EXHIBIT 11

                              [GRUPO ELEKTRA LOGO]

                                 CODE OF ETHICS
      FOR TOP EXECUTIVES, OFFICERS AND MEMBERS OF THE BOARD OF DIRECTORS OF
                          GRUPO ELEKTRA, S.A. DE C.V.

                                    OBJECTIVE

      The purpose of this Code of Ethics (hereinafter "the Code") is to promote
honesty and an ethical conduct for top executives of Grupo Elektra, S.A. de C.V.
(hereinafter "the Company") including the ethical handling of conflicts of
interest that arise from personal and professional relations; to promote the
disclosure of complete, precise, accurate, timely and comprehensible information
in any reports and documents that the Company submits to the National Banking
and Securities Commission (CNBV), the Mexican Stock Exchange (BMV), the
Securities and Exchange Commission (SEC), the New York Stock Exchange (NYSE), as
well as in any other public release that it carries out before any domestic or
international authority; promoting that the conduct of the Company and/or of its
officers abide by the applicable laws, regulations and provisions of general
nature.

                                   APPLICATION

      This Code of Ethics shall apply to the members of the Board of Directors
and to their Committees, to the Chairman and Vice-presidents, to all the
officers of the Company, giving special emphasis in its application to the Chief
Executive Officer, to the Chief Operating Officer, to the Chief Financial
Officer and to the General Counsel (hereinafter jointly referred to as "The Top
Executives and Officers").

                                BASIC PRINCIPLES

      1. BEHAVIOR.

      It is expected that each of the Top Executives and Officers acts according
to the highest standards of honesty and ethical conduct at all times and in any
aspect of their activities, strictly abiding by the laws, regulations and
general provisions applicable in Mexico and the United States, as well as by the
laws of other countries in which the Company conducts businesses; and that they
act according to this Code of Ethics, and in accordance with the guidelines set
by other policies and procedures adopted by the Company in order to regulate the
behavior of its employees.

      Each director shall be responsible for his or her own adherence to this
Code of Ethics.

      To act according to this Code of Ethics is a condition for the
job/employment and any breach thereof shall give rise to the application of
penalties, which could consist in, depending on the seriousness of the breach,
in economic penalties or even, the dismissal from office. The above, regardless
of the legal actions that could derive from the action or omission (when there
is a duty to perform) incurred by them.

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      2. WAIVERS.

      No waiver shall apply to any of the provisions contained in this Code of
Ethics, except when the Board of Directors approves by a majority vote the
existence of a justified cause that allows, in specific cases, the non-binding
effect of any of the provisions contemplated herein. Only for these cases, the
Board shall verify that said exemption is appropriate and it shall ensure that
such exemption has the necessary controls designed to protect the Company.

      In the event that the waiver to any of the provisions is approved, all the
Top Executives and Officers shall be informed of said waiver.

      3. ETHICAL CONDUCT AND CONFLICTS OF INTEREST.

      It is expected that the Top Executives and the Officers of the Company
take the decisions and business actions always seeking the greatest benefit for
the Company, and not based on personal relations or on any personal benefit.

      It shall be understood as conflict of interest, including without
limitation, the following:

      (i)   When there is a cause, fact or a situation of a personal nature that
            interferes, in any manner, with the achievement of the greatest
            benefit for the Company,

      (ii)  When there is an interest that hinders performing the job
            objectively, or

      (iii) When the Top Executives or Officers receive improper personal
            benefits as a result of their position in the Company

      (iv)  When due to whatever reason personal interest is put before the
            interest of the Company.

      When any of the Top Executives or Directors is (are) under a conflict of
interest he or she (they) shall excuse themselves from taking any decision
regarding the situation in question and they shall immediately notify their
hierarchic superior in order that the latter takes the decision that most
benefits the Company.

      As regards the members of the Board of Directors, they hold a special
responsibility before the Company and their shareholders. In order to avoid
conflicts of interest, the director shall inform to the other members of the
Board of any personal interest that he or she may have in any transaction that
is to be taken into consideration by the Board, excusing him or herself from
taking any decision that involves any conflict of interest.

      Any finding of a potential conflict of interest or its existence shall be
informed to the Administration in accordance with the procedure established in
section 13 of this Code.

      Sound judgment shall be used to seek advice when it is appropriate and in
order to adhere to the highest ethical standards. Everyone must be aware that
the activities and the financial interests of the spouse, relatives, children,
parents or in-laws, friends, investors, suppliers, direct competitors, can give
rise to a potential conflict of interest or to an apparent conflict of interest.

      In the event of doubts regarding whether certain behavior would be
considered a conflict of interest, please consult the Chairman of the Audit
Committee.

      4. IMPROPER PERSONAL BENEFIT.

      Conflicts of interest may occur when the Top Executive or Officer
personally, or a relative or friend of said Top Executive or Officer receives a
personal benefit in an improper manner because of his or her position in the
Company.

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      No benefits of the Company shall be accepted if they have not been
authorized and approved pursuant to the policies and procedures of the Company,
including any gratuity, loan or security.

      5. OWNERSHIP OR FINANCIAL INTERESTS IN OTHER BUSINESSES.

      You must be unconditionally loyal to the Company. You must avoid having
ownership interests in any other company, if such interest compromises or
interferes with your capacity to exercise an independent judgment in the best
interest of the company.

      This provision does not apply to investors holding less than one per cent
of the stock of a public company, provided that the amount of the investment is
not such that it could have an effect on the business judgment in detriment of
the Company.

      6. CORPORATE OPPORTUNITIES.

      It is mandatory to have the duty towards the Company to promote its
legitimate interests. No personal advantage shall be taken by means of the use
of property, information or of your position in the Company that is known by
virtue of said position.

      7. BEING EMPLOYED BY OUR COMPETITORS.

      During the time that you are acting as employee of the Company, and during
the year immediately following the one in which your labor relation is
terminated with the Company, it is strictly forbidden to render services as an
officer or to be employed in any manner whatsoever by a competitor of the
Company, as well as to carry out any activity with the intention of seeking or
hoping to promote the interests of a competitor in detriment of the interests of
the Company.

      8. BEING EMPLOYED WITH A SUPPLIER.

      The persons subject to this Code during the time that they act as
employees of the Company, as well as during the year immediately following the
one in which their labor relation is terminated, cannot, with any supplier or
client or direct competitor of the Company:

      (i)   Be a supplier or employee of the aforementioned;

      (ii)  Render services or represent any of the above, and

      (iii) Accept Money or benefits from third parties as payment or
            compensation for any advice or service that you provide to any
            client, supplier, direct competitor or any other person in
            connection with the business of the Company.

      9. CONFIDENTIALITY.

      The confidentiality of the information that has been entrusted by the
Company, suppliers or clients, except when the disclosure is authorized or
ordered in compliance with the law. The confidential information includes all
the information that is not public in nature and that could be used by
competitors, or that could cause any harm to the Company, its suppliers or
clients, in the event that such information is disclosed.

      10. FAIR NEGOTIATIONS.

      An effort shall be made to negotiate in a fair manner with the clients,
suppliers, competitors and employees of the Company, provided unfair advantage
of any person may not be taken, by means of manipulation, concealment or abuse
in the use of privileged information, by misrepresentation of material facts, or
any other unfair practice.

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      The use of privileged information is illegal and unethical. The Top
Executives or Officers shall accept all the aspects of the terms of the policies
for the use of privileged information of the Company set forth in the Policies
for the Use of Privileged Information.

      11. PROTECTION AND USE OF THE ASSETS OF THE COMPANY.

      The assets of the Company shall be protected, ensuring its correct and
efficient use.

      To misappropriate the assets of the Company as well as the mistreatment,
incorrect or non-authorized use or waste of said assets constitutes the
nonperformance of the duty towards the Company and it shall be considered as a
fraudulent action.

      All of the assets of the Company shall be used for the Company's
legitimate business purposes.

      12. ACCURACY OF PERIODIC REPORTS AND OTHER PUBLIC RELEASES.

      Pursuant to the legal framework in effect imposed by the CNBV, BMV, SEC
and NYSE, complete, precise, accurate, timely and comprehensible information is
required in all periodic reports and communications of public nature sent to
such institutions, as well as any other information delivered to the general
public. The highest level of care is required when preparing such reports and
communications.

      In order to guarantee the quality of the information required in the
preceding paragraph, the mandatory guidelines to be followed for their
preparation and remittance are listed below:

      I.    Any accounting records, as well as any reports carried out from such
            records, shall be kept and submitted in accordance with the
            applicable laws.

      II.   All the records shall evidence in a correct and accurate manner the
            relevant transaction or event.

      III.  All records shall reflect in a correct and exact manner with
            reasonable detail the assets, obligations, liabilities and costs of
            the Corporation.

      IV.   The accounting records of the Corporation shall not contain any
            false or misleading entries inserted intentionally.

      V.    No transaction shall be mistakenly classified in an intentional
            manner in connection with accounts, departments or accounting
            periods or in any other manner.

      VI.   All transactions shall be supported with the exact documentation
            with reasonable detail and it shall be recorded in the correct
            account and in the corresponding accounting period.

      VII.  No information whatsoever is to be hidden from the internal or
            independent auditors.

      VIII. Observance of the Generally Accepted Accounting Principles and the
            accounting control systems of the Corporation is required at all
            times.

      Since we are a respectable public company, it is essential that the
information reported to the CNBV, BMV, SEC and NYSE, as well as to any other
domestic or international authority, or any other information delivered to the
general public, is complete, timely and accurate in all aspects.

      The top Executives and Officers are responsible of supplying the
administration accurate and complete information, in order to comply with the
information disclosure requirement and with the commitments with the
shareholders of the Corporation.

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      In accordance with these duties, the top Executives and Officers agree:

      I.    They shall conduct themselves in a correct and honest manner in the
            performance of their duties, avoiding always any conflict of
            interests in their personal and professional relations.

      II.   They shall provide accurate, complete, objective, relevant, and
            comprehensible information in time, making sure that the information
            contained in the reports filed with the CNBV, BMV, SEC, and NYSE, as
            well as with any other authority whether domestic or international,
            or that may be utilized in any other public communication of the
            Corporation is complete, exact, accurate and comprehensible.

      III.  They shall act in compliance to the applicable federal, state and
            municipal laws, regulations and provisions, as well as to the
            appropriate regulations from public or private agencies that may be
            applicable to the management of the Corporation's business and to
            its financial report.

      IV.   They shall act in good faith, with responsibility, due care,
            competitively and with utmost diligence, without making
            misrepresentations of material facts or to allow the subordination
            of their independent judgment.

      V.    They shall honor the confidential nature of the information they
            acquire during the course of their work, except in the event its
            disclosure is authorized or they are legally compelled to disclose
            such information. Accordingly, they shall not use the confidential
            information acquired for the best performance of their duties in
            their own benefit.

      VI.   They shall share the relevant knowledge and capabilities so that the
            other members of the Corporation may carry out their duties.

      VII.  They shall actively promote an ethical conduct and they shall set
            the example of an ethical conduct as responsible executives among
            the other executives and colleague in their own work environment and
            community.

      VIII. They shall make use in a responsible manner and they shall have
            absolute control of all the Corporation's resources and assets
            entrusted to them.

      IX.   They shall inform the Board of Directors, The Chief Executive
            Officer or the Chairman of the Audit Committee forthwith, any
            information related to:

            (i)   Any conduct they deem contrary to the law, business ethics and
                  this Code, including any transaction or relation that may
                  reasonably cause a conflict of interest;

            (ii)  Any meaningful deficiencies in the assigning or operation of
                  internal controls that may affect the ability of the
                  Corporation to register, process or summarize and report
                  financial data, or

            (iii) Any fraud, whether material or not, involving the
                  administration or other employees having an important role in
                  the financial reports, in the disclosure of information or in
                  the internal controls of the Corporation.

      13. COMPLIANCE WITH THE LAW AND THE CODE OF ETHICS; REPORTING ILLEGAL OR
UNETHICAL ACTIONS.

      The conduct of the Top Executives and Officers shall abide to the laws,
regulations and applicable governmental provisions and this Code of Ethics,
provided any violation or suspected violation to said laws, regulations or
applicable governmental provisions must be reported to the Chairman of the Audit
Committee. Nobody shall be subject to retaliation when reporting in good faith,
the suspicion of any violation.

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      The individual suspecting of any violation to this Code shall be obliged
to report it forthwith to the Chairman of the Audit Committee or else, to any
member of the Board of Directors of the Corporation, cooperating in the
investigation of the alleged violation.

      The report shall contain the most specific information as possible in
order to be able to learn the seriousness, the nature and degree of
participation and urgency of the alleged violation.

      Without limiting the foregoing, the report shall contain, to the extent
possible, the following information:

      (i)   The occurrence, circumstance or activity alleged which caused the
            cause violation;

      (ii)  The name of the individual involved;

      (iii) Whether the alleged violation involves any specific event or events,
            approximate dates and the place of the occurrence.

      (iv)  Any additional information, documentation or any other evidence
            available that is related to the alleged violation.

      The Chairman of the Audit Committee and the Board of Directors have the
authority to monitor, investigate, take determinations and carry out any action
with respect to the violations to this Code.

      When determining the existence of a violation to this Code, The Board of
Directors shall consider the following:

      (i)   The nature and seriousness of the violation;

      (ii)  Whether the violation occurred only once or repeatedly;

      (iii) Whether the violation was intentional or not;

      (iv)  Whether the individual in question was advised before the violation
            was committed as to the correct form of conduct;

      (v)   Whether the individual in question has committed other violations in
            the past; and

      (vi)  Any other fact or circumstance that the Board of Directors considers
            appropriate in connection with the alleged violation.

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<PAGE>

                              [GRUPO ELEKTRA LOGO]

                                 CODE OF ETHICS
       FOR TOP EXECUTIVES, OFFICERS AND MEMBERS OF THE BOARD OF DIRECTORS
                         OF GRUPO ELEKTRA, S.A. DE C.V.

                                 ACCEPTANCE FORM

I.    I agree and accept that I have received and read the Code of Ethics for
      Top Executives and Officers of Grupo Elektra, S.A. de C.V.

II.   I fully understand my duty of abiding to the aforementioned Code of
      Ethics.

III.  I agree to conduct myself in compliance with the standards contained in
      this Code of Ethics, the Policies and Procedures related to it and
      established by the Corporation.

IV.   I agree and acknowledge that I am responsible for reporting to the
      Chairman of the Audit Committee any suspicion of violation to this Code of
      Ethics.

      Name:
      Position:
      Date:
      Signature:

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