These Terms and Conditions (TCs) govern your participation in the Tsetela Money Market investment offered by Stanlib Lesotho (Pty) Ltd (hereinafter Stanlib) through an Agency Arrangement licensed by the Central Bank with VCL Financial Services (Pty) Ltd (hereinafter VCL FS and/ M-Pesa). Therefore, by investing, you agree to be bound by these terms and conditions.

1. INTRODUCTION
   1. These Terms and Conditions (TCs) govern your participation in the Tsetela Money Market investment offered by Stanlib Lesotho (Pty) Ltd (hereinafter Stanlib) through an Agency Arrangement licensed by the Central Bank with VCL Financial Services (Pty) Ltd (hereinafter VCL FS and/ M-Pesa). Therefore, by investing, you agree to be bound by these terms and conditions.


2. DEFINITIONS
   1. “Customer” – shall mean a registered VCL FS customer who is on Tier 1 and above (as defined in the VCL FS terms and conditions) who will have subscribed to the Tsetela Product as defined herein. Customer also refers to customers who invest as a Group within their Group Savings account.
   2. “Deactivate” – shall mean the confirmation from investor indicating that they no longer wish to use the product. The customer will do so by withdrawing all their money and allowing the account to go dormant.
   3. “Interest” – shall mean Money earned on top of invested capital by a customer from investing their funds in the Tsetela Product.
   4. “Investment” – shall mean the process of depositing funds in a revenue generating account operated by Stanlib with the aim of accumulating interest.
   5. “Mokhatlo Savings Account” – A group account used by customers to collectively save funds.
   6. “Open Account” – shall mean the confirmation from the investor indicating that they are accepting the Terms and Conditions of the product.
   7. “Tsetela Account” – Stanlib Account available to Individual users or Groups registered under Mokhatlo Savings Account into which you shall deposit funds intended for investment.
   8. “Tsetela Product” – shall for all intents and purpose mean the investment product wholly operated by Stanlib under the Agency Arrangement of VCL FS.
   9. “Primary Wallet” – Shall mean the customer’s main account on the M-Pesa platform.
   10. “M-PESA” – shall mean the money transfer and payments service provided by VCL FS.
   11. “M-PESA Account” – shall mean a record maintained by VCL FS regarding the amount of electronic money from time to time held by an M-PESA Customer that is represented by an equivalent amount of cash held in trust in accordance with the M-PESA Customer Terms and Conditions.
   12. “Withholding Tax” – Shall mean Withholding tax paid to Lesotho Revenue Authority on the customer’s behalf.


3. ACCEPTANCE OF THE TERMS AND CONDITIONS
   1. Before registering for the Product, you should carefully read and understand these T&Cs as they govern the access, use and operation of the Product. These TCs are available on www.Vodacom.co.ls and www.stanlib.com/lesotho. Where you are unable to read and understand these T&Cs from an electronic device, you are requested to collect a printed version from a nearby Stanlib offices and/or Vodacom Shop.
   2. You will be deemed to have read, understood and accepted these T&Cs.
   3. Upon clicking on the “Accept” option on the Terms and Conditions, you confirm that you have read, understood and agreed to abide by these T&Cs.
   4. By registering for the Service, you agree to comply with and be bound by T&Cs as amended and revised from time to time and you affirm that these T&Cs are without prejudice to any rights you may have in law or otherwise regarding your registration, access and use of the Service.
   5. We may from time to time vary or amend these T&Cs and your continued access and use of the Service constitutes your acceptance to be bound by the terms of any such amendment or variation.


4. REGISTERING FOR THE SERVICE
   1. By opting into the Service, you confirm that you are eighteen (18) years old or above and a registered, and active VCL FS Customer.
   2. Stanlib reserves the right to verify the authenticity and status of your M-PESA Account and access to your transactions and may decline your application if not satisfied that you meet these minimum requirements.
   3. You hereby agree and authorize Stanlib to access your personal information in respect of the provision of Tsetela product.
   4. You also hereby agree and authorize us to use information relating to your use of the M-PESA service.
   5. You hereby agree and authorize us to verify and obtain your Personal Information contained in the Home Affairs Registry and/or VCL FS from the Government of Lesotho and you further agree and consent to the disclosure and provision of such Personal Information by the Government of Lesotho to us.


5. CHANNELS
   1. Tsetela Money Market Fund will be accessed via USSD and other channels which may be introduced from time to time.


6. INVESTMENTS
   1. Minimum investable amount allowed is (LSL)50.00 for all customers.
   2. Minimum investable amount allowed is (LSL)300.00 for Mokhatlo Savings Account groups.
   3. To Invest, a customer must make a deposit/transfer from their primary wallet into the Tsetela Account.
   4. To invest, Mokhatlo Savings Account Group Leaders will do a deposit/transfer from the Mokhatlo Savings Account to the Tsetela Account; this transaction will only be successful when two (2) designated group members (Approvers) approve.


7. FEES, CHARGES, TAX AND INTEREST
   1. Funds invested in the Tsetela Account will earn interest on daily basis and paid into the Tsetela account at the end of the month.
   2. Withholding tax is paid on the customer’s behalf by Stanlib. The interest received by customers has already been deducted of tax.
   3. The customer and Groups shall have visibility over their invested funds on the USSD channel in real time.
   4. Interest earned and any principal amount shall be paid out within 72 hours after a request has been initiated by a customer or group.
   5. There shall be no direct fees incurred on funds transfer to and from the Primary Wallet, or when customers invest (deposit into) or withdraw from their Tsetela accounts.
   6. Following withdrawal from the Tsetela account, funds within the customer’s primary wallet will be subject to the applicable M-Pesa fees.
   7. All third-party costs associated with administration of the Fund apply and will be charged to the Fund. This will include but not limited to the fund management fees and all administration fees. A set 3% will be applied to the interest earned directly from Stanlib, before it is transferred to customers. Customers shall earn the applicable Stanlib Money Market interest less the 3% rate attributable to VCLFS.
   8. Collective Investment Schemes are managed with the utmost diligence, however, participatory interest may fluctuate from time to time. Stanlib as the Asset Manager does not provide any guarantee either with respect to capital or return on Tsetela.


8. WITHDRAWALS ON THE INVESTED AMOUNT
   1. Customer shall have access to their invested funds over the following periods;
   2. Withdrawn Funds will be accessible within 72 hours. To withdraw, individual customers will do a transfer from their Tsetela Account to their M-Pesa Primary Wallet.
   3. To withdraw, Mokhatlo Group Savings Accounts through designated members (Group Leader and two Approvers) will do a transfer from the Tsetela Account to their M-Pesa Mokhatlo Group Savings Account.


9. INTELLECTUAL PROPERTY RIGHTS
   1. You acknowledge that the intellectual property rights in the Service (and any amendments, upgrades or enhancements thereto from time to time) and all associated documentation that we provide to you are vested in the Providers of the Product.


10. INDEMNITY
    1. In consideration of us complying with your instructions or Requests in relation to the Tsetela Product, you undertake to indemnify us and hold us harmless against any loss, charge, damage, expense, fee or claim which we may suffer or incur or sustain thereby and you absolve us from all liability for loss or damage which you may sustain from us acting on your instructions or requests or in accordance with these T&Cs.


11. CUSTOMER COMPLAINTS
    1. Complaints and queries shall first be made to VCL FS by calling 114 or customer care WhatsApp line +266 58 114 114 for all queries. Alternatively, you can visit any Vodacom shop.
    2. All complaints will be directed to VCLFS strictly as the Corporate Agent licensed on behalf of Stanlib.


12. DEATH
    1. On your death any investments held in your Account shall be dealt with in accordance with the applicable law.


13. TERMINATION
    1. We may at any time, upon notice to you, terminate our business relationship with you and/or suspend or discontinue your Tsetela Account and or access to the product:
       1. If you use the product for unauthorized purposes or where we detect any abuse/misuse, breach of content, fraud or attempted fraud relating to your use of the products;
       2. if your M-PESA Account is terminated for whatever reason;
       3. if VCL FS or Stanlib suspects or believes that you are in breach of these Terms and Conditions;
    2. Termination shall not affect any accrued rights and liabilities of either party and, in particular, shall not affect your obligations to meet any liabilities incurred prior to such termination or interest earned from your Investment.


14. LOSS OF DEVICE AND UNAUTHORIZED TRANSACTIONS
    1. If you lose your Device or for any reason you believe that your PIN may have been accessed by an unauthorized person, you shall immediately notify the contact details indicated herein above.
    2. Until and unless we receive your notice of loss or unauthorized access of the PIN as above, we shall remain authorized to accept any Requests on your Account using your PIN.
    3. You shall give us and any person acting on our behalf all necessary assistance in any investigations, all information as to the circumstances of the loss or possible misuse of your Device or PIN in order to enable us to take all reasonable steps to mitigate the loss incurred or likely to be incurred as a result of the preceding.
    4. You consent to the disclosure by us to third parties of such information as is relevant in connection with such loss of your Device or possible misuse or unauthorized access of your PIN.


15. PRIVACY STATEMENT
    1. VCLFS and all its associated companies are committed to respecting the privacy of Your personal data. To demonstrate our commitment, VCLFS has put in place a customer privacy statement (available on the website and nearest Vodacom Shop) in order to communicate its intent to provide effective processes for the appropriate handling of such personal information and to comply with applicable legislation that governs the authentication, protection and disclosure of personal information.
    2. We VCLFS may disclose Your Personal information if required to do so by law or in the good-faith where such disclosure is reasonably necessary to:
       1. Comply with regulatory requirements
       2. Legal Processes
       3. Enforce the terms of this Agreement
       4. Respond to claims that the Client’s use of the M-PESA Service violates the rights of third parties or
       5. Protect the rights, property or personal safety of VCLFS, our subscribers or the public.


16. PERMISSIONS
    1. I would like to receive marketing related communications via:
       1. SMS
       2. Mohala
       3. Email
       4. Social Media


17. KEY FACT STATEMENT
    1. What is Tsetela?
       1. Tsetela is an investment product offered to M-Pesa customers and Mokhatlo Group Savings customers. It allows customers to invest money directly from their M-Pesa wallet and earn daily interest on their savings.
    2. Key Features
       1. Earn daily interest on invested funds.
       2. Interest is paid monthly into the Tsetela account.
       3. Real-time balance visibility through USSD.
       4. No charges for investing or withdrawing.
       5. Easy deposits from M-Pesa wallets.
       6. Flexible withdrawals.
       7. Secure approval process for Mokhatlo Group Savings Accounts.
       8. Withdrawal turnaround time: 72 hours.
    3. Who Can Invest?
       1. Individual M-Pesa Customers (Minimum M50)
       2. Mokhatlo Group Savings Accounts (Minimum M300)
    4. How to Register - Individual
       1. Dial *200#
       2. Select Savings Account
       3. Select Tsetela Account
       4. Select Individual Account
       5. Select Open Account
       6. Accept Terms & Conditions
       7. Enter investment amount
       8. Confirm amount
       9. Enter PIN
       10. Receive confirmation message
    5. How to Register - Group
       1. Dial *200#
       2. Select Savings Account
       3. Select Tsetela Account
       4. Select Tsetela Group Account
       5. Select Open Account
       6. Accept Terms & Conditions
       7. Select Group Code
       8. Enter investment amount
       9. Confirm amount
       10. Enter PIN
       11. Receive confirmation message
    6. Interest & Withdrawals
       1. Interest is calculated daily and paid monthly. Withdrawals are processed within 72 hours. Minimum withdrawal amount is M1. A customer may not initiate another withdrawal while a previous request is pending.
    7. Fees
       1. There are no fees for investing or withdrawing. Third-party fund administration costs of up to 3% apply to earned interest only and do not affect customer capital.