KERZNER INTERNATIONAL LIMITED

CODE OF

BUSINESS CONDUCT AND ETHICS

INTRODUCTION

Kerzner International Limited, a foreign private issuer with securities trading on The New York Stock Exchange (the NYSE) and its subsidiary companies (collectively, the Company) has a commitment to moral conduct, to ethical behavior and to operations within the letter and spirit of the law.  The Companys management believes it is appropriate to periodically reiterate the Companys policy on business conduct and ethics in this policy (the Code).

For the purposes of this Code, employee is defined as the Companys employees, officers and directors.

The Company recognizes that it is not possible to document a code of business conduct and ethics that will define the proper conduct and ethical behavior for every situation that may arise.  As a general policy, however, the pervasive theme of the Company and its employees must be one of honesty and integrity in all transactions.  This Code provides a set of basic principles to guide employees regarding the minimum requirements expected of them.  In addition to this Code, employees are required to comply with the policies and procedures established by the Companys Human Resources Department and applicable to the employees business unit.

Only conduct that is in compliance with this Code and intended to advance the proper and legal business interests of the Company is within an employees scope of employment.  It is important that you study them carefully and understand them, as you must abide by them.  If you have any questions about the Code, please direct them to the Companys General Counsel, Compliance Officer, or the senior executive in your Human Resources Department.

Taking actions to prevent problems is part of our Companys culture.  If you observe possible unethical or illegal conduct you are encouraged to report your concerns.  If you report, in good faith, what you suspect to be illegal or unethical activities, you should not be concerned about retaliation from others.  Any employees involved in retaliation will be subject to serious disciplinary action by the Company.

Failure to abide by the guidelines addressed in this Code will lead to disciplinary actions, including dismissal where appropriate.  If you are in a situation, which you believe may violate or lead to a violation of this Code, you are urged to follow the guidelines described in Section XII of this Code.

I.                                         COMPLIANCE WITH LAWS, RULES AND REGULATIONS

We have a long-standing commitment to conduct our business in compliance with applicable laws and regulations and in accordance with the highest ethical principles.  This commitment helps ensure our reputation for honesty, quality and integrity.

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II.                                     CONFLICTS OF INTEREST

Every employee shall deal with suppliers, customers and other persons doing or seeking to do business with the Company in a manner that excludes consideration of personal advantage or which might otherwise be or appear to be inappropriate and inconsistent with the Companys interest.    A conflict of interest exists when a persons private interest interferes in any way with the interests of the Company.

Specific policies include, but are not limited to:

1.                                       Other Employment.  Unless otherwise authorized by the Company, each employee shall devote all of his/her business time and energy to the Company and shall not engage in any other business activity without the prior written consent of the Companys Corporate Human Resources Officer.

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