Exhibit 11.1



ChipMOS TECHNOLOGIES (Bermuda) Ltd.

CODE OF BUSINESS CONDUCT AND ETHICS



The Board of Directors of ChipMOS TECHNOLOGIES (Bermuda) Ltd. (with its subsidiaries, the Company) has adopted this code of ethics (this Code) to:



| |  | promote honest and ethical conduct, including fair dealing and the ethical handling of conflicts of interest;
| | - | -------------------------------------------------------------------------------------------------------------



| |  | promote full, fair, accurate, timely and understandable disclosure;
| | - | -------------------------------------------------------------------



| |  | promote compliance with applicable laws and governmental rules and regulations;
| | - | -------------------------------------------------------------------------------



| |  | ensure the protection of the Companys legitimate business interests, including corporate opportunities, assets and confidential information; and
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------



| |  | deter wrongdoing.
| | - | -----------------



All directors, officers and employees of the Company are expected to be familiar with the Code and to adhere to those principles and procedures set forth
in the Code which apply to them.



For purposes of this Code,
the Code of Ethics Contact Person will be different for various employees. With respect to the Chief Executive Officer and the Chief Financial Officer (the Senior Financial Officers) and directors, the Code of Ethics Contact
Person is the Audit Committee of the Company. With respect to all other employees the Code of Ethics Person is the Personnel Appraisal Committee.



From time to time, the Company may waive some provisions of this Code. Any waiver of the Code for executive officers or directors of the Company may be
made only by the Board of Directors and must be disclosed as required by the rules of the U.S. Securities and Exchange Commission (SEC) or Nasdaq. Any waiver for other employees may be made only by the Chief Executive Officer.



I. Honest and Candid Conduct



Each director, officer and employee owes a duty to the Company to act with
integrity. Integrity requires, among other things, being honest and candid. Deceit and subordination of principle are inconsistent with integrity.



Each director, officer and employee must:



| |  | Act with integrity, including being honest and candid while still maintaining the confidentiality of information where required or consistent with the Companys policies.
| | - | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------





---

| |  | Observe both the form and spirit of laws and governmental rules and regulations, accounting standards and Company policies.
| | - | ---------------------------------------------------------------------------------------------------------------------------



| |  | Adhere to a high standard of business ethics.
| | - | ---------------------------------------------



II. Conflicts of Interest



A conflict of interest occurs when an individuals private interest interferes or appears to interfere with the interests of the Company.
A conflict of interest can arise when a director, officer or employee takes actions or has interests that may make it difficult to perform his or her Company work objectively and effectively. For example, a conflict of interest would arise if a
director, officer or employee, or a member or his or her family, receives improper personal benefits as a result of his or her position in the Company. Any material transaction or relationship that could reasonably be expected to give rise to a
conflict of interest should be discussed with the Code of Ethics Contact Person.



Service to the Company should never be subordinated to personal gain and advantage. Conflicts of interest should, wherever possible, be avoided.



In particular, clear conflict of interest situations involving directors, executive officers and other employees who occupy
supervisory positions or who have discretionary authority in dealing with any third party specified below may include the following:



| |  | any significant ownership interest in any supplier or customer;
| | - | ---------------------------------------------------------------



| |  | any consulting or employment relationship with any customer, supplier or competitor;
| | - | ------------------------------------------------------------------------------------



| |  | any outside business activity that detracts from an individuals ability to devote appropriate time and attention to his or her responsibilities with the Company;
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  | the receipt of non-nominal gifts or excessive entertainment from any company with which the Company has current or prospective business dealings;
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------



| |  | being in the position of supervising, reviewing or having any influence on the job evaluation, pay or benefit of any immediate family member; and
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------



| |  | selling anything to the Company or buying anything from the Company, except on the same terms and conditions as comparable directors, officers or employees are permitted to so
purchase or sell.
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



Such situations, if material,
should always be discussed with the Code of Ethics Contact Person.



-2-



---

Anything that would present a conflict for a director, officer or employee would likely also present a
conflict if it is related to a member of his or her family.



III. Disclosure



Each director, officer or employee involved in the
Companys disclosure process, including the Senior Financial Officers, is required to be familiar with and comply with the Companys disclosure controls and procedures and internal control over financial reporting, to the extent relevant
to his or her area of responsibility, so that the Companys public reports and documents, including the reports that the Company files with the SEC, comply in all material respects with the applicable laws and regulations. In addition, each
such person having direct or supervisory authority regarding the SEC filings or the Companys other public communications concerning its general business, results, financial condition and prospects should, to the extent appropriate within his
or her area of responsibility, consult with other Company officers and employees and take other appropriate steps regarding these disclosures with the goal of making full, fair, accurate, timely and understandable disclosure.



Each director, officer or employee who is involved in the Companys
disclosure process, including without limitation the Senior Financial Officers, must:



| |  | Familiarize himself or herself with the disclosure requirements applicable to the Company as well as the business and financial operations of the Company.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------



| |  | Not knowingly misrepresent, or cause others to misrepresent, facts about the Company to others, whether within or outside the Company, including to the Companys independent
auditors, governmental regulators and self-regulatory organizations.
| | - | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  | Properly review and critically analyze proposed disclosure for accuracy and completeness (or, where appropriate, delegate this task to others).
| | - | -----------------------------------------------------------------------------------------------------------------------------------------------



IV. Compliance



It is the Companys policy to comply with all applicable laws, rules and regulations. It is the personal responsibility
of each employee, officer and director to adhere to the standards and restrictions imposed by those laws, rules and regulations.



V. Reporting and Accountability



The Board of Directors is responsible for applying this Code to specific situations in which questions are presented to it and has the authority to
interpret this Code in any particular situation. Any director, officer or employee who becomes aware of any



-3-



---

existing or potential violation of this Code is required to notify the Code of Ethics Contact Person promptly. Failure to
do so is itself a violation of this Code.



Any questions
relating to how this Code should be interpreted or applied should be addressed to the Code of Ethics Contact Person. A director, officer or employee who is unsure of whether a situation violates this Code should discuss the situation with the Code
of Ethics Contact Person to prevent possible misunderstandings and embarrassment at a later date.



Each director, officer or employee must:



| |  | Notify the Code of Ethics Contact Person promptly of any existing or potential violation of this Code.
| | - | ------------------------------------------------------------------------------------------------------



| |  | Not retaliate against any other director, officer or employee for reports of potential violations that are made in good faith.
| | - | ------------------------------------------------------------------------------------------------------------------------------



The Company will follow the following procedures in investigating and
enforcing this Code, and in reporting on the Code:



| |  | The Code of Ethics Contact Person will take all appropriate action to investigate any violations and potential violations of the Code.
| | - | --------------------------------------------------------------------------------------------------------------------------------------



| |  | If the Code of Ethics Contact Person determines that a violation has occurred, it will inform the Board of Directors, in the case of a director or executive officer, or the Chief
Executive Officer, in the case of any other employee.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



Upon being notified that a violation has occurred, the Board of Directors or the Chief Executive Officer, as the case may be, will take such disciplinary or preventive action as it deems appropriate, up to and including dismissal or, in the
event of criminal or other serious violations of law, notification of appropriate governmental authorities.



VI. Corporate Opportunities



Employees, officers and directors owe a duty to the Company to advance the Companys business interests when the opportunity to do so arises.
Employees, officers and directors are prohibited from taking (or directing to a third party) a business opportunity that is discovered through the use of corporate property, information or position, unless the Company has already been offered the
opportunity and turned it down. More generally, employees, officers and directors are prohibited from using corporate property, information or position for personal gain and from competing with the Company.



Sometimes the line between personal and Company benefits is difficult to
draw, and sometimes there are both personal and Company benefits in certain activities.



-4-



---

Employees, officers and directors who intend to make use of Company property or services in a manner not solely for the
benefit of the Company should consult beforehand with the Code of Ethics Contact Person.



VII. Confidentiality



In carrying out the Companys business, employees, officers and directors often learn confidential or proprietary information about the Company, its customers, suppliers, or joint venture parties. Employees, officers and directors must
maintain the confidentiality of all information so entrusted to them, except when disclosure is authorized or legally mandated. Confidential or proprietary information of our Company, and of other companies, includes any non-public information that
would be harmful to the relevant company or useful or helpful to competitors if disclosed.



VIII. Fair Dealing



We
have a history of succeeding through honest business competition. We do not seek competitive advantages through illegal or unethical business practices. Each employee, officer and director should endeavor to deal fairly with the Companys
customers, service providers, suppliers, competitors and employees. No employee, officer or director should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or
any unfair dealing practice.



IX. Protection and Proper Use of Company
Assets



All employees, officers and directors should
protect the Companys assets and ensure their efficient use. All Company assets should be used only for legitimate business purposes.



-5-