WHEELING ISLAND GAMING, INC.

Code of Ethics for Principal Executive, Financial and Accounting Officers

Introduction
Wheeling Island Gaming, Inc. (the "Company") recognizes that the conduct of its principal executive and financial officers is critical to the Company's commitment to maintain the highest standards of personal integrity, fairness, honesty and good judgment by its officers and employees. This Code of Ethics has been adopted by the Board of Directors of the Company to promote honest and ethical conduct, proper disclosure of financial information in the Company's periodic reports, and compliance with applicable laws, rules, and regulations by the Company's senior officers who have executive and financial responsibilities. This Code of Ethics is in addition to any other applicable policies or codes that the Company may maintain from time to time.

Applicability
This Code of Ethics applies to the Company's principal executive officers, principal financial officers, principal accounting officers and controllers, and any persons performing similar functions. These individuals are hereafter referred to collectively as "Senior Officers".

Principles and Practices
In performing his or her duties, each of the Company's Senior Officers must:

1. Maintain high standards of honest and ethical conduct and avoid any actual or apparent conflict of interest in personal and professional relationships;

2. Report to the Audit Committee of the Company's Board of Directors any conflict of interest that may arise and any material transaction or relationship that reasonably could be expected to give rise to a conflict of interest;

3. Provide, or cause to be provided, full, fair, accurate, timely and understandable disclosure in reports and documents that the Company files with or submits to the Securities and Exchange Commission, and in other public communications made by the Company;

4. Comply and take all reasonable actions to cause others to comply with applicable governmental laws, rules, and regulations of federal, state, and local governments and the regulatory agencies having jurisdiction over the Company's operations; and

5. Promptly report to the Audit Committee violations of this Code of Ethics by such Senior Officer, or any conduct by others that he or she believes to be a violation, or which reasonably could be expected to give rise to a violation, of any provision of this Code of Ethics.

Each of the Company's Senior Officers is personally accountable for adherence to this Code of Ethics.

Waiver
Any request for a waiver of any provision of this Code of Ethics must be in writing and addressed to the Company's Audit Committee. The approval or denial of any such waiver shall be within the exclusive discretion of the Audit Committee. Any waiver of this Code of Ethics granted by the Audit Committee will be disclosed promptly on Form 8-K or by any other means approved by the Securities and Exchange Commission.

Compliance
The Audit Committee will assess compliance with this Code of Ethics, report material violations to the Board of Directors, and recommend to the Board appropriate action. 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.

Approved: March 26, 2004