<DOCUMENT>
<TYPE>EX-99.77D POLICIES
<SEQUENCE>2
<FILENAME>ex9977.txt
<TEXT>
Exhibit 99.77D


Code of Ethics for CEO and Finance Leaders

In my financial leadership role with Willamette Valley Vineyards, Inc, I
recognize that I hold an important and elevated role in corporate governance.
I am charged with ensuring that stakeholders' interests are appropriately
balanced, protected and preserved. Accordingly, this Code provides principles
to which I am expected to adhere.

To the best of my knowledge and ability, in executing my job responsibilities:

1. I act with honesty and integrity, avoiding actual or apparent conflicts of
interest.

2. I provide internal and external constituents with appropriate and
objective information that is full, fair, accurate, timely and understandable.

3. I act in good faith, responsibly, with due care, competence and diligence,
without misrepresenting material facts or allowing my independent judgment to
be compromised.

4. I respect the confidentiality of information acquired in the course of my
work except when authorized or otherwise legally obligated to disclose. I
will not use confidential information acquired in the course of my work for
personal advantage.

5. I proactively promote ethical behavior as a responsible partner among
others in my work environment. I understand my accountability for adhering to
this code and my responsibility to report violations of this code to the
Audit Committee or other appropriate officials in accordance with Willamette
Valley Vineyard's Employee Handbook and Policies.

6. I exercise responsible stewardship over company assets and resources and
maintain appropriate internal controls.

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