Table of Contents


Exhibit 11.1

CODE OF PROFESIONAL
ETHICS                                                Banco de Chile

INDEX

|     | PREFACE                                    
|---- | -------------------------------------------
|    
|I    | INTRODUCTION                               
|     | GENERAL PRINCIPLES AND OBJECTIVES          
|II   | BASIC PRINCIPLES                           
|     | II.1.PERSONAL FINANCES                     
|     | II.2.CONFLICT OF INTERESTS                 
|     | II.3.MANAGEMENT OF CONFIDENTIAL INFORMATION
|     | II.4.ACTING ON BEHALF OF BANCO DE CHILE    
|     | II.5.ILEGAL TRANSACTIONS                   
|     | II.6.PERSONAL INTEGRITY                    
|III. | COMPLYING WITH THE RULES OF PROCEDURE      

PREFACE

Banco
de Chiles Code of  Professional  Ethics  contains the general  principles  and policies
that must  guide the  professional  and  ethical  performance  of all  company
 employees.  Its  objective  is to safeguard  the  values  that are  considered
 essential  for the  ethical  management  of the  business  and administration of the
company, in accordance with the companys corporate philosophy.

It
is  frequently  and commonly  necessary to declare  ethical  values in an explicit and
effective manner in  business.  This  requires  having a clear  management  of the
 company in  accordance  with basic principles, and basic human and social values.

Banco
de Chiles  Code of  Professional  Ethics seeks to define the  framework  that will allow
the company to  accomplish  these  goals.  Employees  and their work are one,  discarding
 the  existence of any duality or incoherence between individual and employee behavior.

The
client  should not only  receive  quality  products for a specific  price,  but also an
honest, transparent and reliable service.  As a financial  institution that depends on
public  confidence,  Banco de Chile is morally responsible for safeguarding clients interests.

Banco
de Chile is a company that works with money and others assets that belong to third
 parties, which means that  confidence  and honesty is required at every level,  both
within the company and vis-à-vis third parties.  The Banks  relationship  with its
employees,  clients and community is based on confidence, trustworthiness and honesty,
which result in the mutual trust of all participants in the system.

I.  INTRODUCTION

GENERAL
PRINCIPLES AND OBJECTIVES

Banco de Chile  has
 approved  this  Code of  Professional  Ethics  that  sets  forth  regulations  that all
employees must respect; employees must report any intent to violate this Code of
Professional Ethics.

Taking into account
the social and  individual  responsibility  of the different  administrative  activities
and functions of the company,  this document defines the general  principles and
policies,  which direct the decisions and actions of all company employees.

Our mission as
employees,  both individually and  collectively,  is to act in accordance with the
principles and ethical values of mankind, the company and society.

The company  promotes
and  safeguards  the ethical  values that it considers  important in its  performance:
honesty, truthfulness, transparency, righteousness and seriousness.

This  documents
 principal  objective  is to establish a general  ethical  standard for every sector of
the company.

This  document
 addresses the basic themes and  situations  present in the business and economic  world,
 as well as those specific to the administration and function of any financial
institution.

These  regulations
 are a tool  and  should  be used as a  reference.  They  establish  a guide  for  making
decisions that will depend on every employee, according to their position and function.

Every  Banco de Chile
 employee  must  comply  with said  values  accordingly,  logically  and at all times.
Employees must undertake their duty in a responsible manner and act correctly at all
times.

This Code of
Professional  Ethics describes general behavioral conduct;  nevertheless,  it is the
employees responsibility  to inform his or her respective  manager or the Human
Resources  office regarding making any kind of difficult ethical decisions.

II.  BASIC
PRINCIPLES

II.1. PERSONAL FINANCES

Every Banco de Chile
 employee must  maintain an  irreproachable  business  conduct,  performing  his or her
duties and business  obligations  in a timely and correct  manner.  It is  imperative
 that those who demand this conduct from his or her clients conduct themselves likewise.

The  previous
 explanation  means  that  each  employee  has to manage  his or her  banking,  financial
 and commercial  duties  responsibly and in accordance with his or her finances.  Maximum
 prudence must be used, which is incompatible with non-payment of debts when due.

If an  employee
 requires  a loan,  he or she  must  borrow  it  though  the  proper  established
 channels. Unofficial lending institutions with high financial costs and inadequate
warranty policies are prohibited.

Employees private
 investments or businesses must adhere to Banco de Chile Code of Professional  Ethics and
customs.

It is considered
 inappropriate  for any employee to give personal loans and or be involved with any
illegal businesses.

II.2. CONFLICT OF
INTEREST

An employee  must
execute his or her duties,  individually  and on behalf of Banco de Chile,  in
 accordance with  the  rules  of  conduct  of the  company.  He or  she  must  maintain
 his  or  her  independence  and professionalism  at all  times  at work or in  private.
 Therefore,  it is  unacceptable  for  employees  to partake in any  activity or action,
 which may present a conflict of  interest  for the  employee,  Banco de Chile or the
companys  clients,  as such acts damage confidence placed in the employee and result in
a lack of transparency.

There is a conflict of
interest,  for  example,  from the moment an employee  makes a work related  decision for
his or her  personal  benefit or for the  benefit of a third  party and not in the
 interest of Banco de Chile and its customers.

II.2.a.Personal
relationships with clients

No Banco de Chile
 employee may represent  the company in any  transaction  that  involves  persons or
banks with a direct family tie or any other personal  relationship with the employee,
 which may affect his or her independence  or business  interests.  Any  connection
 between an employee and a client or supplier must be reported in writing to the
appropriate manager.

In order to maintain
 independence and impartiality  when making  decisions,  employees should not establish
any type of personal business  relationship with clients,  such as commercial or
financial  transactions.  A personal  business  relationship or involvement  with any
client lessens the employees  liberty when making decisions.

II.2.b.
Rewards and gifts

No employee should
solicit or accept fees,  payments,  gifts,  salary or profits from anyone in exchange for
services provided by or business done with Banco de Chile and or its subsidiaries.

Exceptions  to the
previous  paragraph  are  symbolic or corporate  gifts,  dinner  invitations  or business
meetings,  provided  that,  under no  circumstance,  could such  bequests  be
 interpreted  as a  deliberate willingness to compromise  employee  independence,
 impartiality  or principles.  Any doubts  regarding this matter must be directed to the
employees immediate boss or the appropriate manager.

II.2.c.
Management of corporate gifts

Banco  de  Chile
 offers  corporate  gifts  to  clients  in  accordance  with  its  marketing  policies
 and strategies.  These gifts are authorized  only if they  adequately  portray Banco de
Chiles  corporate image and are exclusively for clients.

Payments,  donations
or gifts  cannot be given to  individuals,  political  parties,  government  officials,
public corporations or third parties, for the purpose of guaranteeing or influencing
their decisions.

Neither  should any
 compensation,  special  benefit nor gift be given to any individual or third party with
the  intention of  influencing  or promoting the outcome of a business  transaction,
 even when such outcome may be beneficial for Banco de Chile.

II.2.d.Relationship
with the suppliers

The  relationship
 between Banco de Chiles  employees and suppliers must be  independent  and in
accordance with the  companys  corporate  interests,  which  means that  there may not
be any  special  obligation  or partiality  toward any  specific  supplier.  Employees
 should  always  consider  utility and quality of the product and Banco de Chiles budget.

Anyone  who  maintains
 an  association  with  external  suppliers  must  keep  price,  budget  and  program
information  confidential.  Additionally,  employees are  prohibited  from  divulging
 information to anyone regarding Banco de Chiles purchase of equipment, supplies or
services.

II.2.e.Expense
and allowance report

The funds that Banco
de Chile  provides  employees  for  performing  work related  activities  belong to the
company.  They should be used for their intended purpose and all transactions should be
transparent.

II.2.f.Use
of privileged information

When making personal
 investments,  employees must avoid using privileged  information,  which they obtained
as result of their position,  for personal or third party benefit.  Those who have access
to confidential or privileged  information  regarding  banks or specific  assets  must
avoid  capitalizing  on such  knowledge. Likewise,  those  with  any  knowledge  about
 investment  policies  and  strategies,  plans,  studies,  or negotiations  shall not
directly or indirectly  take advantage of such knowledge for either their benefit or the
benefit of others.

No Banco de Chile
employee may use confidential  information to perform  transactions using documents
issued by any company in their portfolio.

All stock market
 transactions that Banco de Chiles employees perform during a one-month period,  which
are equal to or in excess of UF 500,  must be reported in writing to the Human  Resources
 department.  The same regulation will govern all amounts equal to or in the excess of UF
500 for any one transaction.

All currency,
 exchange rate or similar  derivatives  that are available in the financial market are
subject to the previous  regulation,  particularly,  high-risk  transactions in which a
small capital investment may result in significant losses.

II.2.g.Personal
relations with prospective employees

With regard to
 recruiting  and hiring  personnel,  no applicant  will receive  special  treatment
 based on personal or family connections.

II.3. MANAGEMENT OF
CONFIDENTIAL INFORMATION

II.3.a.Safeguarding
information

Information  regarding
Banco de Chiles  operations and its clients is confidential;  therefore,  the usage,
safeguard and care of related  documents  should be maintained in accordance with Banco
de Chiles  internal rules.

Therefore,  it is the
 employees  responsibility  to safeguard all documents and or assets under his or her
care, as well as to protect information regarding Banco de Chiles property.

II.3.b.Restrictions
on the flow of information

All confidential
 information  regarding  securities,  their issuers and related  transactions  must be
kept strictly  confidential.  Any type of dissemination  or communication of confidential
 information to a third party is  prohibited,  even when the third  party may be another
 Banco de Chile  employee.  The ethical and professional principle of banking
confidentiality must be respected in such instances.

If internally,  during
the course of work, it becomes  necessary to report  confidential  matters to a third
party, the following procedure must be followed:

- Clearly state
that the information given is confidential.
- Alert the
third party about the restrictions concerning the disclosure of such information.
- Alert the
third party that he or she is prohibited from performing financial  transactions based on
such information.

The   communication,
  duplication  or  transmittal  to  a  third  party,   either  orally,  in  writing  or
electronically,  of  information  regarding  certain  aspects  of  Banco  de  Chiles
 business  strategies, databases,  client sectors or any other  information  regarding
Banco de Chiles  business or operations and its clients is prohibited,  even if the
employee is indirectly  involved in such  dissemination.  Similarly, the employee must
avoid  responding to questions  related to such operations or any other matter that may
be a  liability  to or may be  prejudicial  for Banco de Chile or its  clients,  without
 previously  obtaining permission from his or her superior.

It is extremely
 important that employees  responsibly  administer and manage stock market  information
when tending to clients, as well as personally.

Similarly,  each
 employee  must promote  full,  fair,  accurate,  timely and  understandable  disclosure
in reports and documents that Banco de Chile files with, or submits to, the  supervisory
 authorities,  as well as in other public communications made by the Bank.

II.4. ACTING ON BEHALF
OF BANCO DE CHILE

II.4.a.Individual
responsibility

As a Banco de Chile
employee,  each person is  individually  responsible for his or her actions and conduct.
This includes  knowledge of and compliance with the regulations  stated in Banco de Chiles
 internal office manuals, rules and proceedings.

The  employee  must
not  partake  in any  illegally  activity  or  adopt  any kind of  behavior,  which  may
jeopardize  Banco de Chiles  prestige,  interests or assets,  or that of other
 employees.  If an assistant receives instructions contrary to Banco de Chiles values,
 policies and internal practices,  he or she must report such instructions to the Human
Resources department so that the necessary steps may be taken.

Employees  should  be
loyal to Banco de Chile in all  aspects  and must not use  Banco de  Chiles  name for
personal  gains.  Similarly,  it is  prohibited  to  publish or  disseminate  any type of
 information  that tarnishes Banco de Chiles dignity or that of its employees.

II.4.b.Work
responsibility

Employees  must devote
their  complete  time and  capability  to performing  their  responsibilities  during
normal  working  hours.  Consequently,  employees  must  refrain  from  using  Banco de
 Chiles  offices or property for non-related work activities.

With regard to other
 activities or external  commitments,  employees must not assume  responsibilities  nor
work that  conflicts  with the  interest  of Banco de Chile  management.  If there is no
adverse  affect to Banco de Chiles  operations,  before  accepting  work, paid
 representation  or external  consulting  jobs, employees  must inform  management  in
writing,  and  employees  will need  authorization  from the managing office.
 Nevertheless,  such  activities must not hinder the employees  performance  and duties,
 or demand long hours that may affect employees mental and physical competence.

Banco de Chiles
 employees are prohibited from assisting any other bank or financial  institution,  as
well as  companies  owned by or related to Banco de Chiles  clients,  so as to prevent
any conflict of interests that may be the cause of disloyalty  to Banco de Chile,
 except in the case of  managements  written authorization.

Banco de Chiles
 employees  attending  university  and  required to dedicate  part of the work day to
their educational development, will need authorization from their respective manager.

Employees are
permitted to participate in external Ad Honoremactivities, providing that such
involvement does not interfere with the development and behavior in the workplace.
These employees must also be recognized and authorized.

With  regard  to
 nonprofit  institutions,  Banco  de Chile  authorizes  and  encourages  its  employees
 to participate in charitable and social service causes.

II.4.c.Publications
and public presentations

An employee is not
permitted to make public  presentations  of any product,  reports or projects that belong
to Banco de Chile.  If he or she  represents  Banco de Chile in a speech,  conference,
 seminar or any other type of convention,  he or she must have managements
 authorization  and must have previously  reported the content of his or her presentation.

Banco de Chile has the
exclusive right to its products and services,  and owns all employee  contributions to
their  development  and  implementation.  Such  conditions  are  indisputable,  even
after Banco de Chile no longer employs the employee.

Any verbal or written
 personal  communication  must be carried out in the  employees own name and under no
circumstance should the employee involve Banco de Chile.

II.4.d.Nomination
and civil service to positions

Public office
positions or nominations,  such as municipal,  governmental or others, are not compatible
with employment at Banco de Chile,  except if they are obligations  that cannot be
renounced,  such as members in municipal, parliamentary or presidential elections.

II.4.e.Practice
of a profession

The  employee  will
only be able to execute  documents,  represent,  or practice  his or her  occupation  on
behalf of Banco de Chile if he or she has been  authorized to do so by Banco de Chile.
 Any document,  which requires  a  commitment,  agreement  or  contract  from  Banco de
Chile  must be signed  exclusively  by the corresponding executive or the management
committee.

II.5. ILLEGAL
TRANSACTIONS

Banco de Chile will
only partake in legitimate and legal business  transactions.  It will maintain  quality,
price and  superb  services  standards,  and always  proceed  with  fairness,  integrity
 and  transparency. Illegal  transactions  are those  that are not  allowed  by law and
do not  respect  and  adhere to Banco de Chiles internal policies.

Any attempt at money
 laundering  shall be  considered  as a breach of  confidence  and a threat to Banco de
Chiles integrity; as a consequence, Banco de Chile will do anything to avoid such
practice.

The  employee  is
 obligated  to  comply  with  the  stated  policies  and  regulations   regarding
 illegal transactions,  and if he or she encounters any suspicious or unusual
 transaction,  he or she must report it directly to Banco de Chiles compliance office.

In addition,  Banco do
Chile does not desire to establish  any type of  relationship  with such  individuals
corporations,  clients,  investors  or agents,  if it suspects  that the money or
 services  offered are the result of illegal or illegitimate activities.

II.6. PERSONAL
INTEGRITY

Banco de Chiles
 employees  must  maintain  exemplary  behavior  inside and  outside of the Bank.  Banco
de Chile  demands  personal  dignity of all its  employees.  It also demands that its
employees are honest and maintain a  responsible  behavior  in everyday  life.  This
 requirement  must be  respected,  even when the employee is representing the Bank or a
third party.

Banco de Chile does
not tolerate sexual harassment in the workplace.

In addition,  Banco de
Chile encourages its employees to develop a healthy  standard of living.  It strictly
prohibits the consumption,  transport or sale of drugs,  alcohol or narcotic  substances
within the company. In  order to  oversee  the  compliance  of this  regulation,  Banco
de Chile  will  provide  prevention  and education classes to all employees and their
families.

III.  COMPLYING
WITH THE RULES OF PROCEDURE

All the  rules  set
 forth  in this  Code of  Professional  Ethics  are  mandatory  for all  Banco  de Chile
employees,  and generally  complement  the  regulations  stipulated in the  employees
 employment  contract regarding internal hygienic and security regulations, legal rules,
and future internal policies.

Banco  de  Chile
 shall  signal  to its  employees  behavior  that  violates  the  policies  in the Code
of Professional  Ethics,  without  breaching  its internal  policies or the term in the
 employees  employment contract.  If the rules of the latter are  violated,  then the
 appropriate  disciplinary  measures  will be taken.

Banco de Chile shall
provide each employee with a copy of this Code of Professional Ethics at the time of
their respective recruitment and shall ask for acknowledgement of reception.