Exhibit 11.1
 (QUEBECOR Media LOGO)Code of Ethics
 CODE OF ETHICS




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(QUEBECOR Media LOGO)Code of Ethics
 TABLE OF CONTENTS
 CONTENTS
    
    PAGEScope
    
    
    2Purpose
    
    
    3Responsibility
    
    
    4Work Environment
    
    
    5Relations with Customers and Suppliers
    
    
    7Conflict of Interest
    
    
    8Company Property
    
    
    10Company Funds
    
    
    11Confidential Information
    
    
    12Insider Trading
    
    
    14Business Records
    
    
    15Relations with the Public
    
    
    16Respect of the Environment
    
    
    17Competition Behaviour
    
    
    17Legal Compliance
    
    
    18Questions and Reporting of Violations
    
    
    19Violation
    
    
    20Communication of the Code
    
    
    20Appendix 1 - ClearView ConnectsTM  Questions and Answers
    
    
    21Employee Declaration
    
    
    24
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(QUEBECOR Media LOGO)Code of Ethics
 SCOPE
 Code Employees Employee QMI
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(QUEBECOR Media LOGO)Code of Ethics
 PURPOSE
 QMI Company
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(QUEBECOR Media LOGO)Code of Ethics
 RESPONSIBILITY
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(QUEBECOR Media LOGO)Code of Ethics
 WORK ENVIRONMENT
  Discrimination
   Harassment
  Workplace security
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(QUEBECOR Media LOGO)Code of Ethics
 Drugs and alcohol
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(QUEBECOR Media LOGO)Code of Ethics
 RELATIONS WITH CUSTOMERS AND SUPPLIERS
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(QUEBECOR Media LOGO)Code of Ethics
 CONFLICT OF INTEREST
  Directors
  Officers and other employees
   1.
    
    Either for his benefit or that of any person, association or company, conducts activities
during working hours that are neither directly related to nor required for his functions
(except with the managements specific request or permission) and which deprive the Company
from the employees services or prevent that employee from devoting all efforts and attention
to the Companys affairs.2.
    
    Holds a position within the Company whereby the employee can use his authority towards any
relatives or friends and which may prevent that employee from being impartial in his
decision-making process.
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(QUEBECOR Media LOGO)Code of Ethics
 3.
    
    As a result of an outside third party relationship, is in a position that could:
 a)
    
    make personal gain for the benefit of that employee or any relative or friend;b)
    
    render the employee partial towards the third party contrary to the best
interest of the Company;c)
    
    place the employee in an equivocal, embarrassing or ethically questionable
position towards that third party; ord)
    
    reflect unfavourably on the integrity and honesty of the employee.
 4.
    
    Takes advantage of business opportunities that belong to the Company or are discovered
through the use of the Companys resources, property, information or the employees position
with the Company.
 5.
    
    Uses the Companys property or information, or his position held within the Company, for
personal gain, including to further his interest or that of relatives or friends.
 6.
    
    Accepts gifts (other than of a nominal, symbolic or promotional nature) from a supplier,
client or any other person which has or may have dealings with the Company.
 7.
    
    Directly or indirectly competes with the Company or has a direct or indirect interest or
relationship that is actually harmful or detrimental to the Companys best interest.
 8.
    
    Engages in business or gainful activities that might be detrimental to the best interest of
the Company. The term gainful employmentincludes any professional activity, supervision or
training of other persons, or consultation or advice, for any form of remuneration.
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(QUEBECOR Media LOGO)Code of Ethics
 COMPANY PROPERTY
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(QUEBECOR Media LOGO)Code of Ethics
 COMPANY FUNDS
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(QUEBECOR Media LOGO)Code of Ethics
 CONFIDENTIAL INFORMATION
    Disclosure
Policy of Quebecor Media.
  
    
    documents and files containing confidential information must be kept in a safe place to
which access is restricted to employees who need to know such information in the
performance of their duties;
    
    confidential matters should not be discussed in public places (elevators, hallways,
restaurants, airplanes, taxis, or elsewhere);
    
    confidential documents should not be read or remain visible in public places and should
not be discarded where third parties can retrieve them;
    
    employees must ensure that they maintain the confidentiality of information in their
possession inside or outside the workplace;
    
    transmission of documents containing confidential information by electronic means, by
fax or directly from one computer to another, should be made only where it is reasonable to
believe that the transmission can be made and received under secure conditions; and
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(QUEBECOR Media LOGO)Code of Ethics
 
    
    unnecessary copying of confidential documents should be avoided and documents containing
confidential information should be promptly removed from conference rooms and work areas
after the meetings; extra copies should be shredded or otherwise destroyed in a safe
manner.
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(QUEBERCOR MEDIA LOGO)
    
    Code of Ethics
 INSIDER TRADING
    the Policy relating to the use of privileged information .
 Disclosure Policy
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(QUEBECOR MEDIA LOGO)
    
    Code of Ethics
 BUSINESS RECORDS
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(QUEBECOR MEDIA LOGO)
    
    Code of Ethics
 RELATIONS WITH THE PUBLIC
 Disclosure Policy of Quebecor Media Inc.
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(QUEBECOR MEDIA LOGO)
    
    Code of Ethics
 RESPECT OF THE ENVIRONMENT
 
 COMPETITION BEHAVIOUR
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(QUEBECOR MEDIA LOGO)
    
    Code of Ethics
 LEGAL COMPLIANCE
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(QUEBECOR MEDIA LOGO)
    
    Code of Ethics
 QUESTIONS AND REPORTING VIOLATIONS
     TM 
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(QUEBECOR MEDIA LOGO)
    
    Code of Ethics
 VIOLATION
     COMMUNICATION OF THE CODE
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(QUEBECOR MEDIA LOGO)
    
    Code of Ethics
 APPENDIX 1
 CLEARVIEW
CONNECTS TM
- QUESTIONS AND ANSWERS
 Who provides the service?
 TM www.clearviewconnects.com.
 Why use this service?
  Who can use this service?
  When to use this service?
 TM
  
    
    Accounting irregularities;
    
    Falsification of the Companys records;
    
    Fraud;
    
    Misuse of confidential information (Insider Trading);
    
    Irregularity in the handling or reporting of financial transactions;
    
    Significant breach of internal controls;
    
    Theft.
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(QUEBECOR MEDIA LOGO)
    
    Code of Ethics
 How is anonymity preserved?
 TM
 TM
 What happens when you use the toll-free telephone line?
   What happens when you use the ClearView Connects TM website?
  TM
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(QUEBECOR MEDIA LOGO)
    
    Code of Ethics
 TM
 Who may investigate?
  How to use this confidential service?
 1-877-821-5801
 TM www.clearviewconnects.com
 When is the service available?
  Will the employees filing a complaint be informed of the results of any investigation?
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(QUEBECOR MEDIA LOGO)
    
    Code of Ethics
 EMPLOYEE DECLARATION
  Name (in capital letters)Service / LocationSignatureDate
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