Reports contain a variety of detail on the extent of Board responsibility. Many organisations assign accountability for managing climate and nature risks to dedicated committees (most commonly sustainability committees). There is rarely a nature subject matter expert represented at Board level.

Some companies integrate TCFD and TNFD Governance sections, as Board members often focus on climate and nature-related issues together. Organisational approaches to climate and nature are typically presented in the form of an overall environment or sustainability strategy, policy or programme which is reviewed by the Board annually. Reports indicate that, for many companies, there are more frequent updates through sustainability senior management or committees.

The reports analysed generally include diagrams of Board structure and tables indicating individual or committee level responsibility for a variety of sustainability topics, many of which have relevance to nature.

For example, Legal & General delegate accountability for environmental risks to the Group Environment Committee. The report outlines their key decisions and discussions throughout the year (Figure 4). Oxbury Bank’s Board responsibilities for nature-related matters are described in detail in Figure 5.

There is a large variation in management responsibility for nature-related issues. Many organisations have established multiple working groups of senior management, each with responsibility for different aspects of nature. These groups can contain chief risk or regulatory officers, financial officers, impact and sustainability officers who are responsible for both climate and nature. Some organisations have biodiversity groups or ‘centres of excellence’.

Assessment and management responsibility for nature-related matters is often split – with risk, sustainability and regulatory managers assessing and monitoring risks, and divisional leaders managing and incorporating risk factors into their relevant business units. Most reports include specific examples of management roles and their relevant nature-related responsibilities.

For example, United Utilities has a Director of Better Rivers Programme with responsibility to reduce the impact of storm overflow and improve river water quality (pg. 49 of United Utilities report). More broadly, United Utilities embeds nature within existing governance and regulatory structures, with nature accountability sitting with the CEO. Similarly, Anglo American incorporates progress against the group’s biodiversity management programme into a CEO scorecard on a quarterly basis (pg. 58 of Anglo American report). Two reports indicate that responsibility for sustainability (and by extension nature) is within a vertical of the business – one of which is the President of Supply Chain (GSK, pg. 62) and the other the Chief Sustainability Officer (Drax, pg. 57).

Almost all of the reports flag human rights policies or statements, and some report on customer or local community surveys and workshops. None of the reports contain consultation results from Indigenous Peoples, and few reports provide detail on the Board’s oversight of the output from stakeholder engagement activities.

The reports containing engagement activities tabulate stakeholders and detail outcomes from engagement processes (often surveys, workshops and conferences). Some reports contain case studies with specific examples of engagement activities.

For example, Severn Trent publish a five-year business plan (including a nature strategy) and disclose the impact that the business plan will have on different stakeholder groups based on engagements, and how these factors influence decision-making (Figure 8). Oxbury Bank disclose engagements with stakeholders across their value chain on natural capital to identify areas of collaboration (Figure 9).

Reports tend to have more detail on dependencies and impacts versus risks and opportunities. Nature-related dependencies, impacts, risks and opportunities can be organised in different ways including by biome (GSK, United Utilities e.g. water, land, ocean), country (GSK) and sector (Federated Hermes, especially relevant for the banks and asset managers who have considerations across sectors). Climate Asset Management group dependencies by the high-level benefit delivered to the business (Figure 11).

While some reports disclose at site level, the majority of reports do not allocate disclosures to particular locations, instead citing dependencies, impacts, risks and opportunities at an organisational level.

Where disclosed, dependencies, impacts, risks and opportunities are tabulated. Some disclosures integrate nature- with climate-related considerations (see Figure 12 – Legal & General) whereas others keep climate and nature separate (see Figure 13 – Federated Hermes). Legal & General considers timeframes associated with risks and opportunities (see Figure 12).

Most reports contain high-level narratives on nature strategies or transition plans, often incorporated into pre-existing climate strategies or transition plans. For example, British American Tobacco’s report details a 10-year strategic roadmap to promote nature-positive leadership (pg. 85).

Some reports incorporate details on funding which will be allocated to nature restoration projects. For example, United Utilities’ report highlight its AMP8 business plan (Figure 15) with multiple nature-related funding targets.

Some organisations provide more detail on the effect of nature on their business model which then informs elements of their strategy. For example, Oxbury Bank maps dependencies and impacts to loan book products, whereas Federated Hermes discloses the effect of nature-related dependencies, impacts, risks and opportunities on product development, financial planning and alignment across the business with third party suppliers (Figure 16), and has report headings aligned to disclosure recommendations.

Most reports contain climate scenario analysis in line with TCFD reporting requirements. Two organisations (Legal & General, United Utilities) discuss nature-related aspects or outcomes of their scenario analysis. Some reports contain a statement indicating the intention to explore scenarios in future disclosures. Legal & General’s climate modelling incorporates explicit land use modelling and examines the impact of climate scenarios on nature-related variables such as the Biodiversity Intactness Index as seen in Figure 18. United Utilities integrates scenario across multiple factors including climate and water availability, with an adaptation plan as seen in Figure 19.

Some reports also mention that evolving risk management processes will contribute towards business resilience. Oxbury Bank discusses some of the drivers of the resilience of their business including diversification across commodities and locations within their lending portfolio.

Few organisations disclose asset locations in their reports. Those that do range from site-specific locations to country-level disclosures. For example, Oxbury Bank showcases their long-term loan exposure throughout the UK, by commodity and location (Figure 22). Anglo American indicates site country, and in some cases city (Figure 21). GSK mentions the country of their manufacturing sites (pg. 71).

If locations are disclosed, reports typically use maps to visualise these locations. In other cases, countries are listed within a narrative.

Of the reports that disclose against this pillar, most start with a high-level risk assessment, often using the ENCORE tool. These typically overlay data on the materiality of specific impacts and dependencies for an activity with asset locations. This is mentioned by many reports to be the ‘Locate’ and ‘Evaluate’ stage of the LEAP approach. Where used, asset location varies in granularity with some reports performing assessments at the national or regional level.

Some reports mention natural capital baseline assessments. Materiality assessments are disclosed to support prioritisation of dependencies, impacts, risks and opportunities for further analysis. Drax indicates progress against each stage of the LEAP process for their evaluated sites (Figure 24) and provides a case study on its Scottish Hydro pilot. Drax’s report also expresses intent to extend the assessments globally.

Most reports describe some form of engagement process with clients, suppliers, or investees etc. As part of this engagement activity some mention site monitoring through surprise visits or provision of guidance on new expectations such as additional data, training or certification requirements.

Some companies list strategies, policies, programmes or funds (e.g. Federated Hermes, Figure 27) that are specifically allocated to nature. Similarly to Strategy disclosure pillar A, some companies map management processes to biome (e.g. GSK, Figure 28) or business area. Other reports disclose priority actions against key risks.  Landsec has developed a guide for suppliers and partners that outlines core nature requirements and maps these to development stages (see Figure 29).

Most disclosures, especially those integrated into annual reports, have a section or narrative on existing risk management processes. In some cases, integration of nature considerations is through principal risk reporting and mitigation approaches (e.g. Severn Trent, Figure 31).

Some reports include case studies to provide examples of integration and some structure discussions of risk management by business unit or area. A few reports combine climate and nature risk management processes. Drax mentions the development of a nature-related risk register (pg. 57). Oxbury Bank uses materiality of nature-related risks as a threshold for integrating risks into overall risk management processes (see Figure 32).

The reports considered tend to disclose metrics associated with dependencies and impacts rather than risks and opportunities. Where risk and opportunity metrics are disclosed, these tend to be qualitative as opposed to presented in monetary terms.

Different dependencies, impacts, risks and opportunities are material for each company and therefore, companies will naturally focus on different metrics. For example, Federated Hermes and Legal & General both use a metric linked to the share of their portfolio exposed to high deforestation risk (see Figure 34 and Figure 35). Severn Trent discloses the total investment to date in nature-related dependencies and impacts as £549m (pg. 43).

Reports typically focus on impacts metrics over dependency metrics. They disclose nature-related impacts alongside emissions data, most commonly water and waste footprints (e.g. Federated Hermes, Figure 38; GSK, Figure 38; Drax, Figure 39; United Utilities, Figure 40). Reports include metrics such as:

• Percentage of deforestation-free wood used in supply chains;
• Soil organic matter (compared to potential);
• Animal mortality rate;
• Presence of high biodiversity areas;
• Water storage capacity percentage;
• Mean species abundance;
• Habitat change
• Pulp and paper materials sourced with low-risk deforestation, and;
• Hectares of forests planted.

Some reports also include the number of nature-specific engagements with suppliers or clients.

10 out of 11 companies have set nature-related targets within reports. Targets focus is evenly split between processes (i.e. a target to establish a nature strategy, or upskill a group within the organisation) and impact or dependency metrics (i.e. to reduce nature impact). The most common nature-related targets are for water or deforestation. As to be expected, where companies have targets, the metrics underpinning those targets vary between sectors.

For example, as a tobacco company, British American Tobacco’s targets (Figure 42) are supply chain commodity based, whereas United Utilities has a target focused on leakage reduction (Figure 43). United Utilities also has a natural capital performance commitment between 2020-2035, measured by demonstrating additional value created through ecosystem services for customers and the environment. Alternatively, Federated Hermes has set process targets around engagement (see Figure 44) and has committed to assess and disclose public markets, infrastructure and real estate portfolios for nature-related impacts, dependencies, risks and opportunities by 2026.

Some reports contain targets to be ‘nature positive’ or for their activities to result in ‘biodiversity net gain’. For example, Drax defines nature positive as “going beyond avoiding or minimising impacts and finding ways to restore and enhance ecosystems” and commits to demonstrating nature positive outcomes by 2027 (pg. 56). Severn Trent has a target to deliver fifteen percent biodiversity net gain for its capital schemes (pg. 51). Landsec has set targets to achieve biodiversity net gain across its operational assets and developments, (see Figure 45) as well as setting targets for resource efficiency across water and materials.