Legal

Carbon reduction plan

© Sanome (Human Digital Twin Ltd) 2026. All rights reserved.

Field

Detail

Supplier Name

Sanome (Human Digital Twin Ltd)

Company Registration

15713416

Registered Address

Complete HQ 2 Bridge Court, Kingsmill Road, Saltash, Cornwall, England, PL12 6LS

Publication Date

June 2026

Reporting Period

FY2025/26 (1 April 2025 to 31 March 2026)

Baseline Year

FY2025/26

Approved By

Benedikt von Thüngen, Chief Executive Officer

Board Approval Date

29/05/2026

1. Commitment to Achieving Net Zero

Sanome (Human Digital Twin Ltd) is committed to achieving Net Zero greenhouse gas emissions by 2050 for emissions scopes 1, 2 and 3. The commitment was made on the 29/05/2026 by the Board of Directors of Sanome (Human Digital Twin Ltd).

This commitment is consistent with the UK Government’s legal obligation under the Climate Change Act 2008 and supports the broader decarbonisation of the NHS supply chain. Sanome recognises that, as a supplier of AI-enabled software as a medical device (SaMD) to the NHS, it has a responsibility to minimise the environmental impact of its operations and to demonstrate credible, measurable progress towards Net Zero.

This Carbon Reduction Plan has been prepared in accordance with Procurement Policy Note 06/21 (PPN 06/21) and the associated Technical Standard for Carbon Reduction Plans. It sets out Sanome’s baseline carbon footprint, current emissions, reduction targets, and the projects and initiatives through which emissions reductions will be delivered.

2. Baseline Emissions Footprint

Sanome’s baseline emissions have been calculated for the financial year 2025/26 (1 April 2025 to 31 March 2026). This is Sanome’s first Carbon Reduction Plan and first formal carbon footprint assessment. FY2025/26 has therefore been selected as the baseline year.

Reporting Boundary and Methodology

The carbon footprint has been calculated in accordance with the Greenhouse Gas (GHG) Protocol Corporate Accounting and Reporting Standard, using the operational control approach. Emissions have been quantified using the UK Government’s DESNZ Greenhouse Gas Conversion Factors for Company Reporting (2025 dataset, the latest published dataset applicable to the FY2025/26 reporting period).

Sanome is an SME AI software-as-a-medical device company operating from a single shared workspace office at beyond Fox Court, 14 Gray’s Inn Road, London WC1X 8HN. The company has no owned or leased vehicles, no manufacturing operations, and no company-controlled combustion sources. All staff work in a hybrid model, splitting time between the shared office and remote (home) working.

Baseline Year Emissions: FY2025/26

Emissions Source

Scope

tCO2e

Company-owned vehicles

Scope 1

0.00

Natural gas (heating)

Scope 1

0.00

Fugitive emissions (refrigerants)

Scope 1

0.00

Scope 1 Total


0.00

Purchased electricity (office share)

Scope 2

0.47

Scope 2 Total


0.47

Category 4: Upstream transportation and distribution

Scope 3

0.00

Category 5: Waste generated in operations

Scope 3

0.10

Category 6: Business travel

Scope 3

1.20

Category 7: Employee commuting

Scope 3

4.80

Category 9: Downstream transportation and distribution

Scope 3

0.00

Cloud computing (purchased services)

Scope 3

2.50

Scope 3 Total


8.60

Total Emissions


9.07

Notes on Emissions Calculations

Scope 1: Direct Emissions (0.00 tCO2e)

Sanome has no Scope 1 emission sources. The company does not own or operate any vehicles, does not combust any fuels on-site, and does not use refrigerants or other fluorinated gases. The shared workspace facility (beyond Fox Court) manages all building-level energy and HVAC systems; Sanome does not have operational control over these sources.

Scope 2: Purchased Electricity (0.47 tCO2e)

Sanome occupies an 8-person office room within a shared workspace. As a serviced office tenant, Sanome does not hold the electricity supply contract directly. Scope 2 emissions have therefore been estimated using a desk-based apportionment method.

The calculation assumes an average electricity consumption of approximately 2,250 kWh per annum for the occupied office space, derived from published benchmarks for serviced office environments in central London (approximately 280 kWh per desk per annum for an 8-desk room). The DESNZ 2024 UK grid electricity conversion factor of 0.20705 kgCO2e/kWh (generation) plus 0.01830 kgCO2e/kWh (transmission and distribution) has been applied, giving a combined factor of 0.22535 kgCO2e/kWh.

Calculation: 2,250 kWh x 0.22535 kgCO2e/kWh = 507 kgCO2e = 0.51 tCO2e. After adjusting for typical hybrid occupancy patterns (approximately 60% average desk utilisation across the year based on 3 days per week average office attendance), Sanome’s attributed Scope 2 emissions are estimated at 0.47 tCO2e.

Scope 3: Indirect Emissions (8.60 tCO2e)

Category 4, Upstream Transportation and Distribution (0.00 tCO2e): Sanome’s product is a cloud-hosted software platform (SaMD). There is no physical product, no inbound freight, and no physical distribution. This category is therefore reported as zero.

Category 5, Waste Generated in Operations (0.10 tCO2e): Office waste is managed by the shared workspace provider. Sanome’s waste generation is minimal, consisting primarily of small volumes of general office waste (paper, packaging, food waste). An estimate of 0.10 tCO2e has been applied using DESNZ average waste factors for a small office environment.

Category 6, Business Travel (1.20 tCO2e): Sanome’s business travel is minimal and consists predominantly of domestic rail travel within England. International travel is rare. Based on a review of FY2025/26 travel expense data from Xero, total business travel emissions are estimated at 1.20 tCO2e. Rail travel emissions have been calculated using DESNZ 2024 conversion factors for national rail (0.03549 kgCO2e per passenger-km).

Category 7, Employee Commuting (4.80 tCO2e): Commuting emissions have been estimated for all employees based on a hybrid working model averaging 3 days per week in the London office. Average commuting distances have been estimated using London-typical assumptions (average 12 km one-way commute, mixed mode: 60% public transport, 30% cycling/walking, 10% car). DESNZ 2024 conversion factors for London Underground, National Rail, bus, and average car have been applied. Total employee commuting emissions are estimated at 4.80 tCO2e.

Category 9, Downstream Transportation and Distribution (0.00 tCO2e): Sanome’s product is delivered as a cloud-based service. There is no physical distribution to end users. This category is therefore reported as zero.

Cloud Computing, Purchased Services (2.50 tCO2e): Although not among the five mandatory Scope 3 categories under PPN 06/21, Sanome has voluntarily reported emissions from cloud computing infrastructure as this represents a material emission source for a software company. Emissions have been estimated at 2.50 tCO2e based on published cloud provider carbon intensity data and approximate annual compute and storage usage. Both providers have committed to operating on 100% renewable energy, and one has been carbon negative since 2020. As these providers further decarbonise their operations, Sanome’s cloud-related emissions are expected to decrease over time.

3. Current Emissions Reporting

As this is Sanome’s first Carbon Reduction Plan, the current reporting year and baseline year are identical. The table below repeats the baseline emissions for completeness and compliance with the PPN 06/21 template structure.

Reporting Year: FY2025/26

Emissions Source

Total (tCO2e)

Scope 1 (Direct Emissions)

0.00

Scope 2 (Purchased Electricity)

0.47

Scope 3 (Included Sources)

8.60

Total Emissions

9.07

Scope 3 included sources: Category 4 (Upstream transportation and distribution), Category 5 (Waste generated in operations), Category 6 (Business travel), Category 7 (Employee commuting), Category 9 (Downstream transportation and distribution). Cloud computing (purchased services) has been reported voluntarily as an additional material source.

4. Emissions Reduction Targets

Sanome is committed to achieving Net Zero emissions by 2050. As this is Sanome’s first formal carbon footprint, the company has set the following interim reduction targets against the FY2025/26 baseline of 9.07 tCO2e:

Target Year

Target Reduction (vs Baseline)

Projected Emissions (tCO2e)

FY2027/28

25%

6.80

FY2029/30

50%

4.54

FY2034/35

75%

2.27

2050

Net Zero

0.00

These targets will be reviewed annually and updated to reflect changes in organisational scale, operational practices, and the availability of more granular emissions data. Sanome acknowledges that as the business grows, absolute emissions may increase before reducing in line with these targets. In such cases, emissions intensity metrics (tCO2e per employee, or tCO2e per unit of revenue) will be used alongside absolute targets to demonstrate decoupling of growth from emissions.

5. Carbon Reduction Projects

The following carbon reduction measures are currently in effect or planned for implementation. These measures will contribute to achieving the emissions reduction targets set out above.

Completed Measures

Remote-first and hybrid working model: Sanome operates a hybrid working model in which all employees can work from home on any given day. This significantly reduces commuting emissions compared to a five-day office attendance model. The company has no plans to mandate full-time office attendance.

Shared workspace model: By occupying a shared, serviced workspace rather than leasing standalone premises, Sanome benefits from shared heating, cooling, lighting, and facilities management, reducing per-capita energy consumption and associated Scope 2 emissions.

Minimal travel policy: Sanome’s default operating model favours video conferencing over in-person meetings. Business travel is undertaken only where necessary, and domestic rail is the preferred mode of transport. Air travel requires prior approval.

Cloud-native infrastructure: Sanome’s technology platform is hosted entirely on major public cloud providers. Both providers have made public commitments to renewable energy procurement and have published sustainability roadmaps. Sanome does not operate any on-premises servers or data centres.

Planned Measures (FY2026/27 onwards)

Green energy procurement for office space: Sanome will engage with its workspace provider to confirm whether the office is supplied on a 100% renewable electricity tariff backed by Renewable Energy Guarantees of Origin (REGO) certificates. If not, Sanome will advocate for a switch or explore options to procure a REGO-backed tariff for its allocated space.

Cloud carbon monitoring: Sanome will implement active monitoring of cloud carbon emissions using tools such as Microsoft Azure’s Emissions Impact Dashboard and AWS’s Customer Carbon Footprint Tool. This data will be used to right-size cloud infrastructure, select lower-carbon regions for workload deployment, and set cloud-specific reduction targets.

Sustainable commuting incentives: Sanome will explore the introduction of a Cycle to Work scheme and public transport season ticket loans to encourage lower-carbon commuting among employees.

Supply chain engagement: As Sanome’s supply chain matures, the company will incorporate sustainability criteria into procurement decisions for key purchased services, including hosting, professional services, and office supplies.

Annual carbon footprint recalculation: Sanome commits to recalculating its organisational carbon footprint annually, using increasingly granular activity data (actual kWh from workspace provider, itemised travel records, cloud provider carbon reports) to replace estimates with measured data over time.

Employee awareness and engagement: Sanome will integrate environmental awareness into its onboarding process and encourage all employees to consider the carbon impact of business decisions, particularly around travel and technology choices.

6. Environmental Management Measures Applied to Contract Performance

The following environmental management measures are in effect across Sanome’s operations and will be applied when performing contracts under this framework:

Remote-first service delivery: The majority of contract delivery, including implementation support, clinical engagement, and ongoing service management, is conducted remotely by default via video conferencing. On-site attendance is provided only where specifically required by the contracting authority, minimising travel-related emissions associated with contract performance.

Low-carbon travel policy for contract-related travel: Where physical attendance at NHS sites is required for contract delivery purposes, domestic rail travel is the default mode of transport. Air travel for contract-related activities requires prior management approval and is only permitted where no reasonable rail alternative exists.

Cloud infrastructure on renewable-committed providers: Sanome’s product is hosted on major public cloud providers, both of which have published commitments to 100% renewable energy and net zero operations. The computational infrastructure underpinning contract delivery therefore benefits from the decarbonisation trajectories of these providers. Sanome will use cloud providers’ emissions dashboards and carbon footprint reporting tools to track and report emissions associated with contract workloads where practicable.

Paperless and digital-first delivery: All contract documentation, reporting, training materials, and communications are delivered digitally. Sanome does not produce printed materials as part of its standard service delivery, eliminating paper, printing, and associated distribution emissions from contract performance.

Annual reporting and continuous improvement: Sanome will update this Carbon Reduction Plan annually, incorporating improved data quality and reporting on progress against reduction targets. Where contracting authorities require environmental performance reporting as part of contract management, Sanome will provide relevant emissions data from its annual carbon footprint assessment.

7. 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 Reporting Protocol Corporate Standard.

Emissions have been calculated using the UK Government’s DESNZ Greenhouse Gas Conversion Factors for Company Reporting and are quantified in tonnes of carbon dioxide equivalent (tCO2e), covering the seven greenhouse gases specified by the Kyoto Protocol: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulphur hexafluoride (SF6), and nitrogen trifluoride (NF3).

As an SME, Sanome has used best available estimates based on published benchmarks and DESNZ conversion factors where measured activity data is not directly available (specifically for Scope 2 electricity apportionment and Scope 3 employee commuting). Sanome commits to replacing these estimates with measured data as more granular reporting becomes available, including actual energy consumption data from its workspace provider and cloud provider carbon reports.

Scope 1 and Scope 2 emissions have been reported in accordance with the 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) Accounting and Reporting Standard.

This Carbon Reduction Plan has been reviewed and approved by the Board of Directors of Sanome (Human Digital Twin Ltd).

Field

Detail

Signed

Benedikt von Thungen

Title

Chief Executive Officer

Organisation

Sanome (Human Digital Twin Ltd)

Date

29/05/2026

Board Approval Date

29/05/2026

Document Control

Version

Date

Description

Author

Approved By

1.0

May 2026

Carbon Reduction Plan

Tori Nicoll, Founders Associate

Benedikt von Thungen, CEO

This document will be reviewed and updated annually, or sooner if there is a significant change in organisational structure or operations.