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FirstRand Ethics Office

FirstRand's Board of Directors has overseen the appointment of a Group ethics officer and formalised ethics management reporting lines within the Regulatory risk management function. The board has also overseen the creation of the FirstRand Ethics committee which will provide board oversight of the ethics performance of the FirstRand Group.

The Group Ethics office reports into Regulatory risk management and is responsible for institutionalising the commitment of top management to run an ethical and responsible business. The practical implementation of this commitment is facilitated through the application of FirstRand's Ethics management framework.

FirstRand Group Code of Ethics

The FirstRand Group Code of ethics is the cornerstone of FirstRand's Ethics management framework.

Upon joining the Group all directors are obliged to sign a pledge to adhere to the FirstRand Group Code of ethics. The Code addresses duties of care and skill, good faith, honesty and integrity, whistle blowing, processes for dealing with conflicts of interest and the need to always act in the best interests of the Group.

FirstRand does not make donations to political parties. Guidance on political donations and solicitation of gifts is provided in the Code. No issues of improprietary or unethical behaviour on the part of any of the directors were drawn to the attention of the committee during the year.

FirstRand Group whistle-blowing programme

Renewed emphasis has been placed on the issue of whistle blowing. FirstRand encourages safe and effective whistle blowing in the Code of ethics and strives to create an enabling environment for whistle blowing through oversight of the Directors' affairs and governance committee. The committee has ensured that procedures exist for bringing unethical business practices by directors or employees to the attention of the board.

Progress is being made in implementing a Group whistle-blowing programme designed to enhance the detection of unethical conduct. An external service provider has been appointed to serve as an independent whistle-blowing hotline service provider to the Group. These consultants will manage the FirstRand Ethics Line in partnership with the Group Ethics office which will be able to accept confidential or anonymous reports of unethical conduct, including theft, fraud and corruption. A secure email address has also been registered for this purpose.

Anonymous whistle blowing contact lines are:

Email: report@firstrandethicsoffice.co.za

Internet: www.firstrandethicsoffice.com