Exhibit 14

                         PUBLIX SUPER MARKETS, INC.

                CODE OF ETHICAL CONDUCT FOR FINANCIAL MANAGERS
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Publix Super Markets, Inc. including its affiliates and subsidiaries  ("Publix")
is committed to the highest  standards  of business  and ethical  conduct.  This
includes  conducting  business  in  accordance  with the  spirit  and  letter of
applicable laws and regulations. In particular,  Publix's financial managers (1)
are vested with a higher level of  responsibility  over the financial affairs of
Publix.  Financial  managers must fulfill this  responsibility  by adhering to a
high ethical standard. This Code provides principles to which Publix's financial
managers are expected to adhere and advocate. Publix financial managers agree by
their signature below, that they will:

1.  Act with  honesty  and  integrity,  avoiding  actual or  apparent  conflicts
    between his or her personal interests and the interests of Publix, including
    receiving improper personal benefits as a result of his or her position.

2.  Manage financial  transactions and reporting  systems and procedures so that
    business  transactions  are properly  authorized and completely,  timely and
    accurately  recorded  on  Publix's  books and  records  in  accordance  with
    generally accepted  accounting  principles and established company financial
    policies.

3.  Perform  responsibilities  with a view to causing periodic reports and other
    documents  filed  with the SEC and other  public  communications  to contain
    information  that  is  full,  fair,  accurate,   complete,  timely  and  not
    misleading.

4.  Establish and maintain  processes and  procedures to cause  compliance  with
    laws,  rules and  regulations  of  federal,  state,  and  local  governments
    applicable to Publix.

5.  Act in good  faith,  responsibly,  with  due  care  and  diligence,  without
    misrepresenting or omitting material facts or allowing  independent judgment
    to be compromised.

6.  Respect the  confidentiality  of  information  acquired in the course of the
    performance  of  his or  her  responsibilities  except  when  authorized  or
    otherwise legally obligated to disclose.

7.  Use corporate assets and resources in a responsible manner.

8.  Not use corporate information,  corporate assets, corporate opportunities or
    his or her position with Publix for personal gain.

9.  Not compete directly or indirectly with Publix.

10. Comply in all respects with all Publix  policies  governing  ethical conduct
    and financial reporting.

11. Proactively promote ethical behavior among subordinates and peers.

12. Report material violations of this Code to the General Counsel or the CFO.


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(1) For  purposes of this Code,  financial  managers  include the CEO,  CFO, any
Senior  Vice  President  with  financial  reporting  responsibility,   any  Vice
President and  Controller,  General  Counsel,  Vice President of Internal Audit,
Director of Tax and Treasury, and any Manager of Business Analysis and Reporting
with SEC or financial reporting responsibility.





                                                                      Exhibit 14
                                                                          Page 2


Publix  requires  that  its  financial  managers  acknowledge  and  certify  the
foregoing annually and confirm such certification with the Audit Committee.

The Audit Committee shall have the power to monitor,  make  determinations,  and
recommend action to the Board with respect to violations of this Code.

EXECUTED this ____ day of ________________, 2003.


                        Signature:
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                        Print Name:
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                        Title:
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