Carbon Offsetting 2025 - 27

The NDA Group is committed, through Strategy 5 and the Environmental Policy Statement, to achieving carbon net zero by 2050. This follows established good practice: emissions will be avoided and reduced first, with offsetting used only for residual emissions that cannot be eliminated.

For the NDA Group, offsetting is defined strictly as the removal of carbon dioxide from the atmosphere, not emissions avoidance. This is essential to ensure credibility, avoid greenwashing, and ensure that offsets can legitimately be counted towards net zero.

Nature‑based solutions, such as woodland creation and peatland restoration, currently represent the most mature and credible route available to the NDA Group for carbon removal in the UK. Even with ambitious carbon reduction plans, modelling indicates that residual emissions will remain by 2050.

Early investment in verified carbon removal is therefore necessary to ensure sufficient capacity is available in future and to spread cost and delivery risk over time. Due to the nature of offsetting via carbon removal the NDA is yet to offset any of its carbon emitted but we are building long‑term carbon removal capacity once verified units are converted to carbon credits.

The credits purchased through this sole source justification will continue to grow this long-term capacity. Current trajectories predict the NDA Group will require ~ 100,000 units by 2050.

Units within this purchase (1,500) and previous purchases will equate to approximately 4500 tco2e captured. This purchase is therefore both necessary for near‑term reporting and strategically important in preparing for the long‑term delivery of net zero.

Forest Carbon was selected through the 2020/21 pilot and remains the only supplier that meets all NDA requirements, for the following reasons: • Forest Carbon exclusively delivers projects verified under the UK Woodland Carbon Code, the recognised quality assurance standard for woodland‑based carbon removal in the UK. • Woodland Carbon Code units are independently verified, high‑integrity carbon removal credits, which cannot be claimed until carbon has actually been removed from the atmosphere (typically 10+ years), aligning with NDA policy and best practice. • Forest Carbon can provide credits at the scale required by the NDA Group, with projects located close to NDA sites, particularly in Cumbria, delivering additional local environmental and community benefits. • Alternative providers either do not offer verified carbon removal, do not operate under the Woodland Carbon Code, or cannot deliver projects within relevant geographic catchments. This combination of verified carbon removal, UK delivery, local benefit and scale is unique to Forest Carbon and cannot be replicated by other suppliers currently in the market.