Carbon & Greenhouse Gas Reduction Plan

    Supplier name: FLEXZO AI LIMITED

    Publication date: Version 3, June 2026

    Commitment to achieving Net Zero

    FLEXZO AI LIMITED is committed to achieving Net Zero emissions by 2028. We acknowledge that this is an ambitious target and exceeds the typical expectations within the healthcare sector. Nevertheless, we are fully committed to achieving and delivering upon this goal.

    Our carbon reduction plan is fully aligned to:

    • UK Government policy
    • NHS ambitions
    • NHS SBS corporate sustainability strategy as necessary e.g. NHS SBS AI Healthcare Solutions framework
    • Other framework requirements e.g. Health Trust Europe (HTE)

    Baseline Emissions Footprint

    Baseline emissions are a record of the greenhouse gases that have been produced in the past and were produced prior to the introduction of any strategies to reduce emissions. Baseline emissions are the reference point against which emissions reduction can be measured.

    Baseline Year: 2024

    Additional details relating to the Baseline Emissions calculations.

    FLEXZO AI LIMITED is dedicated to acknowledging and addressing the key environmental concerns it influences. Our commitment lies in consistently enhancing our performance in these areas:

    • Encompassing energy reduction
    • Minimised fuel consumption
    • Minimal waste generation
    • Maximal waste recycling
    • Curbing pollution

    FLEXZO AI LIMITED Environmental and Energy Policy:

    • Tonnes of CO₂e per number of FTE (full time equivalent) employees best represents our business intensity ratio.
    • Carbon emissions have been calculated in accordance with UK Government Environment Reporting Guidelines including Streamlined Energy and Carbon Reporting (SECR) guidance.
    • Consumption data has been taken from purchase invoices and motor vehicle mileage data.
    • Activity has been converted into carbon emissions using the published UK Government GHG Conversion Factors for Company Reporting 2020.
    Baseline year emissions: 2024
    EMISSIONSTOTAL (tCO₂e)
    Scope 1571
    Scope 2357
    Scope 3 (Included Sources)We are currently working on finalising our employee commuting emissions. As a workforce technology solutions company, we believe these to be our only scope 3 emissions.
    Total Emissions928*

    * Scope 1 and 2 only

    Current Emissions Reporting

    Reporting Year: 2025
    EMISSIONSTOTAL (tCO₂e)
    Scope 147 — data centre emissions have been recategorised under scope 3
    Scope 238 — data centre emissions have been recategorised under scope 3
    Scope 3 (Included Sources)739

    A full review of scope 3 emissions has been completed. Our scope 3 activities fall into the following categories:

    • Category 6: Business travel including accommodation and subsistence
    • Category 1: Purchased goods and services including data centres
    • Category 7: Employee commuting
    Total Emissions824*

    * Totality of emissions which does not take into consideration the sustainable energy utilised by our data centre providers.

    Emissions reduction targets by 2028

    To continue our progress to achieving Net Zero, we have set the following carbon reduction targets for 2028:

    • Carbon emissions to be net zero by 2028

    When developing our Carbon Reduction Plan we look to implement and adhere to best practice policies that embed and support Carbon Reduction Planning in support of Green Initiatives such as NHS Net Zero, as detailed within the Procurement Policy Note 06/21.

    We have adopted UK Government and/or NHS targets for sustainable development where appropriate, in full consideration of the environmental impacts of any significant policy decisions and requirement to achieve Carbon Net Zero emissions in line with our target date. Sustainable development will include, but is not limited to:

    • Energy management
    • Water, to include system infrastructure maintenance and wastewater management
    • Waste prevention and management including waste hierarchy and segregation
    • Reducing single use plastics in accordance with the Environmental Protection (plastic straws, cotton buds and stirrers) (England) Regulations 2020, related Regulations in place across Devolved Administrations and all future waste related regulations
    • Minimising transport use

    We are not required to publicly report UK energy use and carbon emissions within the Supplier's Director Report as we do not meet any two of the following three thresholds in the preceding financial year, in alignment to the latest guidance published by the Department for Business, Energy and Industrial Strategy (BEIS):

    • A turnover of £36m or greater
    • A balance sheet of £18m or greater
    • A company size of 250 employees or greater

    Completed Carbon Reduction Initiatives

    As a relatively new organisation we are in the initial stages of our journey to Net Zero. We have developed a multi-year action plan which outlines the initiatives we will be undertaking to take us to our Net Zero position by no later than 2028. Our action plan contains a wide range of environmental management measures and projects including, but not limited to:

    • Training for our team
    • Engaging with our local community and supply chain
    • Biodiversity
    • Energy conservation measures
    • Green data storage

    Our net zero action plan is displayed, on an area-by-area basis, below. At a macro level we have also identified the internal and external resources needed to deliver these actions and deliver a net zero position by 2028.

    Internal Resources

    Sustainability Executive Sponsor

    This senior leadership figure will provide high-level governance and strategic oversight, ensuring that sustainability principles are integrated into the core functions of our software development processes. They will champion sustainability initiatives across departments, facilitate alignment with organisational goals and oversee compliance with carbon neutrality commitments.

    Executive Senior Management Team

    Responsible for setting the overarching strategic direction related to sustainability and carbon neutrality, this team will allocate necessary resources, including funding and personnel, to embed these commitments within our documented, ISO-9001 compliant project lifecycle and operational frameworks. Their role is critical in ensuring sustainability is prioritised throughout all phases of Flexzo software development, deployment and maintenance.

    Line Managers and Team Leaders

    These operational managers will actively mentor and support their teams, encouraging the integration of sustainability considerations in software development tasks. They will facilitate team-level tracking of progress on sustainability metrics, support cross-functional communication and ensure that best practices for environmentally conscious engineering are upheld throughout the project pipeline.

    Individual Team Members

    Each Flexzo employee, from system architects and technical contributors to sales teams, will be responsible for executing their designated actions aligned with the sustainability goals outlined in this plan. Their responsibilities will be role dependent — e.g. our system architects will focus on optimising code for energy efficiency, reducing computational waste and participating in relevant training to stay informed about sustainable AI practices, whereas our sales teams will look at incorporating sustainability-based language into communications and the proactive management of mileage.

    External Resources

    Social Value Delivery Experts

    Including specialists in carbon neutrality and sustainability, these external advisors will collaborate with our internal teams to develop, refine and implement effective sustainability programmes tailored for software development and implementation. Their expertise will assist in creating scalable and measurable social value initiatives.

    Sustainability Trainers

    External trainers will provide targeted education on sustainable practices, helping our developers and teams enhance their knowledge and skills to integrate sustainability considerations into their daily work effectively.

    VCSE (Voluntary, Community and Social Enterprise) Partners

    These organisations will support community engagement efforts, ensuring that Flexzo projects deliver meaningful social value and positively impact the communities involved.

    Data Storage and Cloud Service Providers

    Our external data storage and cloud infrastructure partners will be evaluated for their sustainability credentials, ensuring that our data handling practices align with our environmental commitments, such as renewable energy usage and energy-efficient data centres.

    Supply Chain Partners

    Suppliers and third-party vendors involved in hardware provisioning, software components and other critical services will be assessed and engaged to promote sustainable sourcing, reduce environmental impact and align with our overall carbon neutrality objectives.

    Engagement Strategy

    To ensure comprehensive stakeholder involvement, we will actively engage with a diverse range of key stakeholders, including organisational leadership, social value beneficiaries, external partners, community organisations and regulatory bodies, through a structured engagement plan. This will include regular meetings, surveys, collaborative workshops and feedback sessions. The goal is to maintain transparent communication, incorporate stakeholder insights into decision-making processes and foster a shared understanding of our social value and sustainability objectives.

    Through ongoing dialogue and collaboration, we aim to build a strong, aligned community committed to achieving meaningful and measurable outcomes in sustainability, social impact and responsible software development.

    Monitoring, Reporting & Assessing Performance Issues

    Monitoring and reporting on the delivery of our journey to a net zero position will ensure accountability and transparency in our initiatives. We have implemented a robust framework that includes regular assessments, stakeholder engagement and clear reporting mechanisms.

    Our metrics serve as benchmarks to evaluate our progress and impact effectively. Using a Red, Amber, Green (RAG) traffic light system we will conduct biannual reviews to track performance against these indicators, ensuring that we remain on target. Data collection will involve both quantitative and qualitative metrics, enabling us to gain a comprehensive understanding of our activities' effectiveness.

    To enhance our monitoring efforts, we will engage with relevant stakeholders. Regular stakeholder meetings will provide a platform for open dialogue, allowing us to gather insights, address concerns and adjust our strategies. We will compile regular reports summarising our findings, performance against KPIs and any net zero challenges encountered. These reports will be shared with relevant stakeholders to maintain transparency and foster trust in our commitment to delivering Social Value.

    In the event of performance issues, we will promptly initiate a corrective action plan. This plan will involve identifying the root causes of the issue, proposing actionable solutions and assigning responsibilities for implementation. We will communicate transparently with all stakeholders throughout this process, providing updates on progress and adjustments made.

    ISO-14001: Environmental Management System

    Objective: Maintain ISO-14001 certification on a year-on-year basis.

    Actions

    1. Maintain the Flexzo Effective Environmental Management System (EMS) — regularly review and update the EMS to ensure ongoing compliance with ISO 14001 standards and evolving environmental requirements; document processes, procedures and controls clearly to facilitate consistency and continual improvement.
    2. Conduct bi-annual internal audits — schedule comprehensive internal audits at planned intervals to evaluate EMS effectiveness and identify areas for improvement; implement corrective actions promptly to address non-conformities and prevent recurrence.
    3. Management review and leadership engagement — convene biannual management review meetings to assess system performance, review environmental objectives and set new targets.
    4. Monitor and measure environmental performance — track key environmental indicators (e.g. waste reduction, energy use, water consumption) regularly to demonstrate ongoing compliance and progress.
    5. Maintain document control and record keeping — ensure all EMS documentation, including policies, procedures, audit reports and corrective actions, is current, accessible and properly stored.
    6. Engage external certification bodies and prepare for audit cycles — schedule and coordinate surveillance audits well in advance, ensuring readiness through pre-audit assessments.
    7. Foster a culture of continual improvement — promote proactive identification of environmental risks, innovation and best practices to enhance overall EMS performance.

    Performance Management

    Deliver by DateTargetPerformanceRAG
    31.03.2026RecertificationRe-certified-
    31.03.2027Recertification--
    31.03.2028Recertification--
    31.03.2029Recertification--
    31.03.2030Recertification--
    31.03.2031Recertification--
    31.03.2032Recertification--
    31.03.2033Recertification--

    ISO-14001 Training

    Action: Deliver ISO-14001 awareness training, 4 hours per employee, to raise awareness about the importance of the Flexzo EMS and encourage the adoption of sustainable practices at work and in personal lives.

    Objective: 100% of Flexzo employees to undertake 4 hours of ISO-14001 training annually.

    Performance Management

    Deliver by DateTargetPerformanceRAG
    31.03.2026100%100%-
    31.03.2027100%--
    31.03.2028100%--
    31.03.2029100%--
    31.03.2030100%--
    31.03.2031100%--
    31.03.2032100%--
    31.03.2033100%--

    Carbon Literacy Training

    Action: Deliver carbon literacy training, 4 hours per employee, to raise awareness about the importance of carbon reduction and encourage the adoption of sustainable practices at work and in personal lives.

    Objective: 100% of Flexzo employees to undertake 4 hours of carbon literacy training every year.

    Performance Management

    Deliver by DateTargetPerformanceRAG
    31.03.2026100%100%-
    31.03.2027100%--
    31.03.2028100%--
    31.03.2029100%--
    31.03.2030100%--
    31.03.2031100%--
    31.03.2032100%--
    31.03.2033100%--

    Water

    This includes system infrastructure, maintenance and wastewater management.

    ActionDeliver by DatePerformanceRAG
    Undertake a water usage audit across FLEXZO AI to identify areas of high usage31.03.2026Audit complete across all sites-
    Implement a routine inspection schedule for plumbing fixtures, pipes and appliances to identify leaks and inefficiencies31.03.2027--
    Hold discussions with the Landlord regarding the investment and installation of water-efficient fixtures e.g. low-flow toilets, faucets31.03.2028--
    Install smart irrigation systems and rainwater harvesting systems to reduce reliance on potable water31.03.2029--
    Deliver Water Efficient Practices training to all staff31.03.2030--
    Launch an internal campaign (posters, newsletters) highlighting the importance of conserving water and showcasing water-saving tips31.03.2031--
    Deliver Water Efficient Practices training to all staff31.03.2032--
    Install smart meters to continuously monitor water usage and identify unusual patterns that indicate leaks or inefficiencies31.03.2033--

    Waste Prevention

    Waste prevention and management including waste hierarchy and segregation.

    Action: Deliver a 'Waste Wise' workshop lasting no more than 90 minutes annually to the Flexzo team, with an alternating focus on workplace and the home.

    Deliver by DateTargetPerformanceRAG
    31.03.2026100%100% (Workplace focus)-
    31.03.2027100%--
    31.03.2028100%--
    31.03.2029100%--
    31.03.2030100%--
    31.03.2031100%--
    31.03.2032100%--
    31.03.2033100%--

    Action: Reduce single-use plastics in accordance with the Environmental Protection (plastic straws, cotton buds and stirrers) (England) Regulations 2020, related Regulations in place across Devolved Administrations and all future waste-related regulations.

    Deliver by DateTargetPerformanceRAG
    31.03.2026100%50%-
    31.03.2027100%75%-
    31.03.2028100%100%-
    31.03.2029100%100%-
    31.03.2030100%100%-
    31.03.2031100%100%-
    31.03.2032100%100%-
    31.03.2033100%100%-

    Travel

    Objective: Promoting sustainable transportation options for employees, including electric vehicle (EV) incentives and public transit subsidies, aimed at decreasing Scope 3 emissions in:

    • Category 6: Business travel including accommodation and subsistence
    • Category 7: Employee commuting
    ActionDeliver by DatePerformanceRAG
    Undertake audit of journeys by car and public transport (travel mode comparison and shift, time-cost trade-offs, active travel integration, emissions baselines, reduction targets)31.03.2026Complete-
    Review the Flexzo approach to Scope 3 emissions (Cat 6 & 7). Revise policies: expense restructuring, policy refinements on public transport vs cars/taxis, hybrid work alignment, flexible working hours, sustainable transport training, prioritising virtual meetings, preferring train travel and sustainable accommodation31.03.2026Complete-
    Support alternative commuting methods — bike-to-work schemes, secure bike parking, carpooling / ride-sharing platforms31.03.2027--
    Implement EV incentive programmes — financial incentives, on-site EV charging, partnerships with EV manufacturers31.03.2028--
    Decrease Scope 3 emissions in Categories 6 & 731.03.2029--
    Decrease Scope 3 emissions in Categories 6 & 731.03.2030--
    Decrease Scope 3 emissions in Categories 6 & 731.03.2031--
    Decrease Scope 3 emissions in Categories 6 & 731.03.2032--
    Decrease Scope 3 emissions in Categories 6 & 731.03.2033--

    Energy Efficiency

    Objective: Invest in energy efficiency improvements across all facilities, targeting a year-on-year reduction in energy consumption.

    Action: Invest in energy efficiency improvements in our owned/leased facilities which house our staff.

    Deliver by DateTargetPerformanceRAG
    31.03.2026100%100% (Workplace focus)-
    31.03.2027100%--
    31.03.2028100%--
    31.03.2029100%--
    31.03.2030100%--
    31.03.2031100%--
    31.03.2032100%--
    31.03.2033100%--

    Objective: Invest in sustainable sourcing and procurement practices to ensure energy efficiency improvements across all suppliers in our supply chain, targeting a year-on-year reduction in non-sustainable energy consumption.

    Sustainable Data Centre Utilisation

    Our business model involves utilising external data centres to support our cloud infrastructure. We partner with two leading cloud service providers — Amazon Web Services (AWS) and Google Cloud UK — both of which have established themselves as pioneers in embedding sustainability practices into their operations, ensuring our data storage commitments align with environmentally responsible standards and our 2028 net zero ambition.

    AWS Sustainability Efforts

    AWS has committed to achieving net-zero carbon by 2040 and is actively investing in renewable energy. As of 2023, AWS reports 85% renewable energy across its global infrastructure. Key initiatives include:

    • Energy efficiency: advanced cooling technologies and energy-efficient hardware.
    • Renewable energy projects: investment in solar and wind farms worldwide.
    • Circular economy practices: recycling and refurbishing of hardware.

    Google Cloud UK Sustainability Initiatives

    Google Cloud has operated on a fully carbon-neutral basis since 2007 and is committed to 24/7 carbon-free energy by 2030. Key aspects include:

    • Energy optimisation: machine-learning-driven energy and cooling optimisation.
    • Investments in renewable energy projects worldwide.
    • Innovative cooling solutions including evaporative and AI-driven cooling systems.

    Optimising Data Management for Sustainability

    • Cloud-based storage solutions with AWS and Google Cloud reduce reliance on physical hardware and on-premises data centres.
    • Data lifecycle management via regular audits and archiving of non-essential data to maintain a lean data repository.
    • Virtualisation and resource optimisation, running multiple applications on fewer servers.

    Future Strategies for Green Data Storage

    • Adopting advanced technologies such as storage-class memory and tape storage for long-term archival.
    • Utilising AI for predictive data management to minimise energy waste.
    • Ongoing engagement with providers on sustainability innovations.

    Supplier & Supply Chain Emissions (Category 1)

    Action: Reduce supplier and supply chain emissions (Category 1).

    ActionDeliver by DatePerformanceRAG
    Develop and implement sustainable procurement policies — prioritise suppliers with verified environmental credentials, require compliance with recognised sustainability standards (e.g. ISO 14001, Green Seal), incorporate sustainability criteria into RFPs31.03.2026In progress-
    Prioritise energy-efficient data centres and cloud providers — partner exclusively with providers committed to renewable energy and carbon neutrality31.03.2026AWS, Google Cloud UK — see notes above-
    Incorporate supplier sustainability criteria into contracts — require emissions reduction, disclosure of environmental metrics and adoption of energy-efficient practices31.03.2026In progress-
    Optimise hardware and software procurement — select components with high energy efficiency ratings and minimal environmental impact31.03.2026AWS, Google Cloud UK — see notes above-
    Promote circular economy principles — engage suppliers committed to product lifecycle management, including refurbishing, recycling and minimising electronic waste31.03.2026AWS, Google Cloud UK — see notes above-
    Implement responsible supply chain management — map and assess the emissions profile of the Flexzo supply chain and work with non-data-centre suppliers to identify emissions hotspots and develop reduction strategies31.03.2027Successfully mapped the emissions profile across key segments of the supply chain. Engaging with non-data-centre suppliers to identify hotspots and establish initial action plans including process improvements and waste reduction measures.-
    Support and invest in renewable energy solutions — partner with suppliers using renewable energy and advocate for their transition to renewable power31.03.2026AWS, Google Cloud UK — see notes above-
    Leverage innovation and technology for emissions reduction — invest in R&D for energy-efficient algorithms and AI models; collaborate with suppliers on innovative solutions31.03.2028Y1: Significant progress integrating innovative solutions to reduce environmental impact. Initiated targeted research into energy-efficient algorithms and AI models, resulting in a measurable decrease in computational energy consumption during key processing tasks.-

    Objective: Maintain active engagement with and oversight of AWS and Google Cloud to stay informed about their latest sustainability innovations and incorporate those solutions into our operations.

    Deliver by DateTargetPerformanceRAG
    31.03.2026Relationship maintainedRelationship maintained-
    31.03.2027Relationship maintained--
    31.03.2028Relationship maintained--
    31.03.2029Relationship maintained--
    31.03.2030Relationship maintained--
    31.03.2031Relationship maintained--
    31.03.2032Relationship maintained--
    31.03.2033Relationship maintained--

    Carbon Offsetting

    Objective: Progressively minimise the Flexzo carbon footprint by maximising the deployment of renewable energy sources internally and throughout the supply chain, accurately accounting for residual emissions and investing in high-quality offsets — thereby advancing towards and delivering net zero by end of 2028 and demonstrating leadership in sustainable practices.

    ActionDeliver by DatePerformanceRAG
    Quantify and track residual emissions — regularly measure and document the company's net carbon footprint; use credible emission calculation standards to identify residual emissions requiring offsettingAnnual delivery by 31.03 for each year of operationMaintained rigorous measurement and documentation processes, incorporating continued increase in renewable energy utilisation.-
    Prioritise renewable energy — engage and contract with external providers focused on renewable energy; partner with third-party renewable energy projectsAnnual delivery by 31.03 for each year of operationContinue to actively strengthen our commitment to renewable energy year-on-year through reputable external providers delivering verified renewable power.-
    Implement high-quality offset strategies for residual emissions — purchase verified carbon offsets (e.g. Gold Standard, VCS), focused on reforestation, forest conservation or methane captureAnnual delivery by 31.03 for each year of operationContinue to utilise Gold Standard offset strategies to support our journey to net zero.-
    Regularly review and adjust offsetting portfolio — update commitments annually as renewable energy use grows; transition from high-volume offsets to cleaner energy sources over timeAnnual delivery by 31.03 for each year of operationApproach reviewed and updated as our use of sustainable energy sources increases.-
    Incorporate carbon offsetting into corporate sustainability goals — set clear annual targets and report transparently on progress and impact31.03.2026Corporate Sustainability Goals set through 2033.-
    Ensure credibility and transparency — use verified offsets, keep detailed records, submit annual sustainability report to the BoardAnnual delivery by 31.03 for each year of operation--

    Biodiversity

    Objective: Explore and implement ways to enhance the natural environment such as habitat creation and increasing biodiversity such as pollinators.

    ActionDeliver by DatePerformanceRAG
    Biodiversity awareness training rolled out to all staff membersAnnualTraining delivered for Year One-
    Undertake site assessment and planning for Flexzo owned and leased estates and facilities31.03.2027--
    Implement agreed habitat changes e.g. bug hotels, pollinator gardens31.03.2028--
    Evaluation of habitat changes31.03.2029--
    Scaling of successful schemes31.03.2030--

    Reconnecting with the Environment

    Objective: Explore, design and implement activities to reconnect our team and the wider community with the environment and increase awareness of ways to protect and enhance it.

    ActionDeliver by DatePerformanceRAG
    Deliver awareness training to our internal teamsAnnualTraining delivered for Year One-
    Work with a VCSE organisation to engage with our local community via workshops, interviews and focus groups to identify reconnection opportunities31.03.2027--
    Deliver agreed opportunities within our local community e.g. sustainability challenges and competitions31.03.2028--
    Explore volunteering opportunities for the contract workforce to encourage direct positive impact on the environment31.03.2029--
    Scaling of successful schemes31.03.2030--

    Net Zero

    Objective: Achieve NET ZERO by no later than end of 2028.

    Deliver by DateTargetPerformanceRAG
    31.12.202675% progress towards net zero75.6%-
    31.12.202790% progress towards net zero--
    31.12.2028Net Zero achieved--
    31.12.2029Net Zero maintained--
    31.12.2030Net Zero maintained--
    31.12.2031Net Zero maintained--
    31.12.2032Net Zero maintained--
    31.12.2033Net Zero maintained--

    Declaration and Sign Off

    This Carbon Reduction Plan has been completed in accordance with PPN 06/21 and associated guidance and reporting standard for Carbon Reduction Plans.

    Emissions have been reported and recorded in accordance with the published reporting standard for Carbon Reduction Plans and the GHG Reporting Protocol corporate standard and uses the appropriate Government emission conversion factors for greenhouse gas company reporting.

    Scope 1 and Scope 2 emissions have been reported in accordance with SECR requirements, and the required subset of Scope 3 emissions have been reported in accordance with the published reporting standard for Carbon Reduction Plans and the Corporate Value Chain (Scope 3) Standard.

    This Carbon Reduction Plan has been reviewed and signed off by the board of directors (or equivalent management body).

    Signed on behalf of the Supplier:

    FLEXZO AI LIMITED

    JACK HENDERSON

    Date: June 2026 (Version 3)