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                                                                   Exhibit 11.1

                               QUEBECOR MEDIA INC.

        CODE OF ETHICS FOR THE PRESIDENT AND CHIEF EXECUTIVE OFFICER AND
                         THE SENIOR FINANCIAL OFFICERS

This Code of Ethics for the President and Chief Executive Officer and the Senior
Financial Officers has been adopted by the Board of Directors of Quebecor Media
inc. (the "Company") to promote honest and ethical conduct, proper disclosure of
financial information in the Company's periodic reports (including the quarterly
and annual consolidated financial statements), and compliance with applicable
laws, rules and regulations by the Company's senior officers who have financial
responsibilities. As used in this Code of Ethics, the term "Senior Financial
Officer" means the President and Chief Executive Officer, the Vice President and
Chief Financial Officer, the Controller, the assistant Controllers and persons
performing similar functions in the Company. This Code of Ethics is intended to
supplement the other policies or Code of Ethics of the Company.

In performing his or her duties, each of the Senior Financial Officers must:

     1.   engage in and promote honest and ethical conduct, including the
          ethical handling of actual or apparent conflicts of interest between
          personal and professional relationships;

     2.   avoid conflicts of interest and disclose promptly to the Vice
          President, Legal Services and Secretary of the Company any material
          transaction or relationship that reasonably could be expected to give
          rise to such a conflict;

     3.   take all reasonable measures to protect the confidentiality of
          non-public information about the Company or its subsidiaries, their
          customers and suppliers obtained or created in the normal course of
          their activities and prevent the unauthorized disclosure of such
          information unless required by applicable law or regulation or legal
          or regulatory process;

     4.   provide, or cause to be provided, full, fair, accurate, timely, and
          understandable disclosure in reports and documents that the Company
          files with, or submits to, the Securities and Exchange Commission or
          other regulators and in other public communications made by the
          Company or its subsidiaries;

     5.   comply and take all reasonable actions to cause the Company to comply
          with applicable laws, rules and regulations, as well as the rules and
          regulations of self-regulatory organizations of which the Company or
          its subsidiaries is a member; and

     6.   promptly report violations of this Code of Ethics to the Vice
          President, Legal Affairs and Secretary.

Senior Financial Officers must also comply with all other policies applicable to
the Company's directors, officers and employees generally.

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Failure to observe the terms of this Code of Ethics may result in disciplinary
action, including termination of employment. Violations of this Code of Ethics
may also constitute violations of law and may result in civil and criminal
penalties for the persons concerned and/or the Company.

Any questions regarding the best course of action in a particular situation
should be directed promptly to the Vice President, Legal Affairs and Secretary.
Any person may choose to remain anonymous in reporting any possible violation of
this Code of Ethics.

Any request for a waiver of any provision of this Code of Ethics must be in
writing and addressed to the Board of Directors or the Audit Committee of the
Company. Any waiver of this Code of Ethics will be disclosed in accordance with
the rules promulgated by the Securities and Exchange Commission or any relevant
stock exchange rules.


Adopted on May 5th 2003
by the Board of Directors of Quebecor Media Inc.


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I, the undersigned________________ hereby undertake to comply with this Code of
Ethics.


Signed in ______________, this _________ day of ______________




_______________________________
Name
Title