Carbon Reduction Plan
Prepared in accordance with Cabinet Office PPN 006 (formerly PPN 06/21) and the NHS Net Zero Supplier Roadmap
1. Commitment to achieving Net Zero
Keystone Healthcare Ltd is committed to achieving Net Zero greenhouse gas emissions by 2050 for our UK operations.
We also set the following interim targets so the 2050 commitment is not left to the last decade:
- By 31 March 2030: reduce reported Scope 1, Scope 2 (location-based) and the five mandated Scope 3 categories by at least 50% against the 2024/25 baseline.
- By 31 March 2040: reduce the same inventory by at least 90% against the 2024/25 baseline, with residual emissions addressed by high-quality removals only where further reduction is not reasonably practicable.
- From April 2027: expand reporting, proportionately, towards all relevant Scope 3 categories in line with the NHS Net Zero Supplier Roadmap.
These targets apply to Keystone Healthcare Ltd as the bidding entity for RM6397.
2. 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: 1 April 2024 to 31 March 2025.
Additional details relating to the baseline emissions calculations
Keystone Healthcare Ltd is a small UK staffing agency. We have not previously published a formal organisational carbon footprint. 2024/25 is therefore our first baseline year.
Emissions have been calculated under the operational-control approach in the GHG Protocol Corporate Standard, using UK Government greenhouse gas conversion factors for company reporting. Figures for this first baseline are activity-based estimates built from known operations (office energy, staff numbers, typical travel patterns and waste). They will be replaced with metered and logged actuals as soon as a full year of invoices, mileage records and waste data is assembled. Until that refresh, the figures should be treated as a best-available first inventory, not as independently verified SECR data. Keystone is below the SECR reporting threshold.
Organisational context used in the calculation:
- Small employed office team based at Unit 7c Dyson Wood Way, Bradley, Huddersfield HD2 1GN.
- No company-owned vehicle fleet and no on-site combustion plant under Keystone’s operational control in the baseline year (Scope 1 reported as zero).
- Purchased electricity for the office suite is Scope 2 (location-based).
- Agency workers placed onto NHS and care shifts are not Keystone employees. Their travel to client sites is therefore not reported inside the five mandated PPN 006 Scope 3 categories. It is addressed separately in section 6 as a contract-delivery measure, because it is the main climate impact of performing an RM6397 staffing contract.
- Downstream transportation and distribution of sold physical products does not apply to a labour-supply business and is reported as zero.
Baseline year emissions
Emissions | Total (tCO2e) |
Scope 1 | 0.00 |
Scope 2 (location-based) | 2.48 |
Scope 3 (included sources – see breakdown) | 6.71 |
Total emissions | 9.19 |
Scope 3 breakdown – mandated PPN 006 subset
Scope 3 category | tCO2e | Notes |
Upstream transportation and distribution | 0.40 | Inbound office supplies, IT hardware and consumables |
Waste generated in operations | 0.10 | Office residual and recycled waste |
Business travel | 2.16 | Consultant and management travel to NHS Trusts and care homes (grey fleet / public transport) |
Employee commuting | 4.05 | Office staff home-to-work travel |
Downstream transportation and distribution | 0.00 | Not applicable – no physical products sold |
Total mandated Scope 3 | 6.71 |
How the baseline figures were derived
Source | Activity assumption (baseline) | Factor / result |
Scope 1 | No owned vehicles, no gas boiler under Keystone control, no reported refrigerant top-up | 0.00 tCO2e |
Scope 2 electricity | 12,000 kWh purchased electricity for the Huddersfield office suite | UK grid location-based ~0.207 kgCO2e/kWh → 2.48 tCO2e |
Business travel | 8,000 miles grey-fleet / average car equivalent for client visits | ~0.27 kgCO2e/mile → 2.16 tCO2e |
Employee commuting | Office staff car commuting equivalent of 15,000 miles | ~0.27 kgCO2e/mile → 4.05 tCO2e |
Waste + upstream T&D | Small office waste arisings plus inbound parcels and IT | 0.50 tCO2e combined |
Conversion factors are taken from the UK Government GHG Conversion Factors for Company Reporting relevant to the data year. The next annual update will replace estimated kWh and mileage with invoice and logbook actuals and will restate the baseline if material error is found.
3. Current emissions reporting
Reporting year: 1 April 2025 to 31 March 2026.
Current-year figures apply the same boundary and method. The small reduction versus baseline reflects hybrid working, fewer unnecessary client visits, and the continuing fall in the UK grid factor, not a full set of completed capital projects.
Emissions | Total (tCO2e) |
Scope 1 | 0.00 |
Scope 2 (location-based) | 2.10 |
Scope 3 (included sources) | 6.05 |
Total emissions | 8.15 |
Movement versus baseline: 9.19 → 8.15 tCO2e, a reduction of 1.04 tCO2e (11%).
Scope 3 category | Baseline tCO2e | 2025/26 tCO2e | Change |
Upstream transportation and distribution | 0.40 | 0.36 | −10% |
Waste generated in operations | 0.10 | 0.08 | −20% |
Business travel | 2.16 | 1.90 | −12% |
Employee commuting | 4.05 | 3.71 | −8% |
Downstream transportation and distribution | 0.00 | 0.00 | n/a |
4. Emissions reduction targets
In order to continue our progress to achieving Net Zero, we have adopted the following carbon reduction targets.
We project that carbon emissions from Scope 1, Scope 2 and the five mandated Scope 3 categories will decrease over the next five years to 4.60 tCO2e by 31 March 2030. This is a reduction of 50% from the 2024/25 baseline of 9.19 tCO2e.
Year | Reported inventory (tCO2e) | % vs baseline | Milestone |
2024/25 | 9.19 | Baseline | First inventory |
2025/26 | 8.15 | −11% | Current year |
2027/28 | 6.40 | −30% | Metered data + RE tariff |
2029/30 | 4.60 | −50% | Interim target |
2039/40 | 0.92 | −90% | Near-zero operations |
2049/50 | Net Zero | −100% net | UK Net Zero deadline |
Targets will be reviewed each year when the inventory is updated. If the business grows (more office staff or a second site), we will also report an intensity metric – tCO2e per office FTE – so absolute growth is not mistaken for a failure of reduction effort.
5. Carbon reduction projects
Completed carbon reduction initiatives
The following environmental management measures and projects have been completed or implemented since the 2024/25 baseline. The carbon emission reduction achieved by these schemes equates to approximately 1.04 tCO2e in 2025/26, an 11% reduction against the 2024/25 baseline, and the measures will be in effect when performing the contract.
- Hybrid working for office roles where the work allows, reducing commuting days.
- Default video meetings with NHS and care-home clients instead of routine face-to-face visits, with travel reserved for audits, onboarding and relationship meetings that cannot be done remotely.
- Digital candidate compliance files, electronic timesheets and e-payslips, cutting paper, printing and courier use.
- LED lighting and default power-down of office IT at the Huddersfield unit.
- Recycling of paper, card, plastics and WEEE through the building waste service.
- Local-first supply of workers into West Yorkshire NHS and care settings, reducing long-distance travel to shift where clinically appropriate.
Future carbon reduction initiatives
In the future we will implement further measures such as:
- Switch the office electricity contract to a 100% renewable tariff at the next renewal (market-based Scope 2 reduction; location-based figures will still be published).
- Collect 12 months of actual electricity consumption from bills and replace the estimated Scope 2 figure.
- Introduce a simple mileage and mode log for all business travel and office commuting so Scope 3 travel is activity-based rather than assumed.
- Staff travel hierarchy: walk / cycle / bus / train first; grey fleet last; no domestic flights for mainland UK client meetings.
- Cycle-to-work scheme and information on Kirklees and West Yorkshire public transport for office staff.
- When a company or pool vehicle is next required, specify a battery-electric or plug-in hybrid vehicle only.
- Prefer refurbished IT hardware and extend device life to at least four years.
- Ask landlords and building managers at Dyson Wood Way about fabric, heating and on-site generation improvements.
- From 2027, add a proportionate estimate of agency-worker travel to client sites as an additional (non-mandated) Scope 3 disclosure, and use it to steer local-first booking.
- Engage payroll, DBS, occupational health and IT suppliers on their own Net Zero plans as NHS April 2027 roadmap expectations take effect.
- Annual board review of this CRP and republication on the company website.
6. Environmental management measures that will apply when performing RM6397 contracts
PPN 006 and NHS guidance require the CRP to set out measures that will be in effect during contract performance. For a nursing, ODP and healthcare-worker supplier those measures are operational, not a factory energy project. The following will apply on RM6397 call-offs.
Contract activity | Measure in effect during performance |
Filling shifts | Prefer workers who already live within a reasonable travel-to-work area of the Trust or home. Avoid unnecessary long-distance placements when a local compliant worker is available. |
Worker travel to site | Encourage public transport, car-share and active travel in the worker handbook. Do not organise multi-occupancy private transport that could create modern-slavery or safety risk. |
Client meetings and audits | Default to video. Travel to site for Health Assurance Inspection, onboarding and issues that need to be in person. |
Compliance and payroll | Electronic ID, DBS, timesheets and payslips. No routine paper packs posted to Trusts or workers. |
Uniforms / PPE | Workers use client or own uniform arrangements. Keystone does not run a high-volume disposable-PPE supply chain. |
Offices supporting the contract | Huddersfield office operated under the energy, waste and travel controls in section 5. |
Reporting to the buyer | This CRP kept current (annual update). Copy supplied on request. Willing to complete NHS Evergreen Sustainable Supplier Assessment if invited. |
7. Alignment with NHS Net Zero Supplier Roadmap and RM6397
Roadmap / tender requirement | Keystone position |
PPN 006 Carbon Reduction Plan (Scope 1, 2 and five Scope 3 categories) | This document. Published and board-approved. |
Net Zero commitment by 2050 for UK operations | Confirmed in section 1. |
NHS: CRP required from April 2024 on new procurements, proportionately | CRP produced even though Keystone is an SME below the historic £5 million / annum CRP threshold, so it can be used on transactional lots and on any call-off that later exceeds £5 million. |
RM6397: CRP where call-off value is expected to exceed £5 million (managed service lots) | CRP ready for Lots 11/12 if bid, and available as supporting evidence on nursing / ODP / HCA transactional lots. |
From April 2027: wider Scope 3 reporting | Committed in section 1. Worker-travel estimate to be added as an extra disclosure. |
Minimum 10% net zero and social value weighting in NHS procurements | This CRP plus Keystone’s local West Yorkshire employment model supports a net-zero / social-value narrative. |
8. Governance, publication and review
- Owner: Managing Director (Richard Ward).
- Review: at least annually, or after a material change (new site, fleet, or merger).
- Publication: latest CRP on the Keystone website, with a link from a prominent place on the homepage. Previous versions retained so progress can be seen.
- If the website is unavailable, a copy will be provided in writing within 30 days of a request.
- No third-party verification is claimed. PPN 006 does not require audited figures. The inventory will be improved to a reasonable level of assurance using primary data.
- Related documents: Environmental / Sustainability Policy (when issued), Modern Slavery Policy MS-POL-01, Recruitment and Travel procedures.
9. Declaration and sign off
This Carbon Reduction Plan has been completed in accordance with PPN 006 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 Protocol Corporate Standard, and use 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 (where required). Keystone Healthcare Ltd is not in scope of SECR. 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).