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.

The Fraud Act 2006 provides for a general offence of fraud with three ways of committing it, which are by false representation, by failing to disclose information and by abuse of position.

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, deter and detect bribery, corruption and fraud. 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 fraud, 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.

When the statutory guidance on the Economic Crime and Corporate Transparency Act 2023 (ECCT Act) is issued by the Home Office, this statement will be updated to ensure alignment with the Act.

Any act of fraud, bribery and/of corruption 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 fraud, bribery or corruption, or if you have any concerns or suspicions regarding fraud, bribery or corruption being committed, please contact Interim Chief Finance Officer Laks Khangura by email using laks.khangura2@nhs.net. 

The success of our anti-fraud, bribery and corruption measures depends on all employees, and those acting for the organisation, playing their part in helping to detect and eradicate bribery. Sirona has dedicated Counter Fraud staff working for the organisation, however, all employees and others acting for, or on the behalf of Sirona are encouraged to report any suspected fraud, bribery or corruption 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