Proposed acquisition of EMIS Group

Our supply chain

Our Supplier Code of Conduct

1. Objective

As a supplier to the healthcare industry and the NHS, EMIS’s technological innovations, projects and software have a positive impact on UK society. EMIS is proud of being a company that does business responsibly and ethically with an awareness of how our business impacts on society and the environment.

EMIS’ Supplier Code of Conduct sets out the behaviours and minimum standards that our organisation expects of its suppliers and ensures the EMIS Group and suppliers are complying with applicable laws and regulations.

EMIS’s goal is to ensure that we maintain a sustainable supply chain that meets the strategic needs of our business, and which provides products and services that represent value for money under robust contractual terms. 

2. Scope

This Supplier Code of Conduct applies to all suppliers engaged by the EMIS Group. We recognise that without working well with our suppliers we would not be able to deliver for our customers, society and the environment.

The scope of this Supplier Code of Conduct reflects both traditional responsible supply chain practices and the delivery of excellent service and good value for our patients, customers and business; practices which all suppliers must comply with in order to partner with EMIS.

In addition, our supply chain has a pivotal role to play in the delivery of social value (such as reducing health inequalities), and suppliers are expected to develop a net zero strategy that supports EMIS in achieving its net zero objectives by 2045 (at the latest), as more than 80% of EMIS’s carbon emissions occur in its supply chain. As organisations develop their own net zero strategy, EMIS recognises the requirement for collaboration, and this documents further outlines the expectation of the EMIS Group.

The Supplier Code of Conduct is not intended to undermine our contracts with suppliers and does not take precedence where the courts or other institutions such as a regulatory agency, authority or body have jurisdiction.

3. EMIS Expected Standards

Procurement Principles

The EMIS Group operates professionally and respectfully with our supply chain, maintaining a fair and transparent supplier engagement process in accordance with all applicable laws and regulations. We consider the ethical, social, economic and environmental impact of our business, and our expectation is that our suppliers will operate in a similar manner, in line with all applicable government laws and regulations.

Service Excellence & Value

Collectively, the achievement of all 5 Procurement Rights (the “5 R’s”) provides a framework for effective purchasing, strategic production and supply chain management that applies to all suppliers and sectors.

The 5 Rs are; the Right Quality, the Right Quantity, the Right Price, the Right Place, and the Right Time. We require our supplier base act in a way that meets these Procurement Rights. The EMIS Group will award contracts based upon the value for money delivered to our customers and our business, which includes price and quality, including appropriate sustainability criteria.

Information Governance

As a critical provider of healthcare services, the EMIS Group operates strict standards when handling sensitive data. Where relevant, suppliers are expected to maintain the highest industry standards (e.g. ISO/IEC 27001:2013 certification, Cyber Essentials (CE) and Cyber Essentials Plus (CE+) certification) and comply with legislation and regulation (e.g. UK GDPR).

Environmental, Social, and Governance

We recognise the value and importance of a robust environmental, social and governance strategy. The framework we are implementing will underpin EMIS Group’s ability to achieve its strategic goals.

One of our key strategic goals is to make sure we have a sustainable supply chain. Ensuring that suppliers have strategies and measures in place to drive ongoing improvements to their sustainability performance, managing their sustainability risks, including human rights, modern slavery and resilience to climate change. 

  • Compliance: EMIS and suppliers shall comply with all applicable laws and regulations in the countries where they operate and international laws and regulations on human rights (ILO’s Fundamental Principles), international trade (export controls, sanctions and reporting obligations), data protection and anti-trust/competition laws shall be complied with.
  • Modern Slavery: UK Suppliers shall comply with the Modern Slavery Act 2015 and all suppliers shall ensure that it and its supply chain are free from forced labour and child labour. The supplier shall ensure that all work is voluntary, and the supplier will not be involved in human trafficking activity or any activity that promotes modern slavery. The supplier shall comply with all laws preventing child labour and only workers who meet the minimum legal age requirements of the country and have completed compulsory education (whichever is greater) shall be permitted to work.
  • Bribery: UK suppliers must comply with the Bribery Act 2010 and all forms of bribery, corruption, extortion or embezzlement are prohibited. There will be adequate procedures in place to prevent bribery in any and all commercial procedures with all suppliers.
  • Conflict of Interest: We expect suppliers to mitigate appropriately against any real or perceived conflict of interest through their work with EMIS. Any potential conflicts must be brought to EMIS’ attention such that appropriate action can be taken.
  • Protection of Intellectual Property: The supplier shall respect intellectual property rights and safeguard EMIS’ and our customers information. The supplier shall manage technology and know-how in a manner that protects intellectual property rights and confidential information.
  • Gifts and Hospitality: Gifts and hospitality must be offered transparently, lawfully and be reasonable and entirely for maintaining good business relations. They must not be offered to obtain or retain business or a business advantage, to reward the provision or retention of business/business advantage or be intended to influence the outcome of decision making.
  • Environmental Permits and Reporting: The supplier must obtain, maintain and keep current all required environmental permits (e.g., discharge monitoring), approvals and registrations.
  • Hazardous Waste Management: The supplier must effectively identify and manage the safe handling, movement, storage, and disposal of chemicals and other substances that pose a threat to the environment, including providing workers with appropriate training on the safe-handling and disposal of hazardous substances.
  • Management of Environmental Impact: The supplier should manage compliance, minimise environmental impact and drive continual improvement through the implementation of a supplier management system.

You can find a link to our strong ethical standards at

4. Net Zero Reporting Standards

The Road to Net Zero

We have committed to reaching net zero for all the emissions we control directly, as well as those we influence, through the products and services we buy from our partners and suppliers. To achieve this ambitious goal, we will require the support of all our suppliers.

In addition to achieving net zero across all scopes by 2045 (at the latest), part of our commitment includes achieving carbon neutrality across our Scope 1 and 2 greenhouse gas emissions (directly and indirectly controlled emissions) by 2030. We expect that our suppliers will commit to their own goals for reaching net zero for Scope 1 and scope 2 emissions by at least 2040.

As part of this journey, all suppliers will be expected to provide targets, emissions and publish a carbon reduction plan for all scope 1, 2 and 3 emissions aligned to our net zero target.

We recognise that not all suppliers are at the same stage of their net zero journey. While many will welcome this approach, some may face challenges. We will continue to work closely with regulators, suppliers and industry bodies to shape our approach and give all suppliers the opportunity to align with our net zero ambition.

Our Expectations

We expect that the supply chain will measure its maturity in the industry using a relevant science-based method, certified by, or working towards certification through an appropriate body, such as the Science Based Targets Initiative. Reporting disclosures through such systems as the Carbon Disclosure Project (CDP; see below) to aid the management of their environmental impacts is recommended. We recognise that other relevant measures and systems are available to use and should be disclosed as part of any submission to us.

Carbon Disclosure Project (CDP)

As disclosed on the CDP website, CDP is a not-for-profit charity that runs the global disclosure system to manage and calculate environmental impacts. In a world where mandatory disclosure is gaining momentum, disclosing through CDP also helps companies get ahead of regulation.

CDP is the gold standard for corporate environmental reporting and is fully aligned with the Task Force on Climate-related Financial Disclosures (TCFD) recommendations.

Sustainable Supplier Framework

In addition, we will also use the following sustainable supplier framework, (which aligns to the NHS sustainable supplier Evergreen framework), creating a single centralised source of information recording how suppliers are aligning with our net zero trajectory.

Suppliers will be able to self-certify their achievement of our requirements, initially voluntarily. This framework will also provide consistency for – and simplify the process of – purchasing products and services from suppliers that reduce the impact on the environment. 

Level 3: Leadership in sustainability

All of level 2, plus 3 out of the 4 of the following:

  • Recognised as a high performer by a global sustainability reporting platform (e.g. CDP A rating, or equivalent).
  • Has publicly set targets in line with our ambitions that are independently verified.
  • Measures the carbon footprint of products and shares that with EMIS.
  • Can demonstrate other proactive actions to show leadership across the UN Sustainable Development Goals (SDG’s).

Level 2: Demonstrating progress towards targets

All of level 1, plus:

  • Demonstrates progress toward net zero goals through quantifiable GHG emission reduction.
  • Demonstrates circular economy principles embedded in the organisation and their product development strategies.
  • Actively engages their supply chain in emissions reduction.
  • Conducts on-site modern slavery audits in hotpot areas of their supply chain.

Level 1: Targets set in line with EMIS ambitions

Meets the minimum expectation of all suppliers, plus:

  • Publicly committed to robust GHG reductions targets for scope 1, 2 and 3 (by 2040 for directly controlled emissions, and 2045 for indirectly controlled) which are publicly verified and disclosed.

Minimum expectation of all suppliers

  • Acknowledge and comply with EMIS Terms and Conditions and the minimum expectations set out in this policy.