Statement of Compliance Bribery Act

Prepared on 12 August 2021

The Bribery Act 2010 came into force on 1 July 2011 with the aim of tackling bribery and corruption in both the private and public sectors. Bribery is defined as the giving or receiving of a financial or other advantage in exchange for improperly performing a relevant function or activity.

Sirona care & health CIC (Sirona) is committed to applying the highest standards of ethical conduct, following good NHS business practice and having robust controls in place to prevent bribery. However, as an organisation we cannot afford to be complacent and under no circumstances is the giving, offering, receiving or soliciting of a bribe acceptable and Sirona will not tolerate this in any form.

Sirona’s zero tolerance approach to bribery and corruption is set out in further detail within the Counter Fraud Policy, and across a range of other policies and procedural documentation. This applies to all staff and non-executives, together with contractors and agents working or acting on behalf of Sirona.

All are responsible for gaining an understanding of the requirements, the standard of conduct expected of them and ensuring that they comply at all times with all of our policies and procedures. This includes those in relation to procurement, hospitality and the acceptance of gifts.

Bribery and corruption under the act are punishable for individuals as a criminal offence by up to 10 years imprisonment and if Sirona is found to have taken part in the corruption the company could face an unlimited fine and face incalculable damage to our reputation. We therefore take our legal responsibilities very seriously.

Any act of bribery undertaken by a member or an employee of Sirona will result in disciplinary action and will be treated with a similar level of importance by the Board. If you are in any doubt as to whether any conduct could amount to bribery, or if you have any concerns or suspicions regarding bribery being committed, please contact Clive Bassett, Finance Director, email clive.bassett@nhs.net

The success of our anti-bribery measures depends on all employees, and those acting for the organisation, playing their part in helping to detect and eradicate bribery. Therefore, all employees and others acting for, or on the behalf of Sirona are encouraged to report any suspected bribery in accordance with the procedures set out in the Sirona’s Counter Fraud Policy which can be found on the staff intranet and is available on request to the Finance Director or the Corporate Governance team, email sirona.corporategovernance@nhs.net