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EXHIBIT 14
TO FORM 10-K OF
SEA PINES ASSOCIATES, INC.
Code of Ethics for Senior Financial Officers

The Chief Executive Officer, the Chief Financial Officer and the Controller of
Sea Pines Associates, Inc. and its Subsidiaries have a special role which
requires them to adhere to ethical conduct and integrity generally, and to
promote accurate, fair and timely reporting of our Companys financial results
and condition and other information we release to the public and include in
reports we file with the Securities and Exchange Commission. Because of this
special role, the Chief Executive Officer, the Chief Financial Officer and the
Controller of Sea Pines Associates, Inc. and its Subsidiaries are bound by the
following Code of Ethics, under which each agrees that he or she shall:



| |  |  | Engage in and promote honest and ethical conduct, including the
ethical handling of actual or apparent conflicts of interest between
personal and professional relationships.
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| |  |  | Provide information within the scope of his or her duties in a
manner which promotes full, fair, accurate, timely and understandable
disclosure in reports and documents that the Company files with, or
submits to, government agencies and in the Companys other public
communications.
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| |  |  | Comply with all applicable rules and regulations of federal, state
and local governments and regulatory agencies.
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| |  |  | Carry out his or her duties in good faith, responsibly, and with
due care, competence and diligence.
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| |  |  | Take all reasonable measures to protect the confidentiality of
non-public information about the Company or its Subsidiaries and their
customers and vendors obtained or created in connection with his or her
activities, and to prevent the unauthorized disclosure of such
information unless required by applicable law or regulation or legal or
regulatory process.
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| |  |  | Promptly report to the Chairman of the Audit Committee any conduct
that he or she believes to be, or would give rise to, a violation of
law or of any provision of this Code of Ethics or the Companys Code of
Ethical Business Conduct.
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It is against the Companys policy to retaliate against any employee for the
good faith reporting of violations of this Code of Ethics. Violations of
this Code of Ethics, including failures to report potential violations by
others, will be viewed as a severe disciplinary matter that may result in
personnel action, including termination of employment.