March 2026
Written by Mandy Emery, Sustainability and Social Value Specialist and Social Impact framework lead
Ethical commitments in NHS procurement
Ethical procurement is an essential part of how trusts can deliver value, improve outcomes and meet national policy requirements. Alongside cost and quality, there is an increasing focus on how goods and services are sourced responsibly, with clear expectations across social value, carbon reduction and modern slavery.
Social value
From April 2022, all NHS procurements include a minimum 10% weighting for social value. The updated Social Value Model (PPN 002) aligns with the Procurement Act and sets out eight outcomes linked to the Government’s five missions.
For NHS Trusts, this means ensuring that procurements actively contribute to wider community benefits. Suppliers are expected to demonstrate how they will deliver additional social value relevant to the contract, supporting local priorities such as reducing inequalities, creating opportunities, and improving wellbeing.
Carbon reduction and net zero
The NHS has committed to reaching net zero by 2040 for emissions it controls directly, and by 2045 for those influenced through the supply chain. Procurement plays a key role in achieving this.
For procurements valued at £5 million per annum and above, suppliers are required to submit a Carbon Reduction Plan (CRP). For procurements below this threshold but above the relevant procurement thresholds, suppliers are required to make a Net Zero Commitment.
Updated guidance aligns these requirements with the Procurement Act 2023 and the Provider Selection Regime. The core expectations for suppliers remain unchanged, and the proposed extension of Net Zero Commitment requirements to below-threshold procurements will not be implemented.
For NHS Trusts, this means ensuring that carbon requirements are applied proportionately, in line with current thresholds, and that supplier commitments are measurable and aligned to NHS net zero ambitions.
Modern slavery
The National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 will come into force on 17 May 2026, strengthening the requirements on NHS organisations to address modern slavery risks in procurement.
Under these regulations, in-scope organisations must carry out risk assessments for procurements of goods and services and take reasonable steps to address, and where possible eliminate, identified risks within supply chains.
Updated national guidance on tackling modern slavery in NHS procurement sets out how these requirements should be applied in practice. For NHS Trusts, this means embedding modern slavery considerations throughout the procurement lifecycle, from early market engagement and specification design through to social value and contract management.
Suppliers may be required to demonstrate their approach through Modern Slavery Statements, completion of the Modern Slavery Assessment Tool (MSAT), or delivery of awareness activities through Social Value commitments. However, the emphasis is shifting beyond assurance towards active risk identification, management, and ongoing review.
Get in touch
If you have questions about sustainability, social value or modern slavery requirements in public procurement, don’t hesitate to get in touch: [email protected].