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.
For your convenience, there are FNB ATMs available at the following locations:
FNB Lesotho Limited branches can be found at the following locations:
Pioneer Branch
Shop UG33
Pioneer Mall
Corner Mpilo and Pioneer Rd
Maseru
Maseru Branch
Shop 4, LNDC Building
Kingsway Road
Maseru
Lesotho
100
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
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.
Tummy General
Qoaling, Maseru
Two brothers Projects & Investments
BNP Centre, Maseru
MRK Boutique
LNDC, Maseru
Frontline Motors
Next to CBL, Maseru
Mellow Snack bar
Cathedral area, Maseru
Immaculate Suppliers
Medcash Building, Maseru
HMS Farmtech
Ha- Hoohlo, Maseru
Pesi General Dealer
Ha Abia, Maseru
Burdes clothing and footwear
NRH Mall, Maseru
Pally' Beauty
QC-Point, Maseru
Mes technology
Jackpot building, Maseru
Yona Yethu Tavern
Marabeng, Maseru
Roadside Tavern
Morija, Maseru
Thethe's kiosk
Maseru Mall, Maseru
Capita floring
Tradorette, Maseru
Katleho General Dealer
Sekamaneng, Maseru
Sima Communications
Maseru Mall, Maseru
Smith Off Sales
Lekhaloaneng, Maseru
Mabotse General
Qoaling, Maseru
GM Shopping
Motimposo, Maseru
Phethy Off Sales
Ha Leqele, Maseru
Afri Solutions
Kubetsoana, Maseru
Shololo General
Naleli, Maseru
Somies Boutique
NRH, Maseru
Shoebox
Hillsview, Maseru
One C all Pharmacy
Ha Mabate, Maseru
Ether Pharmacy
Tradorette, Maseru
Max Bulk Resellers
Sea- Point, Maseru
KTA Off Sales
Khubetsoana, Maseru
L-Mac Pharmacy
Khubetsoana, Maseru
Mantsopa Herbalist
Ha Pita, Maseru
Lecholi Foods
Khubetsoana, Maseru
Lecholi
Ha Tsolo, Maseru
Naledi Mini Market
Naleli Pela Ha Rasta, Maseru
Solution Pharmaceutical
Borokhoaneng, Maseru
Sime Communication
Pitso Ground
Advance Locksmith
Pioneer Mall
Bright Light
Qoaling Ha Machabachaba
Tumy General
Qoaling Ha Machabachaba
Zeecom Mobile and Computers
Victoria Hotel Building
Bochabela General Cafe
Bochabela Khubetsoana
Pioneer Auto Service
Pioneer Garage
KT Business Solution
Masianokeng
Sima Communications
Pitso Ground
Calabash Catering
Mookoli
Calabash Offsales
Mookoli
Modise Logistics
Ha modise
Dion
Borokhoaneng
Falimehang General Cafe
Ha Lesia
One Price Enterprise
Cathedral Area
Lehloa Petroleum
Thetsane Garage
Bafokeng Filling Station
Ha Matala Garage
IFQ
Pioneer Mall
Seal Technology
Ha Thetsane
Golden Pot Catering
Ha Mokhothu
Kome Careting
Next to TY Branch
Whispers Tavern
Peka, Leribe
Tsoelang Pele
Peka, Leribe
Molakolako Tavern
Peka, Leribe
Two Sisters
Ha Maqele, Leribe
Ha Seotsanyane
Hlotse, Leribe
Leribe Highway
Lisemeng, Leribe
Makabelane Tavern
Tabola- Peka, Leribe
Makabelane Tavern
Peka, Leribe
Precious of Africa
Maputsoe, Leribe
Liba's Factory
Lisemeng, Leribe
Payrite
Maputsoe, Leribe
Showery Year .co
Maputsoe, Leribe
Bkoena General
Peka, Leribe
All in one Mini Market
Hlotse, Leribe
Whispers Tavern
Peka, Leribe
Tsoelang Pele
Peka, Leribe
Molakolako Tavern
Peka, Leribe
Two Sisters
Ha Maqele, Leribe
Ha Seotsanyana
Hlotse Filling Station
Nortern Giants
Maputsoe Filling Station
Hongcai Shopper
Next to Maputsoe Branch
London Take Away
Pitseng
Ha Seotsanyane
Ha Nyenye Filling Station
Machabeng General Cafe
Matukeng
Phoenix Holdings
Butha Bothe reserve, Butha, Buthe
LKL Investments
Traffic circle. Butha- Buthe
Pally Jane
Butha Bothe reserve, Butha, Buthe
Aabian Electronics
Likila Complex, Butha- Buthe
Baba Enterprise
Opposite Cash Build
Maqdum Enterprises
Old Bus Stop
Shoppers Rite Mini-Market
Marekeng
Real Tech
Excel Garage
Thabelo Enterprise
Near Mokhotlong Bus-Stop
Gandhi and Babudi Sons Enterprise
Makholokoe, Mokhotlong
Sima Communication
Mokhotlong
Khutlisi GeneralL
Makhoaba
Maluba-luba General
Mapolaneng
Bay Fruits and Veg
Mapolaneng
Ntja Mokoatle Trading
Ntja Mokoatle
MS Suppliers
Thabong, Thaba, Tseka
MalibaFarm Feed
Phomolong, Thaba -Tseka
Machabeng Catering
Mantsonyane, Thaba- Tseka
808 Public Bar
Thaba Tseka
Mamosiane Catering
Ha Mme Mamosiane
JJ Brick Works
Mantsonyane
Nanabolela General Cafe
Mantsonyane
Seotloaneng Public Bar
Upper Moyeni, Quthing
Moments Café
Upper Moyeni, Quthing
Ha Thato
Upper Moyeni, Quthing
Sima Communication
Upper Moyeni, Quthing
Rolling Wheel
Mphaki
Mitchell Trading
Quthing
Simma Communications
Qacha's Nek Reserve, Qacha
SPU Building, Qacha
Kedis Phamarcy
Qacha's Nek Reserve, Qacha
Qacha's Nek Filling Station
Qacha's Nek Garage
Boliba holdings
Phamong, Mohales Hoek
Q. City butchery
Qalakheng, Mohales Hoek
Simma Communication
Mohale's hoek
Holy City
Oppoite Cash Build
Majantja Supermaket
Qalakheng
Agro Pro Investments
Mafeteng CBD, Mafeteng
Green City
Four Square, Mfeteng
Easy Pay 2
Ha- Sehlabo, Mfeteng
F & L Holdings
Matholeng, Mafeteng
Dawn Hair
Next to Mafeteng Branch, Mafeteng
Lephola Farm
Next to the Old Bus Stop
Mult Distributors
Leboneng Opposite Build It
Lerato General Cafe
Ha ntate Molise
Mohlakola Car Rentals
Ha Motjoka, Berea
TY Four Square
Ha Mokhothu, Berea
All in one services
Ha Motjoka, Berea
Allif Supermarket
Ha Motseki, Berea
Phokeng General Dealer
Machoaboleng, Berea
Makhoroana Tavern
Ha Makhoarana,Berea
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
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.
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:
DECLARATION
This statement has been approved by the FNB Lesotho Social and Ethics Committee on behalf of the board of directors.
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.
This Code of Ethics applies to:
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:
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".
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.
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:
Copies of these documents and all applicable acts are kept in the Compliance/Internal Audit Departments and are available for reference to all employees.
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.
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.
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:-
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.
Managers shall:
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.
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:
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.
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:
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.
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.
Code of Ethics
A commitment to high moral, ethical and legal standards are non-negotiable qualities that FNB Lesotho Limited expects from its employees.