Commitment to Achieving Net Zero

Value Associates Limited, trading as Acorn Compliance ("Acorn Compliance"), is committed to achieving Net Zero greenhouse gas emissions by 2045 across all Scopes, and confirms it has already achieved an effective Net Zero position in Scopes 1 and 2 by virtue of its fully remote operating model (target maintained through to 2040 and beyond in line with NHS Net Zero ambitions for Scopes 1 and 2).

This commitment involves reducing Acorn Compliance's absolute greenhouse gas emissions by at least 90% against the FY 2024/25 baseline, with any residual emissions addressed through verified removals only after all practicable reduction measures have been exhausted. This commitment does not rely on carbon offsetting, tree planting, or the purchase of carbon credits to meet the target.

Baseline Emissions Footprint

Acorn Compliance has not previously measured or reported its organisational carbon footprint. In accordance with the CRP guidance, the Company's first reporting period, Financial Year 2024/25 (1 October 2024 to 30 September 2025), is used as both the Baseline Year and the current Reporting Year.

Additional Details Relating to Baseline Emissions Calculations

Acorn Compliance is a fully remote consultancy with no owned or leased office premises, no company vehicles, and no employees or subcontractors with a fixed commuting pattern. As a result, Scope 1 and Scope 2 emissions are nil. The Company's material emissions arise entirely within Scope 3, specifically business travel undertaken by employees and subcontractors (rail, air, and taxi/private hire) in the course of client engagements.

Baseline Year Emissions (FY 2024/25)

Scope 3 category breakdown:

Current Emissions Reporting

Reporting Year: FY 2024/25 (1 October 2024 – 30 September 2025)

As this is Acorn Compliance's first Carbon Reduction Plan, the Reporting Year emissions are identical to the Baseline Year emissions set out above.

Emissions Reduction Targets

Having reviewed the baseline breakdown, business travel and air travel in particular, which accounts for approximately 93% of Acorn Compliance's total footprint, is the clear and controllable lever for reduction. Acorn Compliance therefore adopts the following targets:

• By FY 2027/28: reduce total emissions by 25% against the FY 2024/25 baseline (to approximately 10.1 tCO2e), through the travel policy measures set out below.
• By FY 2029/30: reduce total emissions by 50% against the FY 2024/25 baseline (to approximately 6.7 tCO2e).
• By 2040: maintain an effective Net Zero position for Scopes 1 and 2 (already achieved via the Company's remote operating model).
• By 2045: achieve Net Zero across all Scopes, including Scope 3, representing at least a 90% absolute reduction against the FY 2024/25 baseline, with any residual balance addressed through verified removals rather than offsetting.

Progress against these targets will be reviewed annually alongside the Company's financial year end (30 September) and the Carbon Reduction Plan will be updated and republished at least annually, and within 6 months of each financial year end, in accordance with PPN 06/21.

Targets will be pursued in line with business growth and client requirements, with a focus on reducing emissions intensity per engagement.

Carbon Reduction Projects

Completed Carbon Reduction Initiatives

The following environmental management measures have been in place since the Company's inception and are in effect for the FY 2024/25 baseline period, and will remain in effect during performance of any contract awarded under this Framework:

• Fully remote operating model: Acorn Compliance has no owned or leased office premises, eliminating Scope 1 and Scope 2 emissions and eliminating employee commuting emissions entirely.
• Cloud-based infrastructure: all core business systems and client-facing tools run on Amazon Web Services (AWS) and Microsoft Azure, both of which operate published carbon-reduction commitments (including Microsoft's carbon-negative-by-2030 commitment and AWS's target to power its operations with 100% renewable energy), rather than on Company-owned or on-premises servers.
• Digital-first service delivery: client engagements, workshops, and documentation are delivered through video conferencing and cloud-based collaboration tools by default, reducing the need for business travel.
• Hardware / digital footprint: the Company operates a digital-first model with minimal hardware footprint and encourages efficient use of equipment and extended device lifecycles.
• Internal awareness: the Company promotes awareness of low-carbon practices among its team, particularly in relation to travel and digital working.

Future Carbon Reduction Initiatives

In the future, Acorn Compliance intends to implement the following measures, targeting the business travel emissions identified as the Company's primary source of Scope 3 emissions:

• Adopt a formal Travel Policy requiring video conferencing as the default for client meetings, with in-person travel reserved for engagements where it is genuinely required.
• Introduce a "rail-first" policy for domestic and short-haul European travel, requiring rail to be used in preference to short-haul flights wherever the journey time is under a defined threshold (e.g. 5 hours).
• Consolidate client-site visits to reduce the frequency of individual trips (e.g. combining multiple meetings into a single visit).
• Encourage use of public transport over taxis/private hire for journeys under a defined distance where practicable and safe to do so.
• Begin tracking business travel on a mileage/spend basis (rather than transaction-count basis) from FY 2025/26 to improve the accuracy of future Carbon Reduction Plans.
• Where relevant, Acorn Compliance will prioritise suppliers and cloud providers with published carbon reduction commitments.

Declaration and Sign Off

This Carbon Reduction Plan has been completed in accordance with PPN 06/21 and the 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, 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 SECR requirements, and 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 Managing Director of Value Associates Limited, trading as Acorn Compliance.

Signed on behalf of the Bidder:

Name: Roxana Valea
Position: Managing Director
Date: 20/01/2026

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