EXHIBIT 14

EQUITY LIFESTYLE PROPERTIES, INC.
BUSINESS ETHICS AND CONDUCT POLICY

REVISED JULY 2005

The enclosed Business Ethics and Conduct Policy sets forth
certain guidelines Equity LifeStyle Properties, Inc. expects its
officers, directors and employees to follow in the conduct of its
business. Each officer, director and employee of Equity LifeStyle
Properties, Inc. and its subsidiaries must complete and sign the
acknowledgement card enclosed herein. This acknowledgement should
be returned to the General Counsel's office in Chicago.

I. INTRODUCTION

This Policy sets forth the basic guidelines which Equity LifeStyle
Properties, Inc. and its subsidiaries (collectively, the "Company") expects its
officers, directors, management, and other employees to follow in conducting
business on behalf of the Company with the Company's customers, the general
public, creditors, suppliers and competitors, governmental entities and with
fellow Company personnel. This Policy supplements and is in addition to the
information contained in the Employee Handbook previously distributed to you.
The Company reserves the right to modify this Policy from time to time.

No policy can be complete in all respects. Good judgment based upon an
understanding of the laws, regulations, and canons of ethics is the best
safeguard against improper or unethical conduct. Each employee is expected to
attain a level of understanding of this Policy which will permit the proper
exercise of such judgment, and to seek legal counsel in those circumstances
where such judgments could be questioned.

The Company's internal auditors and legal staff will monitor compliance
with this Policy to assure that the Company conducts itself in a manner
consistent with its obligations to society and its stockholders. In addition,
those with management responsibilities within any area covered by this Policy
may periodically be required to complete the "Management Representation of
Compliance with Company Policies" - a written assurance of compliance with the
legal and ethical principles set forth in this Policy. The form of this
questionnaire is set forth at the end of this Policy.

A. GENERAL POLICY

The Company and its personnel will at all times transact business in
full compliance with the law and in accordance with the highest principles of
honesty and ethical conduct. Each employee should endeavor to deal fairly with
the Company's customers, suppliers, competitors and employees. No employee
should take unfair advantage of anyone through manipulation, concealment, abuse
of privileged information, misrepresentation of material facts, or any other
unfair-dealing practice.

These Policy guidelines are to be strictly adhered to at all times and
under all circumstances. Policy violations will result in disciplinary action,
including, if appropriate, discharge from employment.

B. SCOPE

The guidelines set forth in this Policy apply to all Company personnel
and all Company related transactions. Every director, officer and employee must
be familiar with and comply with this Policy. Moreover, those with supervisory
responsibilities must

ensure that employees under their direction or control are acquainted with
applicable portions of the Policy. Company officers and directors should also be
aware that there are special legal requirements, not covered by this Policy,
which apply to corporate fiduciaries.

The Company's commitment to full compliance applies to all applicable
laws, regulations and judicial decrees of the United States (federal, state and
local) and of other countries where the Company transacts its business. Portions
of this Policy concentrate on laws and regulations which are particularly
relevant to our business activities; however, this special emphasis on relevant
areas of law does not limit the general policy requiring full compliance with
all applicable laws and regulations.

In addition to compliance with all legal requirements, each officer,
director and employee must adhere to the overriding ethical and professional
standards generally governing the conduct of business. The Company's interests
are not served by any unethical practice or activity even though not in
technical violation of the law.

C. EFFECT OF POLICY VIOLATION

Any knowing violation of the laws, regulations, or principles of ethics
set forth in this Policy will be grounds for disciplinary action or dismissal
from employment, and may subject the employee or former employee to civil
liability and/or criminal prosecution under appropriate law. Any employee who
knowingly authorizes or permits another to engage in a violation will also be
subject to disciplinary action, dismissal, and other penalties.

D. EMPLOYEE RESPONSIBILITIES AND RIGHTS UNDER POLICY

Every employee is obliged to strictly adhere to this Policy at all
times and under all circumstances. Any employee who is aware of violations or
potential violations of laws, rules, regulations or this Policy has a duty to
advise his supervisor, or the General Counsel's office. Further, any
uncertainties regarding legal or ethical issues involving Company affairs or
doubts about the best course of action in a particular situation requires the
employee to seek the advice of the General Counsel's office for clarification.
An error in failing to secure advice or report policy violations could be costly
to the individual and to the Company.

It is the right of every employee to report other persons' (individual
or Company) violations or seek the advice of the General Counsel's office
without risk to the employee's job status or position by reason of such report
or inquiry. It is the policy of the Company not to allow retaliation for reports
of misconduct by others made in good faith by employees. Employees are expected
to cooperate in internal investigations of misconduct.

E. DEFINITIONS

The terms "personnel" and "employee" apply to all Company officers,
directors, managers, and other employees. "General Counsel's office" refers to
the internal legal counsel of the Company.

F. ADDITIONAL INFORMATION

Additional copies of this Policy are available from the Human Resources
Department or the General Counsel's office. Any employee in doubt about whether
this Policy applies to a particular transaction or uncertain about the proper
course of conduct to follow, should contact the General Counsel's office which
is available to answer questions and provide guidance.

II. CONFLICTS OF INTEREST, CORPORATE OPPORTUNITIES AND
VIOLATIONS OF TRUST

A. GENERAL

The Company is determined to build and maintain a high standard of
business ethics in the conduct of its affairs. Accordingly, this places a heavy
responsibility on all employees of the Company on whose character and judgment
the confidence of the public ultimately depends. The responsibility is shared by
all employees, but obviously it rests in special measure on the directors and
officers of the Company and on those management employees by whose decisions and
advice the Company is guided.

This portion of the Policy deals with one aspect of that responsibility
- - the avoidance of circumstances which might, in fact or in appearance, cause an
individual to place his or her own interest above his or her obligations to the
Company. The words "in appearance" should be noted particularly since the
appearance of an action might tend to impair confidence even though the
individual may not actually do anything wrong. The requirements of this Policy
Statement are in addition to any provisions of law pertaining to this subject.

For the purpose of this Policy, the interest of each director, officer
or employee includes any interests of their immediate family: (a) spouse and
children under the age of eighteen (18) and (b) children who are eighteen (18)
years of age or older, parents, siblings, mothers and fathers-in-law, sons and
daughters-in-law and brothers and sisters-in-law provided that the director,
officer or employee has knowledge of such persons conflict of interest under
this Policy.

1. FINANCIAL INTERESTS IN COMPANY TRANSACTIONS

It is the duty of each director, officer and employee to avoid having
any financial interest in any transaction between the Company, any of its
subsidiaries and a third party which might conflict with the proper performance
of his or her corporate duties or responsibilities, or which might tend to
adversely affect his or her independent judgment with respect to such
transaction.

Accordingly, (a) unless, in the case of directors and officers,
specifically approved by the Board of Directors after full disclosure of all
relevant facts or (b) unless, in the case of other employees, specifically
approved by appropriate supervisors (i.e. Regional Vice President and Executive
Vice President-Operations) and the General Counsel, and if necessary as
determined by such supervisors and General Counsel, approved by the Board of
Directors of the Company after full disclosure of all relevant facts:

a. No director, officer or employee shall own a direct or indirect
interest in any supplier, contractor, subcontractor, competitor, customer or
other entity with which the Company does business.

This Policy is not intended to preclude ownership of publicly-traded
securities of a corporation with which the Company or any of its subsidiaries
has dealings; nor is it intended to preclude ownership of other security
holdings which could not be used to exert any influence whether because of their
relatively small size or because of the insignificance of the company's dealings
with the Company. Accordingly, ownership of securities which are traded on a
public stock exchange and ownership of securities where the aggregate amount
owned by the director, officer or employee constitutes less than two and one
half percent (2.5%) of the securities shall not be deemed to involve financial
interest prohibited by this Policy.

The above exception notwithstanding, purchases and sales of securities
and other property should be avoided which are so timed in relation to the
Company's or any of its subsidiaries' operations that they might be regarded or
viewed as attempting to profit by using improperly obtained special knowledge of
the Company's investment intentions or other confidential information obtained
by reason of official positions.

b. No director, officer or employee shall acquire property with the
knowledge that its value is likely to be benefited by action that the individual
is aware is being considered by the Company.

c. No director, officer or employee shall acquire any property where
confidential or unpublished information, obtained through the Company or in
course of performing duties for the Company, has in any way been utilized in
such acquisition.

d. No director, officer or employee shall appropriate or divert to
others any business opportunity in which it is known or could reasonably be
anticipated that the Company would be interested.

e. No employee may use corporate property, information or position for
improper personal gain, and no employee may compete with the Company directly or
indirectly. Directors, officers and employees owe a duty to the Company to
advance its legitimate interests when the opportunity to do so arises.

f. No officer or employee shall be employed by or hold any officership,
directorship, partnership or other official position in a business or
professional firm or corporation outside of the Company, without the consent of
the Audit Committee of the Board of Directors of the Company.

g. All officers and full time employees should avoid outside business
activities which may conflict with their ability to devote their efforts
full-time to the business of the Company.

In many cases, a potential conflict of interest or violation of trust
may be avoided by making a full disclosure of the facts prior to any transaction
thereby permitting the Company to make an informed, independent decision
regarding the transaction. Such disclosure should be made to the General
Counsel's office via use of the Related Party Disclosure form or other direct
communication with the General Counsel. The Company reserves the right to
condition the approval of any specific transaction on such terms and conditions
as the Company in its sole discretion may require including, but not limited to,
specific financial reporting and audit requirements.

2. BENEFITS, FAVORS, GIFTS AND ENTERTAINMENT

It is the duty of each director, officer or employee to avoid receipt
of benefits, favors, gifts and entertainment which might conflict with the
proper performance of his or her corporate responsibilities, or which might tend
to adversely affect his or her independent judgment on behalf of the Company or
any of its subsidiaries.

If the benefit, favor or gift is more than a token gift of
insubstantial value and is offered in return for or in expectation of corporate
business, it should not be accepted. In regard to acceptance of business
entertainment, it is recognized that entertainment often may be incidental to
business relationships of value to the Company. But expensive hospitality should
not be accepted unthinkingly. Before expensive hospitality is accepted, the
individual should be satisfied that it is consistent with the best interests of
the Company and consistent with this Policy.

3. DISCLOSURE

It is the duty of each director, officer or employee, when he or she
finds that he or she has an interest or affiliation which might conflict with
the proper performance of his or her corporate duties or responsibilities or
which might tend to adversely affect his or her independent judgment on behalf
of the Company, or when he or she finds himself or herself in doubt as to the
proper application of this Policy, to report the facts to the General Counsel or
Chairman of the Audit Committee and be guided by the instructions he or she
receives from the General Counsel or Chairman. Except as otherwise directed by
those instructions, he or she should refrain from participating in any matters
which might reasonably be affected by his or her adverse interest. The Chairman
of the Audit Committee will advise the auditors of the Company of any matters
approved by the Board of Directors pursuant to this Policy.

B. SPECIFIC EXAMPLES OF CONFLICTS OR VIOLATIONS

It may be considered to be in conflict with the Company's interest, or
a violation of trust for a director, officer or employee or any immediate member
of their family:

1. to have an undisclosed interest in or involvement with any
organization which has business dealings with the Company where there is an
opportunity for preferential treatment to be given or received, except where
such an interest comprises securities in widely-held corporations which are
quoted and sold on the open market and the interest is not material (less than
two and one half percent of the outstanding securities);

2. to buy, sell or lease any kind of property, facilities or equipment
from or to the Company or to any company, firm or individual who is or is
seeking to become a contractor, supplier or customer without disclosing (and
obtaining permission) prior thereto;

3. to accept commissions, a share in profits (other than dividends or
interest on securities of widely-held corporations) or other payments, loans
(other than with established banking or financial institutions), services,
excessive entertainment and travel, or gifts of more than nominal value, from
any individual or organization doing or seeking to do business with the Company;
or

4. to take advantage of any opportunity for personal gain that
rightfully belongs to the Company. This would include business opportunities of
which an employee becomes aware because of their employment by the Company. Such
opportunities must be offered to the Company.

C. EFFECT OF VIOLATIONS

As with any other violation of Policy, a violation of the above
conflict of interest and corporate opportunity provisions will be grounds for
disciplinary action including possible dismissal from employment, and may
subject the director, officer or employee to civil liability and/or criminal
prosecution under appropriate law. Even so, not every potential conflict of
interest is a Policy violation - under some circumstances following a full
disclosure by the director, officer or employee, the Board of Directors or
senior management of the Company, as provided in this Policy, may determine to
engage in a particular transaction which is beneficial to the Company
notwithstanding the potential conflict or to permit the director, officer or
employee to engage in such transaction. In such a case, the above conflict of
interest provisions are not violated. Therefore, the effect of a particular
conflict of interest will depend upon the nature of the conflict, its disclosure
by the director, officer or employee, its effect upon the Company and the means
available to recompense loss or prevent future injury.

III. COMPLIANCE WITH LAWS, RULES AND REGULATIONS

A. COMPLIANCE WITH GOVERNMENTAL AUTHORITY

The Company and its directors, officers and employees shall comply with
the laws, regulations, decrees and orders of every governmental agency,
regulatory authority, and judicial body having jurisdiction over the Company's
operations. The Company holds information and training sessions to promote
compliance with laws, rules and regulations, including insider trading laws. The
Company shall cooperate with governmental agencies in the proper performance of
their duties to the fullest extent possible. To ensure the Company's compliance
and cooperation commitment is satisfied, the General Counsel's office should be
immediately informed of any governmental request or inquiry.

B. ANTITRUST AND TRADE REGULATION

Every officer, director, and employee of the Company shall at all times
abide by the antitrust laws and trade regulations of the United States.
Violations of the antitrust laws or trade regulations may subject the Company to
fines, injunctions and substantial monetary damages. Moreover, violations of
certain antitrust laws are considered felonies, exposing an employee to the risk
of fine and/or imprisonment.

C. RELATIONSHIPS WITH GOVERNMENTAL OFFICIALS

Payments (regardless of amount), entertainment (other than meals where
Company-related work activities are conducted), or gifts (of more than nominal
value) to government officials and other government personnel of the United
States and other domestic or foreign jurisdictions, regardless of motive, are
viewed by the Company as

improper and not permitted. The Company's relationship with public officials
shall in all respects be of such a nature that the integrity and reputation of
the officials and the Company will not be impugned in the event the full details
of the relationship, including any gifts or entertainment, become a matter of
public discussion.

IV. EMPLOYMENT AND PERSONNEL PRACTICES

A. GENERAL

Every officer, director, and employee of the Company shall at all times
abide by the strict legal requirements governing employment practices and
employee relations. In addition, every person coming in contact with the
Company, as an employee, customer, supplier, candidate for employment, or other
third party, shall be treated fairly, courteously and respectfully. The Company
has previously published its policies on discrimination and harassment as well
as on the employment relationship in the Human Resources Policies and Procedures
Manual and this Policy is meant as a supplement to such previously published
policies.

B. NON-DISCRIMINATION

The Company shall not discriminate against any person on the basis of
race, religion, national origin, age, sex, disability or veteran's status or
other characteristic or status protected by applicable law. This prohibition on
discrimination applies to practices in recruiting, employment, training,
promotion, working conditions, compensation, benefits, job rules, discipline,
and all other aspects of employment and employee relations.

C. HARASSMENT

The Company is committed to maintaining a work environment that is free
from intimidation and harassment. Company policy prohibits sexual, racial, and
other unlawful harassment in the work place. The Company will not tolerate undue
influence, offensive behavior, sexual harassment, intimidation, or other
disrespectful conduct by one employee toward another or by an employee toward a
customer or supplier. Neither shall any employment or employee relations matter
be decided based upon the existence or non-existence of any personal
non-business relationship between employees.

D. EMPLOYMENT CONTRACTS

The Company shall not enter into any contract of employment without the
prior written approval of the Compensation Committee of the Board of Directors
of the Company.

E. EMPLOYEE RECORD CONFIDENTIALITY

The personnel records of all Company employees shall be treated as the
confidential information of the Company. No Company officer, director or
employee shall copy or release any personnel or salary record to any third
party, nor shall any private personal information contained in any personnel
record be disclosed to any third party without the prior written approval of the
General Counsel's office. Employees with authorized access to personnel or
salary records shall institute measures to prevent the disclosure of any such
records under their control.

V. TRANSACTIONS IN SECURITIES

A. TRADING IN COMPANY SECURITIES

Directors, officers and employees are prohibited from trading in
Company securities when they have material information which is not publicly
known. Information is considered material if it is important enough to affect a
decision by anyone to buy, sell or hold securities. Even when a director,
officer or employee lacks undisclosed material information, it is a prudent
practice to trade only when it is unlikely there is any unannounced material
information anywhere within the Company. Therefore, it is the Company's policy
that each Company director, officer and employee contact either the General
Counsel's office or corporate secretary for approval before making any trade in
Company securities. The Company has previously published its policies on
securities trading and this Policy is meant as a supplement to such previously
published policies.

Directors, officers and employees should not engage in short-term
speculation in Company securities, nor should they engage in any transaction
where they profit if the value of Company securities falls.

B. TRADING IN THE SECURITIES OF OTHER COMPANIES

Directors, officers and employees should not trade in securities of a
company which has been targeted for acquisition or is being reviewed or a
property which is being reviewed or targeted as an acquisition candidate or a
company which is being considered for or has just been awarded an important
contract or relationship with the Company without first checking with the
General Counsel's office.

C. TRANSACTIONS BY OTHERS

No director, officer or employee shall in any way encourage any third
party to engage in any transaction in which the director, officer or employee
himself cannot engage.

D. TRANSACTIONS BY OFFICERS AND DIRECTORS

Officers and directors of the Company are subject to additional
statutory restrictions covering transactions in Company securities. These
restrictions (a) prohibit officers and directors from profiting on transactions
within a six month period, (b) prohibit them from selling the stock short, and
(c) may restrict the amount of securities some of them can sell within a three
month period. Officers and directors of the Company should review proposed
transactions in Company securities with the General Counsel's office.

VI. FAIR AND ACCURATE REPORTING AND RECORDKEEPING

It is the policy of the Company to provide full, fair, accurate, timely
and understandable disclosure in the reports that the Company files with, or
submits to, the Securities and Exchange Commission ("SEC") and in other public
communications made by the Company. All funds, assets and disbursements of the
Company shall be properly recorded in the appropriate records and books of
account. To assure the Company's financial statements are maintained in
accordance with generally accepted accounting principles or such other standards
as may be appropriate and to assure that reports filed by the Company with the
SEC are accurate and complete, the following policies are specifically adopted:

1. Full Disclosure of Accounts. No secret or unrecorded fund of monies
or other assets of the Company shall be established or maintained, and all
payments and disbursements shall be properly recorded on the books and records
of the Company.

2. Accurate Entries to Accounts. The making of false or fictitious
entries on the books and records of the Company and the issuance of false or
misleading reports pertaining to the Company and its operations are prohibited,
and no employee or officer shall engage in any transaction that requires or
contemplates such prohibited activities on the part of the Company.

3. Accurate Expense Accounts. All employees who seek reimbursement
from the Company for expenses shall keep and submit to the Company complete and
accurate records of such expenditures and their business purpose.

Business records and communications often become public, and employees
should avoid exaggeration, derogatory remarks, guesswork or inappropriate
characterizations of people and companies. This applies equally to email,
internal memos and formal reports. Records should always be retained or
destroyed according to the Company's record retention policies. In accordance
with these policies, in the event of actual or possible litigation or
governmental investigation, employees should consult with the General Counsel's
office.

VII. DISCLOSURE OR USE OF COMPANY INFORMATION

A. GENERAL

Each employee shall safeguard and keep private all Company proprietary
and confidential information, including without limitation, trade secrets,
trademarks, trade names or other intellectual property, as well as all such
information relating to the Company's customers and employees. The disclosure of
such Company information shall be permitted only when required by law and the
approval of the General Counsel's office shall be obtained prior to the release
of such information. Absent such approval, it shall be considered a violation of
trust for any director, officer or employee:

1. to use or release to a competitor, or any other third party any
data on decisions, plans, or any other information concerning the Company which
might be prejudicial to the interests of the Company;

2. to appropriate, for their own use or for the unauthorized use by a
third party, any Company technology, software, trade secrets or written
materials (whether or not copyrighted or patented), business information,
including but not limited to contracts, sales or customer information, marketing
or other plans, data relating to costs and suppliers, system design information,
manuals, computer tapes, discs, data processing records, financial data, or any
other confidential or proprietary matters of any nature whatsoever;

3. to copy, use, or release to a third party any employee data,
personnel records, or any other private information concerning the Company's
current or former employees; or

4. to use or release any undisclosed material information concerning
the Company, its plans or its performance, or any unpublished facts bearing upon
the Company's business, plans, or performance.

B. OUTSIDE INQUIRIES AND REQUESTS FOR INFORMATION

If any third party makes contact with any Company personnel requesting
an interview or seeking information concerning any Company-related matter, or if
any media representative requests an interview or seeks information or opinions
concerning any Company-related matter, whether or not the matter is confidential
or proprietary, the requestor should be instructed to address its inquiry
directly to the General Counsel's office so that questions can be answered with
appropriate care by authorized personnel having unrestricted access to the
Company's information resources. Employees with certain responsibilities will
periodically be requested to complete a questionnaire similar to the one
presented below.

VIII. PROTECTION AND PROPER USE OF COMPANY ASSETS

All employees should endeavor to protect the Company's assets and
ensure their efficient use. Theft, carelessness and waste have a direct impact
on the Company's profitability. Any suspected incident of fraud or theft should
be immediately reported for investigation. Company equipment should not be used
for non-Company business, although incidental personal use may be permitted.

The obligation of employees to protect the Company's assets includes
its proprietary information. Proprietary information includes intellectual
property such as trade secrets, patents, trademarks and copyrights, as well as
business, marketing and service plans, databases, records, salary information
and any unpublished financial data and reports. Unauthorized use or distribution
of this information would violate Company policy. It could also be illegal and
result in civil or criminal penalties.

IX. WAIVERS OF THE BUSINESS ETHICS AND CONDUCT POLICY

Any waiver of this Policy that applies to officers or directors may be
made only by the Board of Directors or a committee of the Board of Directors and
will be disclosed as required by law or stock exchange regulation.

EQUITY LIFESTYLE PROPERTIES, INC.
Management Representation of
Compliance with Company Policies
July 2005

It is the responsibility of each Company officer, director, and employee to read
and understand the ELS Business Ethics and Conduct Policy (the "Policy"), and to
complete this questionnaire and promptly return it to the Company's General
Counsel, Equity LifeStyle Properties, Inc., Two North Riverside Plaza, Suite
800, Chicago, Illinois 60606. If you have supervisory duties, it is also your
responsibility to ensure that employees reporting to you have read and
understand the Policy and comply with the Policy. In addition, if the answer to
any of Questions 2(a) through 3 is "YES", you must attach a brief explanatory
statement disclosing the facts supporting your answer.

YES NO

1. Have you read the ELS Business Ethics and Conduct Policy
and do you understand its contents? ____ ____

2. Are you aware of any of the following practices relating
to the Company's affairs:

(a) A situation or transaction described in the Conflicts of
Interest, Corporate Opportunities and Violation of Trust
guidelines set forth in the Policy regardless of whether
or not that situation or transaction may have been
disclosed or approved in accordance with the Policy? ____ ____

(b) A violation of federal, state or local law? ____ ____

(d) An activity in violation of the Antitrust and Trade
Regulation guidelines set forth in the Policy? ____ ____

(e) A practice in violation of the Employment and Personnel
Practices guidelines of the Policy? ____ ____

(f) A transaction in violation of the Transactions in
Securities guidelines set forth in the Policy? ____ ____

(g) A payment or gift to governmental officials? ____ ____

(h) An unauthorized disclosure of information which is
confidential or proprietary to the Company? ____ ____

(i) A practice in violation of the Protection and Proper
Use of Company Assets guidelines set forth in
The Policy: ____ ____

3. Are you aware of any other transaction, practice, activity,
event or circumstance which you believe should be brought to
the Company's attention? ____ ____

================================================================================
The foregoing answers and any attached explanatory statements are true and
correct to the best of my knowledge and belief.

Name:
---------------------------------

Signature:
----------------------------
Date:
---------------------------------

EQUITY LIFESTYLE PROPERTIES, INC.
Business Ethics and Conduct Policy
Acknowledgement

I have received, read, understand and will retain a copy of the Equity
LifeStyle Properties, Inc. Business Ethics and Conduct Policy dated
July, 2005, and comply with such Policy.

Name
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Signature
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Position
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Date
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Property
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This acknowledgment is to be completed by all employees of Equity
LifeStyle Properties, Inc. and its affiliates and returned to the
Company's General Counsel.

Employees with certain responsibilities will periodically be required
to complete an additional questionnaire which will be furnished to them
separately.