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                                                                      EXHIBIT 11

                            STENA AB - CODE OF ETHICS
                FOR CHIEF EXECUTIVE AND SENIOR FINANCIAL OFFICERS

The Company is committed to conducting our business in accordance with
applicable laws, rules and regulations and the highest standards of business
conduct, and to full and accurate financial disclosure in compliance with
applicable law. This Code of Ethics, applicable to the Company's Chief Executive
Officer, Chief Financial Officer, Chief Controller and Chief Accounting Officer
(together, "Senior Officers"), sets forth specific policies to guide you in the
performance of your duties.

As a Senior Officer, you must not only comply with applicable law. You also must
engage in and promote honest and ethical conduct and abide by this Code of
Ethics and other Company policies and procedures that govern the conduct of our
business. Your leadership responsibilities include creating a culture of ethical
business conduct and commitment to compliance, maintaining a work environment
that encourages employees to raise concerns, and promptly addressing employee
compliance concerns.

COMPLIANCE WITH LAWS, RULES AND REGULATIONS

You are required to comply with the laws, rules and regulations that govern the
conduct of our business and to report any suspected violations in accordance
with the section below entitled "Compliance With Code Of Ethics."

CONFLICTS OF INTEREST

Your obligation to conduct the Company's business in an honest and ethical
manner includes the ethical handling of actual or apparent conflicts of interest
between personal and professional relationships. No Senior Officer shall make
any investment, accept any position or benefits, participate in any transaction
or business arrangement or otherwise act in a manner that creates or appears to
create a conflict of interest unless the Senior Officer makes full disclosure of
all facts and circumstances to, and obtains the prior written approval of, the
Chairman of the Board of Directors.

DISCLOSURES

It is Company policy to make full, fair, accurate, timely and understandable
disclosure in compliance with all applicable laws and regulations in all reports
and documents that the Company files with, or submits to, the Securities and
Exchange Commission and other regulatory authorities and in all other public
communications made by the Company. As a Senior Officer, you are required to
promote compliance with this policy and to abide by Company standards, policies
and procedures designed to promote compliance with this policy.

COMPLIANCE WITH CODE OF ETHICS

If you know of or suspect a violation of applicable laws, rules or regulations
or this Code of Ethics, you must immediately report that information to the
Chairman of the Board of Directors. No one will be subject to retaliation
because of a good faith report of a suspected violation.

Violations of this Code of Ethics may result in disciplinary action, up to and
including discharge. The Board of Directors shall determine, or shall designate
appropriate persons to determine, appropriate action in response to violations
of this Code.

WAIVERS OF CODE OF ETHICS

If you would like to seek a waiver of the Code of Ethics you must make full
disclosure of your particular circumstances to the Board of Directors.
Amendments to and waivers of this Code of Ethics will be publicly disclosed as
required by applicable law and regulations.

NO RIGHTS CREATED

This Code of Ethics is a statement of certain fundamental principles, policies
and procedures that govern the Company's Senior Officers in the conduct of the
Company's business. It is not intended to and does not create any rights in any
employee, customer, client, supplier, competitor, shareholder or any other
person or entity.

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