The case of Phillips v Fieldstone Africa (Pty) Ltd and another 2004(3) SA 465 (SCA) dealt with the fiduciary duties of employees in relation to their employer, in cases where the employee is not a director of the employer.  It is important to note that the fiduciary duties of directors also extends to non-directors.

The main issue in this case concerned the liability of an employee to account to his employer for secret profits made by the employee out of an opportunity arising in the course of his employment.