CORTRIUM
Sustainability Policy
1. Purpose
Cortrium is committed to developing and supplying safe, effective and innovative medical devices, software and ECG analysis services while managing environmental, social and governance impacts responsibly.
This Sustainability Policy establishes Cortrium’s commitments to environmental responsibility, social responsibility, ethical business conduct and continual improvement. The policy complements Cortrium’s Quality Management System and supports implementation of the Carbon Reduction Plan and related sustainability objectives.
2. Scope
This policy applies to Cortrium employees, management, contractors and consultants; Cortrium products, software and services; operational activities under Cortrium’s control; strategic suppliers, contract manufacturers and service providers where relevant and proportionate; and relevant upstream and downstream value-chain activities considered in Cortrium’s sustainability program.
3. Our Sustainability Principles
Cortrium recognises sustainability as an integral part of responsible medical device and healthcare service management. The sustainability program is based on environmental responsibility, social responsibility, ethical and responsible governance, evidence-based and risk-based decision-making, and continual improvement.
Patient Safety, Product Quality and Regulatory Compliance
Environmental improvements shall never compromise patient safety, intended use, clinical performance, device performance, usability, cybersecurity, product quality, regulatory compliance or risk acceptability.
Sustainability considerations shall be evaluated alongside applicable quality, risk-management, design-control and regulatory requirements. Lower-impact alternatives may be implemented only where they maintain or improve the safety, effectiveness, performance and compliance of Cortrium products and services.
Integration with the Quality Management System
Sustainability is managed alongside Cortrium’s Quality Management System. Sustainability objectives, greenhouse gas performance, supplier information, improvement actions and relevant risks and opportunities are followed through Cortrium’s monthly Management Meetings and Annual Wheel. ESG/sustainability is reviewed at least annually in February and additionally where open actions or material changes require.
Evidence-Based Sustainability
Cortrium bases sustainability decisions and public statements on objective evidence, recognised methods and documented assumptions. Relevant evidence may include greenhouse gas inventories, Life Cycle Assessments, supplier reports, utility and logistics data, employee surveys and environmental performance indicators.
4. Environmental Commitment
Cortrium is committed to reducing the environmental impact of its operations, products and value chain through measurable objectives and continual improvement. Cortrium will:
- establish and maintain a corporate greenhouse gas inventory covering Scope 1, Scope 2 and relevant Scope 3 emissions in accordance with the GHG Protocol, using 2025 as the approved corporate baseline year
- maintain and review a Carbon Reduction Plan and work towards the Executive Management-approved Net Zero target of 2045
- measure, monitor and reduce greenhouse gas emissions where technically feasible and proportionate
- apply documented activity data, emission factors, assumptions, exclusions and allocation methods
- support efficient use of electricity, heating, water and other resources
- minimise waste and support reuse, recycling and appropriate end-of-life management
- optimise transport and logistics where operationally appropriate, including shipment consolidation
- consider environmental performance when selecting or reviewing strategic suppliers and service providers
- comply with applicable environmental legislation and contractual commitments
- review environmental objectives and performance at least annually
5. Product Sustainability
Cortrium recognises that a significant proportion of the environmental impact associated with its medical devices occurs in purchased goods, electronic components, outsourced manufacturing and other value-chain activities. Cortrium will therefore:
- apply life-cycle thinking during product development and significant change activities
- use Life Cycle Assessment and other environmental evidence to identify material hotspots and improvement opportunities
- consider material selection, component choice, durability, repairability, product lifetime, recyclability and end-of-life implications where relevant
- assess environmental implications for significant product, packaging or manufacturing changes where identified hotspots may be affected
- maintain protective packaging at the level necessary to safeguard product integrity, transport protection, regulatory compliance and patient safety
- review lower-impact alternatives when technically feasible and proportionate
- retain the existing solution where no safe, effective and compliant lower-impact alternative is available, and review the decision during future design or supplier changes
6. Social Responsibility
Cortrium is committed to maintaining a safe, inclusive and responsible working environment. Cortrium will:
- respect internationally recognized human rights
- prohibit modern slavery, forced labour, human trafficking and child labour
- maintain equal opportunities and fair employment practices
- promote employee health, safety and wellbeing
- provide training and development appropriate to employee responsibilities
- support flexible working arrangements where operationally feasible
- contribute positively to healthcare through safe and effective medical technology and services
7. Responsible Supply Chain
Cortrium recognizes that its most significant environmental opportunities are expected to arise through supplier engagement, product lifecycle improvements and procurement decisions rather than through direct operational emissions. Cortrium applies a risk-based and proportionate approach to strategic supplier sustainability and may:
- consider environmental policies, environmental management systems and sustainability reports
- request greenhouse gas, product carbon footprint or Life Cycle Assessment information
- consider responsible sourcing, human rights, modern slavery, conflict-minerals, REACH and RoHS information
- review environmental information from manufacturing, logistics, cloud infrastructure and other material service providers
- encourage suppliers to improve environmental performance and data transparency
- retain supplier evidence where it is relied upon for Cortrium’s greenhouse gas inventory, Carbon Reduction Plan, customer reporting or supplier evaluation
8. Governance
Cortrium is committed to conducting business with integrity, transparency and accountability. Cortrium will:
- comply with applicable legislation, regulations and contractual sustainability requirements
- maintain appropriate policies addressing anti-bribery, corruption, modern slavery and ethical conduct
- assign clear responsibilities for sustainability data, objectives and actions
- approve the Sustainability Policy, Carbon Reduction Plan and material sustainability commitments through Executive Management
- establish measurable sustainability objectives and review performance at least annually
- maintain records sufficient to support reported emissions, targets and public claims
- ensure public sustainability statements remain consistent with approved evidence, boundaries and known limitations
9. Current Sustainability Initiatives
Cortrium currently supports sustainability through initiatives including:
- operation from a shared office facility with owner-operated rooftop photovoltaic generation. For greenhouse gas reporting, shared electricity and other relevant utilities are allocated to Cortrium using a documented and evidence-based allocation methodology. Renewable-energy attributes are only claimed where supported by appropriate evidence
- no company-owned vehicle fleet and no identified direct combustion or refrigerant sources under Cortrium’s operational control
- an electronic Quality Management System using digital documents, records, training, approvals and electronic signatures, with printing limited to exceptional situations
- consolidation of shipments where operationally practical
- flexible working arrangements for eligible employees
- electric vehicle charging facilities available at the shared office for employees and visitors; charging is included in the facility’s overall electricity consumption and is not reported separately unless Cortrium-specific charging data become available
- participation in approved electronic, battery and other producer-responsibility or recycling schemes
- participation in waste-separation and recycling arrangements provided through the shared facility, including separate food-waste collection where available
- product Life Cycle Assessment and use of identified hotspots in supplier and design activities
- continued review of packaging while maintaining necessary product protection
- collection and review of sustainability information from significant manufacturing, logistics and digital service providers where available
10. Continual Improvement
Cortrium recognises that sustainability is an ongoing process and that lower-impact technologies, supplier capabilities, reporting methods and regulatory expectations will evolve over time. Cortrium will:
- review sustainability objectives and KPIs at least annually
- review the Carbon Reduction Plan and greenhouse gas inventory at least annually and following material organisational or operational changes
- periodically reassess environmental risks, opportunities and significant value-chain categories
- review technological and supplier developments that may offer safe and compliant environmental improvements
- plan, assign, monitor and close approved sustainability actions
- engage employees, management, suppliers and customers where appropriate
11. Related Documents
- Carbon Reduction Plan
- Modern Slavery Statement
- Business Code of Conduct
- Annual Greenhouse Gas Inventory
- Product Life Cycle Assessment reports
12. Approval and Review
This policy is approved by Executive Management and reviewed at least annually or following significant organisational, operational, regulatory or sustainability-related changes.