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                                                                      Exhibit 14

                             GOLF HOST RESORTS, INC.
                                 CODE OF ETHICS

The Company is committed to conducting its business in accordance with
applicable laws, rules and regulations and the highest standards of business
ethics, and to full and accurate financial disclosure in compliance with
applicable law. This Code of Ethics, applicable to the Company's Chief Executive
Officer, Chief Financial Officer, Principal Accounting Officer and Controller
(or persons performing similar functions) (together, "Senior Officers"), sets
forth specific policies to guide you in the performance of your duties.

As a Senior Officer, you must not only comply with applicable law. You also must
engage in and promote honest and ethical conduct and abide by the Code of
Business Conduct and Ethics and other Company policies and procedures that
govern the conduct of the Company's business. Your leadership responsibilities
include creating a culture of high ethical standards and commitment to
compliance, maintaining a work environment that encourages employees to raise
concerns, and promptly addressing employee compliance concerns.

COMPLIANCE WITH LAWS, RULES AND REGULATIONS

You are required to comply with the laws, rules and regulations that govern the
conduct of the Company's business and to report any suspected violations in
accordance with the section below entitled "Compliance with Code of Ethics".

CONFLICTS OF INTEREST

Senior Officers should avoid, to the extent possible, situations in which their
own interests conflict, or may appear to conflict, with the interests of the
Company. In any case in which a Senior Officer finds himself or herself with an
actual or apparent conflict of interest, he or she should promptly disclose it
to the Company's General Counsel, who will review the transaction or
relationship. If the General Counsel determines that a material conflict does
exist, he or she will refer the matter to the Audit Committee of the Board of
Directors, which shall determine how the situation should be resolved.

DISCLOSURES

It is Company policy to make full, fair, accurate, timely and understandable
disclosure in compliance with all applicable laws and regulations in all reports
and documents that the Company files with, or submits to, the Securities and
Exchange Commission and in all other public communications made by the Company.
As a Senior Officer, you are required to promote compliance with this policy by
all employees and to abide by Company standards, policies and procedures
designed to promote compliance with this policy.

COMPLIANCE WITH CODE OF ETHICS

If you know of or suspect a violation of applicable laws, rules or regulations
or this Code of Ethics, you must immediately report that information to any
member of the Board of Directors. No one will be subject to retaliation because
of a good faith report of a suspected violation.

Violations of this Code of Ethics may result in disciplinary action, up to and
including discharge. The Board of Directors shall determine, or shall designate
appropriate persons to determine, appropriate action in response to violations
of this Code.


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WAIVERS OF CODE OF ETHICS

If you would like to seek a waiver of the Code of Ethics you must made full
disclosure of your particular circumstances to the Board of Directors.
Amendments to and waivers of this Code of Ethics will be publicly disclosed as
required by applicable law and regulations.

NO RIGHTS CREATED

This Code of Ethics is a statement of certain fundamental principles, policies
and procedures that govern the Company's Senior Officers in the conduct of the
Company's business. It is not intended to and does not create any rights in any
employee, customer, supplier, competitor, shareholder or any other person or
entity.








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