Exhibit 14

MAGNA ENTERTAINMENT CORP.  Code of Business Conduct

GENERAL

This Code of Business Conduct (this "Code") is a statement of guiding principles for the conduct of all of our employees with respect to our business. This Code
applies to employees of Magna Entertainment Corp. and its consolidated subsidiaries, collectively referred to in this Code as "our company" or "MEC".

All
of our employees are required to use sound judgment and to act ethically in the performance of their employment responsibilities. Specifically, each of our employees is expected to
be familiar with the principles outlined in this Code and to adhere to such principles and to all applicable laws governing our company and its business.

All
employees are expected to report appropriately any indications of illegal or improper conduct of any person or entity involving our company or its business.

This
Code is only intended to be a statement of guiding principles. It is not a contract and is not intended as a detailed guide for all situations you may face.

WAIVERS OF THIS CODE

This Code applies to our officers and our employees equally. Our directors are also required to abide by the principles of this Code, within the scope of their
duties as directors of our company, as if they were employees of our company. Any waiver of this Code for any officer or director of our company must be approved in advance by the Corporate
Governance, Human Resources and Compensation Committee of our Board of Directors. Any such waivers will be publicly disclosed by appropriate means and as required by applicable law.

QUESTIONS, REPORTING YOUR CONCERNS AND ENFORCEMENT



If
your report involves wrongdoing by your Supervising Manager or you are uncomfortable reporting to your Supervising Manager, please promptly contact your Human Resources Department,
the General Manager of your facility or MEC's Chief Executive Officer at 905-726-2462. If necessary, the person receiving the report will then contact senior management to
investigate the matter or delegate its investigation to the appropriate person or committee. Generally, non-material technical violations of this Code or isolated incidents that do not
have a material effect on our company should be reported to your Supervising Manager. If you are unsure who to report your concerns to, please call the MEC FYI Line at
1-866-9 MEC FYI (1-866-963-2394) or 905-726-7442.

If
you wish to communicate anonymously, you are free to do so, and we will maintain the confidentiality of your communication to the extent possible under applicable laws.
Communications intended to be confidential can be made in one of two ways. You may communicate in writing without indicating your name or address by writing to: Magna Entertainment Corp.,
337 Magna Drive, Aurora, Ontario, L4G 7K1, Attention: Chief Executive Officer. Please write "CONFIDENTIAL" conspicuously on the front of the envelope. Alternatively, you
can call the MEC FYI Line anonymously at 1-866-9 MEC FYI (1-866-963-2394) or 905-726-7442 to report any
violations of this Code or to seek guidance on matters involving this Code.

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If
you have concerns about accounting, internal accounting controls, or auditing matters relating to our company or your report involves senior management of our company, in addition to
making a report as described above, you may also contact the Audit Committee of our Board of Directors directly. Inquiries or communications intended to be anonymous should be mailed in writing
without indicating your name or address to Magna Entertainment Corp., 337 Magna Drive, Aurora, Ontario, L4G 7K1, Attention: Chairman, Audit Committee. Please write
"CONFIDENTIAL" conspicuously on the front of the envelope.



Any
person making a report of a breach of this Code has the right, if they so choose, to be informed of the resolution of their report.

WE HAVE A DUTY TO ACT IN THE BEST INTERESTS OF OUR STOCKHOLDERS

Our employees share a duty to protect our assets and manage our business in the best interests of our stockholders.



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Selective Disclosure Prohibited.Applicable securities laws, rules and regulations generally prohibit selective disclosure
of material nonpublic information to persons outside our company. All employees are expected to keep all material nonpublic information about our company strictly confidential unless and until we have
made full public disclosure regarding the information by way of a press release or appropriate filing with securities regulatory authorities.

Providing Information to the Public.Our policy is to disseminate material information about our business in a timely manner
and only through our employees authorized for this purpose. Employees are not under any circumstance to discuss our company's financial, business or other information with the press (except for those
employees expressly authorized for this purpose), at any public venue or on any website, chat room or similar forum. Requests from the media, analysts or stockholders about our company must be
forwarded promptly in accordance with our Corporate Disclosure Policy.

For
more information concerning the foregoing disclosure practices, please refer to the MEC Corporate Disclosure Policy, a copy of which can be obtained from the Corporate Secretary
at 905-726-2462.



WE ARE COMMITTED TO OUR CUSTOMERS

We are committed to excellence in service and performance and building strong customer relationships.



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WE RESPECT OUR EMPLOYEES AND OUR EMPLOYEES ARE EXPECTED TO RESPECT EACH OTHER

Each MEC employee has a duty to promote a positive working environment for all of our employees, our horsemen and their employees who work at
our racetracks.



WE COMPLY WITH ALL APPLICABLE LAWS

We expect our employees to comply with all applicable laws and regulations affecting our company and its business, whether or not referred to explicitly in this
Code. The following is a non-exhaustive summary of certain laws and regulations applicable to our company and its business.



U.S. Political Contributions.There are various complex laws governing political contributions in the U.S. As
a result, we have adopted a policy in respect of U.S. political contributions and gifts to U.S. public officials. All U.S. political contributions and gifts to U.S. public
officials (whether in the form of cash, property or services) must be made in compliance with this policy which essentially requires that any U.S. political contributions made by or on behalf
of our company be made only after approval is obtained from the applicable political contributions officer. For more details on our policy on

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U.S. political
contributions, please consult the MEC U.S. Political Contributions Policy, a copy of which can be obtained by contacting the Corporate Secretary at
905-726-2462.

Political Contributions Outside the U.S.None of our employees shall contribute in our company's name or on our company's
behalf, any cash, property or services of any kind for or in support of any political candidate, committee, initiative, or activity outside the U.S. unless it is first approved by an executive
officer of our company. No lobbying efforts shall be undertaken in our company's name or on our company's behalf without prior authorization from our Legal Department.



OUR EMPLOYEES ARE EXPECTED TO ACT IN THE BEST INTERESTS OF OUR COMPANY AND AVOID CONFLICTS OF INTEREST

All of our employees must be wary of any investment, business interest or other personal interest that interferes, or even appears to interfere, with their
objective ability to act in the best interests of our company. A conflict of interest arises in any situation where an employee's private interests or personal considerations, including potential
benefits to the employee's family, may detrimentally affect the independent judgment of the employee to act in the best interests of our company. A conflict of interest also arises where an employee
uses his position, confidential information or corporate time or facilities for private gain.

All
employees who, by virtue of their employment duties and responsibilities are in a position to retain or influence the retention of persons or companies to provide goods and services
to our company, are required to complete a questionnaire disclosing the direct or indirect business interests of themselves and their immediate family members. For more information on this area,
please refer to the MEC Conflict of Interest Policy, a copy of which can be obtained from the Human Resources Department by calling 905-726-2462.

WE COMPETE FAIRLY AND ETHICALLY

We are committed to providing high quality racing, entertainment, pari-mutuel wagering and hospitality services to our customers on a lawful and
ethical basis. Our company and its employees must comply with the antitrust and unfair competition laws of the countries in which our company engages in business. Antitrust is the general term for
laws that protect the free enterprise system by promoting fair competition and restricting restraints on trade. Generally, these laws prohibit or regulate: attempts to monopolize or otherwise restrain
trade, price fixing or other agreements with competitors that would divide or allocate customers or otherwise harm customers, selling products and services below cost, "tied selling", and certain
other overly restrictive agreements. Employees responsible for any dealings with competitors are expected to know the laws that apply to their business activities, and should speak to the Legal
Department as questions arise.

EFFECTIVE DATE

This Code was implemented and became effective on May 4, 2004.

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