The NHS net-zero checklist - Jaco Marais

10 January 2022

Trusts and integrated care systems are required to contribute significantly to the NHS’s net-zero targets. In this, the first part of a two-part article, GGI’s head of corporate social responsibility Jaco Marais focuses on what is expected of trusts and ICSs.

In the thick of COP26, Health Secretary Sajid Javid wrote to all NHS trusts about their vital role in ensuring the NHS achieves the ‘our shared ambitions on climate change and the environment’.

This work is already underway. Last October Greener NHS published the new national sustainability strategy for the NHS, Delivering a net-zero National Health Service, setting clear carbon reduction targets:

  • NHS Carbon Footprint: net-zero carbon emissions by 2040 for emissions directly controlled, with 80% reduction by 2028/32
  • NHS Carbon Footprint Plus: net-zero carbon emissions by 2045 for those influenced, such as via its supply chain, with 80% reduction by 2036/39

The NHS Standard Contract for 2021/22 set a requirement for all provider trusts and ICSs to develop Green Plans, detailing their approaches to reducing carbon emissions in line with the national targets, by early 2022.

Today we’re going to look at the actions facing NHS trusts related to their green plans. We will focus on ICS actions in a follow-up article.

By the end of 2021/22 there are several actions trusts are expected to have taken forward:

The 2021/22 NHS Standard Contract -

  • Every trust to ensure a board member is responsible for their net-zero targets and their Green Plan.
  • Every trust to purchase 100% renewable energy from April 2021, with supply contracts changing as soon as possible.
  • Every trust to reduce its use of desflurane to less than 10% of its total volatile anaesthetic gas use, by volume.

Delivering a net-zero National Health Service:

  • Ensure that, for new purchases and lease arrangements, systems and trusts solely purchase and lease cars that are ultra-low emissions vehicles (ULEVs) or zero-emissions vehicles (ZEVs).
  • Develop a green travel plan to support active travel and public transport for staff, patients and visitors.

2021/22 NHS planning guidance:

  • Where outpatient attendances are clinically necessary, at least 25% of outpatient activity should be delivered remotely, resulting in direct and tangible carbon reductions.

Question for boards: what progress is your trust making on these actions? Have you received assurance that this work is being done?

NHS Green Plans

The purpose of Green Plans, which have replaced Sustainable Development Management Plans (SDMPs), is to translate this national strategy into local action to ensure that these targets are met. They are expected to help the NHS meet its net-zero emissions target by taking a delivery focus with three clear outcomes:

  • Ensure every NHS organisation is supporting the NHS-wide ambition to become the world’s first healthcare system to reach net-zero carbon emissions.
  • Prioritise interventions that simultaneously improve patient care and community wellbeing while tackling climate change and broader sustainability issues.
  • Support organisations to plan and make prudent capital investments while increasing efficiencies.

Green governance

The production and ongoing development of Green Plans should be led by a designated board-level net-zero lead. This should be one of the existing executive directors. Is that nominated executive director equipped for that role? One idea might be a buddy system of a NED and an exec.

Green Plans need to be signed off by the board. Every trust and ICS is expected to have a Green Plan approved by that organisation’s board or governing body by the set deadlines.

Green Plans are to cover a three-year period. Each trust is expected to formally review and update its plans annually, considering:

  • the progress made and the ability to increase or accelerate agreed actions
  • new initiatives generated by staff or partner organisations
  • advancements in technology and other enablers
  • the likely increase in ambition and breadth of national carbon reduction initiatives and targets.

Developing Green Plans

To support and accelerate the development of Green Plans, in June 2021 Greener NHS published guidance on their structure and governance - How to produce a Green Plan: a three year strategy to net zero.

In developing Green Plans, trusts should:

  • Review progress on carbon reduction related activity in the organisation: what worked, what did not?
  • Account for the national targets from the NHSCF and NHCF Plus.
  • Learn from other trusts.
  • Engage with internal stakeholders/key partners to inform sustainability priorities and identify areas for collaboration.
  • Develop and refine SMART actions with regards to carbon reduction.
  • Develop systems/processes to measure and report on progress, annually.

Beyond Green Plans, many trusts have developed supplementary strategies and formed collaborative partnerships with other anchor institutions in place to scale up the impact they can have. We will be publishing more about this soon, looking at best practice.


Trusts are expected to report annually on progress against their sustainability targets. This is to be done formally to the board. Progress should also be reported formally to the relevant regional greener NHS team, in a format and frequency agreed with them.

The UK government produced sustainability reporting guidance for 2020/21 with the aim of ensuring public sector organisations were properly monitoring and reporting on their sustainability performance. The guidance encourages the use of integrated reporting, advising organisations to: “demonstrate through integrated reporting how sustainability is an essential characteristic within strategic objectives, operations and policy making.” (UK government, 2020)

GGI is a long-time advocate of integrated reporting. We believe it fosters a better understanding of the factors that affect an organisation’s ability to create value, which can lead to behavioural change and performance improvements. Boards would do well to work with their executive and management teams to establish what the metrics for this reporting should be and how to measure them.

Questions for boards

Key questions for NHS trust and ICS boards:

  • Is your Green Plan already in place?
  • How are you going to monitor, evaluate and report on progress?
  • Have you identified the board’s risk appetite in relation to progress on reaching carbon neutrality?
  • How are you identifying, recording and managing risks associated with climate change?
  • Have you added the risks of non-compliance to your BAF?
  • Are you getting the right assurance on your progress towards carbon neutrality? Are you getting any independent assurance?
  • Have you identified the risk tolerance levels that if not reached will be escalated and what that escalation pathway is?
  • How are you engaging staff, patients, partners and the communities you serve on your Green Plan and sustainability governance activities?
  • Have you asked your internal auditors to include a review of your compliance and progress in their 2022/23 audit plan?

For boards that need support with anything covered in this article, GGI is ready to help. Please call us on 07732 681120 or email

Meet the author: Jaco Marais

Director of Corporate Communications

Find out more

Prepared by GGI Development and Research LLP for the Good Governance Institute.

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