Minnigard Medical | Carbon Reduction Plan
Carbon Reduction Plan
Minnigard Medical Ltd — Net Zero by 2040
Prepared in accordance with Procurement Policy Note 006 (formerly PPN 06/21), the Technical Standard for the Completion of Carbon Reduction Plans, and NHS England's Carbon Reduction Plan and Net Zero Commitment requirements for the procurement of NHS goods, services and works (Version 3, December 2025).
| Document control | |
|---|---|
| Publishing entity | Minnigard Medical Ltd |
| Registered office | Cypress House, Mid Cornwall Business Centre, Par Moor Road, St Austell, Cornwall, PL25 3RT |
| Version | 1.0 |
| Publication date | 7 September 2026 |
| Baseline year | 1 January 2025 – 31 December 2025 |
| Current reporting year | 1 January 2025 – 31 December 2025 |
| Net Zero target date | 2040 |
| Emissions boundary | Global — Scope 1, Scope 2 and Scope 3 |
| Approved by | Cooper Hill, Director and Co-Founder |
| Date of approval | 7 September 2026 |
| Review frequency | Annually, or sooner following material change |
| Next scheduled review | On or before 7 September 2027 |
1. Commitment to achieving Net Zero
Minnigard Medical Ltd is committed to achieving Net Zero greenhouse gas emissions by 2040.
This commitment is made ten years ahead of the minimum date of 2050 required under PPN 006 and the NHS Carbon Reduction Plan requirements, and five years ahead of the 2045 date NHS England encourages suppliers to adopt. It is aligned with the NHS Carbon Footprint Plus target date of 2045 and with the NHS's own directly controlled net zero date of 2040.
The commitment covers:
- All Scope 1 emissions — direct emissions from sources owned or controlled by Minnigard Medical Ltd.
- All Scope 2 emissions — indirect emissions from purchased electricity, reported on both a location-based and a market-based basis.
- The five Scope 3 categories mandated by PPN 006 — upstream transportation and distribution, waste generated in operations, business travel, employee commuting, and downstream transportation and distribution.
- All other material Scope 3 categories, phased in on the schedule set out in Section 9 and Annex B, including purchased goods and services, which we expect to represent the substantial majority of our total footprint.
The geographic boundary of this commitment is global. This exceeds the minimum UK boundary set out in PPN 006 and reflects the fact that a significant proportion of Minnigard's supply chain — including manufacturing and inbound freight — sits outside the United Kingdom.
We further commit to:
- Measuring and publicly reporting our organisational carbon footprint every year.
- Achieving an absolute reduction of at least 90% against our baseline year before any use of carbon removals, consistent with the definition of net zero in the Science Based Targets initiative Corporate Net-Zero Standard.
- Neutralising only the residual emissions that cannot be eliminated, and doing so through certified, permanent carbon removals rather than avoidance-based offsets.
- Making no claim of carbon neutrality on the basis of purchased offsets in place of genuine emissions reduction.
- Publishing this plan on our website in a clearly signposted location, and updating it at least annually.
Statement of commitment
Minnigard Medical Ltd is committed to achieving Net Zero emissions by 2040 for its global Scope 1, Scope 2 and Scope 3 emissions. This commitment was approved on 7 September 2026 by Cooper Hill, Director and Co-Founder, acting as the approving authority for the company.
2. About Minnigard Medical Ltd
Minnigard Medical Ltd is a United Kingdom medical consumables business operating from Cypress House, Mid Cornwall Business Centre, in St Austell, Cornwall. The company designs, assembles and supplies bespoke sterile procedure packs, drape kits and associated clinical consumables to dental practices, private and public hospitals, and humanitarian surgical programmes.
The business is organised into three divisions: a Dental Division, a Private and Public Hospitals Division, and a Personal Care Division. Minnigard Medical Ltd is a small and medium-sized enterprise as defined by the Companies Act 2006, and this plan has been prepared proportionately to the size, resource and data maturity of the company, in line with the provisions for SMEs set out in PPN 006 and in NHS England's supplier guidance.
2.1 Why carbon reduction matters to our business
Single-use clinical consumables are a recognised contributor to the carbon footprint of healthcare delivery. NHS England has identified that the majority of the NHS Carbon Footprint Plus arises in the supply chain, and medical devices and consumables form a substantial share of that total. As a supplier of these products, Minnigard sits directly within the emissions that our customers are working to reduce.
We regard this as a commercial opportunity as much as an obligation. The core of our product proposition — kits built to the exact specification of an individual clinician or procedure — is inherently a waste reduction proposition. Generic procedure packs routinely contain items that are opened, unused and discarded. Every item removed from a kit that would not have been used is an avoided emission in our customer's footprint, an avoided cost on their purchase order, and an avoided item in their clinical waste stream. Section 10 sets out how we intend to quantify and evidence this.
2.2 Principal emissions sources
Minnigard's operational footprint is small. The company occupies a single leased unit, operates no owned vehicle fleet, and does not carry out manufacturing processes that combust fuel on site. Our footprint is therefore concentrated in the value chain: in the products we purchase, in inbound freight from suppliers in the United Kingdom and continental Europe, and in outbound courier movements to customers.
This shape has a direct consequence for our strategy. Reductions achieved solely within our own four walls will not deliver net zero by 2040. The material work is in procurement, product design, packaging and logistics, and this plan is weighted accordingly.
3. Reporting boundary and methodology
3.1 Organisational boundary
This plan is prepared for Minnigard Medical Ltd, the trading entity that contracts with NHS and other customers. Emissions are consolidated using the operational control approach as defined in the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard. All operations over which Minnigard Medical Ltd has the full authority to introduce and implement its operating policies are included within the boundary at 100%.
Where Minnigard Medical Ltd forms part of a wider group structure, this plan is specific to the bidding entity, Minnigard Medical Ltd, and is published on that entity's website, satisfying the requirement in NHS England's guidance that a Carbon Reduction Plan be specific to the bidding entity.
3.2 Operational boundary
| Scope | Definition | Application to Minnigard |
|---|---|---|
| Scope 1 | Direct emissions from sources owned or controlled by the company | Fuel used in any company-controlled vehicles; on-site combustion of natural gas or other fuels; fugitive emissions from refrigerant loss in air conditioning and cold storage |
| Scope 2 | Indirect emissions from purchased electricity, heat, steam and cooling | Purchased electricity consumed at Cypress House, reported on both a location-based and a market-based basis |
| Scope 3 | All other indirect emissions in the value chain | Reported for the five PPN 006 mandated categories in this edition, with purchased goods and services and other material categories phased in as set out in Annex B |
3.3 Methodology and standards applied
- Greenhouse Gas Protocol Corporate Accounting and Reporting Standard (revised edition) for Scope 1 and Scope 2.
- Greenhouse Gas Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard for Scope 3.
- Greenhouse Gas Protocol Scope 2 Guidance, applying dual reporting on a location-based and market-based basis.
- UK Government greenhouse gas reporting conversion factors, published annually by the Department for Energy Security and Net Zero, applied at the rate published for the reporting year in question.
- PPN 006 Technical Standard for the Completion of Carbon Reduction Plans.
- NHS England Carbon Reduction Plan and Net Zero Commitment requirements for the procurement of NHS goods, services and works, Version 3, 10 December 2025.
All emissions are reported in tonnes of carbon dioxide equivalent (tCO2e) and cover the seven greenhouse gases of the Kyoto Protocol: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulphur hexafluoride (SF6) and nitrogen trifluoride (NF3). Where a source is known not to generate a given gas, the contribution of that gas is recorded as nil rather than omitted.
3.4 Baseline year and rationale
Minnigard Medical Ltd has selected the calendar year 1 January 2025 to 31 December 2025 as its baseline year. This is the first year for which the company holds a complete and internally consistent set of energy, freight, waste and travel records, and it is representative of normal trading activity. It is the earliest year for which a defensible footprint can be constructed and it therefore provides the fairest available benchmark against which future performance will be measured.
Because 2025 is both the first year of measurement and the most recent complete reporting period, the baseline year and the current reporting year are the same in this first edition of the plan. From the 2026 edition onward, the reporting year will advance annually while the 2025 baseline remains fixed.
3.5 Baseline recalculation policy
The 2025 baseline will be recalculated where any of the following occur and the cumulative effect exceeds 5% of total baseline emissions: a structural change to the company such as an acquisition, disposal or transfer of operations; a change in calculation methodology, emission factor source or data granularity that materially improves accuracy; the discovery of a material error; or the addition of a Scope 3 category not previously reported. Any recalculation will be disclosed transparently in the relevant annual update, with both the original and restated figures shown.
4. Baseline emissions footprint
Baseline year: 1 January 2025 – 31 December 2025
| Emissions source | Category | tCO2e |
|---|---|---|
| SCOPE 1 — Direct emissions | ||
| Company-controlled vehicles (fuel) | Mobile combustion | [ ] |
| On-site fuel combustion (natural gas / LPG / oil) | Stationary combustion | [ ] |
| Refrigerant losses (air conditioning, cold storage) | Fugitive emissions | [ ] |
| Scope 1 total | [ ] | |
| SCOPE 2 — Indirect energy emissions | ||
| Purchased electricity — location-based | Grid average factor | [ ] |
| Purchased electricity — market-based | Supplier-specific factor | [ ] |
| Scope 2 total (location-based, used for target setting) | [ ] | |
| SCOPE 3 — Value chain emissions (PPN 006 mandated categories) | ||
| Upstream transportation and distribution | Category 4 | [ ] |
| Waste generated in operations | Category 5 | [ ] |
| Business travel | Category 6 | [ ] |
| Employee commuting | Category 7 | [ ] |
| Downstream transportation and distribution | Category 9 | [ ] |
| Scope 3 total (mandated categories) | [ ] | |
| TOTAL BASELINE EMISSIONS (Scope 1 + 2 + 3) | [ ] |
Scope 2 is reported on both a location-based and a market-based basis in accordance with the Greenhouse Gas Protocol Scope 2 Guidance. The location-based figure is used for target setting and progress measurement, so that reductions reflect genuine changes in consumption rather than changes in tariff alone.
5. Current emissions reporting
Reporting year: 1 January 2025 – 31 December 2025
As set out in Section 3.4, 2025 is both the baseline year and the current reporting year in this first edition of the plan. The figures below are therefore identical to those in Section 4. From the next annual update, this section will report the most recently completed calendar year and will show the percentage change against the fixed 2025 baseline.
| Emissions source | Category | tCO2e |
|---|---|---|
| SCOPE 1 — Direct emissions | ||
| Company-controlled vehicles (fuel) | Mobile combustion | [ ] |
| On-site fuel combustion (natural gas / LPG / oil) | Stationary combustion | [ ] |
| Refrigerant losses (air conditioning, cold storage) | Fugitive emissions | [ ] |
| Scope 1 total | [ ] | |
| SCOPE 2 — Indirect energy emissions | ||
| Purchased electricity — location-based | Grid average factor | [ ] |
| Purchased electricity — market-based | Supplier-specific factor | [ ] |
| Scope 2 total (location-based, used for target setting) | [ ] | |
| SCOPE 3 — Value chain emissions (PPN 006 mandated categories) | ||
| Upstream transportation and distribution | Category 4 | [ ] |
| Waste generated in operations | Category 5 | [ ] |
| Business travel | Category 6 | [ ] |
| Employee commuting | Category 7 | [ ] |
| Downstream transportation and distribution | Category 9 | [ ] |
| Scope 3 total (mandated categories) | [ ] | |
| TOTAL REPORTING YEAR EMISSIONS (Scope 1 + 2 + 3) | [ ] |
5.1 Emissions intensity
Absolute emissions are the primary measure against which our targets are set. Alongside these, we track two intensity metrics so that performance can be understood in the context of a growing business, and so that customers can see the carbon efficiency of what they buy from us.
| Intensity metric | Baseline 2025 | Purpose |
|---|---|---|
| tCO2e per £100,000 of revenue | [ ] | Comparability with other suppliers and with published sector benchmarks |
| kgCO2e per kit despatched | [ ] | Product-level carbon efficiency; foundation for the product footprinting required by NHS England from April 2028 |
| tCO2e per full-time equivalent employee | [ ] | Operational efficiency of the non-product footprint |
6. Emissions reduction targets
Minnigard Medical Ltd has set absolute reduction targets against the 2025 baseline. Targets are expressed as percentage reductions so that they remain valid and auditable as the underlying absolute figures are confirmed, and so that they cannot be met simply by a contraction in trading activity — performance against the intensity metrics in Section 5.1 is reported alongside to demonstrate this.
6.1 Headline trajectory
| Milestone | Scope 1 and 2 (absolute) | Scope 3 (absolute) | Total footprint |
|---|---|---|---|
| 2028 | 40% reduction | 15% reduction | Complete Scope 3 screening across all 15 categories; purchased goods and services measured and reported |
| 2030 | 70% reduction | 35% reduction | Aligned with the NHS requirement that suppliers demonstrate measurable progress to remain eligible for contracts from January 2030 |
| 2035 | 90% reduction | 65% reduction | Scope 1 and 2 substantively eliminated; supply chain decarbonisation the dominant remaining workstream |
| 2040 | 100% reduction | At least 90% reduction | Net Zero achieved; residual emissions of no more than 10% of the 2025 baseline neutralised through certified permanent removals |
6.2 Interpretation of the targets
- Targets are absolute, not intensity-based. A reduction achieved only by falling output does not count as progress and will be reported as such.
- The 2040 Net Zero position requires an absolute reduction of at least 90% across all scopes before any removals are applied. Removals are used only for the genuinely irreducible remainder.
- Scope 3 targets are set at a lower percentage than Scope 1 and 2 in the earlier years because the levers are indirect and depend on supplier action. They are not set lower because they matter less — Scope 3 is expected to be the overwhelming majority of our footprint, and the majority of the absolute tonnes we remove will come from it.
- Progress against every target is reported annually in the updated edition of this plan, whether or not the trajectory has been met. Where we fall behind, the shortfall and the corrective action are stated explicitly.
6.3 Science-based target alignment
The trajectory above is designed to be consistent with a 1.5°C-aligned pathway. Minnigard Medical Ltd intends to submit its targets for validation through the Science Based Targets initiative SME route, which offers a streamlined validation pathway proportionate to a company of our size. The target submission is scheduled within Phase 1 of the delivery roadmap set out in Section 13. Until validation is obtained, no claim of science-based validation is made in this plan or in any customer-facing material.
7. Scope 1 reduction plan — direct emissions
Scope 1 covers emissions from sources Minnigard owns or controls directly. As a business without manufacturing plant or an owned vehicle fleet, this is our smallest scope in absolute terms. It is also the scope over which we have complete control, and we therefore hold ourselves to the most demanding trajectory here: full elimination by 2040 and a 70% reduction by 2030.
7.1 Sources and measures
| Source | Reduction measures | Timeline |
|---|---|---|
| Vehicle fuel | No internal combustion vehicles will be purchased or leased by the company from 2026 onward. Any vehicle brought into company control will be battery electric. Where deliveries or site visits are unavoidable, we prioritise consolidated journeys and, where practical, rail. | Policy effective 2026; full electrification of any company-controlled vehicles by 2030 |
| On-site fuel combustion | Cypress House is a leased unit. We will establish with the landlord whether any space or water heating is fossil-fuelled and, where it is, request a transition to electric heating at the next plant replacement cycle or lease renegotiation. Where we cannot compel the change, we will report the emissions transparently and reflect the constraint in our site selection criteria. | Landlord engagement opened 2026; heating decarbonisation agreed or site reviewed by 2032 |
| Refrigerant losses | Maintain an asset register of all refrigerant-containing equipment recording gas type, charge and global warming potential. Move to low-GWP refrigerants at end of asset life. Annual leak inspection by a qualified F-gas engineer. | Register complete 2026; low-GWP transition on natural replacement cycle to 2035 |
| Grey fleet (employee-owned vehicles used for business) | Recorded under Scope 3 Category 6 but managed under the same policy: mileage reimbursement structured to favour low-emission vehicles, and a video-first default for meetings that do not require physical attendance. | Policy effective 2026 |
7.2 Scope 1 milestones
- 2026 — Complete refrigerant asset register; adopt zero-emission vehicle procurement policy; establish landlord position on building heating.
- 2028 — 40% reduction against baseline delivered.
- 2030 — 70% reduction against baseline delivered.
- 2035 — 90% reduction; any remaining Scope 1 emissions limited to residual refrigerant loss.
- 2040 — Scope 1 emissions eliminated.
8. Scope 2 reduction plan — purchased energy
Scope 2 comprises the electricity purchased and consumed at Cypress House. The decarbonisation route here is well established and largely a matter of execution: reduce consumption first, then ensure the remaining consumption is supplied from certified renewable generation.
8.1 Measures
| Measure | Detail and expected effect |
|---|---|
| Certified renewable electricity supply | Transition the Cypress House supply to a tariff backed by Renewable Energy Guarantees of Origin certificates at the next contract renewal, with contractual verification retained as evidence. This reduces market-based Scope 2 emissions to zero while location-based emissions continue to be reported so that genuine consumption reduction remains visible. |
| Half-hourly consumption monitoring | Install or activate half-hourly metering and review consumption monthly. Out-of-hours baseload is the single most common source of avoidable electricity use in small warehouse and light-assembly units and is typically the first meaningful saving identified. |
| LED lighting and controls | Complete replacement of any remaining fluorescent or halogen fittings with LED, with occupancy sensing in storage areas and daylight dimming where the unit permits. Typical reduction of 50–70% of lighting load. |
| Heating, cooling and building fabric | Set and lock heating and cooling setpoints with a dead band; time-control to occupied hours only; address obvious fabric losses such as loading door sealing and roller-shutter draughts in conjunction with the landlord. |
| Equipment and IT | Enforce power management on all IT equipment; specify high-efficiency models at replacement; eliminate unnecessary always-on equipment identified through the half-hourly data. |
| On-site generation | Assess the technical and commercial feasibility of rooftop solar photovoltaic generation at Cypress House with the landlord, including a landlord-funded or shared-benefit model where direct investment by a tenant is not appropriate. |
8.2 Scope 2 milestones
- 2026 — Half-hourly monitoring live; LED conversion complete; renewable tariff secured at next renewal.
- 2028 — Location-based consumption reduced by 20% against baseline through efficiency alone; market-based Scope 2 at zero.
- 2030 — Location-based consumption reduced by 30%; on-site generation feasibility concluded and, if viable, installed.
- 2040 — Scope 2 emissions eliminated on both a market-based and, through grid decarbonisation and on-site generation, a substantially reduced location-based basis.
9. Scope 3 reduction plan — value chain emissions
Scope 3 is where Minnigard's footprint genuinely sits, and it is where the substance of this plan lies. The five categories mandated by PPN 006 are reported in Sections 4 and 5. Purchased goods and services is not among the mandated five, but for a business that buys, assembles and resells physical clinical consumables it is almost certainly the largest single category in our inventory. We therefore report it voluntarily on the schedule below rather than defer it to the point at which the NHS makes it mandatory in April 2027.
9.1 Category 4 — Upstream transportation and distribution
Covers inbound freight from suppliers to Cypress House, including consignments from suppliers in continental Europe and from UK-based manufacturers, together with associated customs and handling movements.
- Consolidate inbound orders into fewer, fuller shipments. Fragmented ordering is the largest single controllable driver of inbound freight emissions and also the largest controllable driver of inbound freight cost — the commercial and carbon incentives are aligned.
- Eliminate air freight from routine replenishment. Air freight is reserved for genuine clinical urgency, is authorised individually rather than by default, and is recorded separately so the volume is visible.
- Shift European inbound movements to road and short-sea groupage in place of express air services wherever lead time permits.
- Request primary emissions data from our freight forwarders and couriers in place of spend-based or distance-based estimates, so that our Category 4 figure moves from modelled to measured.
- Weight supplier proximity in sourcing decisions, and actively seek UK or near-European alternatives for products currently sourced at longer distance where quality, regulatory status and price permit.
9.2 Category 5 — Waste generated in operations
Covers waste arising at Cypress House, principally transit packaging from inbound goods, secondary packaging materials, damaged or expired stock, and general office and operational waste.
- Segregate all waste streams at source and record weights by stream rather than by bin lift, so the figure is measured rather than estimated.
- Eliminate landfill disposal entirely by 2028, with residual non-recyclable waste directed to energy recovery only where no recycling route exists.
- Reuse inbound transit packaging for outbound consignments wherever it meets our presentation and protection standards.
- Reduce expired and damaged stock write-off through improved demand forecasting and stock rotation. Write-off is a triple loss — the embodied carbon of the product, the disposal emissions, and the full purchase cost.
- Engage suppliers to reduce inbound packaging at source, including requesting removal of unnecessary secondary packaging and a move to recyclable or reusable transit materials.
9.3 Category 6 — Business travel
Covers travel undertaken by employees for business purposes in vehicles not owned or controlled by the company, including grey fleet mileage, rail, air and accommodation. Practice visits to build bespoke kits with clinicians, and attendance at trade exhibitions, are the principal sources.
- Adopt a video-first default. Physical attendance is justified by the value of being present — kit-building consultations with clinicians and exhibition attendance qualify; routine account reviews generally do not.
- Plan practice visits geographically so that multiple appointments are served by a single journey, rather than treating each visit as a separate trip.
- Rail before air for all domestic and near-European travel where journey time is competitive; a specific and recorded justification is required for any domestic flight.
- Capture full mileage and travel records through the expenses process so the figure is derived from actual claims rather than estimated.
- Structure mileage reimbursement to favour low-emission vehicles.
9.4 Category 7 — Employee commuting
Covers the transport of employees between home and Cypress House. Our Cornwall location means commuting is predominantly by private car with limited public transport alternatives, and we recognise that the practical levers here are fewer than in an urban location.
- Conduct an annual commuting survey capturing distance, mode and frequency for every employee, so this category is calculated from actual data rather than assumed.
- Maintain hybrid and flexible working arrangements where the role permits, which is the single largest available reduction in this category.
- Offer a salary sacrifice scheme for ultra-low-emission vehicles and support the Cycle to Work scheme.
- Install electric vehicle charging at Cypress House, subject to landlord agreement, to remove a practical barrier to employee vehicle transition.
- Facilitate lift-sharing among employees travelling from the same direction.
9.5 Category 9 — Downstream transportation and distribution
Covers outbound distribution of finished kits and consumables to customers, primarily through third-party courier networks. Our proposition includes rapid delivery, and we are explicit that fast delivery and low-carbon delivery are in tension. Our approach is to remove the emissions from the movement rather than to remove the service from the customer.
- Offer customers a consolidated delivery option at the point of order, with a clearly stated carbon and cost benefit for scheduled rather than expedited despatch.
- Right-size outbound packaging. Void space in a parcel is paid for twice — once in material and once in the volumetric weight that determines the carriage charge and the emissions.
- Select courier partners on the strength of their own published decarbonisation commitments and the availability of primary emissions reporting, and make this an explicit criterion at each carriage tender.
- Prioritise carriers offering electric vehicle final-mile delivery in the geographies where it is available.
- Reduce split consignments through improved stock availability, so that a single order is fulfilled in a single movement.
9.6 Category 1 — Purchased goods and services (reported voluntarily)
Not mandated by PPN 006, but expected to constitute the majority of Minnigard's total footprint. We will report this category from the 2026 reporting year, ahead of the April 2027 NHS milestone requiring all suppliers to publish a Carbon Reduction Plan covering their global Scope 1, 2 and 3 emissions.
- Complete a spend-based screening of all purchased goods and services for the 2026 reporting year to establish scale and identify the highest-impact categories.
- Transition the highest-impact categories from spend-based estimation to supplier-specific primary data. Spend-based factors are adequate for prioritisation and inadequate for demonstrating reduction, because they fall only when spend falls.
- Engage the suppliers representing the top 80% of purchased-goods emissions to obtain product-level carbon data and their own reduction commitments, as set out in Section 12.
- Embed material and product carbon intensity as a scored criterion in sourcing decisions alongside price, quality and regulatory status.
- Work with manufacturing partners on material substitution, reduced material intensity and lower-carbon sterilisation routes, as set out in Section 10.
10. Product and packaging decarbonisation
From April 2028, NHS England will introduce requirements for the carbon footprinting of individual products supplied to the NHS. For a supplier of clinical consumables this is the most consequential milestone on the roadmap, and it is one we intend to reach early rather than meet under pressure.
10.1 Bespoke kit configuration as a decarbonisation lever
The clearest carbon advantage available to Minnigard is structural to what we already sell. A generic procedure pack is specified for the widest plausible range of cases, which means that for any individual case it contains items that are opened, contaminated and discarded unused. Each of those items carries its full manufacturing, packaging, freight and disposal footprint and delivers no clinical benefit.
Kits configured to the specification of an individual clinician or procedure remove that waste at source. We intend to quantify this rather than assert it. The work is as follows:
- Establish a reference specification for the comparable generic pack in each of our principal procedure categories.
- Record, with participating customers, the items in that reference pack that are routinely unused.
- Calculate the avoided emissions and the avoided clinical waste weight per procedure, using published life cycle assessment data for the relevant materials where product-specific data is unavailable.
- Publish the methodology openly so that customers can interrogate it, and present the result as a customer-side avoided emission rather than a reduction in Minnigard's own footprint, which it is not.
10.2 Packaging
| Workstream | Commitment |
|---|---|
| Material reduction | Reduce packaging weight per kit despatched by 30% against the 2025 baseline by 2030, without compromise to sterile barrier integrity or compliance with EN 868 and ISO 11607. |
| Material substitution | Eliminate non-recyclable plastic from all secondary and transit packaging by 2030. Sterile barrier materials are governed by regulatory and clinical requirements and will be changed only where an alternative is demonstrably equivalent and validated. |
| Recycled content | Achieve a minimum of 70% recycled content in all outer cartons and transit packaging by 2028. |
| Void reduction | Introduce carton size optimisation across the outbound range by 2027, reducing both material use and volumetric freight. |
| Customer-side recyclability | Provide clear disposal and recycling guidance on packaging so that customers can divert our materials from clinical waste streams where clinically appropriate. Non-contaminated outer packaging directed away from clinical waste is a significant emissions and cost saving for the customer. |
10.3 Product carbon footprinting
- 2026 — Establish a bill-of-materials database for the core kit range capturing material type and mass by component.
- 2027 — Complete cradle-to-gate carbon footprints for the highest-volume kit lines using ISO 14067 or PAS 2050 methodology, supported by supplier data where available and recognised secondary data where not.
- 2028 — Product-level carbon data available for the range supplied to NHS customers, meeting the April 2028 NHS milestone at its commencement.
- 2030 — Carbon footprint data published for the full product range and refreshed annually.
10.4 Sterilisation and manufacturing
Sterilisation is a material contributor to the footprint of a sterile procedure pack, and the choice of route — ethylene oxide, gamma irradiation, electron beam or steam — carries materially different emissions and different regulatory validation burdens. We will work with our manufacturing partners to establish the emissions profile of the sterilisation route used for each product line, and to evaluate lower-carbon alternatives where the validation and regulatory position under EN 13795, EN ISO 11135 and EN ISO 11137 permits. No change to a validated sterilisation process will be made on carbon grounds where it would compromise sterility assurance.
11. Carbon reduction projects completed to date
The following measures are already in effect within Minnigard Medical Ltd and will be applied during the performance of any contract awarded. In line with the PPN 006 Technical Standard, they are stated as measures in effect rather than as quantified savings, since the 2025 baseline is the first year of measurement and no verified year-on-year saving can yet be evidenced. Quantified savings will be reported from the 2026 edition of this plan onward.
| Measure in effect | Description |
|---|---|
| Bespoke kit configuration | Kits are built to individual clinician and procedure specification, with a minimum order quantity of five, removing the unused-item waste inherent in generic procedure packs and avoiding the over-ordering that large minimum quantities force on smaller customers. |
| Low minimum order quantities | A minimum order quantity of five kits allows customers to order to actual demand rather than to a supplier-imposed volume, reducing customer-side expiry and write-off. |
| Order consolidation and rapid turnaround | A one-hour quotation turnaround and a one to three working day delivery cycle allow customers to hold lower buffer stock, reducing expiry-driven waste in the customer's own inventory. |
| Delivery model assessment | A self-delivery fleet option was formally evaluated and not adopted, in part because consolidated third-party courier networks achieve materially higher load factors and lower emissions per consignment than a dedicated low-utilisation van operation. |
| Digital-first commercial operation | Customer acquisition, quotation and account management are conducted digitally by default, with physical visits reserved for kit-building consultations where in-person attendance adds genuine value. |
| Paperless finance and administration | Accounts payable, receivable, VAT filing and record keeping are operated through cloud accounting, eliminating routine document printing and physical archiving. |
| Reuse of inbound transit packaging | Serviceable inbound cartons and protective materials are reused for outbound consignments where they meet presentation and protection standards. |
| Regional supplier engagement | European supplier relationships are managed to consolidate consignments rather than order piecemeal, reducing the number of individual freight movements. |
12. Supply chain engagement
Because the majority of our footprint sits upstream, our supplier relationships are the principal instrument of this plan. Engagement is structured in three tiers according to the emissions significance of the supplier rather than the size of the spend alone.
| Tier | Scope | Requirement |
|---|---|---|
| Tier 1 — Strategic | Suppliers representing the top 80% of purchased-goods emissions, including principal manufacturing partners and freight providers | Annual carbon data exchange; product-level footprint data; a published net zero commitment; joint reduction projects; carbon performance reviewed at each contract renewal |
| Tier 2 — Significant | Remaining suppliers above a defined materiality threshold | Annual questionnaire covering emissions reporting status, net zero commitment and packaging; encouragement and signposting toward measurement support including the UK Business Climate Hub |
| Tier 3 — General | All other suppliers | Carbon and environmental criteria included in supplier onboarding; our expectations communicated at the point of engagement |
12.1 Procurement policy commitments
- From 2027, all new supplier tenders above a defined threshold will carry a minimum 10% weighting on carbon and environmental performance, mirroring the weighting the NHS applies to us.
- From 2028, new Tier 1 suppliers will be required to hold a published carbon reduction plan or equivalent as a condition of onboarding.
- Existing Tier 1 suppliers unable or unwilling to provide emissions data will be reviewed at contract renewal, with substitution considered where a comparable alternative exists that meets our regulatory and quality requirements.
- We will not pass our own reduction obligation to suppliers without support. Smaller suppliers will be signposted to free measurement tools and given reasonable time to build capability, recognising that we are ourselves an SME working through the same transition.
13. Delivery roadmap to 2040
13.1 Phase 1 — Foundation and measurement (2026 to 2028)
The objective of this phase is to move from estimated to measured data, to close the gap between our reported footprint and our actual footprint, and to deliver the readily available operational reductions.
| Year | Actions |
|---|---|
| 2026 | Complete and verify the 2025 baseline. Appoint carbon accounting software or an external adviser. Establish half-hourly electricity monitoring and complete LED conversion. Build the refrigerant asset register. Adopt the zero-emission vehicle and video-first travel policies. Run the first employee commuting survey. Begin the bill-of-materials database. Open Tier 1 supplier engagement. |
| 2027 | Report the 2026 footprint including purchased goods and services. Secure a certified renewable electricity tariff. Complete carbon footprints for the highest-volume kit lines. Introduce the 10% carbon weighting in supplier tenders. Publish a Carbon Reduction Plan covering global Scope 1, 2 and 3 emissions to meet the April 2027 NHS milestone. Submit targets to the Science Based Targets initiative SME route. Complete the Evergreen sustainable supplier assessment. |
| 2028 | Deliver a 40% reduction in Scope 1 and 2 and a 15% reduction in Scope 3 against baseline. Eliminate landfill waste disposal. Achieve 70% recycled content in transit packaging. Publish product-level carbon data for the NHS range, meeting the April 2028 milestone at commencement. Complete Scope 3 screening across all 15 categories. |
13.2 Phase 2 — Acceleration and supply chain transition (2029 to 2034)
The objective of this phase is to shift the burden of reduction from our own operations, which by this point are substantially decarbonised, onto the supply chain, where the majority of the remaining tonnes sit.
| Period | Actions |
|---|---|
| 2029–2030 | Deliver a 70% reduction in Scope 1 and 2 and a 35% reduction in Scope 3 against baseline. Complete any on-site renewable generation. Achieve full electrification of any company-controlled vehicles. Demonstrate documented progress through published progress reports and continued Evergreen reporting to satisfy the January 2030 NHS qualification requirement. Publish carbon footprint data for the full product range. |
| 2031–2034 | Convert the top 80% of purchased-goods emissions to supplier-specific primary data. Complete material substitution across the packaging range. Establish low-carbon sterilisation routes where validated. Extend product carbon footprinting to every line. Begin evaluating certified carbon removal suppliers for the post-2040 residual. |
13.3 Phase 3 — Residual elimination and Net Zero (2035 to 2040)
| Period | Actions |
|---|---|
| 2035–2038 | Deliver a 90% reduction in Scope 1 and 2 and a 65% reduction in Scope 3. Eliminate Scope 1 other than residual refrigerant loss. Complete the transition of the supply chain to suppliers with validated net zero pathways. Contract certified permanent carbon removals for the projected residual. |
| 2039–2040 | Deliver at least a 90% absolute reduction across all scopes against the 2025 baseline. Neutralise the residual through certified permanent removals. Obtain independent third-party verification of the Net Zero position. Publish the verified Net Zero declaration. |
14. Governance and accountability
Minnigard Medical Ltd does not operate a formal board. In accordance with the PPN 006 requirement that a Carbon Reduction Plan be board approved, or director approved where no board is in place, this plan is approved by Cooper Hill, Director and Co-Founder, who holds accountability for its delivery.
| Role | Responsibility |
|---|---|
| Director and Co-Founder | Accountable owner of this plan. Approves the plan and each annual update, approves capital and revenue expenditure required to deliver it, and reports progress to shareholders. |
| Operations | Collects and maintains energy, waste, freight and travel data. Implements site-level efficiency measures. Maintains the refrigerant asset register. |
| Procurement and supply chain | Delivers supplier engagement under Section 12. Applies carbon criteria in sourcing. Obtains supplier emissions data. |
| Commercial | Applies the travel policy. Communicates carbon performance to customers accurately and without overstatement. Manages Evergreen and Carbon Reduction Plan submissions to NHS customers. |
| All employees | Follow operational, travel and waste procedures. Raise reduction opportunities. |
14.1 Review cycle
- Quarterly — internal review of data collection completeness and progress against the current year's actions.
- Annually — full recalculation of the footprint, assessment of performance against the trajectory in Section 6, revision of this plan, director approval, and publication on the Minnigard Medical website.
- On material change — recalculation and republication where a structural or methodological change meets the threshold in Section 3.5.
- Reporting period currency — we note that under NHS England guidance a reporting period more than 12 months prior to the commencement of a procurement will fail assessment unless an acceptable explanation is provided. Our annual update cycle is scheduled to keep the published plan within that window at all times.
14.2 Assurance
The 2025 baseline and subsequent annual footprints are prepared internally. We will seek independent third-party verification of the footprint from the 2028 reporting year, and independent verification is a stated precondition of any Net Zero declaration made in 2040. No claim of external verification is made in this edition of the plan.
15. Residual emissions and carbon removals
Reaching Net Zero in 2040 requires an absolute reduction of at least 90% against the 2025 baseline across all scopes. Only the remaining balance — emissions that are genuinely unabatable given the technology and regulatory constraints of sterile medical device supply — will be neutralised.
Our principles for the use of removals are as follows:
- Removals neutralise a residual; they never substitute for a reduction that is technically and commercially achievable.
- Only permanent carbon removal will be used, not avoidance-based offsetting. Avoided deforestation and comparable avoidance credits do not remove carbon from the atmosphere and will not be purchased for this purpose.
- Removals will be independently certified against a recognised standard with durable storage, monitoring and clear additionality.
- Removals will be purchased only in the final phase, from 2038, once the achievable reduction has been delivered. Purchasing removals earlier would obscure whether real reduction is occurring.
- The volume, provider, standard and cost of any removals purchased will be disclosed in the relevant annual update.
- No claim of carbon neutrality will be made in the intervening years on the basis of purchased credits.
16. Alignment with the NHS Net Zero Supplier Roadmap
Minnigard Medical Ltd supplies, and intends to continue supplying, NHS organisations. The table below sets out each milestone of the NHS Net Zero Supplier Roadmap and our position against it.
| Milestone | NHS requirement | Minnigard position |
|---|---|---|
| April 2022 | A minimum 10% weighting on net zero and social value in all NHS procurements | Understood and factored into our bid preparation. We mirror this weighting in our own supplier tenders from 2027. |
| April 2023 | Carbon Reduction Plan required for contracts above £5m per annum, covering UK Scope 1 and 2 and a subset of Scope 3 | Met and exceeded. This plan covers global Scope 1, 2 and 3 rather than UK Scope 1 and 2 only. |
| April 2024 | Carbon Reduction Plan requirements extended proportionately to all new NHS procurements | Met. This plan is published, director approved, and updated annually. |
| April 2027 | All suppliers to publicly report targets and emissions and publish a Carbon Reduction Plan covering global Scope 1, 2 and 3 emissions aligned to the NHS net zero target | On track. Global boundary and all-scope commitment already adopted in this edition. Purchased goods and services reported from the 2026 reporting year, ahead of the milestone. |
| April 2028 | Carbon footprinting of individual products supplied to the NHS | On track. Bill-of-materials database from 2026, product footprints for high-volume lines in 2027, NHS range complete for the milestone in 2028. |
| January 2030 | Suppliers to qualify for NHS contracts only where they can demonstrate progress through published progress reports and continued reporting via the Evergreen sustainable supplier assessment | On track. Annual published progress reporting from 2026; Evergreen assessment completed in 2027 and maintained thereafter; a 70% Scope 1 and 2 reduction and 35% Scope 3 reduction targeted by 2030. |
17. Data quality, limitations and improvement plan
We consider it more useful to a procurement assessor to state plainly where our data is weak than to present a uniform appearance of precision. The following disclosure is made in that spirit.
17.1 Data quality by source
| Emissions source | Data quality | Basis and improvement action |
|---|---|---|
| Purchased electricity | High | Metered supplier invoice data. Improvement: half-hourly monitoring from 2026 to enable granular consumption analysis. |
| Refrigerants | Low | No asset register currently maintained. Improvement: complete register with gas type, charge and global warming potential during 2026. |
| Upstream freight | Medium | Derived from carrier invoices and consignment records with distance-based factors. Improvement: obtain primary emissions data from carriers from 2027. |
| Waste | Low | Waste contractor records only, without stream-level weights. Improvement: source segregation with weight recording by stream from 2026. |
| Business travel | Medium | Derived from expense claims. Improvement: structured capture of mode and distance at the point of claim from 2026. |
| Employee commuting | Low | Modelled from headcount and assumed patterns. Improvement: annual commuting survey from 2026. |
| Downstream freight | Medium | Carrier consignment data with distance-based factors. Improvement: carrier primary emissions reporting from 2027. |
| Purchased goods and services | Not yet reported | To be screened on a spend basis for the 2026 reporting year, then transitioned to supplier primary data for the highest-impact categories. |
17.2 Known limitations
- This is the first year in which Minnigard has measured its carbon footprint. Estimation is used where primary data is not available, and the methodology for each such line is disclosed in Annex A.
- Scope 3 reporting in this edition is limited to the five categories mandated by PPN 006 together with a commitment to report purchased goods and services from the 2026 reporting year. Annex B records the relevance assessment for all fifteen categories.
- Cypress House is a leased unit and certain building energy and heating decisions rest with the landlord. Where our influence is limited, we state so rather than claim a reduction we cannot deliver.
- No emissions figure in this plan has been externally verified. External verification is planned from the 2028 reporting year.
17.3 Data improvement plan
- 2026 — Implement carbon accounting software or engage an external adviser; complete refrigerant register; begin stream-level waste weighing; run the first commuting survey; structure travel data capture.
- 2027 — Obtain primary emissions data from freight and courier partners; complete the spend-based screening of purchased goods and services; complete the Evergreen sustainable supplier assessment.
- 2028 — Transition the highest-impact purchased-goods categories to supplier primary data; obtain first external verification of the footprint.
- 2030 — All material Scope 3 categories calculated from primary or supplier-specific data rather than spend-based proxies.
17.4 Statement on incomplete data
PPN 006 and NHS England's guidance provide that where a supplier has an acceptable reason for being unable to gather complete emissions data, a Carbon Reduction Plan may be submitted with the emissions data available together with an explanation and the steps that will be taken to improve it. Minnigard Medical Ltd relies on that provision to the extent that any line in Sections 4 and 5 is marked "not reported".
The reason is that 2025 is the first year in which the company has measured its carbon footprint, and certain source records — notably stream-level waste weights, refrigerant charge data and structured commuting data — were not collected during that year because no measurement framework was yet in place. These records cannot be reconstructed retrospectively with sufficient integrity to publish. Rather than publish an unsupported figure, we have disclosed the gap.
The remedy is set out in Section 17.3. Every source currently unreported has a specific collection mechanism scheduled for implementation during 2026, and each will be reported in full from the 2026 reporting year onward. We would rather present a plan an assessor can trust than a complete-looking table they cannot.
18. Declaration and sign-off
This Carbon Reduction Plan has been completed in accordance with Procurement Policy Note 006 and the associated Technical Standard for the Completion of Carbon Reduction Plans, and with the NHS England Carbon Reduction Plan and Net Zero Commitment requirements for the procurement of NHS goods, services and works.
Emissions have been reported and recorded in accordance with the published reporting standard for Carbon Reduction Plans and the Greenhouse Gas Protocol Corporate Standard, using the appropriate UK Government emission conversion factors for greenhouse gas company reporting.
Scope 1 and Scope 2 emissions have been reported in accordance with Streamlined Energy and Carbon Reporting requirements, applied voluntarily as the company falls below the mandatory SECR reporting threshold. The required subset of Scope 3 emissions has 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 director of Minnigard Medical Ltd, no board being in place, and will be published and updated in accordance with the published reporting standard for Carbon Reduction Plans and the associated guidance.
Signed on behalf of Minnigard Medical Ltd
| Name | Cooper Hill |
| Position | Director and Co-Founder |
| Entity | Minnigard Medical Ltd |
| Date | 7 September 2026 |
This plan is published on the Minnigard Medical Ltd website and will be reviewed and reissued on or before 7 September 2027.
Annex A — Emissions calculation methodology by source
This annex records, for each line in Sections 4 and 5, the source record required and the calculation applied. It exists so that the footprint can be reproduced and challenged, and so that the same method is applied consistently year on year.
All conversion factors are taken from the UK Government greenhouse gas reporting conversion factors published by the Department for Energy Security and Net Zero for the relevant reporting year. Factors are applied at the rate published for the year in which the activity occurred, not the year of reporting.
| Line | Source record | Calculation |
|---|---|---|
| Vehicle fuel (Scope 1) | Fuel card statements or litres purchased for company-controlled vehicles | Litres by fuel type × the relevant fuel conversion factor. Where only mileage is available, mileage × the vehicle-size and fuel-type factor. |
| On-site fuel combustion (Scope 1) | Gas or oil invoices for Cypress House, or the landlord's apportionment where the supply is shared | kWh (gross calorific value) × the natural gas factor. Where the supply is shared and apportioned by floor area, the apportionment basis is recorded. |
| Refrigerants (Scope 1) | F-gas service records; refrigerant asset register | Mass of refrigerant recharged during the year × the global warming potential of the gas. Where no recharge occurred, a nil entry is recorded rather than the line omitted. |
| Electricity, location-based (Scope 2) | Electricity invoices or half-hourly meter data for Cypress House | kWh consumed × the UK grid average electricity factor for the reporting year. |
| Electricity, market-based (Scope 2) | Supply contract and any Renewable Energy Guarantees of Origin certificates | kWh × the supplier-specific factor. Where a fully REGO-backed tariff is in place and evidenced, this figure is zero. The contractual evidence is retained. |
| Upstream transport (Category 4) | Inbound carrier invoices and consignment records showing weight, origin, destination and mode | Tonne-kilometres by mode × the relevant freight factor. Where weight is unavailable, chargeable weight from the carrier invoice is used and the substitution noted. |
| Waste (Category 5) | Waste contractor collection records with weights by stream | Tonnes by waste stream and treatment route × the relevant waste factor. Where only collection frequency is available, container volume and a standard density assumption are used and flagged as estimated. |
| Business travel (Category 6) | Expense claims; mileage claims; rail and air booking records; hotel nights | Grey fleet mileage × the vehicle factor; rail and air passenger-kilometres × the relevant factor including radiative forcing for air; hotel nights × the country-specific factor. |
| Employee commuting (Category 7) | Annual employee commuting survey capturing mode, one-way distance and days per week | Per-employee annual distance by mode × the relevant passenger transport factor, scaled for actual attendance days including homeworking. Homeworking energy use is included using the recognised homeworking methodology and stated separately. |
| Downstream transport (Category 9) | Outbound courier consignment reports showing weight, destination and service level | Tonne-kilometres by mode and service level × the relevant freight factor. Where the carrier provides primary emissions data, that data supersedes the calculation and the source is stated. |
| Purchased goods and services (Category 1) | Purchase ledger analysed by category; supplier product carbon footprints where available | Supplier primary data in preference. Where unavailable, spend by category × the relevant spend-based factor, with the limitation of spend-based factors disclosed. |
Annex B — Scope 3 category relevance screening
All fifteen Scope 3 categories defined by the Greenhouse Gas Protocol Corporate Value Chain Standard have been assessed for relevance to Minnigard Medical Ltd. Categories assessed as not relevant are recorded with the reason, in accordance with the Standard's requirement that exclusions be disclosed and justified rather than silently omitted.
| No. | Category | Status | Assessment |
|---|---|---|---|
| 1 | Purchased goods and services | Relevant — reporting from 2026 | Expected to be the largest single category. Not mandated by PPN 006 but reported voluntarily; spend-based screening in 2026, transitioning to supplier primary data. |
| 2 | Capital goods | Relevant — low materiality | Limited capital expenditure as an asset-light SME. Screened annually; reported if it exceeds the materiality threshold. |
| 3 | Fuel and energy related activities | Relevant — reporting from 2027 | Well-to-tank and transmission and distribution losses associated with purchased electricity and fuel. Calculated using published UK Government factors. |
| 4 | Upstream transportation and distribution | Relevant — mandated | Reported. Inbound freight from UK and European suppliers. |
| 5 | Waste generated in operations | Relevant — mandated | Reported. Packaging waste, damaged and expired stock, general operational waste. |
| 6 | Business travel | Relevant — mandated | Reported. Practice visits, exhibitions, supplier meetings. |
| 7 | Employee commuting | Relevant — mandated | Reported, including homeworking energy use. |
| 8 | Upstream leased assets | Not relevant | Cypress House energy use is captured within Scope 1 and 2 under the operational control approach. No other upstream leased assets. |
| 9 | Downstream transportation and distribution | Relevant — mandated | Reported. Outbound courier movements to customers. |
| 10 | Processing of sold products | Not relevant | Products are supplied as finished sterile kits requiring no further processing by an intermediate party. |
| 11 | Use of sold products | Not relevant | Products are passive single-use clinical consumables that consume no energy in use. Emissions arising at the point of use are captured under Category 12. |
| 12 | End-of-life treatment of sold products | Relevant — reporting from 2028 | Material for a supplier of single-use clinical consumables, given that a proportion enters the clinical waste stream and is treated by high-temperature incineration. To be quantified alongside product carbon footprinting. |
| 13 | Downstream leased assets | Not relevant | No assets are leased to third parties. |
| 14 | Franchises | Not relevant | No franchise operations. |
| 15 | Investments | Not relevant | No investment activity within the reporting entity that meets the Standard's definition. |
Annex C — Annual data collection calendar
This annex fixes the operating rhythm that makes annual reporting routine rather than a year-end exercise, and ensures the published plan stays within the twelve-month currency window that NHS England applies at assessment.
| Period | Activity | Owner |
|---|---|---|
| January | Close the prior calendar year. Collect electricity, fuel and refrigerant records. Request annual summaries from waste and freight contractors. | Operations |
| February | Issue the employee commuting survey. Extract travel and mileage data from the expenses system. Extract the purchase ledger for Scope 3 Category 1 analysis. | Operations and Finance |
| March | Calculate the footprint. Apply the current year's UK Government conversion factors. Compare against the trajectory in Section 6. | Operations |
| April | Draft the annual update to this plan, including performance against target, corrective actions where behind, and any baseline recalculation. | Commercial |
| May | Director review and approval. Publish the updated plan on the company website. | Director |
| June | Update NHS Evergreen submission and refresh Carbon Reduction Plan links in all live tender and framework records. | Commercial |
| Quarterly | Review data collection completeness and progress against the current year's roadmap actions. | Director and Operations |
| Ongoing | Tier 1 supplier carbon data exchange; carbon criteria applied at every sourcing decision and contract renewal. | Procurement |
Minnigard Medical Ltd · Cypress House, Mid Cornwall Business Centre, Par Moor Road, St Austell, Cornwall, PL25 3RT
Carbon Reduction Plan · Version 1.0 · Published 7 September 2026 · Next review on or before 7 September 2027