Code of Ethics

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Find an ATM

For your convenience, there are FNB ATMs available at the following locations:

Key Filling Station - Excel Garage
Bafokeng Filling Station
Benson Butchery
Bus Stop
Dion Fnb Atm
Gateway Filling Station
Metcash Complex
Modise Off-sales
Pioneer Shopping Centre
Scooters Maseru Fnb Atm
Sefika Complex
Thetsane Filling Station
Usave Hatsolo
Express Foods Maputsoe
Hlotse Excel Garage
Shoprite Building Hlotse
Total Garage Maputsoe
TY Thabo's Fruits and Veg
Kayce's Restaurant
LCS Mafeteng
LCS Mohales Hoek
Mohales Hoek Exel Garage
Morija Excel Garage
Butha Buthe Branch
Kingsway Branch
DLM Complex
Maseru Mall
Masianokeng Total Garage
Pioneer Mall Parking Fnb Atm
Sefika Complex
TY Excel Garage
Village-Walk Mall
Lower Moyeni Store
Mafeteng Branch
Fnb Lesotho Maputsoe
Maputsoe Branch
Maseru Branch
Pioneer Mall Branch
TY Branch
Hlotse Branch

Find a branch

FNB Lesotho Limited branches can be found at the following locations:

Pioneer Branch

Shop UG33
Pioneer Mall
Corner Mpilo and Pioneer Rd
Maseru

Maputsoe Branch

Crystal Packers Building
Sir Seretse Khama Road
Maputsoe
Lesotho
350

Kingsway Branch

Star Lion Building
Corner Kingsway and Parliament Road
Maseru
Lesotho
100

Butha-Buthe Branch

Shop 2 and 3
Muslim Congregation Building
Sechele Street
Butha-Buthe
Lesotho

Mafeteng Branch

High-way Complex Building
Corner Mafeteng Hotel Road
Plot 06472-518

TY Branch

Moshoeshoe Road
Teyateyaneng
Berea

Hlotse Branch

Shop No. B1 & B2
Nolans Complex
Lisemeng 1
Main Road
Hlotse Lesotho

Mokhotlong Branch

Alliance Building
Plot # 50274
Main Road
Mokhotlong
Lesotho ATM & ADT

Masianokeng Branch

Masianokeng Lifestyle Centre
Masianokeng Urban Area,
Maseru 100,
Lesotho

Maseru Mall Branch

Racecourse Mall PTY LTD T/A MASERU MALL,
cnr KOFI ANNAN and POPE JOHN, PAUL DRIVE,
Maseru 100,
Lesotho

Cash Plus Agents

Deposit and withdraw cash conveniently at any FNB Cash Plus agent listed below instead of queuing at branches or ATMs. All you need is an FNB account and be registered for Cellphone Banking. Additional Cash Plus services include airtime and electricity purchases.

Agent	Region	Community
Tummy General	Qoaling, Maseru	Maseru
MRK Boutique	LNDC, Maseru	Maseru
Frontline Motors	Next to CBL, Maseru	Maseru
Immaculate Suppliers	Medcash Building, Maseru	Maseru
HMS Farmtech	Ha- Hoohlo, Maseru	Maseru
Pally' Beauty	QC-Point, Maseru	Maseru
Mes technology	Jackpot building, Maseru	Maseru
Yona Yethu Tavern	Marabeng, Maseru	Maseru
Thethe's kiosk	Maseru Mall, Maseru	Maseru
Capita floring	Tradorette, Maseru	Maseru
Katleho General Dealer	Sekamaneng, Maseru	Maseru
Lancer's Gap General Dealer	Sehlabeng sa Thuathe	Maseru
Sima Communications	Maseru Mall, Maseru	Maseru
Mabotse General	Qoaling, Maseru	Maseru
GM Shopping	Motimposo, Maseru	Maseru
Phethy Off Sales	Ha Leqele, Maseru	Maseru
Afri Solutions	Kubetsoana, Maseru	Maseru
Shololo General	Naleli, Maseru	Maseru
Somies Boutique	NRH, Maseru	Maseru
Shoebox	Hillsview, Maseru	Maseru
One C all Pharmacy	Ha Mabate, Maseru	Maseru
Ether Pharmacy	Tradorette, Maseru	Maseru
KTA Off Sales	Khubetsoana, Maseru	Maseru
Mantsopa Herbalist	Ha Pita, Maseru	Maseru
Naledi Mini Market	Naleli Pela Ha Rasta, Maseru	Maseru
Solution Pharmaceutical	Borokhoaneng, Maseru	Maseru
Advance Locksmith	Pioneer Mall	Maseru
Bright Light	Qoaling Ha Machabachaba	Maseru
Tumy General	Qoaling Ha Machabachaba	Maseru
207 Retail	Ha- Shelile	Maseru
Zeecom Mobile and Computers	Victoria Hotel Building	Maseru
Bochabela General Café	Bochabela Khubetsoana	Maseru
Pioneer Auto Service	Pioneer Garage	Maseru
Sima Communications	Pitso Ground	Maseru
Dion	Borokhoaneng	Maseru
Falimehang General Café	Ha Lesia	Maseru
Lehloa Petroleum	Thetsane Garage	Maseru
Maletsunyane JCK Holdings	Khololikane	Maseru
Bafokeng Filling Station	Ha Matala Garage	Maseru
Seal Technology	Matsoatlareng	Maseru
Desire Kiosk	Lower Thamae	Maseru
Bofelo PTY	Peka, Leribe	Maseru
Alumnus	Mafikeng (Roma)	Maseru
GM General Dealer Lancers Gap	Ha Mabote	Maseru
Bashanyaneng General Dealer	Khololikane	Maseru
Nets Sourcing	Ha Thetsane	Maseru
La Reine Fashion	Mookoli	Maseru
Cool side	Khubetsoana	Maseru
Machache Tavern	Nazareth	Maseru
Mountain Off-sales	Nazareth	Maseru
Mykasi Home	Lower Thamae	Maseru
Metmok Holdings	Upper Thamae	Maseru
Lamshine Snack Bar	Roma	Maseru
Leratong General Café	Sefateng (Motimposo)	Maseru
Progress Hair & Salon Academy	Seipobi Building	Maseru
Blue Hill Café	Ha Ramabanta	Maseru
Malekeleke Public Bar	Mohalalitoe	Maseru
Get to know me	Ha Leqele	Maseru
Ebay Saver Enterprise	Masianokeng	Maseru
Harmony Creatives	Ha Leqele	Maseru
Chips Away Mini Market	Naleli	Maseru
Maluti Fruits & Vegetables Market	Pitso Ground	Maseru
All in one Construction	Maseru Craft	Maseru
Basaltic Construction	Upper Thamae	Maseru
BRS Entrepreneurship	Khubetsoana	Maseru
Grace Pharmacy	Morija	Maseru
Makhemeng General Dealer	Ha Thetsane	Maseru
Infotime Investments	Sefika mall	Maseru
Nala Butchery	Ha Tsosane	Maseru
SIM SIM General Dealer	Likotsi	Maseru
Smart Choice	LNDC	Maseru
Sima Communications	Khubetsoana	Maseru
Salang Mini Market	khubetsoana	Maseru
Hero Autotronics Accessories	Khubetsoana	Maseru
Get water with M & M	Cathedral Area	Maseru
Thabang Moreneng	Ha Motsoeneng	Maseru
Shine general dealer	Ha- Motsoeneng	Maseru
Katleho General Dealer	Motlakaseng Khubetsoana	Maseru
Elegant Fashion	Roma	Maseru
Balekeng General Dealer	Ha Thetsane	Maseru
Qhala Lounge	Khubetsoana	Maseru
Itekeng General Dealer	Serviceng, Ha Thetsane	Maseru
Malcom	Ha- Pita	Maseru
Jeans & Tonic	Sea Point	Maseru
Dezired Hair Salon	Ha Seoli	Maseru
Likepolana Construction	Ha - Foso	Maseru
Thumbs Up	Ha- Abia	Maseru
Bobz General	Ha- Tsosane	Maseru
Majela Construction	Koporasi	Maseru
Destiny Fresh Produce	Ha - Foso	Maseru
Sima Communications	Roma	Maseru
Mago enterprise	Nutri- Foods	Maseru
Frontline Motors	Maseru Mall, Maseru	Maseru
Greenfield Butchery	Selakhapane	Maseru
Greenfield Butchery	Ha Foso	Maseru
Lephola Savings and Credit	Kingsway	Maseru
Kasa General	Seputana Area	Maseru
All for Sports	Metcash Building	Maseru
Nkata General Dealer	Ha Seoli	Maseru
ATM General Dealer	Koalabata	Maseru
Thetsane Hardware	Maponeseng, Ha Thetsane	Maseru
Five Star	Ha Makhalanyane	Maseru
PASCOS Enterprise	Ha Abia	Maseru
Home of Joy	Ha Leqele	Maseru
Thamae General	Ha Tsolo	Maseru
Glamour World	Opposite Lesotho High School	Maseru
Lady M	Pitso Ground	Maseru
Moletsane Supermarket	Ha Thamae	Maseru
Lancer's Gap General Dealer	Mookoli	Maseru
Happy Angels	Ha Foso	Maseru
Garden of Victory Foods and Veg	Ha Leqele	Maseru
Mabotlenyana Guest House	Nazareth	Maseru
Vita Sana Pharmaceuticals	T'senola	Maseru
Diana Holdings	Traffic, Ha Foso	Maseru
Neltar Clothing	T'senola	Maseru
Aggie's Refridgerator	Ha Makhalanyane	Maseru
Lihlabeng Truck and Plant	BEDCO	Maseru
Tit for Tat	Semongkong	Maseru
Tsiu General	Ha Tsiu	Maseru
Atlantic Pharmacy	Ha Leqele	Maseru
Memoma Holdings	Ha Leqele	Maseru
Greenfield Distribution	Metcash Building	Maseru
Trustee Cosmetics	Old Industrial Area	Maseru
Mini Box	Lithabaneng	Maseru
Wezzy Shop	Ha Makhalanyane	Maseru
Sticks General Dealer	Motimposo, Maseru	Maseru
Red Square Group	Ha 'Nelese	Maseru
Wenhui Enteprises	Roma	Maseru
Koena General	Maponeseng, Ha Thetsane	Maseru
Rainbow Supplies	Koalabata	Maseru
Buzy Junction Offsales	Ha Leqele	Maseru
The Elite Group	Ha Mabote	Maseru
THATHOO GENERAL	KHUBETSOANA MASERU	Maseru
SUGAH DA HOUSE	HA- MAKHOATHI MASERU	Maseru
REBIRTH Café	HA MATALA MASERU	Maseru
MOCHABA INDOOR GAMES LESOTHO	MASELENG MASERU	Maseru
PUX HOLDINGS	HA -TIKOE MASERU	Maseru
TUCK SHOP KELLY	MASERU EAST- MASERU	Maseru
POUNDOLAR LOGISTICS PTY LTD	HA NGOATONYANE MASERU	Maseru
KHAYALETHU PHARMACY	HA TSOLO MASERU	Maseru
Two Sisters	Ha Maqele, Leribe	Leribe
Ha Seotsanyane	Hlotse, Leribe	Leribe
Tsoelang Pele	Peka, Leribe	Leribe
Leribe Highway	Lisemeng, Leribe	Leribe
Bakomane Tarvern	Khanyane	Leribe
Makabelane Tavern	Peka, Leribe	Leribe
Precious of Africa	Maputsoe, Leribe	Leribe
Kome Careting	Next to TY Branch	Leribe
Liba's Factory	Lisemeng, Leribe	Leribe
Payrite	Maputsoe, Leribe	Leribe
Showery Year .co	Maputsoe, Leribe	Leribe
Bkoena General	Peka, Leribe	Leribe
All in one Mini Market	Hlotse, Leribe	Leribe
Whispers Tavern	Peka, Leribe	Leribe
Tsoelang Pele	Peka, Leribe	Leribe
Molakolako Tavern	Peka, Leribe	Leribe
Two Sisters	Ha Maqele, Leribe	Leribe
Ha Seotsanyana	Hlotse Filling Station	Leribe
Nortern Giants	Maputsoe Filling Station	Leribe
Hongcai Shopper	Next to Maputsoe Branch	Leribe
London Take Away	Pitseng	Leribe
Ha Seotsanyane	Ha Nyenye Filling Station	Leribe
Machabeng General Café	Matukeng	Leribe
The Blue Diamond	Ha Bene	Leribe
Plush Restaurant	Hlotse	Leribe
Macabela Liqour	Lisemeng	Leribe
Lagoon Off Sales	Hlotse	Leribe
Roadside Tavern	Roadside Tavern	Leribe
Areka Public Bar	Ha Nyenye	Leribe
Waters Public Bare	Khanyane	Leribe
Jabari Off Sales	Ha Lejone	Leribe
Tsipa- Tsipa	Ha Makokoana	Leribe
Roots General Café	Maputsoe, Pela Borokhong	Leribe
Market Day	Maputsoe	Leribe
Ten70	Maputsoe	Leribe
BI Park Liqour	Ha Makhata	Leribe
Lihoja General Dealer	Maputsoe	Leribe
Sima Communications	Ha Foka, Peka	Leribe
Sima Communications	Hlotse	Leribe
Da Royal General Café	Ha Molibeli, Pela Junction	Leribe
Phoenix Holdings	Butha Bothe reserve, Butha, Buthe	Butha-Bothe
Arabian Electronics	Likila Complex, Butha- Buthe	Butha-Bothe
Real Tech	Excel Garage	Butha-Bothe
Thabelo Enterprise	Near Mokhotlong Bus-Stop	Butha-Bothe
Sebipela Off Sales	BEDCO	Butha-Bothe
Sima Communications	BEDCO	Butha-Bothe
Saucy and Spicy Hub	Botha Bothe Reserve	Butha-Bothe
Nchela Energy	Botha Bothe Reserve	Butha-Bothe
Mr Shoppers	Likoting	Butha-Bothe
Mr Shoppers	Likoting	Butha-Bothe
Ultimate Restaurant	Lipelaneng	Butha-Bothe
Raletsoho Transport	Mapoko	Butha-Bothe
Sima Communication	Mokhotlong	Mokhotlong
Botshelo General	Letseng	Mokhotlong
Semausing General Dealer	Mapholaneng	Mokhotlong
Tlokoeng Off-Sales	Malingoaneng	Mokhotlong
Batlokoa Off sales	Mapholaneng	Mokhotlong
Malinyane & Cellular	Ntlolohetsane	Mokhotlong
Blitz Botique	Mokhotlong Reserve	Mokhotlong
Reitumetse Shop	Mapholaneng	Mokhotlong
Basia General Dealer	Ntlolohetsane sekoting	Mokhotlong
Casian General Dealer	Ntlolohetsane sekoting	Mokhotlong
Seotlong general Dealer	Salang	Mokhotlong
Lilomong General Café	Salang	Mokhotlong
Medi - Land Pharmacy	Matamong	Mokhotlong
Ma Bk Catering	Matamong	Mokhotlong
Sports Fite	Mokhotlong Garageng	Mokhotlong
P&D Discount Electronics	Alliance Building	Mokhotlong
T&M CONSTRUCTION	MATAMONG MOKHOTLONG	Mokhotlong
MS Suppliers	Thabong, Thaba, Tseka	Thaba-Tseka
Methalaneng Store	Mant'sonyane	Thaba-Tseka
Machabeng Catering	Mantsonyane, Thaba- Tseka	Thaba-Tseka
Mamosiane Catering	Ha Mme Mamosiane	Thaba-Tseka
Nanabolela General Café	Mantsonyane	Thaba-Tseka
Venus Enerprises	Thabong pela Bankeng	Thaba-Tseka
Lilala Mini Market	Thabong 2	Thaba-Tseka
Likepolana General Dealer	Mantsonyane	Thaba-Tseka
Ntina Botique	Thabong	Thaba-Tseka
Katse General Dealer	Khokhoba	Thaba-Tseka
Seotloaneng Public Bar	Upper Moyeni, Quthing	Quthing
Big Sisters General Dealer	Lower Moyeni	Quthing
Sima Communication	Upper Moyeni, Quthing	Quthing
Rolling Wheel	Mphaki	Quthing
Mitchell Trading	Quthing	Quthing
Buy A Futhi General Café	Ha Pokane	Quthing
Tip Top	Sixons	Quthing
Greenworld Distribution	Lower Moyeni	Quthing
Ha Thato	Lower Moyeni	Quthing
Simma Communications	Qacha's Nek Reserve, Qacha, SPU Building, Qacha	Qacha's Nek
Push Push	Chaka Complex	Qacha's Nek
Boliba holdings	Phamong, Mohales Hoek	Mohale's Hoek
Four Sister	Shell Garage	Mohale's Hoek
Eclipse Butchery	Phahameng	Mohale's Hoek
Infinity Off-Sales	Thabaneng	Mohale's Hoek
Tony Off-Sales	Likhutlong	Mohale's Hoek
Mjuza Filling Station	Mohale Street	Mohale's Hoek
Nchorosetsa Public Bar	Qalakheng	Mohale's Hoek
Mat'seliso Catering	Qalakheng	Mohale's Hoek
Crossby Off sales	Holy Cross	Mohale's Hoek
Agro Pro Investments	Mafeteng CBD, Mafeteng	Mafeteng
Green City	Four Square, Mfeteng	Mafeteng
Multi Distributors	Leboneng Opposite Build It	Mafeteng
Lerato General Café	Ha ntate Molise	Mafeteng
Dawn Hair	Next to Mafeteng Branch, Mafeteng	Mafeteng
Botsana General Café	Ha Maine	Mafeteng
Supa General Dealer	Thabaneng	Mafeteng
Borata Milling	Matsaneng	Mafeteng
Mohope Public Bar	Ha Seitlheko	Mafeteng
Tsimong Public Bar	Motse- mocha	Mafeteng
Lehae Ripple Tarven	Matelile	Mafeteng
Mantso Enterprise	Khubetsoana	Mafeteng
Choice General Café	Matsaneng	Mafeteng
Kome Careting	Next to TY Branch	Berea
Mohlakola Car Rentals	Ha Motjoka, Berea	Berea
The Stone Guest House	Koro-Koro (TY)	Berea
Phokeng Store	Mapoteng Next to Police station	Berea
Makhoroana Tavern	Ha Makhoroana	Berea
Ts'epa Sweet Delight	Ha Mokhothu	Berea
Molato Tuckshop	Ha Lebina	Berea
Kap Tech Pty Ltd	Ha Lebina	Berea
Supercare Pharmacy Pty Ltd	Ha Mokhothu	Berea
Sima Communications	Ha Motjoka	Berea
Lehae farm feeds	Kolonyama	Berea
BM21 Tarvern	Ha Letsoela	Berea

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Introduction

1. Philosophy

The FirstRand Banking Group and all its subsidiaries and associates globally, referred to as the Group, are committed to a policy of fair dealing and integrity in the conduct of its business.

This comment rests on the fundamental belief that business should be conducted honestly, fairly and within the framework of applicable laws.

The Group expects employees to share its commitment to high moral, ethical and legal standards, and be committed to contribute to the commercial success of the Group, achieved against this ethical background.

Adherence to this Code is a strategic business imperative and a source of competitive advantage.

2. Purpose and scope of this Code

The purpose of the Code is to promote and enforce ethical business practices and standards within the Group and to provide a benchmark for all behaviour. All employees are requested to take careful note of the contents of this Code and ensure that they comply with both the written word and the spirit of the Code.

ANTI-TRAFFICKING IN-PERSON COMMITMENT

ANTI-TRAFFICKING IN-PERSON COMMITMENT

FNB Lesotho is a financial service business that was registered in Lesotho in 2008, it is one of the leading commercial banks in Lesotho. Operating in six districts of Lesotho through its 8 branches offering credit, savings, investments, insurance, and transacting services.

FNB Lesotho's brand philosophy is based on the desire to help. We have a strong conviction and firm belief in help and the potential it has to forge a bridge.

FNB Lesotho seeks to conduct its business in compliance with legislation and regulations. This statement constitutes the bank's anti-human trafficking statement for the financial year ending 30 July 2024. This statement provides an overview of the steps the bank has taken to manage the occurrence of human trafficking risk in its supply chains and in its business.

FNB Lesotho adopts a zero-tolerance approach to human trafficking and will not knowingly hold a direct or indirect relationship with persons or entities engaged in human trafficking.

Policies

Listed below are the bank's policies and codes which outline the principles the bank expects employees, directors, customers, and suppliers to align with and adhere to.

FNB Lesotho operates according to a code of ethics which provides guidance on ethical decision-making and behaviour. It creates a common understanding of the behaviour the bank expects from its employees. The code sets standards with regard to promoting and maintaining fair labour practices, respecting human rights and reporting employees who wilfully disregard the rights of people, amongst other requirements.
FNB Lesotho maintains a supplier code of conduct which sets out the minimum standards that FNB Lesotho expects from all its suppliers. FNB Lesotho requires all suppliers to refrain from any form of slavery and to actively monitor and prevent modern slavery in their own supply chains.

Supplementary controls

FNB Lesotho continues to update its supplier contracts to include clauses that outline the obligations of suppliers. In addition, all FNB Lesotho employees have a responsibility to report any actual or suspected forms of illegal, unlawful or unethical conduct to line management or by means of FNB Lesotho's whistle-blowing line, in accordance with FNB Lesotho's ethics line policy.

Training

FNB Lesotho seeks to raise awareness of the issue of modern slavery and human trafficking risk among its employees. To this purpose, general awareness and communication initiatives regarding slavery and human trafficking have commenced and will remain ongoing.

Screening and due diligence

As part of its overall compliance ecosystem, FNB Lesotho has adverse media screening standards and procedures in place that are applied to customers and suppliers at onboarding. Ongoing due diligence is also conducted regarding all customers and active suppliers.

Industry engagements

FNB is an active member of the South African Anti-Money Laundering Integrated Taskforce (SAMLIT) expert working group through membership of FirstRand on modern slavery and human trafficking, the purpose of which is to increase efficiency and effectiveness in combating financial crime by sharing knowledge and expertise. The outcomes of these engagements include:

information sharing among member banks, various law enforcement agencies, and industry bodies; and
identification of entities and systems previously unknown to law enforcement in order to contribute to increased enforcement actions.

DECLARATION

This statement has been approved by the FNB Lesotho Social and Ethics Committee on behalf of the board of directors.

Media Relations

The employee acknowledges that he/she will accumulate, during the course of his/her employment with the Group, a considerable amount of information, which he/she acknowledges to be of a confidential nature, the employee acknowledges responsibility for ensuring the protection of such information and will not divulge it in any unauthorized manner.

No information, financial or otherwise, regarding any clients of the Group may be provided to outsiders, without the prior written permission of the client.

Application and General Obligations

This Code of Ethics applies to:

The managers and directors of the Group, including non-executive directors; and
Employees;
Other representatives (i.e. contract employees, fulltime consultants, etc. of the Group).

All persons listed above are individually and/or collectively referred to as "employees" in this Code.

In practicing this Code, all employees are expected to:

Respect their terms and conditions of employment
Defend and maintain the reputation of the Group
Practice sound labour relations
Develop their personal capabilities

If employees are in doubt about how to apply the Code, they should discuss the matter with the person to whom they report.

The Group may, from time to time, and after consultation with staff representative bodies, amend the Code and these changes will be communicated to all employees.

If employees become aware of, or suspect a contravention of the Code, they must promptly and confidentially advise the Group as set out in the section "Contravention of the Code".

Personal Behaviour

No information, financial or otherwise, regarding any clients of the Group may be provided to outsiders, without the prior written permission of the client.

Compliance with Laws and Regulations

Employees must comply with the applicable laws, rules and regulations which relate to their activities for and on behalf of the Group.

Employees may not break the law or enter into unethical business practices, including taking money for, or taking part in, any unlawful act/s including but not limited to bribery, fraud, theft or money laundering.

Employees must ensure that their behavior cannot be interpreted in any way as contravening any laws and rules that govern the operations of the Group. Employees should ensure that they are not involved in any form of dishonesty, deceit or misrepresentation, during or after working hours, that may affect the Group or the employment relationship.

The Group will not condone any violation of the law or unethical business practices by any employee.

An employee who has to appear in a court of law, on a matter which may affect the Group, either on his/her own behalf or as a representative of the Group, should inform his/her immediate senior with immediate effect.

The Group supports:

The King Report on Corporate Governance;
The Code of Banking Practice of the Banking Council of South Africa;
The Register of Employees Dismissed;
The Code of Ethics and Standards of Professional Conduct of the Institute of Financial Markets;
The rules and directives of the Johannesburg Stock Exchange; the rules of the South African Futures Exchange; and the Rules of the Bond Exchange of South Africa.
The Central Bank of Lesotho Corporate Governance Guidelines and all Laws applicable in the Kingdom of Lesotho

Copies of these documents and all applicable acts are kept in the Compliance/Internal Audit Departments and are available for reference to all employees.

Environmental Responsibility

The Group is committed to providing a safe work environment for all employees in terms of the law, and supports environmental management where it is applicable.

Group Assets and Records

Employees should, at all times, ensure that the Groups assets, including copyright and intellectual property, are used for lawful business purposes only, and remain the sole property of the Group.

When using material in substantially the same form as prepared by other persons, employees should acknowledge the author or publisher of that material.

Employment Equity

The Groups Employment Equity Policy ensures compliance with the Employment Equity Act and the Group is committed to achieving the purposes of the Act, namely:-

Eliminating all forms of unfair discriminat
Promoting diversity and a culture of equality

The Group therefore promotes a system of equal opportunity and equal treatment for all and rejects any form of tokenism, window dressing, "jobs for loyalty" employment.

The Group commits itself to creation of an environment within which an employee can assure his/her own employability, inside or outside the organization.

Obligation of Managers

Managers shall:

be responsible for communicating this Code to all employees and ensuring that they understand it
be responsible for the observance of the ethical obligations of their areas of control;
make sure employees comply to the Code when relating to customers;
respect the confidentiality of sensitive customer information;
act honestly and in good faith;
not allow Group services to be used for private purposes, unless special prior approval has been obtained from a senior;
act within his/her powers, in the interest of, and for the benefit of, the Group;
not place themselves in a position where their personal interests could conflict with their duties to the Group;
ensure good buying practices with suppliers to the Group;
report honestly on the financial position of the Group to its creditors, when necessary.

Contravention of the Code

Non-compliance with the Code is a serious and disciplinary offence. Any investigation into suspected or possible breaking of the rules must be kept confidential.

If an employee is of the belief that his/her conduct may have contravened the Code, this should be immediately reported to his/her senior, who will take the necessary action.

If an employee becomes aware or suspects that someone else within the Group has or may have contravened the Code, this information should also be reported immediately to his/ her senior, preferably in writing and in a confidential manner. The employee should not confront the individual concerned to ensure confidentiality and for the matter to be investigated objectively.

All information received even anonymously should be reported to the Group.

Non-compliance with the Code may lead to disciplinary action being taken against an employee, which may lead to dismissal. Certain breaches of the Code could also culminate in civil or criminal proceedings.

This Code and its Principles as set out above are to be implemented throughout the Group.

Conflict of Interest

A conflict of interest exists when employees in association with immediate family members have direct or indirect personal interests in, or derive benefits from, transactions to which the Group is also a party. Such situations must be avoided and prevented at all times, in the interest of honest and bona fide busi ness practices.

Employees are expected to perform their duties conscientiously, honestly and in accordance with the best interests of the Group.

Employees will, therefore, not carry on business on their own account or have other conflicting interests, without full disclosure to the Group.

If employees are of the opinion that the conduct, behavior or activity in which they are involved may constitute a conflict of interest with the Group, it should immediately be brought to the attention of that employee's immediate senior.

1. Personal account trading

The Group acknowledges and respects the right of all employees to make personal investment decisions as they see fit, as long as these decisions do not contravene the provisions of the Code, any applicable legislation, or any policies or procedures established by the various operating areas of the Group.

This includes the provision that these decisions are not made on the basis of material confidential information obtained by reason of their employment.

Employees may enter into personal account joint trading, provided that the trading:

Is not insider trading (using confidential information that may affect the share price);
Does not conflict with the interests of the Group or its client;

2. Gifts, hospitality and favours

Financial services officials have a specialized position in the business world which places them in situations where efforts will surely be made to influence their discretion.

Conflicts of interest can arise when employees are offered gifts, hospitality or other favours that may, or could be perceived to influence their judgment in relation to business transactions such as placing orders and contracts or procuring clients and accounts.

Employees may under no circumstances accept gifts that can be regarded as bribes e.g. valuable and expensive gifts, airline tickets, etc.

Any gift that has the potential to affect that employee's future objectivity or places that employee under any obligation, is not acceptable, unless fully approved by the employees senior. Cash gifts may not be accepted under any circumstances.

Any offer of this kind must be declined politely or returned to the sender immediately, if it is delivered without prior notice. The onus is on the employee to seek clarification from his senior in the event of uncertainty.

Accepting small gifts such as promotional items, company pens, or items of limited value, would not be regarded as breaking this Code.

Occasional personal hospitality, such as tickets to local sporting events or theatres may be accepted, provided that the person receiving the favour pays for any travel or accommodation him/herself.

If an employee receives an invitation to out-of-town events, trips or promotions involving travel and accommodation arrangements that the employee does not pay for him/herself, he/ she should obtain approval from the head of the business unit.

Employees should follow the same guidelines when handing out gifts to clients.

3. Outside activities, employment and directorships

We all share a very real responsibility to contribute to our local communities, and the Group encourages employees to take part in religious, charitable, educational and civic activities.

Employees should, however, avoid taking part in any activity outside the Group which would constitute an unreasonable demand upon their time, attention and energy and which would hinder their job performance/best efforts on the job.

Valid participation in the activities of the recognized trade union would not constitute a conflict of interest. A conflict of interest is a duty, interest or distraction that would interfere with his/her independent judgment in the Groups best interest.

Employees should obtain prior written permission from the Group to hold any employment and/or interest in any business undertaking, outside the Group, including any temporary employment. Employees must therefore obtain prior approval from their immediate senior before accepting any appointments as a director of public or private company is outside the Group (See Appendix I).

4. Relationships with customers and suppliers

Employees should ensure that they are independent, and are perceived to be independent, from any business organization having a contract with the Group or providing goods or services to the Group.

Employees may not invest in, or obtain a financial interest, directly or indirectly, in such a business organization, other than shareholdings in public companies.

5. Remuneration

No employee may accept commissions or other payment related to the sale of any product or service belonging to the Group, except as specified in the employee's terms of employment. Employees may only sell authorized products and services.

No employee may accept payment or commission of any kind from a customer, supplier, etc.

Appendix I - Procedure to be followed in declaring outside interests

1. Definition of outside interests to be disclosed:

The onus rests on employees and directors to disclose all potentially conflicting interests.

These interests should be declared on the following basis:

Any position or beneficial interests that an employee or his/her immediate family may hold in any company (public or private), partnerships, close corporations, bodies corporate, or business venture of any nature, must be disclosed.
This situation does not apply to the acceptance of office on club committees, welfare organizations or bodies of a similar nonprofit making nature.
All existing outside interests which were established before the issue of this Code document, must be disclosed and declared.
All existing and new appointments will be required to declare any outside business interests in accordance with the above Code and provide details of any changes in future.

2. Procedure for Disclosure

This information should be disclosed to the employee's immediate senior or any higher authority, who will be responsible for recording the interests concerned in a confidential register and submitting it to the CEO.

Details of the interest are required in order to decide whether the interest conflicts with group business.

Confidentiality and Protection of Information

No information, financial or otherwise, regarding any clients of the Group may be provided to outsiders, without the prior written permission of the client.

Code of Ethics

Introduction

Application and general obligations

Compliance with laws and regulations

Group assets and records

Obligation of managers

Conflict of interest

Confidentiality and protection of information

Media relations

Personal behaviour

Environmental responsibility

Employment equity

Contravention of the Code

Appendix I - Procedure to be followed in declaring outside interests

Anti-Trafficking Statement

Customer Privacy Notice

Code of Ethics

Commited to high standards

A commitment to high moral, ethical and legal standards are non-negotiable qualities that FNB Lesotho Limited expects from its employees.

First National Bank of Lesotho Limited - A Subsidiary of FirstRand EMA Holdings Limited and a
member of the FirstRand group of Companies. An authorised Financial Services Provider. Reg No: 2008/729.

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Appendix I - Procedure to be followed in declaring outside interests

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Code of Ethics

Commited to high standards

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