Exhibit 11

 Code of Ethics for Principal Executive Officer and Senior Financial Officers

The principal executive officer and senior financial officers and others
responsible for the preparation, evaluation and dissemination of financial
information hold an important and elevated role in corporate governance.
Therefore, INFICON expects that such personnel foster a culture of transparency,
integrity and honesty, and to ensure that everyone in the organization also
fully complies with this Code.

To the best of their knowledge and ability, such personnel shall:

      1.    Act with honesty and integrity, ethically handling actual and
            apparent conflicts of interest in personal and professional
            relationships.

      2.    Provide full, fair, accurate, timely and understandable disclosure
            in reports and documents that INFICON files with, or submits to, the
            SWX Swiss Exchange, the United States Securities and Exchange
            Commission and in public communications made by INFICON.

      3.    Comply with applicable laws, rules and regulations of federal,
            state, provincial and local governments, and other appropriate
            private and public regulatory agencies.

      4.    Promptly report any evidence of a violation of these principles to
            the Audit Committee of INFICON's Board of Directors to (address
            TBD). Calls, detailed notes and/or emails will be dealt with
            confidentially.

Any violation of this Code will be subject to appropriate discipline, up to and
including dismissal from the Company and prosecution under the law. The Board of
Directors shall have the sole and absolute discretionary authority to approve
any deviation or waiver from this Code of Ethics. Any change in or waiver of
this Code of Ethics shall be promptly disclosed through a filing with the United
States Securities and Exchange Commission.