Exhibit 11.1
 ICA
 BUSINESS ETHICS AND CONDUCT CODE
 EMPRESAS ICA , S.A.B. DE C.V.
 BUSINESS ETHICS AND CONDUCT CODE 1
 Introduction
   
 1
    
    Approved by the Board of Directors on May 3, 2004.
Revised and amended by the Corporate Practices Committee on January 15,
2007 and approved by the Board of Directors on January 29, 2007.
Revised and amended by the Corporate Practices Committee on January 19,
2009 and approved by the Board of Directors on January 26, 2009.
Revised and amended by the Corporate Practices, Finance, Planning and
Sustainability Committee and the Audit Committee on January 17, 2011 and
approved by the Board of Directors on January 24, 2011.




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
  BUSINESS ETHICAL AND CONDUCT STANDARDS
  Observance of the Laws




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
  Conflict of Interests




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
    Conflict of interests with third parties derived from professional services




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
  Conflict of interests derived from investments
  Conflicts of interest derived from the use of Company time and the Companys assets for officers own benefit




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
   Conflict of interests due to loans granted to employees
  Conflict of interests derived from third parties courtesies and gifts




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
  Conflict of interests derived from relations with family members and friends




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
 Conflict of interests derived from public activities




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
 Use of position and relations in their own benefit
  Abuse of privileged information




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
   Confidential information and patents




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
 Fair treatment
  Fair treatment of clients




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
  Fair treatment to suppliers
  Fair treatment to competitors




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
  Fair treatment to employees




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
 Limitations to competitiveness




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
 Austerity
  Protection and proper use of the companys assets and other resources




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
 Adequate books and records
   Access to the Companys assets, transactions under approval and their recording




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
 Adequate books and records
  See
 Justification of payments




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
 Adequate internal control
  Complete, accurate and timely disclosure




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
 Discrimination and harassment
   Safety and Hygiene




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
  Environment
  Bribery of Public Officers




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
    Exemptions to the Business Ethics and Conduct Code




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
  Government Investigations




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
  Audits, investigations, disciplinary action




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
   Where to obtain advice




---



##### 



ICA
 BUSINESS ETHICS AND CONDUCT CODE
 ACKNOWLEDGEMENT OF ACCEPTANCE