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                                                                      EXHIBIT 11

                        VIATEL HOLDING (BERMUDA) LIMITED

                                 CODE OF ETHICS

The principles set forth in this Code of Ethics define a minimum set of ethical
standards for all Viatel employees worldwide. The Code of Ethics is intended to
reflect cultural and legal differences in the various locations where we do
business. Viatel adheres to strict standards of honesty and conducts business
with uncompromising integrity and professionalism.

These principles:

         -    Reflect a corporate decision on how we perform global activities

         -    Are relevant to ALL Viatel employees worldwide

         -    Are approved and managed by Viatel executive staff

         -    Are reviewed on a regular basis

Viatel is committed to apply our management systems and reporting structures to
ensure adherence to these principles across our organisation.

ACCORDINGLY:

         -    Viatel respects, values and welcomes diversity in its workforce,
              its customers, its suppliers and the global marketplace. Viatel
              will comply with applicable laws and provide equal employment
              opportunity for all applicants and employees without regard to
              race, colour, religion, sex, national origin, ancestry, age,
              disability, veteran status, marital status, sexual orientation or
              gender identity. This applies to all areas of employment. Viatel
              also provides reasonable accommodation to disabled applicants and
              employees to enable them to apply for and to perform the essential
              functions of their jobs.

         -    Viatel will provide a workplace free of sexual harassment as well
              as harassment based on race, colour, religion, sex, national
              origin, ancestry, age, disability, veteran status, marital status,
              sexual orientation or gender identity. We will not tolerate such
              harassment of employees by managers, co-workers or non-employees
              in the workplace.

         -    Viatel will achieve high standards of environmental quality and
              safety, and provide a safe and healthful workplace for our
              employees, contractors and communities. We will comply with
              applicable environmental, health and safety regulatory
              requirements as a minimum and implement programs and

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              processes to achieve greater protection, where appropriate. We
              seek a workplace free of occupational injury and illness. We are
              committed to conserving natural resources and reducing the
              environmental burden of waste generation and emissions.

         -    Viatel respects the privacy of consumers, customers and employees.
              Viatel is committed to user privacy in our products and services.
              We support consumer choice and informed consent.

         -    Viatel will provide a secure business environment for the
              protection of our employees, product, materials, equipment,
              systems and information.

         -    Viatel prohibits bribes and kickbacks. Viatel employees may not
              offer or accept a bribe or a kickback. Bribes and kickbacks are
              prohibited either directly or through a third party.

         -    Viatel encourages competition, which benefits consumers by
              prohibiting unreasonable restraints on trade. Viatel competes
              vigorously while at the same time adhering to both the letter and
              spirit of competition laws.

         -    Viatel recognises and respects the right of our employees to
              support or oppose representation or association with outside
              organisations. We are committed to treating our employees fairly
              and providing them with safe jobs and competitive wages and
              benefits.

         -    Viatel prohibits "insider dealing". Employees may not use
              material, non-public information to profit from trades in the
              Company's shares or other securities and must be equally careful
              not to make such information available to others who might profit
              from it.

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