Carbon Reduction Plan

Prepared in accordance with PPN 006 (Taking Account of Carbon Reduction Plans in the Procurement of Major Government Contracts) and the NHS Carbon Reduction Plan and Net Zero Commitment requirements.

1. Introduction

This Carbon Reduction Plan (CRP) has been prepared by Delphyr B.V. (“Delphyr”) in support of its submission to the NHS SBS Healthcare AI Solutions Open Framework (SBS10523). It sets out Delphyr’s commitment to achieving net zero greenhouse gas emissions, its current baseline emissions position, and the environmental management measures Delphyr has in place and is putting in place to reduce its carbon footprint.

Delphyr B.V. is incorporated and headquartered in the Netherlands (IJsbaanpad 2, 1076 CV Amsterdam) and has no UK-registered legal entity or UK operations at the date of this plan. In line with the guidance, this CRP therefore applies a global emissions boundary covering all of Delphyr’s operations, which meets the minimum UK boundary requirement.

2. Commitment to Achieving Net Zero

Delphyr B.V. is committed to achieving Net Zero greenhouse gas emissions by 2050 across Scope 1, Scope 2 and the relevant Scope 3 emissions categories set out in this plan, for its global operations.

3. Baseline Emissions Footprint

The baseline emissions footprint represents the first year against which Delphyr will measure its progress towards Net Zero.

Baseline year: [TO BE CONFIRMED]

Explanation: Delphyr is a cloud-native Software as a Medical Device (SaMD) provider operating as a distributed organisation.

Formal greenhouse gas emissions measurement and reporting processes have not yet been established, and baseline figures across Scope 1, 2 and the relevant Scope 3 categories are not currently available.

As a small organisation engaging with these requirements for the first time, Delphyr is relying on the provision within the NHS and PPN 006 guidance permitting suppliers to provide an explanation where emissions data is not yet available, alongside the steps being taken to obtain it (see Section 5).

4. Current Emissions Reporting

Reporting year: [TO BE CONFIRMED]

5. Emissions Reduction Targets

Delphyr has not yet set quantified, scope-specific reduction targets, as these depend on the baseline data described in Section 3. Delphyr commits to the following steps to establish a measurable baseline and reduction trajectory:

• Establish a documented process for collecting Scope 1 and Scope 2 emissions data, principally relating to cloud infrastructure energy consumption and any office or equipment use.

• Establish a documented process for collecting data across the five required Scope 3 categories (upstream and downstream transportation and distribution, waste generated in operations, business travel, and employee commuting).

• Publish a baseline emissions figure and a reduction trajectory towards Net Zero by 2050 within the next published update of this plan.

• Review and update this Carbon Reduction Plan at least annually, in line with the NHS and PPN 006 requirement.

6. Carbon Reduction Projects and Environmental Management Measures

As a cloud-native organisation, Delphyr’s primary operational carbon footprint arises from cloud infrastructure energy consumption rather than from physical estate, fleet, or manufacturing activity. The environmental management measures currently in place, and planned, are set out below.

• Cloud infrastructure: [TO BE CONFIRMED – provider(s) and any published sustainability/net-zero commitments]

• Remote/distributed working model: [TO BE CONFIRMED – impact on commuting and office energy use]

• Business travel policy: [TO BE CONFIRMED]

• Equipment and device lifecycle: [TO BE CONFIRMED]

• Other measures: [TO BE CONFIRMED]

Delphyr recognises that AI solutions must be operated responsibly, with attention to cloud infrastructure, energy use, travel, working practices and device lifecycle management. Delphyr is currently developing an official net zero plan, which has not yet been published. In parallel, we have adopted practical measures to minimise avoidable emissions and to build sustainable operating practices into our delivery model.

Delphyr uses Nebius as its cloud infrastructure provider for Apollo, specifically using Nebius data centre capacity in France and Finland. Nebius publishes a 2024 Sustainability Report and positions its AI infrastructure around sustainable AI computing, energy efficient servers and racks, data centre design, product embedded optimisation tools, low carbon energy sourcing, heat recovery and e-waste recycling. Nebius reports that its in-house server design uses approximately 20% less energy than comparable off the shelf alternatives under the same conditions, saving approximately 10 GWh in 2024. It also reports 20% more compute servers per MW of power capacity, an annual average PUE of 1.3 at its Finland data centre, and 94% low carbon energy consumption across the Group in 2024.

Nebius’ report describes specific sustainability measures at the facilities relevant to Delphyr’s cloud footprint. In Finland, Nebius reports free cooling with no chillers or refrigerants, heat recovery for district heating, and an energy supply mix estimated at approximately 90% low carbon sources, supported by on-site solar production. In France, Nebius reports 100% renewable electricity coverage for its Paris facility through renewable energy power purchase agreements and energy attribute certificates. Nebius also describes product embedded optimisation tools such as autoscaling, workload scheduling, granular GPU allocation and storage tiering, which support more efficient compute use.

Nebius states that it does not yet have a formalised climate transition plan or specific disclosed climate targets, so Delphyr does not present Nebius as having a confirmed net zero commitment. Instead, Delphyr relies on Nebius’ published sustainability reporting as part of supplier oversight and will continue to review its environmental performance as part of our cloud governance.

Delphyr operates a hybrid working model and keeps office attendance proportionate, typically limiting office days to two to three days per week. This reduces routine commuting and office related emissions compared with a full time office based model, while still allowing in person collaboration where it adds value. Remote collaboration is used for many internal meetings, customer workshops, technical reviews, governance discussions and implementation planning, unless an in person meeting is necessary for clinical, operational or deployment reasons.

Delphyr does not currently have a formal business travel policy, but our working preference is video conferencing first. Where travel is required, we aim to keep it proportionate and purposeful, for example for deployment workshops, clinical engagement, user research or governance meetings. For domestic and short haul European travel, Delphyr’s preference is to use rail where practical and reasonable, rather than air travel. We also aim to combine meetings into a single visit where possible to reduce repeat journeys.

Delphyr applies a pragmatic equipment lifecycle approach. As a software and cloud based organisation, we do not require customers to procure dedicated hardware for Apollo beyond existing clinical devices and EHR access arrangements. Internally, we aim to extend the useful life of laptops and devices, avoid unnecessary replacement cycles, securely wipe redundant equipment and use responsible disposal or recycling routes for e-waste.

Additional measures already in place include remote onboarding, digital first documentation, electronic contracting and policy workflows, minimal printing, cloud based collaboration and avoiding unnecessary customer site attendance. As Delphyr scales, we are formalising our environmental approach through our official net zero plan, supplier sustainability review, travel preferences, equipment lifecycle management and cloud efficiency monitoring.

7. Declaration and Sign Off

This Carbon Reduction Plan has been reviewed and signed off by:

Name: Michel Abdel Malek
Role: Chief Executive Officer and Director
Date: [TO BE CONFIRMED]
Signature: ___________________________

Delphyr B.V. has no parent company and is bidding, and reporting under this Carbon Reduction Plan, on its own behalf. This plan covers Delphyr B.V.’s global operations and will be published on Delphyr’s website, with a direct link provided as part of the SBS10523 submission, and reviewed at least annually.