Exhibit 14.1

                                                                Code Of Business
                                                             Conduct And Ethical
                                                                      Guidelines
                                                                   November 2003



Dear Amkor Colleagues,

As representatives of Amkor Technology, Inc. and our subsidiaries ("Amkor"), we
are each responsible for helping to define our company in a positive way.

The purpose of this Code of Business Conduct and Ethical Guidelines is to assist
us in understanding the values and beliefs that we share, and stand for as an
organization.

It offers many guidelines, but it cannot make decisions for you. You should seek
guidance from your supervisor, human resources or the legal department if you
have questions.

We urge each employee to thoroughly read this booklet and discuss it with his or
her supervisor.

Through our alignment to our values, and in demonstrating commitment to this
code of conduct, we will ensure that our message to our constituencies and each
other is clear. The Amkor team will operate at the highest level of integrity
and strive to demonstrate exemplary behavior.

Sincerely,

Jim Kim                                    John Boruch
Chairman and Chief Executive Officer       President and Chief Operating Officer



CONTENTS


                                                                           
I.       Definition and Applicability...................................       3
II.      Our Values.....................................................       4
III.     Ethics and Compliance..........................................       6
             Honest and Ethical Conduct.................................       6
             Compliance with Applicable Rules and Regulations...........       6
             Foreign Corrupt Practices Act..............................       6
             Bribes, Kickbacks, Gifts and Gratuities....................       6
IV.      Conflicts of Interest and Using Insider Information............       9
             Conflict of Interest.......................................       9
             Using Insider Information..................................      10
V.       Employment Practices...........................................      11
             Employees and the Workplace Environment....................      11
             Compensation and Benefits..................................      12
             Work Hours.................................................      13
             Environmental, Safety and Health...........................      14
             Physical Security..........................................      14
             Internal Information Posting...............................      15
             Quality....................................................      15
             Employee Reimbursement/Advances............................      16
VI.      Business Practices.............................................      17
             Antitrust Compliance.......................................      17
             Financial Reporting and External Communications............      17
VII.     Use and Protection of Assets and Electronic Systems............      20
             Use and Protection of Assets...............................      20
             Information Security.......................................      20
VIII.    Violations of the Code and the Ethics Hotline..................      22
             Reporting Violations of the Code...........................      22
             Retaliation................................................      22
             Violations of the Code.....................................      22
IX.      Phone Numbers..................................................      23


                                        2


I. DEFINITION AND APPLICABILITY

To run our business effectively, we developed management tools that include a
mission statement, corporate values and strategic objectives. In addition, we
created this Code of Business Conduct and Ethical Guidelines upon which we base
the operation of our business.

This Code of Business Conduct and Ethical Guidelines is a standing guide for
handling business situations in an honest and professional manner, and should be
used in determining key business decisions and actions. We designed this code to
deter wrongdoing and to promote:

- -    Honest and ethical conduct, including the ethical handling of actual or
     apparent conflicts of interest between personal and professional
     relationships;

- -    Full, fair, accurate, timely, and understandable disclosure in reports and
     documents that we file with, or submit to, the Securities and Exchange
     Commission and in other public communications made by us;

- -    Compliance with applicable governmental laws, rules and regulations;

- -    The prompt internal reporting to an appropriate person or persons
     identified in the code of violations of the code; and

- -    Accountability for adherence to the code.

This code applies to all Amkor employees worldwide. These principles are not
intended to be all-inclusive, but they do provide important information about
the company's established way of doing business. Local or department guidelines
may be issued in various offices to supplement or implement the principles.

International laws or customs may sometimes require us to modify the practices
that we have outlined here. If you have any questions or concerns about the
proper course of action, discuss the situation with your supervisor or with
human resources.

Any amendment or waiver of this Code of Business Conduct and Ethical Guidelines
for our executive officers or senior financial officers, including the Chief
Financial Officer and Controller, must be approved in writing by the board of
directors and promptly disclosed as required by law or stock exchange
regulations.

Please keep in mind that failure to conduct business in compliance with these
guidelines may result in disciplinary action, up to and including termination.

These guidelines should be a part of your daily working practices. If you need
further guidance in applying them to your specific situation, your supervisor or
manager should be able to help you. In some cases, you may need to contact a
group such as the legal department or human resources for more specific
guidelines or opinions. When in doubt, ask!

Your understanding of these guidelines will help to ensure that the company and
our employees conduct their business with uncompromising integrity and
professionalism.

                                        3


II. OUR VALUES

Our business environment is constantly changing. We can count on changes in our
products, our people, our customers, and our suppliers. What will not change is
our commitment to our company values. Our values are the foundation for
sustaining our business environment within Amkor. They are:

- -    Respect and Integrity

- -    High Energy

- -    Teamwork and Cooperation

- -    Caring and Well Being of our People

- -    Open Communication

These values define who we are as a company -- to each other, to our customers,
our suppliers and to our shareholders. They define what we stand for, and they
are guiding principles for behavior.

Our company values are demonstrated through the following examples:

RESPECT & INTEGRITY

- -    When we need to give constructive feedback to each other, we speak about
     the issue, not the person. We are not condescending or rude.

- -    Respect goes beyond how we treat each other and includes how we treat the
     company.

     -    We conserve and optimize our resources -- this includes time and
          money.

     -    We speak highly of Amkor.

- -    We do not give our word unless we know we can meet our commitment.

- -    We recognize that gossip is destructive, and we strive to eliminate it.

HIGH ENERGY

- -    When a customer presents us with a challenge, our first response is to look
     for ways to meet their needs. We respond eagerly to opportunities for
     innovative thinking.

- -    We know that enthusiasm is spirited by people who support each other, so we
     make a concentrated effort to offer support when others are down, and to
     back each other up when the pressure is on.

- -    We boldly take calculated risks.

TEAMWORK & COOPERATION

- -    Knowing we cannot get our job done without other people, we have
     team/departmental meetings to keep our people up to date on new
     information.

- -    We use a team approach in decision making by involving key players before a
     commitment is made.

     -    We recognize people who contribute to our success.

                                        4


CARING & WELL BEING OF OUR PEOPLE

- -    We support one another in finding the best ways to maximize their
     contributions to Amkor's success -- through personal growth, learning and
     development, or job changes.

- -    We make a point to have fun in our work because it refuels and inspires us.

- -    We encourage each other to think and act creatively and go beyond the fears
     that inhibit growth.

OPEN COMMUNICATION

- -    We are accessible to one another.

- -    We deal openly and honestly with conflict by taking concerns directly to
     the person responsible. Our focus is on the issue, not the person.

- -    We recognize the importance of sharing our ideas, expressing gratitude and
     recognizing others.

Our values provide the foundation of our business culture, and our Code of
Business Conduct and Ethical Guidelines provides information about the way
business is conducted at Amkor. These guidelines provide the foundation for
understanding how to handle most business situations in the honest and
professional manner expected of every Amkor employee.

                                        5


III. ETHICS AND COMPLIANCE

HONEST AND ETHICAL CONDUCT

We expect all employees to act with the highest standards of honesty and ethical
conduct while working on our company's premises, at offsite locations where
Amkor business is being conducted, at Amkor sponsored business and social
events, or at any other place where the employees are representing Amkor.

In all cases, if you are unsure about the appropriateness of an event or action,
please seek assistance in interpreting the requirements of these practices by
contacting your supervisor or Amkor's legal department.

COMPLIANCE WITH APPLICABLE RULES AND REGULATIONS

All Amkor employees must comply with all applicable laws and regulations.
Employees are expected to be familiar with the legal and regulatory requirements
applicable to their business responsibilities and to fulfill their duties in
accordance with these laws and regulations.

Questions concerning the applicability of any legal or regulatory provision
should be directed to Amkor's legal department.

FOREIGN CORRUPT PRACTICES ACT

Among other things, the Foreign Corrupt Practices Act prohibits bribing any
public official, government, or other individual-regardless of nationality or
local custom to secure any concession, contract, or favorable treatment. Bribes
include any kickbacks or other unlawful payments.

BRIBES, KICKBACKS, GIFTS AND GRATUITIES

BRIBES AND KICKBACKS

Amkor employees may not offer or accept a bribe or a kickback. A bribe is
defined as a thing of value given to someone with the intent of obtaining
favorable treatment from the recipient. Kickbacks consist of payment in cash or
in kind, including goods, services, the use of another company's property, or
forgiving any sort of obligation provided to a customer or supplier for the
purpose of improperly obtaining or rewarding favorable treatment in connection
with a sale or purchase. Bribes and kickbacks may not be offered either directly
or through a third party in order to obligate the recipient to return the favor.

                                        6


Sample Situation:

- -    Paying a freight forwarder to expedite a shipment through customs is not
     acceptable if the agent doesn't follow applicable rules and regulations,
     and if the agent gives money or payment in kind to a government official
     for personal benefit. On the other hand, expediting by following rules and
     regulations and without bribing officials is acceptable.

- -    Questions about specific cases should be sent to the legal department.

RECEIVING GIFTS AND GRATUITIES

Any form of a gift that obligates an employee is a bribe and is forbidden,
regardless of its value. Cash gifts are not allowed, whether for referring an
Amkor employee to a recruiter, for purchasing favors or for sales to outside
parties. A sample from a customer or supplier is Amkor property and is not for
personal use or profit.

No entertainment shall be accepted in any circumstance from present or potential
suppliers, unless it is a multi-customer event, sanctioned in a professional
environment and does not, or appear to, influence purchasing decisions, create a
conflict of interest or violate rules or proprietary exchanges of information.

No favors, services, travel or lodging of any kind from present or potential
suppliers may be accepted.

Working meals are acceptable if the work performed is proximate to a supplier or
third party facility and passes the common sense test for reasonable behavior in
a business environment.

Promotional items with company logos are acceptable as long as their value is
less than $100. If an item's value is unclear, the item should be returned. If
it cannot be returned, it must be turned over to the company. The gift can then
be given to a charitable organization.

If employees know that they will receive a gift of value, they can suggest that
instead of a gift, a donation be made in their honor to a charity. Some Sample
Situations:

- -    Business discussions held at lunch or dinner are legitimate. A free private
     meal for an employee and spouse is not a legitimate function.

- -    An invitation to an entertainment or sporting event such as a golf or
     tennis tournament may be appropriate if it demonstrably helps build a
     business relationship.

When unsure about proper conduct, an employee should describe the situation to
his or her manager and the legal department. Policy violations should be
reported promptly to the legal department.

GIVING GIFTS AND GRATUITIES

Equivalent rules apply to the giving of gifts. Obviously, they should not be
offered as bribes. Care should be taken to avoid giving gifts that are intended
to be innocent but may be construed as a bribe especially with respect to gifts
to government officials for which strict

                                       7


rules apply. An acceptable gift to a business person might be perceived as a
bribe to a government worker.

When in doubt, contact the legal department.

- -    It is permissible to give away plaques, supplier awards and prizes that are
     part of official programs with fair, openly-published rules for competing
     companies.

- -    Samples may not be provided to a customer for private use. Free access to
     company resources or assets, such as computer time, and scrap or excess
     materials, is expressly forbidden.

- -    In some countries other than the U.S., local customs require the exchange
     of gifts under certain circumstances. In these cases, the country manager
     may ask for an exception through a written request to the legal department.
     Such requests must specify the manager's understanding of the country's
     customs and the proposed rules for gift giving and receiving, including the
     occasions on which such gifts may be exchanged and the dollar equivalent
     value of such gifts to be permitted. If approved, the country manager may
     publish such rules to affected employees on an exception basis. Gifts
     outside the provisions of the approved local rules cannot be given or
     received without approval from the legal department.

                                        8


IV. CONFLICT OF INTEREST AND USING INSIDER INFORMATION

CONFLICT OF INTEREST

It is Amkor's policy that all employees avoid any activity that is or has the
appearance of being hostile, adverse or competitive with the company, or that
interferes with the proper performance of duties, responsibilities or loyalty to
the company.

An employee's best course of action is to review the specific situation with his
or her supervisor to assess whether there are any problems and, if so, how they
can be resolved. If the employee's supervisor concludes that there is or may be
a perceived conflict of interest, the manager will consult with the legal
department. The legal department will work with the vice president of
purchasing, the regional sales manager or appropriate employee management to
determine if there is a real or perceived conflict of interest. If a conflict
exists, it may be necessary to transfer that employee, require the employee to
divest himself or herself of the interest, or remedy the situation as a
condition of continued employment.

Some Sample Situations:

- -    If an employee is in a position to influence the business situation of a
     supplier or customer, the employee must disclose to his or her supervisor
     all financial, proprietary or other type of controlling or influencing
     interest (for example, a member of the immediate family or a close personal
     friend) that the employee may directly have. (Note: Financial or
     proprietary interest includes investments, ownership of securities or loan
     agreements.)

- -    Any employee in a position to influence the purchase of materials or
     services must formally declare any situation wherein a member of the
     employee's immediate family or a close personal friend is employed by
     Amkor's supplier. A conflict of interest form is normally used to make this
     declaration.

- -    It is not Amkor's policy to discourage the employment of family members or
     employees' close personal friends as suppliers or competitors. Clearly,
     everyone is entitled to pursue a career of his or her choice. It is the
     company's intention, however, to ensure that neither real nor apparent
     influence is exerted in its business relationships as a result of such
     employment.

- -    Amkor will not conduct business with a former employee who becomes employed
     by a supplier or who offers his or her services as an independent
     contractor for a period of 12 months from the employee's termination date,
     without prior written approval from the vice president of purchasing.

- -    An employee may not directly or indirectly conduct outside business that
     interferes with the proper performance of the employee's job at Amkor, is
     conducted during an employee's normal working hours, or utilizes Amkor
     confidential information or specialized skills and knowledge gained as an
     employee of the company. This includes becoming a contractor, consultant or
     supplier to Amkor while being employed at Amkor.

- -    Employees may not enter into any short sales or short positions with
     respect to Amkor securities.

Certain employees who are in particularly sensitive positions are required to
complete a conflict of interest form each year. The internal audit department
will provide these forms. The completed

                                        9


and signed forms must be returned to the internal audit department.

Employees completing conflict of interest forms must properly notify the
internal audit department of any changes to their responses.

USING INSIDER INFORMATION

Employees may at some time have access to information related to our company or
our business that is not known to the general public. This is known as "insider
information." It is Amkor policy that insider information may not be used at any
time for improper purposes.

PROTECTING INSIDER INFORMATION

Insider information may not be disclosed to anyone outside the company, except
for the purpose of conducting company business.

STOCK TRANSACTIONS AND MATERIAL INSIDER INFORMATION

Some insider information may be considered material; that is, it is information
that could affect Amkor's stock price. If an employee has material insider
information about the company, than he or she should not trade in company stock
until the information is released to the public. Some examples of information
that may be material are financial results, plans to acquire another company or
planned key product announcements.

Certain material insider information that is related to company business may not
affect the stock price, but may affect the stock price of another company or the
value of other investment opportunities. An Amkor employee may not use this
material insider information to gain personal financial benefit. This type of
insider information would include, for example, Amkor's plan to make a major
investment in another company or to award a large piece of business to a
supplier.

In all situations, if an employee is prohibited by this policy from acting for
his or her own benefit (for example, by trading stock or investing), than he or
she may not "tip" another person to act.

Securities laws prohibit trading stock based on material insider information. A
violation of these laws can result in civil and criminal penalties. Any issue
regarding this type of transaction should be reviewed with the legal department.

                                       10


V. EMPLOYMENT PRACTICES

EMPLOYEES AND THE WORKPLACE ENVIRONMENT

NONDISCRIMINATION AND DIVERSITY

Amkor respects, values and welcomes diversity in our workforce, as well as in
our customers, our suppliers and the global marketplace. Amkor's policy is to
comply with all applicable laws and to provide equal employment opportunity for
all applicants and employees without regard to non-job related factors such as
race, color, religion, sex, national origin, ancestry, age, disability, veteran
status, marital status or sexual orientation. This policy applies to all areas
of employment, including recruitment, hiring, training, promotion, compensation,
benefits, transfer, and social and recreational programs.

AT-WILL EMPLOYMENT

Unless otherwise agreed in writing and subject to any applicable law, each Amkor
employee is employed by Amkor on an at-will-basis. This means that employment is
not guaranteed for any specific duration of time and Amkor retains the right to
terminate an individual's employment at any time with or without cause. No oral
representations made by any Amkor employee with respect to continued employment
can alter this relationship.

HARASSMENT-FREE WORKPLACE

Amkor is committed to providing a workplace free of all types of harassment.
Amkor strongly disapproves of, and will not tolerate, harassment of employees by
managers or co-workers. Amkor will also provide a work environment to protect
employees from harassment by non-employees in the workplace.

Harassment includes verbal, physical and visual conduct that creates an
intimidating, offensive or hostile working environment or that interferes with
work performance. Some examples include racial slurs; ethnic or sexual jokes;
offensive statements, posters or cartoons; intimidation tactics; distribution of
inappropriate jokes or offensive language on electronic mail or any other Amkor
computer or networks; use of pornographic screens or software; or other similar
conduct. Sexual harassment includes behaviors such as solicitation of sexual
favors, unwelcome sexual advances or other verbal, visual or physical conduct of
a sexual nature.

OPEN COMMUNICATION

Amkor promotes performance, teamwork and results through open communications. We
encourage communications meetings at all sites where employees have the
opportunity to share any concerns with senior management. Amkor also supports an
"open door" management policy. Employees are encouraged to raise work-related
concerns with their immediate manager. If this is not the most appropriate
person, they are encouraged to bring their concerns to the attention of the
functional manager, human resources or any senior manager, up to and including
the corporate vice

                                       11


president. Employees can also send their questions to the Amkor Connect
newsletter regarding clarification of company values, policies and standard
practices. These questions may be sent anonymously, if desired.

PERFORMANCE MANAGEMENT

Performance management is an ongoing process of setting clear expectations,
holding employees accountable for meeting those expectations, and directly and
effectively addressing performance issues. Managing employee performance is a
responsibility that is shared by managers and employees.

Amkor formally appraises the performance of employees worldwide every year. The
evaluation provides the employee with a documented review of performance and may
result in a change in compensation. Employee performance is measured against
factors such as individual performance expectations, departmental and/or
corporate business objectives, contributions to team efforts, performance
relative to peers and performance to company values. Input on performance may be
gathered from several sources, including managers, peers, subordinates and
customers. Performance is documented each March using the Performance Appraisal
Form, available on ATDOCs. This form was designed very simply, to allow managers
and employees to discuss performance results as well as areas for improvement.

Remaining competitive requires that Amkor employees strive for continuous
improvement in performance. Amkor encourages employees to take responsibility
for their career development by maintaining and developing useful and marketable
skills. In addition, managers are encouraged to provide a supportive environment
to assist employees in career development.

WORKPLACE VIOLENCE

Amkor has a policy of zero tolerance for violence. Violence includes physically
harming another, shoving, pushing, harassing, intimidating, coercing,
brandishing weapons, and threatening or talking of engaging in those activities.

It is Amkor's intent to ensure that everyone associated with the business,
including employees and customers, never feels threatened by any employee's
actions or conduct. It is everyone's business to prevent violence in the
workplace. Employees can help by reporting any workplace incident that could
indicate a co-worker is in trouble. Employees are encouraged to report any
incident that may involve a violation of any of the company's policies that are
designed to provide a comfortable workplace environment. Concerns may be
presented to your supervisor, human resources, or the legal department. All
reports will be investigated and information will be kept confidential.

COMPENSATION AND BENEFITS

Amkor's compensation and benefits philosophy, which distinguishes the company
and contributes to our success, is an integral part of our culture and
management approach.

                                       12


TOTAL COMPENSATION AND PHILOSOPHY

The total compensation approach responds to the cyclical nature of our business.
This philosophy is based on creating a pay structure that we can maintain in
down cycles while being among the best paying in good times. This is
accomplished through a combination of base pay, benefits and variable,
profit-driven components such as cash and stock.

EQUITY

Pay equity is a method that Amkor uses to ensure that market pay rates are
obtained in dynamic growth areas. These pay adjustments typically respond to
specific job functions.

COMPETITIVE COMPENSATION AND BENEFITS PACKAGES

To strike a balance between Amkor's need to be viable and profitable, and the
needs and desires of our employees, each country's compensation package is
designed to be competitive with those of a select group of comparable companies
within that country. The individual program components of a specific country may
differ from local practices in that country to be consistent with Amkor's
culture.

WORK HOURS

At Amkor, being at work on time and being available during normal business hours
are part of our company's commitment to our customers and co-workers. Start
times are generally consistent with local business start times for the geography
in which Amkor operates. Amkor does not support flexible work hours (a program
in which employees can arrive at work anytime between set hours).

ALTERNATE START TIMES

Alternate start times (starting at other than the local business start time on a
regular basis) are supported only when business requirements can be met or
exceeded as a result of the change.

Setting an alternate work schedule or start time for an employee or group of
employees may be approved by a manager in the following circumstances:

- -    To accommodate a specific shift structure in facilities, manufacturing or
     other departments that use varied shifts as a part of the business.

- -    To accommodate regular business communication needs with a team or
     customers in geographies or time zones other than one's own.

- -    To accommodate an employee who has a disability or family hardship, as long
     as there is no undue hardship on the business results.

- -    To support local commuter traffic restrictions or requests from the city or
     country, as long as business requirements are not jeopardized.

Employees with alternate start times must have their supervisor's approval.

                                       13


ENVIRONMENTAL, SAFETY AND HEALTH

Amkor is committed to achieving a safe, healthy and environmentally friendly
workplace, and is dedicated to principles and practices of "continuous
improvement" in striving to provide high quality Environmental, Safety and
Health (ESH) standards and practices for team members, customers, visitors,
suppliers and the communities in which we live and work.

Amkor shall continue to demonstrate environmental responsibility through
compliance with all relevant environmental regulations; implementation and
monitoring guidelines; and training of team members to minimize the opportunity
for environmental insult to include proper storage, transportation and disposal
of hazardous waste materials, conservation of natural resources and energy
management.

Amkor shall strive to eliminate accidents, occupational injuries and workplace
illnesses by providing the appropriate training and support for team members,
suppliers, contractors and visitors.

Amkor shall ensure that safety and environmental responsibility take precedence
over expediency, and that our ESH standards meet international and local
requirements.

Amkor expects all team members to comply with the ESH policy by getting the
appropriate education and training to carry out ESH requirements in all phases
of work and business.

Amkor shall communicate and make available our ESH policy, objectives and
programs to all team members, suppliers, contractors and the public to encourage
and promote the positive participation in achieving our goals for environmental
responsibility, safety and health.

Amkor shall establish and maintain appropriate controls, including periodic
reviews, to ensure adherence to this policy.

PHYSICAL SECURITY

Amkor aims to provide a secure business environment for the protection of our
employees, products, valuable materials, equipment and proprietary systems and
information. Materials, equipment and systems incorporated into the design of
facilities and grounds will ensure adequate security in these areas. Security is
the responsibility of all employees. Any breach of security should be reported
immediately to your supervisor.

IDENTIFICATION AND BADGING

Anyone entering an Amkor facility is required to wear an Amkor-issued
identification badge. Badges should be visible at all times. All badges are the
property of Amkor and must be returned upon request. No modifications or
additions should be made that interfere with the visibility, clarity or use of
the badge.

                                       14


AMKOR COMPANY ASSETS AND COMPANY RIGHT TO SEARCH

Amkor does not allow the unauthorized removal of company assets or physical
property from our premises, or sharing of our intellectual property in an
unauthorized manner. To ensure proper protection of our employees and assets,
Amkor regulates the possession and movement of assets, subject to the
limitations imposed by local law.

Areas subject to search include an employee's workspace, desk, computer, file
cabinet, locker or similar place where employees may place personal possessions,
whether or not such places are locked. Such inspections or searches may also
include, but are not limited to, computer files, floppy disks, hard drives,
e-mail or other electronic mail; an employee's vehicle when on Amkor property;
or items of personal property while on Amkor property.

INTERNAL INFORMATION POSTING

Amkor has a number of methods for posting information located within the
facilities and on information systems for the purpose of communicating. Posting
in any of these places is limited to company-related material, including
statutory and legal notices, safety and disciplinary rules, company policies,
memos, announcements of general interest and other items relating to Amkor. All
postings require prior approval by the office manager at each site who manages
the posting place in question.

QUALITY

Amkor is committed to pursue quality in every aspect of our business.

Therefore, we strive to:

- -    Continuously improve our company -- people, processes, product quality and
     cost of ownership, technology, service and delivery -- and achieve/maintain
     world-class competitiveness in each of these areas.

- -    Build in customer-defined quality at each step as our products are
     developed, manufactured, delivered and supported.

BUSINESS RESULTS

Successful quality practices will:

- -    Foster adherence to Amkor corporate values and promotes a culture where
     excellence is expected, commitments are honored, and teamwork, openness,
     hard work, and dedication to process improvement and quality results are a
     daily routine for everyone.

- -    Encourage the continuous improvement of our products, processes, and people
     to become better, faster and more cost effective in everything we do.

- -    Require us, individually and collectively, to understand the needs of our
     internal/external customers and satisfy them in a way that ensures mutually
     beneficial business results.

- -    Promote the quest for quality and competitiveness at Amkor, in the
     semiconductor business, global industry and the communities where we live.

                                       15


DEPLOYMENT

All managers will:

- -    Provide quality leadership and direction for all management functions and
     quality related activities at Amkor.

- -    Ensure each employee understands the Code of Business Conduct and Ethical
     Guidelines.

- -    Provide the appropriate environment for each employee to implement the
     Quality principle.

All employees will:

- -    Talk, act and make decisions consistent with the tenets of this principle.

- -    Promote teamwork and support the improvement efforts of others for the good
     of Amkor as a whole.

EMPLOYEE REIMBURSEMENT/ADVANCES

Amkor's intention is to fund management-approved business travel, education,
relocation, in/expatriate expenses, business entertainment and other expenses
necessary to conduct our business. The employee is responsible for the accuracy,
completeness and timely filing of the required forms, including appropriate
backup documentation for receiving reimbursements, advances of funds or credit
card purchases. It is the responsibility of the approving manager to ensure that
reimbursable expenses or funds advanced are reasonable, ordinary and necessary
to conduct Amkor's business. In addition, human resources is responsible for
collecting funds and credit cards from terminating employees.

                                       16


VI. BUSINESS PRACTICES

ANTITRUST COMPLIANCE

The purpose of antitrust laws in the United States and other countries where
Amkor does business is to encourage competition, which benefits consumers by
prohibiting unreasonable restraints on trade. It is company policy to compete
vigorously while at the same time adhering to both the letter and spirit of
antitrust laws. Some of the more common antitrust problem areas are discussed
next.

RESTRAINTS OF TRADE

Any agreement, understanding or arrangement expressed or implied, formal or
informal, in restraint of trade or commerce is prohibited by antitrust laws. All
employees must avoid even the appearance of engaging in the restraint of trade.
All questions should be referred to the legal department.

DEALING WITH COMPETITORS

It is against Amkor policy to have a discussion or communication with any
competitor relating to price or any matter that affects pricing, including
costs, credit terms, allocation of markets, geographies, customers or lines of
business.

FINANCIAL REPORTING AND EXTERNAL COMMUNICATIONS

FULL, FAIR, ACCURATE, TIMELY AND UNDERSTANDABLE DISCLOSURE IN OUR COMPANY'S
FILINGS AND PUBLIC COMMUNICATIONS

The Chief Executive Officer and the senior financial officers have the direct
and primary responsibility to ensure full, fair, accurate, timely and
understandable disclosure in Amkor's filings and public communications. Senior
financial officers include the Chief Financial Officer, the Controller and each
of their direct reports who have responsibility for the preparation of financial
statements and public disclosure of financial information, and persons
performing similar functions at our subsidiaries. The information included in
all filings with the SEC and the Nasdaq Stock Market, and all other public
communication must be complete, timely and accurate, and must not omit any
material fact required so that the information disclosed is not misleading.

Since accurate records play a vital role in assuring the maintenance of high
ethical standards, all employees have responsibility to record all transactions
accurately, completely and in a timely manner. Never make false or artificial
entries in any company records. Never understate or overstate reports of sales
or expenses, or alter any documents used to support those reports.

Our financial statements must fairly and accurately present the financial
condition of the business. Reporting Amkor's proper financial condition is a
fundamental aspect of each employee's responsibilities. Reporting false
information is strictly prohibited.

                                       17


Amkor maintains a system of internal controls to assure appropriate
authorization, recording and accountability of our company's assets. Amkor's
internal control system is never to be intentionally circumvented.

All of our company's books and records are subject to review and audit. When
employees are asked to respond to requests by internal auditors, legal staff and
independent accountants, responses must be complete and truthful. Employees must
include all relevant information, even if the request is not specific as to what
information is required. If you know something that could be relevant, it must
be disclosed.

All records shall be prepared accurately, reliably, honestly and in accordance
with established finance and accounting procedures. An employee must not enter
false or misleading information into records and must report to management any
transaction they feel is questionable.

INTERACTION WITH INDEPENDENT ACCOUNTANTS

It is prohibited to take any action to fraudulently influence, coerce,
manipulate or mislead an independent accountant who is engaged in the
performance of an audit or review of Amkor's financial statements for the
purpose of rendering the financial statements misleading.

Types of conduct that would constitute improper influence, include, but are not
limited to, directly or indirectly:

- -    Offering or paying bribes or other financial incentives, including offering
     future employment or contracts for non-audit services;

- -    Providing an auditor inaccurate or misleading legal analysis;

- -    Threatening to cancel or canceling existing audit or non-audit engagements
     if the independent accountant objects to the company's accounting;

- -    Seeking to have a partner removed from the audit engagement because the
     partner objects to the company's accounting;

- -    Blackmailing;

- -    Making physical threats.

RECORDS RETENTION

Business documents and records are important company assets. They contain data
and information critical to the continuity of our business, preserve information
necessary to protect our legal rights and support and document tax and other
regulatory requirements. Employees are prohibited from tampering with company
records or removing or destroying them prior to the dates specified in record
retention schedules.

PUBLIC RELATIONS/PRESS

It is Amkor's intention to maintain open and consistent communications with the
media.

To ensure the accuracy of all information provided, spokespeople are designated
to respond to all inquiries. Except for designated spokespeople, individual
employees should not respond on Amkor's behalf to policy inquiries in any public
forum, including the Internet, on-line services and

                                       18


the press a even when they are visiting our facilities.

All press inquiries should be forwarded immediately to the director of Marketing
Communications, to the local Public Relations manager or to a designated
spokesperson.

EMPLOYEE POSTING ON THE INTERNET

Amkor employees may choose, or be required by their jobs, to participate in
public forums on the network, Internet mailing lists and so on. Employees may
not represent Amkor's corporate opinion in these forums unless they have been
specifically asked to do so. To avoid confusion, employees should indicate in
their postings that the views they express are their own and not those of Amkor.
If the posting is not obviously from an Amkor site, employees should clearly
identify their affiliation with Amkor.

Employees should remember that, even with this disclaimer, they will be
identified with Amkor and that their network behavior reflects on the company in
a broader way. In addition, employees should never comment on confidential or
internal company matters, and should never comment on pending legal actions
involving Amkor, our customers or our partners.

All comments should be well informed and within the employee's sphere of
expertise. Further, if the posting affects others at Amkor those affected should
be copied on the posting or be advised of it in advance.

                                       19


VII. USE AND PROTECTION OF ASSETS AND ELECTRONIC SYSTEMS

USE AND PROTECTION OF ASSETS

PROTECTION OF COMPANY ASSETS

Every Amkor employee is responsible for protecting the assets of the company.
Each employee is also responsible for understanding Amkor's obligations for
protecting assets that have been entrusted to it by customers or suppliers, and
for treating them accordingly.

The company's assets include physical assets, such as equipment and buildings,
as well as our funds, intellectual property, trade secrets and confidential
information.

To protect Amkor's assets, they must be adequately safeguarded. This means
locking up and securing valuable assets. Amkor's assets may not be sold,
borrowed, lent, given away or modified in any way that would impact their value,
unless there is a good business reason and with approval of the department
manager.

USE OF COMPANY RESOURCES

Company resources, including (but not limited to) cash, personnel, equipment and
vehicles may only be used for legitimate company business purposes.

Some sample situations:

- -    An Amkor employee may not make business trips or purchase an airline ticket
     at a premium price just to obtain frequent flier miles or other awards for
     his or her private use.

- -    No one outside the company may have access to our computers.

- -    In some cases, using an Amkor PC to do personal work is permissible if it
     is clearly outside of business hours and you have your manager's approval.
     Be sure that you and your supervisor agree on the exact meaning of "outside
     of business hours."

INFORMATION SECURITY

Confidential information generated by or used in any company business activity
is considered an information asset. This includes (but is not limited to)
information originating from direct access to computer systems, information
carried over networks, information preserved on portable electronic media and
information appearing in hard-copy format.

At the time of hire, all employees must sign an agreement to protect Amkor's
confidential information and intellectual property rights during and after
employment with Amkor. Upon termination of employment, employees must provide
Amkor with any company owned material or proprietary information (i.e., patents,
designs, data), and authorize ownership of that information to Amkor.

                                       20


Amkor requires that each employee be personally responsible for safeguarding the
company's information assets, in all its various forms, from loss, inappropriate
modification and disclosure to anyone who lacks either the authorization or the
need-to-know.

All employees are required to:

- -    Protect the confidentiality of information such as product roadmaps,
     strategic long-range plans, product pricing, and employee salary data,
     which, if disclosed, could cause financial or other damage to Amkor.

- -    Hold in confidence and not use (except for the benefit of Amkor) any
     confidential information that they have access to or that was created by
     them while employed at Amkor.

- -    Protect third-party confidential information in the manner required by the
     terms of a Memorandum of Agreement. If such terms are not known, that
     information should not be used, copied or disclosed until the terms of the
     Memorandum of Agreement are known.

- -    Ensure that confidential information that may need to be released to
     customers or suppliers is handled properly. In such cases, an employee must
     have received proper authorization (approval from their manager or the
     legal department) and must ensure that the recipient has a need-to-know and
     signs a nondisclosure agreement. Requests for confidential information from
     outside sources must be handled only by authorized persons.

- -    Be personally accountable to Amkor and legally accountable for their
     actions.

EMERGENCY MANAGEMENT PLAN

Amkor aims to provide our customers with flawless delivery of the products and
services they need and want.

Amkor recognizes that a wide variety of natural, human-caused, and physical and
information system failures can happen. Plans must be in place and responsible
people trained at all sites to ensure that employees, guests and neighbors are
protected from injury; that Amkor's assets are protected from damage or loss;
and that the effects of such an incident do not severely compromise Amkor's
ability to achieve our mission.

Although these incidents cannot always be avoided, reducing the duration of an
unplanned outage may control their severity. This may be accomplished by
repetitively exercising recovery plans to ensure that they work when needed, and
by taking preventative actions and measures to reduce the risk or impact when an
occurrence is likely (such as in war zones).

Every major site and function must have an Emergency Management Plan reviewed by
management and tested periodically. Preparations must include a cost-effective
combination of emergency response, recovery planning, protection of critical
data via backup, and secure storage and interim processes until normal services
can be resumed.

During emergency situations, Amkor's communications with the press must be
timely, honest and accurate, and they should not compromise the company's
reputation. Except for designated spokespersons, individual employees should not
respond to public inquiries from the press or any other forum during a time of
emergency.

                                       21


VIII. VIOLATIONS OF THE CODE AND THE ETHICS HOTLINE

REPORTING VIOLATIONS OF THE CODE

If an employee needs assistance in evaluating proposed conduct, or if an
employee observes or suspects any violation of the Code of Business Conduct and
Ethical Guidelines, he or she should first tell his or her supervisor. If the
employee is uncomfortable speaking with his or her supervisor for any reason, he
or she should contact, human resources, the legal department, or internal audit
or call the confidential Ethics Hotline at 877-22AMKOR (877-222-6567). The
confidential Ethics Hotline is operated by an independent third party provider.
Callers can remain anonymous when calling the Ethics Hotline and the
representative with whom the caller speaks will respect that decision.

The Ethics Hotline is available 24-hours a day, 7 days a week from any location
in the world. Nearly all languages can be accommodated when calling the Ethics
Hotline, including Korean, Tagalog, Japanese and Mandarin. To obtain the
toll-free Amkor telephone number from outside the U.S., a caller will first dial
the AT&T Direct Access Code for the country he or she in, then dial 877-22AMKOR
(877-222-6567). Specific country dialing instructions can be found on the
Amkor's intranet site, by asking the local Amkor human resources department, or
by calling the local AT&T telephone operator. Every report received will be
investigated promptly, and a caller may make a report without giving his or her
name.

RETALIATION

Employees can raise their concerns of violations of the Code of Business Conduct
and Ethical Guidelines, or other illegal or unethical conduct without fear that
they will be disciplined or terminated. We will not permit retaliation of any
kind against an employee for reporting information in good faith, which means
telling the truth as the employee knows it to be, to his or her supervisor, an
Amkor manager, a human resource representative or the Ethics Hotline.

VIOLATIONS OF THE CODE

Amkor will take appropriate disciplinary actions, up to and including
termination, for any violation of this Code of Business Conduct and Ethical
Guidelines.

                                       22


IX. PHONE NUMBERS

AMKOR IN CHANDLER, ARIZONA

INTERNAL TIE LINE 83.501 AND EXTENSION # OR EXTERNAL 480.821.5000 AND EXTENSION
#


                                                                                
Human Resources Hotline........................................................    ext. 5097
Internal Audit: Joanne Solomon, VP Finance and Business Assurance..............    ext. 5416
Purchasing: Buddy Farr, VP Asset Management....................................    ext. 5214
Marketing Communications: Jeff Luth, VP Corporate Communications...............    ext. 5130


AMKOR IN WEST CHESTER, PENNSYLVANIA

INTERNAL TIE LINE 83.101 AND EXTENSION # OR EXTERNAL 610.431.9600 AND EXTENSION
#


                                                                                     
     Legal: Kevin Heron, Sr. VP and General Counsel.................................      ext. 5535

ETHICS HOTLINE......................................................................     877.22AMKOR
                                                                                        (877-222-6567)


                                       23


UPHOLD AMKOR'S VALUES
SEEK GUIDANCE, ASK QUESTIONS, REPORT YOUR CONCERNS

                       ETHICS HOTLINE
                          877-22AMKOR
                       (877-222-6567)
             TOLL-FREE, DAY OR NIGHT,
                        CONFIDENTIAL,
                     IN YOUR LANGUAGE

[AMKOR TECHNOLOGY LOGO]

                                       24