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Exhibit 11.1

Forum National Investments Ltd

Code of Ethics

1. IntroductionForum National Investments Ltd is committed to: 
  • conducting its business in a way that is accountable to shareholders
  and the wider financial marketplace 
  • being a company respected for integrity in all its dealings 
  • being an employer that provides opportunity and reward in an environment
  of trust and respect between all employees regardless of position or function
  
  • earning the trust of shareholders 
  • being respected and welcomed in the communities where it does business
  The reputation and integrity of Forum relies on employees observing the highest
  standards of behavior when engaging in corporate activity.

2. Purpose of the CodeThis Code of Conduct (Code)
provides a common behavioral framework for all employees in the conduct of Forum
National Investments business, irrespective of their specific job, or
location.The code is a key part of Forums culture. It sets out the
standards for our relationships with our customers, employees, shareholders,
suppliers, competitors, and the community.All employees are bound by the
Code and are expected to comply with the Code when representing the company.
The objective of the Code is to ensure that: • high standards of
corporate and individual behavior are observed by all Forums employees in the
context of their employment. • employees are aware of their responsibilities
under their contract of employment • all persons dealing with Forum whether
it be employees, shareholders, suppliers, customers or competitors can be guided
by the stated values and policies of Forum. For the purpose of this document
"employees" includes Forums contractors and directors.

3. General principles• Forum National Investments
employees will conduct themselves with integrity in all areas and at all times.
• Forum will apply appropriate industry best practices to the health, safety
and wellbeing of its employees, customers, suppliers and the communities in
which it operates.
  • Forums employees will aim to bring long-term benefits to Forum
  National Investments rather than short-term advantage for individuals at the
  expense of the company's long-term interests. 
  • Forum employees will
recognize that effective teamwork requires cooperation with our colleagues
across the Company to achieve our corporate goals.

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• Forums employees will strive to ensure their words and
actions show respect for the diverse range of people and cultures with whom they
work and for their human rights.
  • Forum National Investments and its employees will exercise due care
  and diligence in the performance of their duties and responsibilities. 
  • Assets and confidential information will be
appropriately protected and must not be used by employees for personal gain.
• Employees who raise their concerns with management when they have genuine
suspicions of wrongdoing anywhere in the organization will be taken seriously
and will not be victimized.

4. Obligation to comply with codeEmployees will
adhere to the Code both in letter and in spirit. Violation of the Code by any
employee, or unethical behavior which may affect the reputation of Forum may be
subject to disciplinary action including termination of employment.

5. IntegrityAll Forums National Investments
employees are expected to conduct business in a manner that enhances the
Company's reputation and integrity. The overriding principles which govern
behavior and business dealings are: • All business should be conducted in
accordance with the laws and regulations of the provinces in which Forum
operates.• Forum will compete fairly in the markets in which it operates.
• Corrupt practices are unacceptable. No bribes or similar payments will be
made to, or accepted from, any party. Business entertainment must be in
compliance with Forums general business expense policy. • All commercial
transactions will be properly and accurately recorded. • Sales agents,
consultants and similar advisers will be appointed in accordance with these
principles and paid at a rate consistent with the value of their services. •
Conflicts of interest: Employees will disclose to the company any activities
that involve, or could appear to involve, a conflict between their personal
interests and the interests of Forum National Investments. Areas where conflicts
might arise include: ownership interests in businesses with which Forum deals,
share ownership, direct or indirect personal interest in contracts, seeking or
accepting gifts or entertainment beyond levels considered reasonable in the
business environment, employment outside of Forum or use of confidential
information.

Where a conflict of interest arises or may arise, an employee
must disclose the conflict to his or her supervisor. The supervisor will ensure
that measures are put in place to protect parties affected by the conflict of
interests from that conflict. Depending upon the nature and extent of the
conflict, the measures taken to protect against conflict of interest may include
ensuring that the conflicted or potentially conflicted employee does not
participate in the relevant decision or activity, or disclosing the conflict to
third parties affected by the conflict and ensuring that the conflicted or
potentially conflicted employee is not the sole decision maker on the matter.
Employees who are directors of Forum or its subsidiaries will be guided by the
constitution of Forum National Investments or the subsidiary and will ensure
that they abide by the provisions in the Corporations Act or equivalent local
legislation

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governing conflicts of interest. Where there is doubt the
matter should be raised with the President.• Corporate opportunities:
Employees will not take advantage of property, information or position, or
opportunities arising from these, for personal gain or to compete with Forum
National Investments. • Confidentiality: Employees will not breach Forums
confidentiality or make use of confidential information obtained from Forum for
personal gain or in a manner which would be detrimental to Forum. Confidential
information of Forum is not to be used except in ways which are authorized by
Forum or legally mandated. The same applies to confidential information
belonging to third parties which an employee may obtain in the course of their
duties. Forum will respect the confidentiality of its employees.• Share
trading policy: Employees will comply with the Forums Share Trading Policy.
• Continuous disclosure and shareholder communications: Employees will
comply with Forums Continuous Disclosure and Shareholder Communications Policy.
• Email: Employees are responsible for using the companys email and
internet resources responsibly and for company use. All communications and
information transmitted by, received from or created or stored in the companys
information systems are the companys records and property.• Improper
Influence on Conduct of Audits: It is inappropriate behavior to attempt to
improperly influence the Companys auditor.

6. Employment practicesEmployees should be treated
justly and fairly and rewarded for their achievements. Employees should feel
that they can discuss, on a confidential basis, any problem associated with
their employment with the Company. Forum National Investments employment
policies include: • Non-discrimination and sexual harassment: Forum National
Investments is an equal opportunities employer. The company is committed to
developing an appropriately qualified and experienced workforce, and providing a
work environment in which everyone is treated fairly and with respect,
irrespective of gender, race, sexual orientation, age, disability, religion or
ethnic origin. Employment and advancement within Forum National Investments will
be based on merit. • Creating an environment where everyone is encouraged to
give their best and realize their full potential. • Freedom of association:
Forum respects the individual's right to freedom of association. • Creating
an environment where employees can discuss any problems connected with their
work confident that they will receive a fair, impartial and confidential review
of the issue. • Except in the case of summary dismissal for serious
misconduct, giving employees a reasonable chance to remedy any inappropriate
conduct or performance.

7. Reporting violations of the code of ethics or other
unethical conductTrust and integrity are vital to Forum National
Investments. Misconduct and malpractice breach trust and endanger our reputation
and business. The best way of protecting trust is for employees who have genuine
suspicions about wrongdoing to know that they have a safe environment in which
to speak up without fear of reprisal

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or victimization. Employees who raise their concerns with
management when they have genuine suspicions of wrongdoing will be taken
seriously and will not be victimized. As Forum National Investments is currently
a small company, employees should contact the chief financial officer or the
president with respect to ethical and conduct issues. Their concerns will be
properly investigated and any necessary action taken. Each employee shall
receive a copy of this Code of Conduct. Management shall monitor compliance and
implement special training and/or additional monitoring as appropriate.

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