Exhibit 11.1 Code of Ethics of Chunghwa Telecom Co.  Ltd. All articles adopted by the 2nd special meeting of the Company’s 3rd Board of Directors on April 28  2004. The amendment adopted by the 12th meeting of the Company’s 4th Board of Directors on March 28  2006. All 19 articles amended by the 8th meeting of the Company’s 6th Board of Directors on April 26  2011. Chunghwa Telecom Co.  Ltd. (hereinafter referred to as the “Company”) and its directors  supervisors  managers   and employees shall conduct business throughout the world in accordance with the highest ethical standards. This Code  of Ethics is hereby stipulated in order to establish an obedience and maintenance standard. The Code of Ethics embodies rules regarding individual and group responsibilities  as well as responsibilities to  the Company  the public  and other stakeholders. This Code of Ethics applies to the Company’s directors  supervisors   managers  and employees. The purpose of this Code of Ethics is to prevent from wrongdoing and to cause their conducts  to be in compliance with the following requirements: Article 1 Purpose and applicable scope Article 2 Honesty and ethics Articles 3 Avoiding conflict of interest  PART III The Company’s directors  supervisors  managers  and employees shall act according to the ethics and perform their  duties with honesty. Honest conduct mentioned above refers to a conduct that is free from intent of fraud or fact of deception. Conduct  in compliance with ethics refers to a conduct that meets the professional standards  including the handling of conflict of  interests in connection with the personal matters or their duties. “Conflict of interests” stipulated in the previous Article refers to a situation where directors  supervisors  managers   and employees face a choice between their personal interests (financial interests or otherwise) and the interests of the  Company. Conflict of interests will always cause public concerns toward the Company’s image. Services to the Company shall  not be provided basing on personal interests  and directors  supervisors  managers  and employees are required to act in  the Company’s best interest to avoid from any conflict of interests. Where the Company’s directors  supervisors  managers  and employees are in a position whose objectivity may  be questioned because of personal interests or interests of their spouse  children  or relatives within the second degree  (including working for companies whose interests are in direct competition with the Company) shall notify their  immediate supervisor or the Company’s Human Resources Department. Where any individual is aware that a material  transaction or relationship might gives rise to a personal conflict of interests  he/she shall discuss about the matter with  his/her immediate supervisor or the Company’s Human Resources Department immediately. 14.  Full understanding and compliance with this Code of Ethics. 13.  Reporting and handling discovered violations against the Code of Ethics; and 12.  Implementing environmental protection and establish a healthy and safeworking environment; 11.  Preventing from corruption and bribery; 10.  Preventing from insider trading; 9.  Complying with laws  rules  and regulations; 8.  Protecting the Company’s assets and utilizing them in an efficient and legitimate manner; 7.  Treating fairly with the Company’s customers  suppliers  and competitors; 6.  Disclosing the Company’s information in a full  fair  accurate  timely  and understandable manner; 5.  Keeping trade secrets; 4.  Caring for employees; 3.  No appropriation for personal gains; 2.  Avoiding conflict of interest; 1.  Honesty and ethics;