’s Chief Executive Officer and/or the Nominating and Governance Committee of the Board of any such transaction or relationship. The Company’s Chief Executive Officer, General Counsel and/or the Nominating and Governance Committee of the Board may take such actions as are necessary and proper to remove or alleviate the conflict, if any, which actions may include procedural safeguards, removal of an officer’s, director’s or employee’s discretion in the area of conflict, reassignment of an officer, director or employee, or prohibition against continued participation in the conflicting activity. The resolution of a potential conflict situation by the Company’s Chief Executive Officer, General Counsel and/or the Nominating and Governance Committee of the Board, consistent with the provisions of this Code, will not constitute a violation or waiver of this Code or the Company’s Policies and Procedures for Related Party Transactions.

ICG officers, directors and employees must maintain the confidentiality of, and must not improperly use, any confidential information entrusted to them in connection with their service to ICG, except when disclosure is authorized by the Company’s Legal Department or required by applicable laws or regulations. Additionally, no ICG officer, director or employee may improperly use or disclose in connection with his or her service to ICG any confidential information obtained outside of the scope of his or her service to ICG, including from his or her former employer.

Confidential information includes any and all proprietary or confidential information relating to ICG, as well as its partner companies, acquisition candidates, investors, customers, suppliers and other potential and existing business partners. Confidential information is generally described as information that is proprietary in nature, sensitive, not generally known, would be considered a trade secret, or which is marked or treated as confidential. All non-public information about ICG should be considered confidential information. Examples of confidential information include (a) information relating to pending acquisitions, divestments, joint ventures or other major business transactions, (b) trade secrets, patents, trademarks and copyrights, (c) business plans, forecasts and any unpublished financial data and reports, (d) marketing plans, engineering and product ideas, designs, databases, records, salary information and (e) any other information subject to any obligation or agreement of confidentiality. If an officer, director or employee is unsure whether a particular piece of information is subject to confidentiality obligations, he or she should consult with the Company’s Legal Department.

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ICG has adopted an Insider Trading and Disclosure Policy to restrict the use and disclosure of non-public material information by officers, directors and other insiders and to ensure that ICG’s officers, directors and other insiders comply fully with federal securities laws when trading in securities of the Company and its public partner companies. Under federal securities laws, corporate insiders cannot trade in the stock of their companies or on the basis of non-public material information, nor can they “tip” others with material information that the recipients may use to trade in their companies’ securities. These laws are designed to put all investors on an equal footing, permitting them to rely on the same information in making investment decisions. Anyone who has knowledge of non-public and material information may be considered an insider for this purpose.

It is critically important that all ICG’s officers, directors and employees carefully read and understand the Company’s separate, more detailed Insider Trading and Disclosure Policy. Any ICG officer, director or employee with any questions about this policy should contact the Company’s General Counsel.

ICG resources, including (but not limited to) computers, faxes, office telephones, mobile telephones, BlackBerries and similar wireless devices are intended for company-related business use. ICG understands that employees may sometimes use such resources for limited personal interests. However, such personal use should be reasonable in scope and amount and must be consistent with the standards set forth in this Code and ICG’s Policy Prohibiting Sexual and Other Harassment. ICG reserves the right to examine, use, copy and/or delete the user files and related data of any ICG officer, director or employee for purposes consistent with (a) the furthering of ICG’s business interests and (b) the enforcement of this Code and ICG’s other policies.

ICG’s success is contingent upon its ability to build and maintain strong business relationships, not only with ICG employees but also with current and prospective ICG partner companies, consultants, customers, suppliers and other business partners. It is important that those who deal with ICG feel confident and secure that the relationships are fair, honest and based on mutual respect. It is sometimes customary for persons or companies involved in a business relationship to exchange gifts or other gratuities. For instance, during the course of a business relationship, the parties may conduct meetings over lunch or dinner, the celebration of a deal may facilitate the exchange of novelties, or, during the holidays, one party may invite the other to a holiday event. The appropriateness of exchanging such gratuities will depend on the circumstances surrounding the particular exchange. To protect ICG and its employees and directors from possible claims of bribery or special treatment, appropriate guidelines must be followed with respect to any such exchange.

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In general, it is best to use a “reasonableness” standard in determining whether to offer or accept gifts or meals. ICG officers, directors and employees should avoid offering or accepting any gift or meal that is lavish or beyond what would be reasonable or expected, given the particular circumstances. The following guidelines should be helpful in deciding whether a particular action would be reasonable:

The appropriateness of any gift, meal or other gratuity will depend on the relevant circumstances, including the relevant business relationship. If you have any questions as to the appropriateness of a particular gift, meal or other gratuity, please discuss the situation with the Company’s General Counsel.

ICG promotes a work environment where the dignity, worth and differences of each individual are valued and respected. ICG prohibits discrimination, harassment or intimidation that is unlawful or otherwise violates ICG policies and has adopted a Policy Prohibiting Sexual and Other Harassment to foster a work environment that is free from all forms of discriminatory harassment. Discrimination and harassment, whether based on a person’s race, gender, color, religion, national origin, age, disability, veteran status or other legally protected characteristic, are repugnant and completely inconsistent with our tradition of providing a respectful, professional and dignified workplace. Moreover, depending on the relevant circumstances, such conduct may violate federal, state and local laws. Accordingly, all officers, directors and employees of ICG are expected to avoid any behavior that could be interpreted or perceived as discriminatory harassment.

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ICG will promptly investigate all allegations of harassment or discrimination and will take appropriate corrective action. Retaliation against individuals for raising good faith claims of harassment and discrimination is prohibited. It is important that ICG’s officers, directors and employees understand ICG’s Policy Prohibiting Sexual and Other Harassment. If you have any questions about this policy, please contact the Company’s Legal Department.

ICG strives to provide a safe and healthy work environment at its facilities. Each ICG officer and employee has responsibility for maintaining a safe and healthy ICG workplace by following safety and health rules and practices and reporting accidents, injuries and unsafe equipment, practices and conditions. ICG officers, directors and employees are expected to be fit for duty and capable of performing their responsibilities in a safe and productive manner, free from any substance abuse; substance abuse of any form in the workplace will not be tolerated. Any ICG officer, director or employee with a health, safety or environmental concern must promptly report his or her concern to the Human Resources manager. The failure of any officer, director or employee to do so would not only violate ICG policy but may also violate federal, state and local laws and regulations.

ICG does not make contributions to political campaigns. ICG does not solicit or inquire as to individual political contributions and will not reimburse employees for any such contributions.

The U.S. government has a number of laws and regulations regarding the acceptance of business-related gratuities by U.S. government personnel. The promise, offer or delivery to an official or employee to the U.S. government of a gift, favor or other gratuity in violation of these rules would not only violate ICG policy but could also constitute a criminal offense. State and local governments, as well as foreign governments, may have similar rules. The Foreign Corrupt Practices Act (“FCPA”) prohibits a company and its employees and agents from directly or indirectly (e.g., through an agent, partner, reseller or third party) providing, or promising to provide, anything of value to any foreign governmental employee or official (including a political party, party official or candidate for political office) for the purpose of influencing an official act or decision to obtain business for the company. Violations of the FCPA or other laws and regulations governing payments to government officials could result in substantial monetary penalties for the guilty company and substantial prison sentences and monetary penalties for the individuals involved.

All contributions, payments or gratuities to foreign officials, even those that appear to be routine in the relevant country, must be approved in advance by the Company’s General Counsel, subject to his or her determination that such payment is in accordance with local law and custom, violates no applicable laws (U.S. or otherwise) and is not made for the purpose of improper influence. Any ICG officer, director or employee who has any questions regarding the propriety of any payment to a government official should consult the Company’s General Counsel.

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When an ICG officer, director or employee learns of activity that may violate this Code, any ICG policy or any applicable law, rule or regulation (including any inadvertent violation by him or her), it is such person’s responsibility to promptly report the activity to his or her supervisor, the Company’s Chief Executive Officer, General Counsel or Human Resources manager. Any such activity that relates to questionable accounting, internal accounting controls, auditing matters or the reporting of fraudulent financial information must be reported in accordance with the Company’s separate, more detailed Financial Information Integrity Policy. If any supervisor at ICG has received information from an officer, director or employee or becomes aware of any activity that he or she believes may violate this Code, any ICG policy or any applicable law, rule or regulation, that person is required to promptly report the matter to the Company’s Chief Executive Officer, General Counsel or Human Resources manager; such individuals will investigate the matter and consult with supervisors, managers and other appropriate personnel and, if appropriate, with the Board or an appropriate committee thereof regarding observed illegal or unethical behavior and the best course of action to take in response to such behavior. In many cases, prompt reporting can substantially reduce the adverse impact on all involved.

In any case in which a report has been made by an ICG officer, director or employee, whether with respect to himself, herself, or others, ICG will investigate and keep the officer, employee or director informed of its progress to the extent permitted by law or as otherwise appropriate under the circumstances. The report and subsequent investigation will be handled with sensitivity and treated confidentially to the extent reasonably possible in light of the nature of the report and ICG’s responsibility to address the issue raised. ICG strictly forbids any form of punishment of, or retaliation against, any ICG officer, director or employee, who, in good faith and for lawful purposes, directly or indirectly (a) reports or assists in the investigation of suspected improper, unethical or illegal conduct or activities by anyone at ICG, including pursuant to this Code or any other ICG policy, or (b) lawfully provides information to, or assists in an investigation conducted by, any federal, state or local regulatory or law enforcement agency or legislative body concerning the topics addressed by this Code or any other ICG policy.

In addition to any other rights and remedies available to ICG to protect its interests under applicable law, any ICG officer, director or employee who fails to comply with the standards contained in this Code is subject to disciplinary action, including termination of such person’s employment or service with ICG. Any person charged with a violation under this Code will be afforded an opportunity to explain his or her actions before disciplinary action is taken. Disciplinary action may be taken against:

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Any amendment or waiver of this Code for any Company executive officer or director may be made only by the Board (or an authorized committee thereof) and will be disclosed promptly as required by applicable law, rule or regulation.

ICG’s officers, directors and employees must all work to ensure prompt and consistent action against violations of this Code. However, it is often difficult to determine whether a violation has in fact occurred in a particular situation or what action this Code requires an ICG officer, director or employee to take or refrain from taking in a particular situation. To aid in making these often difficult determinations, set forth below are some guidelines for ICG officers, directors and employees to consider when addressing a new question or problem relating to the Code.

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APPENDIX A

ICG POLICIES