EXHIBIT 11.1


                                  EUROTRUST A/S

                 CODE OF ETHICS FOR THE CHIEF EXECUTIVE OFFICER,
                 CHIEF FINANCIAL OFFICER, AND FINANCIAL MANAGERS

The Company's Chief Executive Officer (the "CEO"), Chief Financial Officer (the
"CFO"), and all financial managers of EuroTrust A/S (the "Company") are bound by
the provisions set forth herein relating to honest and ethical conduct,
including the handling of conflicts of interest and compliance with applicable
laws, rules and regulations:

         1.       The CEO, CFO, and financial managers are responsible for
                  maintaining the Company's accounting records in accordance
                  with all applicable laws, and ensure that the accounting
                  records are proper, supported, classified, and do not contain
                  any false or misleading entries.

         2.       The CEO, CFO, and financial managers are responsible for the
                  Company's system of internal financial controls and shall
                  promptly bring to the attention of the Chairman of the Audit
                  Committee, any information he or she may have concerning:

                  a)       significant deficiencies and material weaknesses in
                           the design or operation of internal control over
                           financial reporting which are reasonably likely to
                           adversely affect the Company's ability to record,
                           process, summarize and report financial data; and

                  b)       any fraud, whether or not material, that involves
                           management or other employees who have a significant
                           role in the Company's financial reporting,
                           disclosures, or internal control over financial
                           reporting.

         3.       The CEO, CFO and all financial managers are responsible for
                  full, fair, accurate, timely and understandable disclosure in:

                  a)       reports and documents that the Company files with or
                           submits to the SEC; and

                  b)       the Company's other communications with the public,
                           including both written and oral disclosures,
                           statements and presentations.

         4.       The CEO, CFO and all financial managers are not permitted,
                  directly or indirectly, to take any action to fraudulently
                  influence, coerce, manipulate, or mislead any independent
                  public accountant engaged in the performance of an audit or
                  review of the financial statements of the Company that are
                  required to be filed with the SEC if such person knew or was
                  unreasonable in not knowing that such action could, if
                  successful, result in rendering such financial statements
                  materially misleading. For purposes of this Code of Ethics,
                  actions that "could, if

<PAGE>

                  successful, result in rendering such financial statements
                  materially misleading" include, but are not limited to,
                  actions taken at any time with respect to the professional
                  engagement period to fraudulently influence, coerce,
                  manipulate, or mislead an auditor:

                  a)       to issue a report on the Company's financial
                           statements that is not warranted in the circumstances
                           (due to material violations of generally accepted
                           accounting principles, generally accepted auditing
                           standards, or other applicable standards);

                  b)       not to perform audit, review or other procedures
                           required by generally accepted auditing standards or
                           other applicable professional standards;

                  c)       not to withdraw an issued report; or

                  d)       not to communicate matters to the Audit Committee.

         5.       The CEO, CFO and each financial manager shall promptly bring
                  to the attention of the Chairman of the Audit Committee any
                  information he or she may have concerning:

                  a)       evidence of a material violation of the securities or
                           other laws, rules or regulations applicable to the
                           Company or its employees or agents, or

                  b)       any violation of this Code of Ethics.

         6.       The CEO, CFO, and financial managers shall not, during the
                  term of their employment with the Company, compete with the
                  Company and shall not let business dealings on behalf of the
                  Company be influenced, or even appear to be influenced, by
                  personal or family interests. The CEO, CFO and financial
                  managers shall promptly bring to the attention of the Chairman
                  of the Audit Committee any information he or she may have
                  concerning any actual or apparent conflicts of interest
                  between personal and professional relationships, involving any
                  management or other employees who have a significant role in
                  the Company's financial reporting, disclosures or internal
                  controls.

         7.       The Company is committed to complying with both the letter and
                  the spirit of all applicable laws, rules and regulations. The
                  Company intends to prevent the occurrence of conduct not in
                  compliance with this Code of Ethics and to halt any such
                  conduct that may occur as soon as reasonably possible after
                  its discovery. Allegations of non-compliance will be
                  investigated whenever necessary and evaluated at the proper
                  level(s). Those found to be in violation of this Code of
                  Ethics, including failures to report potential violations by
                  others, are subject to appropriate disciplinary action, up to
                  and including termination of employment. Criminal misconduct
                  may be referred to the appropriate legal authorities for
                  prosecution.


                                       2
<PAGE>

         8.       The Company will strive to keep confidential the identity of
                  anyone reporting a possible violation. To facilitate the
                  fullest compliance possible, and encourage employees to ask
                  questions when presented with potential violations, the
                  Company will not tolerate retaliation against any employee
                  asking questions or making a good faith report in an attempt
                  to comply with this code. Open communication of issues and
                  concerns by all employees without fear of retribution or
                  retaliation is vital to the successful implementation of this
                  Code. All employees are required to cooperate with internal
                  investigation of misconduct and unethical behavior.

         9.       Any waiver of this Code of Ethics may be made only by the
                  Audit Committee and will be promptly disclosed as required
                  pursuant to federal securities laws, regulations and
                  applicable listing standards.





                                       3