Exhibit 11.1


                              SUN MEDIA CORPORATION

      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 Sun Media
Corporation (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.




                                                                    Exhibit 11.1

                                      - 2 -


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 June 30, 2003
by the Board of Directors of Sun Media Corporation


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


Signed in ______, this _______ day of _______2003