Exhibit 11.1

PIXELPLUS CO., LTD.

(the Company)

CODE OF BUSINESS CONDUCT AND ETHICS

Adopted November 25, 2005

I. Introduction

This Code of Business Conduct and Ethics (the Code) has been adopted by our Board of Directors and summarizes the standards that must guide our actions. While covering a wide range of business
practices and procedures, these standards cannot and do not cover every issue that may arise, or every situation where ethical decisions must be made, but rather set forth key guiding principles that represent Company policies and establish
conditions for employment at the Company.

We must strive to foster a culture of honesty and accountability. Our commitment to the highest
level of honest and ethical conduct should be reflected in all of the Companys business activities including, but not limited to, relationships with employees, customers, suppliers, competitors, governments, government agencies and the public,
including our shareholders. All of our employees, officers and directors must conduct themselves according to the language and spirit of this Code and seek to avoid even the appearance of improper behavior. Even well intentioned actions that violate
the law or this Code may result in negative consequences for the Company and for the individuals involved.

One of our Companys most
valuable assets is our reputation for integrity, professionalism and fairness. We should all recognize that our actions are the foundation of our reputation and adhering to this Code and applicable law is imperative.

II. Conflicts of Interest

Our employees, officers
and directors have an obligation to conduct themselves in an honest and ethical manner and act in the best interest of the Company. All employees, officers and directors should endeavor to avoid situations that present a potential or actual conflict
between their interest and the interest of the Company.

A conflict of interest occurs when a persons private interest
interferes in any way, or even appears to interfere, with the interest of the Company, including its subsidiaries and affiliates. A conflict of interest can arise when an employee, officer or director takes an action or has an interest that may make
it difficult for him or her to perform his or her work objectively and effectively. Conflicts of interest may also arise when an employee, officer or director (or his or her family members) receives improper personal benefits as a result of the
employees, officers or directors position in the Company.

Although it would not be possible to describe every situation
in which a conflict of interest may arise, the following are examples of situations which may constitute a conflict of interest:



| |  |  | Working, in any capacity, for a competitor, customer or supplier while employed by the Company.
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| |  |  | Accepting gifts of more than modest value or receiving personal discounts (if such discounts are not generally offered to the public) or other benefits as a result of your position
in the Company from a competitor, customer or supplier.
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| |  |  | Competing with the Company for the purchase or sale of property, products, services or other interests.
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| |  |  | Having an interest in a transaction involving the Company, a competitor, customer or supplier (other than as an employee, officer or director of the Company and not including
routine investments in publicly traded companies).
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| |  |  | Receiving a loan or guarantee of an obligation as a result of your position with the Company.
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| |  |  | Directing business to a supplier owned or managed by, or which employs, a relative or friend.
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Situations involving a conflict of interest may not always be obvious or easy to resolve. You should report actions that may involve a conflict of
interest to the General Counsel.

In order to avoid conflicts of interests, senior executive officers and directors must disclose to the
General Counsel any material transaction or relationship that reasonably could be expected to give rise to such a conflict. Conflicts of interests involving the General Counsel shall be disclosed to the Board of Directors.

In the event that an actual or apparent conflict of interest arises between the personal and professional relationship or activities of an employee,
officer or director, the employee, officer or director involved is required to handle such conflict of interest in an ethical manner in accordance with the provisions of this Code.

III. Quality of Public Disclosures

The Company has a responsibility to communicate effectively with
shareholders so that they are provided with full and accurate information, in all material respects, about the Companys financial condition and results of operations. Our reports and documents filed with or submitted to the United States
Securities and Exchange Commission and the Nasdaq National Market and our other public communications shall include full, fair, accurate, timely and understandable disclosure.

IV. Compliance with Laws, Rules and Regulations

We are strongly committed to conducting our business
affairs with honesty and integrity and in full compliance with all applicable laws, rules and regulations. No employee, officer or director of the Company shall commit an illegal or unethical act, or instruct others to do so, for any reason.

If you believe that any practice raises questions as to compliance with any applicable law, rule or regulation or if you otherwise have
questions regarding any law, rule or regulation, please contact your supervisor/manager or the General Counsel.

V. Compliance with this Code and
Reporting of Any Illegal or Unethical Behavior

All employees, directors and officers are expected to comply with all of the provisions
of this Code. The Code will be strictly enforced and violations will be dealt with immediately, including subjecting persons to corrective and/or disciplinary action such as dismissal or removal from office. Violations of the Code that involve
illegal behavior will be reported to the appropriate governmental authorities, if required under applicable laws, rules and regulations.

Situations which may involve a violation of ethics, laws, rules, regulations or this Code may not always be clear and may require difficult judgment. Employees, officers and directors should promptly report any concerns about violations of
ethics, laws, rules, regulations or this Code to their supervisors/managers or the General Counsel or, in the case of accounting, internal accounting controls or auditing matters, the Audit Committee of the Board of Directors.

Any concerns about violations of ethics, laws, rules, regulations or this Code by principal executive officer, principal financial officer, principal
accounting officer or controller, or persons performing similar function (the Covered Officers) should be reported promptly to the General Counsel and the General Counsel shall notify the Board of Directors. Any such concerns
involving the General Counsel should be reported to the Board of Directors.

The Company encourages all employees, officers and directors
to report any suspected violations promptly and intends to thoroughly investigate any good faith reports of violations. The Company will not tolerate any



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kind of retaliation for reports or complaints regarding misconduct that were made in good faith. Open communication of issues and concerns by all employees,
officers and directors without fear of retribution or retaliation is vital to the successful implementation of this Code. You are required to cooperate in internal investigations of misconduct and unethical behavior.

The Company recognizes the need for this Code to be applied equally to everyone it covers. The General Counsel will have primary authority and
responsibility for the enforcement of this Code, subject to the supervision of the Board of Directors, or, in the case of accounting, internal accounting controls or auditing matters, the Audit Committee of the Board of Directors, and the Company
will devote the necessary resources to enable the General Counsel to establish such procedures as may be reasonably necessary to create a culture of accountability and facilitate compliance with this Code. Questions concerning this Code should be
directed to the General Counsel.

VI. Waivers and Amendments

Any waivers (including any implicit waivers) of the provisions in this Code for the Covered Officers may only be granted by the Board of Directors and will be promptly disclosed to the Companys shareholders.
Amendments to this Code must be approved by the Board of Directors and will also be disclosed in the Companys annual report on Form 20-F.