 Although it is clearly established a clause seeking to exclude liability for fraud is invalid, yet liability may be excluded for employees’ dishonest conduct if their employer does not profit from it, and even for a party's own “wilful default.” A party can be exempted from liability not only for negligence but, as per "Afrox", also for gross negligence.In "Government of the Republic of South Africa v Fibrespinners & Weavers" the Appellate Division gave effect to a clause exempting an employer from liability for theft by its employee.More recently, "FNB v Rosenblum" confirmed this approach.