MI Developments Inc. Corporate Disclosure Policy

Application of the Policy

As a public company, MI Developments Inc. ("MID") has an obligation to ensure that all communications of MID information are timely, factual, accurate and in compliance with the applicable regulatory and legal requirements of the various securities commissions and exchanges to which MID is subject from time to time, including, without limitation, the requirements of the Ontario Securities Commission ("OSC"), the United States Securities and Exchange Commission ("SEC"), the Toronto Stock Exchange ("TSX") and the New York Stock Exchange ("NYSE"), and other applicable securities laws in both Canada and the United States. This Corporate Disclosure Policy (the "Policy") has been developed to promote consistent disclosure practices aimed at informative, timely and broadly disseminated disclosure of material information to the market in accordance with all applicable legal, regulatory and stock exchange requirements.

Unless otherwise noted, this Policy applies to all of MID's current officers, directors, employees, insiders and any other person or company that is engaged or may engage in a business or professional activity with MID (including authorized representatives) (collectively, "MID Personnel") as well as former MID Personnel who served in that capacity in the past. Failure of current MID Personnel to adhere to this Policy may lead to disciplinary action and will constitute grounds for termination of office and employment without notice.

This Policy deals with how MID and MID Personnel handle Material Non-Public Information (as defined below) about MID. It deals with MID's formal disclosure requirements such as annual and quarterly reports, prospectuses and news releases and with information that MID posts on its website. It also extends to oral communications and statements. For example, speeches by senior management, responses to media inquiries and statements made in meetings with analysts and investors must comply with this Policy.

The MID Board of Directors periodically reviews this Policy with a view to making any amendments necessary to support the achievement of its objectives.

The General Principle

1. MID Personnel should not discuss internal matters or developments regarding MID or its subsidiaries (particularly its publicly traded subsidiary, Magna Entertainment Corp. ("MEC")) of which they are aware and which constitute Material Non-Public Information with any person (including, without limitation, MID Personnel who do not need to know the information, family members, relatives and friends), other than in the necessary course of business.

Similarly, MID Personnel should not discuss MID affairs which relate in any way to Material Non-Public Information in public or quasi-public areas where conversations may be overheard (e.g., airplanes, restaurants, restrooms, elevators, etc.) or participate in Internet chat rooms, bulletin boards or newsgroups which discuss such or other information relating to MID's activities or securities. MID Personnel who encounter information or discussions pertaining to MID on the Internet should advise MID's Chief Operating Officer ("COO"), Chief Financial Officer ("CFO"), General Counsel or Corporate Secretary immediately. In addition, MID Personnel must ensure that any document containing Material Non-Public Information is properly protected, may not be viewed in any public location and is stored safely at all times at locations to which access is restricted to individuals who "need to know" such information in the necessary course of business.

2. It is impossible to delineate in advance what information will or will not be considered "material" to MID. Under Canadian securities legislation, information is "material" if it significantly affects, or may be reasonably expected to have a significant effect on, the market price or value of any of MID's securities. Under U.S. federal securities laws, information is "material" if there is a substantial likelihood that a reasonable shareholder or other investor would consider it important in making an investment decision regarding MID's securities. While the obligation is generally to disclose material information immediately, there will necessarily be a period of time during which MID is preparing to make this disclosure when some MID Personnel will be aware of that information. Any such material information which has not been disseminated in a manner which makes it available to the public generally would constitute "Material Non-Public Information". Examples of Material Non-Public Information include, without limitation, previously undisclosed information concerning MID and/or MEC regarding (i) revenues, income or earnings per share, (ii) forecasts or projections (including those covering one or more of revenues, SG&A, income, earnings per share or proposed transactions or developments), (iii) significant mergers, acquisitions, dispositions, tender offers or takeover bids, joint ventures or changes in assets, (iv) changes in control of MID or MEC, (v) changes in debt ratings, (vi) significant write-downs of assets or additions to reserves for bad debts or contingent liabilities, (vii) liquidity problems, (viii) significant developments regarding material tenants, partners, contractors or suppliers, including the entering into or loss of significant contracts, (ix) bankruptcies or receiverships, (x) changes in the board of directors or executive management, (xi) changes in the Auditors or the Auditors' audit report to the shareholders, (xii) significant events regarding MID's securities (such as defaults on senior securities, calls of securities for redemption, repurchase plans, stock splits or changes in dividends, changes in the rights of security holders, public or private issuances and sales of additional securities, and the like), (xiii) significant litigation or other contingencies, including warranty claims, (xiv) significant investigations by government bodies, (xv) significant collective bargaining agreements or significant labour disputes, and (xvi) borrowing of a significant amount of funds. Note that this list is merely illustrative and not exhaustive and that what is considered "material" or "significant" depends on the facts of each situation. A list of the current outstanding equity securities of MID is included at the end of this Policy.

3. The decision about whether information is considered Material Non-Public Information and what action should be taken so that the necessary disclosure will be made in accordance with all legal and stock exchange requirements must only be made by the Disclosure Team (described below). If MID Personnel become aware of information that may be considered Material Non-Public Information, such MID Personnel should advise the relevant immediate supervisor or a member of the Disclosure Team so that a proper determination can be made about whether the information should be publicly disclosed.

4. MID disseminates material information broadly to the market in accordance with all applicable legal, regulatory and stock exchange requirements, subject to the provisions of paragraph 12 of this Policy. MID does not disclose such information selectively to certain groups or individuals, such as analysts or institutional investors, before it has been disclosed to the public. This type of disclosure, often referred to as "selective disclosure", is both improper and illegal and constitutes a violation of this Policy.

Disclosure Team

5. The Chief Executive Officer of MID (the "CEO") has established a Disclosure Team for overseeing MID's disclosure practices. The Disclosure Team will consist of the COO, the CFO, the General Counsel, the Corporate Secretary, the Controller and the Associate General Counsel. The current members of the Disclosure Team are listed at the end of this Policy.

6. The Disclosure Team will meet as conditions warrant and, in consultation with the CEO and with outside counsel to the extent deemed necessary, will determine what developments justify public disclosure.

7. It is essential that the Disclosure Team be fully apprised of all material corporate developments to be able to determine whether there is information that should be publicly disclosed and what action should be taken so that the necessary disclosure will be made in accordance with all legal and stock exchange requirements. It is critical that all MID Personnel make known to a member of the Disclosure Team material information relating to MID and any of its subsidiaries. MID Personnel must provide that information to a member of the Disclosure Team as he or she becomes aware that it is, or may be, material. This applies throughout the year, but is particularly critical when annual and quarterly financial statements and MD&A and MID's annual information form are being prepared.

Authorized Spokespeople

8. Unless otherwise approved by MID's Board of Directors or as specified below, the only persons authorized to discuss MID matters with the media, securities industry professionals (e.g. securities analysts, investment bankers and institutional investors or mutual fund representatives) or MID security holders are as follows: The Chairman, the Vice-Chairman, the CEO, the COO, the CFO, the General Counsel and the Corporate Secretary (each an "Authorized Spokesperson"). In certain special circumstances, such Authorized Spokespersons may designate senior employees of MID to discuss specified MID matters on their behalf. The current Authorized Spokespersons are listed at the end of this Policy.

Disclosure Of Material Non-public Information

9. Except in accordance with the procedures set forth in this Policy, no MID Personnel may ever discuss or otherwise disclose Material Non-Public Information with any person other than in the necessary course of business. If disclosure to third party recipients is required, MID Personnel shall ensure that adequate measures are taken to protect the confidentiality of the information, which may include the execution of a written confidentiality agreement with the third party recipient of such information in a form approved by the General Counsel or Corporate Secretary. In addition, MID Personnel should limit access to such Material Non-Public Information to those MID Personnel who need to know the information by virtue of their position and responsibilities and such persons must be notified that such information is to be kept confidential.

10. Subject to the specific provisions detailed below regarding the disclosure of quarterly financial information and to paragraph 12 of this Policy, all Material Non-Public Information pertaining to MID should be first disclosed to the public either (i) by means of a widely disseminated press release, or (ii) by another method reasonably expected to effect a broad and non-exclusionary distribution of information to the public, i.e., pre-announced webcast or open conference call. The Market Surveillance department of the TSX and the relevant department at the NYSE must generally be advised prior to the dissemination of any Material Non-Public Information, including providing a copy of any press release. This will allow the stock exchanges to determine whether a trading halt is necessary if the dissemination will occur during trading hours.

11. Disclosure must include any information the omission of which would make the rest of the disclosure misleading. In addition, unfavourable Material Non-Public Information must be disclosed as promptly and completely as favourable Material Non-Public Information. In the case of the disclosure of Material Non-Public Information which, according to the applicable legal rules, constitutes a material change for MID, MID shall file, in addition to the press release as provided above, (a) a material change report with the OSC and other applicable Canadian securities regulatory authorities as soon as practicable and in any event within ten days of the date on which the change occurs, (b) such information and documents with the SEC as required pursuant to the U.S. Securities Exchange Act of 1934, as amended and (c) such other forms, reports and information as the OSC, SEC or other applicable regulatory agencies or stock exchanges may require from time to time.

12. In certain cases, the Disclosure Team may determine that disclosure of Material Non-Public Information would be unduly detrimental to MID (for example, if disclosure would prejudice negotiations in a corporate transaction). In this case, MID will continue to keep such Material Non- Public Information confidential and, to the extent required, MID will file with the OSC and other applicable Canadian securities commissions a confidential material change report. At least every ten days thereafter the decision to keep the information confidential must be reviewed by MID and at that time MID must either notify the applicable securities commission in writing of its decision to keep the report confidential (to the extent required) or disseminate the Material Non-Public Information pursuant to paragraph 10 of this Policy. During the confidentiality period, MID will take the necessary precautions to maintain the confidentiality of the information, including the execution of written confidentiality agreements with any third party recipient of the information.

Disclosure Of Quarterly Earnings Information

13. Quarterly earnings information regarding MID shall be disclosed in the following manner:

First, a press release containing a discussion of MID's quarterly earnings results shall be submitted to the appropriate newswire services for dissemination in Canada and the U.S. as approved by the COO, CFO, General Counsel or Corporate Secretary. Second, advance notice of the time, date and connection instructions for the quarterly earnings conference call and/or webcast will be:

(i) released in advance (generally not less than five (5) business days, but in any event not less than 18 hours prior to the conference call and/or webcast) or, where not released in advance, included in the quarterly earnings press release which is generally issued on the morning of the conference call and/or webcast, and

(ii) posted on MID's website, generally not less than five (5) business days prior to the quarterly earnings release. Third, the quarterly earnings conference call should be broadcast live on a medium (i.e. open conference call or webcast) that will allow the public, without charge, to listen in on the call, and, to the extent reasonably possible, provision should be made for a taped replay of the conference call to be made available for a number of days thereafter. Assuming that these steps have been followed, the information contained in the quarterly earnings press release may be discussed freely on the scheduled conference call.

14. No MID Personnel should ever discuss MID's income, funds from operations or earnings per share information (including giving any "guidance" or "comfort" on securities analyst estimates or reports) with any person, except in accordance with the provisions of this Policy.

Dealing with the Press, General Media and Industry Communications, Rumours and Leaks

15. All press releases to be issued by or on behalf of MID or its subsidiaries (including its public subsidiary, MEC) must be forwarded, at least 48 hours (or as promptly as practicable) prior to issuance, to the COO, CFO, General Counsel and Corporate Secretary for their review and approval prior to release.

16. This Policy acknowledges that MID communicates on a regular basis in the ordinary course of business with its customers, suppliers, partners, tenants, consultants, contractors and other third parties other than investors and shareholders, by means of media communications and otherwise. Such communications are not, in and of themselves, subject to this Policy except in those instances where such communications involve the dissemination or discussion of Material Non-Public Information. In the event of any doubt as to whether or not information in a particular instance constitutes Material Non-Public Information, such information will be referred to the COO, CFO, General Counsel or Corporate Secretary for consideration prior to distribution or discussion.

17. If any individual (including a securities industry professional, MID security holder, government official, media representative, etc.) contacts MID Personnel seeking information regarding MID, that individual must notify the outsider that in accordance with this Policy, all such inquiries are to be directed to the CEO, COO or CFO or, in their absence, the General Counsel or Corporate Secretary. If such inquiry relates to a market rumour, the Authorized Spokesperson should, subject to legal advice to the contrary, advise the outsider that MID has a Policy that it does not comment on market rumours. If any applicable securities regulatory authority or stock exchange requests that MID make a definitive statement in response to a market rumour that is causing significant fluctuation in MID's listed securities, MID will consider whether to make a Policy exception and respond to the rumour.

18. If any MID Personnel becomes aware that there has been an inadvertent disclosure of Material Non-Public Information, he or she should immediately contact a member of the Disclosure Team. Upon being contacted under such circumstances, the member of the Disclosure Team shall (in consultation with MID's legal advisors, if considered appropriate) develop a plan to make public disclosure of the information in accordance with the provisions of this Policy and shall use his or her best efforts to execute such plan as soon as practicable, but in any event within the time period, if any, prescribed by applicable law.

19. Each Authorized Spokesperson should, prior to any scheduled interaction with securities industry professionals or MID's security holders, take an inventory of what information relating to MID or its subsidiaries (in addition to the information listed in paragraph 2 of this Policy) might reasonably be considered to be Material Non-Public Information. Prior to the scheduled interaction, the Authorized Spokesperson should decide whether to (i) keep the information "off-limits" for the interaction with the outsider(s) or (ii) disclose the information publicly by one of the means mentioned in clauses (i) or (ii) of paragraph 10 of this Policy. All speeches or talks at a public forum or an event where a member of the media could have access (other than industry conferences where Material Non-Public Information is not anticipated to be disclosed or discussed) must be approved in advance by the COO, CFO, General Counsel or Corporate Secretary. No Material Non-Public Information may be released in any forum unless approved by an Authorized Spokesperson and accompanied by wide public dissemination in accordance with this Policy. Participants in industry conferences are encouraged to check with the COO, CFO, General Counsel or Corporate Secretary if the subject matter of an industry conference appears to be sensitive or controversial.

20. All "road show" and other similar materials (including analyst presentations) to be distributed to or discussed with securities industry professionals or MID's security holders (or prospective security holders) must, prior to the time of their use, be sent to the COO, CFO, General Counsel and Corporate Secretary for their review and approval prior to use.

Analyst Reports

21. MID may review, upon request, analysts' models or reports subject to the applicable restrictions of the OSC, SEC, TSX or NYSE or other applicable securities regulatory authority or stock exchange. Any review will be conducted by the CEO, COO, CFO, General Counsel or Corporate Secretary and any comments will be limited to those portions of the model or report that constitute statements of historical fact or a factual description of MID's business or which discuss information which is not material or has otherwise been publicly disclosed. An Authorized Spokesperson may correct factual errors in analysts' reports and models, provided the factual information has already been broadly disseminated to the public or is not material. In no event shall the Authorized Spokesperson or any other MID Personnel publicly comment on, confirm, deny, or guide any forward-looking statements or financial projections contained in such reports. Analyst reports are proprietary products of the analyst's firm. Re-circulating a report by an analyst may be viewed as an endorsement by MID of the report. For these reasons, careful consideration should be given before any analyst reports are recirculated to persons outside of MID or to employees of MID, and it must always be made clear that the report is being provided for information purposes only and not as an endorsement of the views expressed therein. MID may post on its website a complete list, regardless of the recommendation, of all the investment firms and analysts who provide research coverage on MID. Such list will not include links to analysts' or any other third party websites or publications.

Continuous Disclosure Record

22. When MID has in the past offered securities to the public, it has issued a prospectus in accordance with applicable laws. Such a prospectus sets out "full, true and plain disclosure" of the material facts relating to the securities issued by MID. This means that the document does not contain any untrue statement of a material fact nor does it omit to state a material fact required to be stated or that is necessary to be stated to make a statement not misleading in light of the circumstances in which it was made. If MID offers securities in the future, and to the extent required by applicable laws, a similar document will be prepared and will also contain "full, true and plain disclosure" of the material facts relating to the securities issued by MID.

23. As a public entity, MID must provide certain information to its security holders, to securities regulators and to the stock exchanges on which it is listed on a regular basis. The CEO and the CFO are ultimately accountable for MID's public disclosure. They have supervised the design of disclosure controls and procedures in connection with the creation of that disclosure. The Disclosure Team is responsible for the implementation of these controls and procedures.

24. If any MID Personnel is asked to review a continuous disclosure document of MID, that person must consider all information about MID of which he or she is aware in order to adequately assess whether the disclosure being reviewed is accurate, fails to state a material piece of information or is misleading or inaccurate in any way. MID Personnel must bring to the attention of the Disclosure Team any information that they know or reasonably believe to be misleading or inaccurate in a continuous disclosure document. MID Personnel should also advise the Disclosure Team if they believe that a continuous disclosure document omits to state a fact or information that may be material to an understanding of the results of operations of MID or the performance of MID as a whole.

25. All electronic and other regulatory filings made by or on behalf of MID, including without limitation, all periodic and other filings required to be made with applicable securities regulatory authorities and stock exchanges, shall be prepared under the supervision of the General Counsel or Corporate Secretary.

Forward-looking Information

26. If MID decides to disclose forward-looking information or financial projections in continuous disclosure documents, speeches, webcasts, conference calls, etc., the following guidelines shall be observed:

(a) The information, if deemed material, will be broadly disseminated (for example, via press release) prior to any other type of disclosure.

(b) The information will be clearly identified as forward-looking.

(c) MID will identify all material assumptions used in the preparation of the forward-looking information.

(d) The information will be accompanied by MID's then current "Forward Looking Information Disclaimer" together with a reference to MID's current "Risk Factors" disclosure. Notwithstanding this disclaimer, should subsequent events prove past statements about current trends to be materially off target, MID may choose to update prior disclosures explaining the reasons for the difference. In this case, MID will update its guidance on the anticipated impact, if any, on revenue and earnings (or other key metrics).

Website Disclosure

27. Disclosure of Non-Public Material Information on MID's website currently does not in and of itself constitute adequate public disclosure of such information. As such, Material Non-Public Information which has not otherwise been disclosed in accordance with one or more of the methods noted in paragraph 10 of this Policy, shall not be posted on MID's website.

28. The COO, CFO, General Counsel or Corporate Secretary shall be responsible for reviewing and approving in advance all financial and other information to be posted on MID's website so as to ensure the accuracy, completeness and currency of the information posted thereon. MID's website shall at all times incorporate by reference the most current version of MID's "Risk Factors" disclosure as contained in MID's public disclosure record. The website shall also set forth in a clear and prominent manner, a current version of MID's forward-looking statement disclaimer. The COO, CFO, General Counsel or Corporate Secretary must approve all links from MID's website to third party websites. As noted above, in no event shall MID's website post or hyperlink to analysts reports or any other similar third party information regarding MID.

Related Policies

29. Please see MID's Insider Trading and Reporting Policy for additional prohibitions relating to trades in MID securities including those using Material Non-Public Information, a copy of which may be obtained from the General Counsel or Corporate Secretary.

It is critical that all MID Personnel adhere to this Policy. If you have any doubts as to your responsibilities under this Policy, please seek clarification and guidance from the COO, CFO, General Counsel or Corporate Secretary before you act. Do not try to resolve uncertainties on your own.

Dated: October 1, 2004; revised as of October 4, 2006, July 3, 2007 and November 7, 2008.

Notes

1. For the purposes of the Policy, Frank Stronach is MID's Chairman, Dennis Mills is MID's Vice-Chairman and Chief Executive Officer, Don Cameron is MID's Chief Operating Officer, and Rocco Liscio is MID's Chief Financial Officer.

2. As November 7, 2008, MID's outstanding equity securities consist of its Class A Subordinate Voting Shares and Class B Shares.