Anti-Bribery and Anti-Corruption Policy
Anti-Bribery and Anti-Corruption Policy
1. Introduction
Versah UK Ltd is committed to conducting its business honestly, fairly, transparently and with integrity.
We operate a zero-tolerance approach to bribery and corruption and are committed to complying with all applicable anti-bribery and anti-corruption legislation, including the Bribery Act 2010.
This policy sets out the standards we expect from our directors, employees and anyone acting on behalf of Versah UK Ltd.
2. Scope
This policy applies to all directors, employees, contractors, consultants, representatives and other persons acting for or on behalf of Versah UK Ltd.
We also expect our suppliers, distributors and other business partners to conduct their activities in accordance with applicable anti-bribery and anti-corruption laws.
3. Bribery and Corruption
Bribery includes offering, promising, giving, requesting, agreeing to receive or accepting a financial or other advantage in order to encourage or reward improper conduct.
A bribe does not have to involve cash. It may include gifts, hospitality, discounts, commissions, services, travel, accommodation or other benefits.
Versah UK Ltd does not permit bribery or corruption in any form.
4. Prohibited Conduct
No person acting for or on behalf of Versah UK Ltd may:
- offer, promise or give a bribe or improper advantage;
- request, agree to receive or accept a bribe;
- make or authorise facilitation payments;
- offer inappropriate gifts, hospitality or benefits in order to influence a business decision;
- use a third party to carry out an activity that would otherwise be prohibited; or
- conceal or misrepresent payments or transactions.
5. Healthcare Professionals
As a supplier and distributor within the dental sector, Versah UK Ltd may work with dentists, clinicians, educators, speakers and other healthcare professionals.
All such relationships must be conducted ethically and transparently.
Payments, sponsorship, educational support, hospitality, discounts or other benefits must never be offered for the purpose of improperly influencing a healthcare professional's clinical judgement, recommendation or purchasing decision.
Where healthcare professionals provide legitimate services to Versah UK Ltd, such as training, education, consultancy or speaking services, there must be a genuine business need and any payment should be reasonable and proportionate to the services provided.
6. Gifts and Hospitality
Reasonable and proportionate business hospitality may be acceptable where it has a legitimate business purpose.
Gifts or hospitality must not:
- be intended to improperly influence a business or clinical decision;
- create an obligation or expectation of favourable treatment;
- be excessive or inappropriate; or
- breach applicable laws, professional standards or company procedures.
Cash gifts or cash equivalents are not permitted.
7. Training and Educational Activities
Versah UK Ltd may organise or support legitimate professional education, product training and clinical education.
Any hospitality associated with these activities must be reasonable, proportionate and secondary to the educational or business purpose of the event.
Educational support must not be provided as an inducement to purchase, recommend or use Versah UK Ltd products.
8. Discounts and Commercial Arrangements
Legitimate discounts, promotional offers and commercial arrangements are permitted where they have a genuine business purpose and are appropriately documented.
They must not be used to provide a concealed personal benefit or improper incentive to an individual responsible for purchasing, recommending or using products.
9. Facilitation Payments and Kickbacks
Versah UK Ltd does not permit facilitation payments, kickbacks, secret commissions or other unofficial payments intended to secure or speed up a routine action or obtain an improper business advantage.
10. Charitable and Political Contributions
Any charitable donation made by Versah UK Ltd must be legitimate and transparent and must not be used to obtain an improper business advantage.
Political contributions may only be made on behalf of Versah UK Ltd where lawful and specifically authorised by the Board of Directors.
11. Third Parties
Versah UK Ltd may carry out proportionate checks on agents, consultants, suppliers, distributors and other business partners where appropriate.
We will not knowingly enter into or continue a business relationship where we believe bribery, corruption or other improper conduct is taking place.
12. Financial Records
Versah UK Ltd will maintain appropriate financial records and internal controls.
Payments, expenses and other transactions must be recorded accurately and must not be concealed, deliberately misclassified or supported by false or misleading information.
13. Conflicts of Interest
Directors and employees should avoid situations where personal interests could improperly influence, or appear to influence, decisions made on behalf of Versah UK Ltd.
Any actual or potential conflict of interest should be disclosed appropriately.
14. Reporting Concerns
Anyone who becomes aware of, or reasonably suspects, bribery, corruption or a breach of this policy should report the matter promptly to a director of Versah UK Ltd.
Concerns raised honestly and in good faith will be taken seriously and handled appropriately.
Versah UK Ltd will not tolerate retaliation against anyone who refuses to participate in bribery or corruption or who raises a genuine concern in good faith.
15. Breaches of this Policy
A breach of this policy may result in disciplinary action, termination of a contractual or business relationship and, where appropriate, referral to the relevant authorities.
Bribery and corruption may also constitute criminal offences.
16. Responsibility and Review
The Board of Directors of Versah UK Ltd has overall responsibility for this policy.
The policy will be reviewed periodically and updated where necessary to reflect changes in legislation, regulation or the company's activities.
Last reviewed: September 2026