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Confirmed momentum: nature-related integration in investment practices
From September to December 2023, we conducted a survey to understand investors’ position on the challenges of biodiversity integration in their activities, their needs and expectations in order to participate in the fight against nature loss.
It reveals a momentum towards further biodiversity integration in investment decision and portfolio monitoring triggered by International commitments, strengthened regulations, reporting initiatives and supported by the deployment of tools, indicators and databases.
Investors usually tackle nature-related thematics through investment policies on deforestation, controversies related to palm oil, soy, cattle, and through biodiversity restauration. Reducing risk exposure of aggravated ecosystem degradation through sectoral policies is the most commonly shared attribute among investors. Biodiversity integration is mainly motivated by risk mitigation.
This momentum also materialized on the opportunity side with the multiplication biodiversity-related thematic funds yearning to fund biodiversity pressure alleviation or related solution providers. This momentum would benefit from being extended to entire entities reducing their impacts on biodiversity and not only in dedicated thematic funds. Indeed, most investors do not have a firm-wide biodiversity strategy but are undertaking to create one.
Investors are starting to measure their impacts on biodiversity notably in France where LEC 29 article made it compulsory to disclose pressure and impacts contributions with potential use of biodiversity footprints. Target setting, pressure reduction objectives and consequent investment decisions constitute the next logical step to align with global biodiversity objectives as stated in the regulation (LEC 29 article or ESRS E4).
Strong commitments are often impaired by grey areas, inconsistencies and a lack of actions, leaving biodiversity as one of the biggest challenges in sustainable investment. Some aspects seem unexplored, yet crucial, such as assets geospatial analyses and sensitive geographical areas exposure, particularly regarding deforestation. The bottleneck, however, remains the availability and reliability of the data required alongside with internal competencies. Consensus over metrics remains yet to be established as tools and metrics multiply. Nonetheless, that diversity in methodologies and metrics must not stifle action as long as they provide useful insights into an organisation’s interface with nature.
Some practices are set to grow such as the launch of biodiversity thematic funds, the introduction of exclusion policies based on biodiversity criteria and dedicated engagement policies. Biodiversity considerations must be integrated throughout value chains. To achieve this, all companies must be able to report on their impact on nature, using reliable and verifiable data. Sustainable finance instruments can prove effective in highlighting companies nature-related performance and efforts, provided that they are based on material indicators.
Kunming-Montreal COP15 negotiations in December 2022 resulted in the political translation of scientific recommendations into national or regional regulations, thus embarking the private sector in further considering nature and biodiversity, to the least through enhanced disclosure expectations.
Biodiversity disclosure and target setting standards are multiplying (TNFD, ISSB, GRI, SBTN, CISL, ECB guide, EFRAG[1]) and 2023 was packed with guidelines publications, giving market participants a tough job to keep up with market evolutions but also offering materials and approaches to better integrate biodiversity in investment, financing or operational decisions (see our latest article on biodiversity, available here[2]).
An accelerating trend following the steps of climate integration
Source: Natixis GSH based
Existing and incoming regulations have forced and will force investors to report on their impacts on biodiversity. In France, the French energy and climate law, article 29, also referred to as LEC 29 article, made it compulsory, from 2022, for financial companies[3] to disclose (i) their alignment with global biodiversity objectives; (ii) pressure and impacts contributions; and (iii) the mention of the use of biodiversity footprinting[4] tools. The SFDR’s mandatory Principle Adverse Impact (PAI) indicator on biodiversity, indicator n°7, requires that investors disclose activities that negatively affect biodiversity sensitive areas[5]. Added to this, reporting on biodiversity at company level will increase through the Corporate Sustainability Reporting Directive (CRSD) and European Sustainability Reporting Standards (ESRS), which include disclosure requirements and considerations of biodiversity and ecosystems in strategy and business model, if it is a material topic for the entity, through ESRS E4[6].
Voluntary standards are gaining in consistency. Among others, the Science Based Target Network (SBTN) published its draft guidance for Land Science-Based Targets[7] in February 2023 creating three targets aligned with science[8]. In March 2023, the Taskforce on Nature-related Financial Disclosure (TNFD) released the final draft of its Nature-related Risk and Opportunity Management and Disclosure Framework (here). This framework is poised to inspire regulations and corporates in the reporting of their biodiversity impacts and dependencies[9].
These developments have led to the emergence of new approaches in biodiversity-related investments. Investors are facing increasing pressure in their asset management practices, alongside climate change, whether it is regulatory or market driven. According to Environmental Finance[10], biodiversity funds top $1.5bn in Q1 2024 ($300m in 2021) and 24 strategies were identified by Carbon pulse[11] in Q1 2024. Although dedicated funds’ AuMs remain quite low, we have seen a steady growth in new biodiversity-focused equity funds, including launches by Mirova in January 2024, Ofi invest, Xtrackers by DWS, and Redwheel AM in 2023.
From September to December 2023, we conducted a survey to understand investors’ position on the challenges of biodiversity integration in their activities, their needs and expectations in order to participate in the fight against nature loss. It reveals a momentum towards further biodiversity integration in investment decision and portfolio monitoring, particularly since COP15. We gathered 29 answers from investors representing a cumulated €16,857bn in assets under management including 19 Head of ESG research. Key questions were related to investors’ strategies to reduce portfolios’ pressures[12] on biodiversity, measures put in place towards this objective (e.g. assessment of their footprint, launch of biodiversity-related thematic funds, engagement policies and proxy voting), their expectations from companies, projects on biodiversity reporting and, last but not least, their consideration of biodiversity offsetting.
We use these results with caution as the respondents do not reflect the heterogeneity of investors’ advancement on the matter. We believe only most advanced investors responded to the entire survey, thus indicating a bias in our analysis. Nonetheless, these investors still represent a significant amount of assets under management. The following article encapsulates and examines the key insights gleaned from our survey and provides our pieces of analysis.
Overall, we notice investors’ strong commitments and efforts towards biodiversity integration in asset management practices.
Biodiversity integration into asset managers’ strategies
Among 29 investors, 73,3% have or plan to have a strategy engaging on a pathway to reduce their portfolios’ pressures on biodiversity.
On the other hand, actual strategies to reduce pressures on biodiversity beyond sectoral investment policies, are nascent. Investors are starting to measure their impacts on biodiversity notably in France where LEC 29 article made it compulsory to disclose pressure and impacts contributions with potential use of biodiversity footprints. Target setting, pressure reduction objectives and consequent investment decisions constitute the next logical step to align with global biodiversity objectives as stated in the regulation (LEC 29 article or ESRS E4).
When a strategy to reduce pressures on biodiversity is in place, it is mainly through dedicated funds.
Biodiversity-related thematic funds
75% of respondents said their biodiversity integration in investment policies and decision-making was driven by new product marketing, expected financial returns, and/or in terms of communication and display etc..
Nonetheless, only 33% of investors, launched or plan to launch biodiversity-related thematic funds. Most common underlying thematics are related to the food sector, ecosystem restauration, blue economy, natural capital (land/sea) including investments generating carbon credits, precision agriculture [13]or circular economy. Dedicated funds commercialisation can be considered as a first step towards biodiversity integration at corporate scale such that the mismatch between intention 75% and realisation 33% may be explained by a lack of means (dedicated capacity or time to get acquainted with the thematic).
Indeed, if 73% of the firms, out of 29 respondents, have dedicated resources with responsibilities on biodiversity matters (an expert, a team, a setup), this responsibility is often diluted among others translating in one of the ESG/sustainability analysts focusing on biodiversity on top of other responsibilities.
We conducted an analysis on biodiversity funds and did not encounter any bond fund dedicated to biodiversity, but several equity funds. We identified mainly two types of funds dedicated to biodiversity:
- Products & Services related: companies are selected based on their products and services that help reduce pressures on biodiversity or contribute to address biodiversity challenges (e.g., BNP Paribas Ecosystem Restoration, Mirova Biodiversity Solution Equity, Axa WF ACT Biodiversity). The main criteria used is the share of revenues (at least 20 or 30%). And SDG mapping is used to assess positive contributions. Those funds are actively managed, they overweight the Industry and materials sectors (On average, Investment in those two sectors accounts each for more than 20% of the funds’ assets; They also have a high exposure to the consumer staples sector);
- Biodiversity footprint related: the selection is based on companies’ Biodiversity footprint assessments through a biodiversity score, mainly using the Mean Species Abundance [14](MSA) metric (e.g., BNPP Easy ESG Eurozone Biodiversity Leaders PAB ETF). Those funds are mainly ETF/Index funds or quantitative funds and use a Best-in-Class approach.
Funds can combine both approaches: e.g., Ofi Invest Biodiversity Global Equity (cf below)
Ofi Invest Biodiversity Global Equity selects companies that are committed to managing and reducing their negative impacts on biodiversity and those that provide solutions for conservation; Ofi Invest:
- Measures the degree of exposure of sectors to the 5 major pressures of biodiversity Low/ medium/ high according to the ENCORE standard
- Developed a proprietary score that for each company measures the company’s contribution to each of the 5 major pressures (land and sea use change, resource overexploitation, climate change, pollution, invasive alien species); a bonus is granted to companies that provide solutions for the protection or restoration of biodiversity
- AUM: €68.6M as of 2024, April 8th
- The fund is classified Article 8 under SFDR
Biodiversity footprint quantification challenges
Just like initiatives and standards, indicators are numerous and differ on their purpose (risk exposure, impact measurement), methodological approaches (field studies, estimated impacts), usage (reporting, decision-making, engagement), scale of analysis (asset, corporate level) and underlying metrics (STAR, MSA, PDF, BII, BIM for example)[15].
When asked about their quantification of biodiversity footprint, 36%, among 28 investors, are currently using or implementing synthetic biodiversity footprints to report and understand the impacts of their portfolios. The Mean Species Abundance (MSA) is the most widely shared metric. MSA metrics are quite popular both for funds dedicated to biodiversity and entire portfolio assessments for they provide an aggregated measure of a company’s biodiversity impact based on economic and physical flows on a large number of listed companies.
The heterogeneity and the distribution of investors’ practices show that synthetic indicators (MSA) is leading a race on biodiversity-related indicator. That position may not be definitive as TNFD and CSRD may give investors with enough raw data not to use synthetic indicators in the future. Consensus over metrics remains yet to be established as tools and metrics multiply. Nonetheless, that diversity in methodologies and metrics must not stifle action as long as they provide useful insights into an organisation’s interface with nature.
Investors are moving relatively fast in integrating biodiversity metrics in portfolio management. The first biodiversity dedicated funds using SDG mapping are progressively integrating footprint4 indicators (e.g., AXA). 61% assess or are in the process of assessing their funds’ biodiversity footprint, even though scopes differ from one to another. Mirova assesses 100% of its listed equity portfolio in MSA.km². For Natural capital dedicated assets, two categories of indicators will be reported such as (i) Species counting through DNA sampling and acoustic monitoring (ii) ecosystem integrity (habitat, biodiversity credits, satellite imaging). EU investors and especially French ones seem more advanced, mainly due to the French energy and climate law (LEC29).
Biodiversity-related data collection remains quite low overall as less than half of respondents (43%) buy data on companies/projects they invest in. We can expect it to grow in the coming years as regulation requires it.
Investors’ strong commitments are often impaired by grey areas, inconsistencies and a lack of actions, leaving biodiversity as one of the biggest challenges in sustainable investment.
Biodiversity sensitive geographies and geospatial data exploitation
When asked about lenses to integrate biodiversity-related criteria in asset management practices, investors indicate choosing ESG analysis by default for high-stake sectors (agriculture, energy, infrastructure, and fashion) and companies related to plastic, pesticides and fertilizers or hazardous chemicals.
The next challenge for most advanced investors relies on the integration of geographic parameters in biodiversity assessments (Richness, criticality, etc.) at both corporate and asset level. Investors themselves do not yet seem to consider a presence in sensitive geographies to be relevant. Yet it is in these sensitive geographies that consumer goods contributing most to local deforestation or biodiversity degradation are produced.
Only 21% use geospatial data (KBA, IUCN, Ramsar convention, etc.) and 14% field studies as part of due diligence processes (mainly due to the nature of investments : asset vs corporate equity).
None of investors expect companies to locate their assets, even though it constitutes a necessary step to measure the state of ecosystems where companies operate. While location is taken into account in the financing of assets as part of the due diligence process, this is not the case for financing at corporate level; when investing in corporate bonds or equities, no attention is given to the corporate’s assets geographical positioning.
Locating asset is a necessary step to understand a financial institution’s risk exposure, particularly when ecosystems and the services they provide are continuously degrading. Indeed, as for climate physical risks, geospatial data is necessary to identify a company’s assets at risk of dysfunctional ecosystems upon which they rely. Companies exposed to degraded ecosystems are more likely to experience ecosystem services failures that may impact operations and lead to stranded assets.
Data providers have been conscious of this appearing need to geolocate assets and now propose consolidated geospatial data for a large number of corporates (S&P and MSCI for example).
Imported deforestation is the sinews of war as a large proportion of the consumption of finished products in the European Union, and more widely in the Northern economies, comes from the Southern economies where the standards of responsible production, deforestation and environmental policies are not as demanding as the ones established or to be established in the European Union.
Published in June 2023, The EU Regulation 2023/1115 aims to prohibit, from the end of 2024, the placing on the market or export from the European market of products that have contributed to deforestation or forest degradation after 31 December 2020. The products covered by the new legislation are livestock, cocoa, coffee, palm oil, soy and wood, as well as products that contain them or have been fed or manufactured from them (such as leather, chocolate and furniture), as set out in the Commission's initial proposal. The regulation could also apply to financial institutions in the future, "where their services are likely to support activities directly or indirectly linked to deforestation, forest degradation and forest conversion". Here again, the lack of data on the traceability of inputs and the location of infrastructures complexifies investors' ability to take account of sensitive geographical areas in their biodiversity impacts.
TNFD goes beyond deforestation to tackle priority ecosystems through its core indicator "quantity and share of natural commodities sourced from priority ecosystems[6]" as a first attempt at spatializing risk exposure.
Exclusions and weighted exposures
Only 16% consider exclusions of and over/under weight exposures to companies related to plastics pesticides and fertilizers or hazardous chemicals as relevant avenues to integrate biodiversity-related criteria. We believe exclusion policies, whether sectorial, geographical or practices-oriented, and weighted exposures are effective action levers to get the players involved in reducing their pressures on nature.
We can foresee growing biodiversity-related exclusions or weighted exposures on companies with revenues related to deforestation exposed commodities, plastics, biocides (pesticides, insecticides, or other chemical substances susceptible to have a negative impact on the environment). Most advanced sustainable investors already commit on such thresholds. A parallel can be drawn with climate-related exclusions on exposure to coal and even fossil fuels for the most engaged investors.
Necessary disclosure
The urgent necessity to reduce pressures on nature and to improve efficiency and consistency of actions has repercussions throughout the value chain, as needed actions involve investee companies and projects. Investors ought to report with granularity and transparency on their impacts on biodiversity, but this can’t be done unless investee companies do the same.
Investors rely on their investees to better understand their impacts on biodiversity and risk exposure. Investors expect from companies to:
- engage and report on pressures on biodiversity (57%), including using TNFD;
- use regulatory indicators such as SFDR PAIs, ESRS (29%)
- monitor their own biodiversity footprints (14%);
Some practices are set to grow such as the launch of biodiversity thematic funds, the introduction of exclusion policies based on biodiversity criteria and dedicated engagement policies. Though there would be a strong merit to extend biodiversity approaches to entire entities and not only in dedicated thematic funds.
Integrating biodiversity-related issues into investment practices would also imply that investors implement biodiversity-related engagement policies or proxy voting, which only 55% of respondents currently do. Engagement policies include biodiversity charter, recommendations from investors coalitions, integration of biodiversity in the corporate governance and voting policies.
Sustainable finance instruments
Sustainable finance offers instruments to tackle nature-related issues and help reduce pressures on biodiversity, based on the same model as those used for climate mitigation. However, the use-of-proceeds approach does not seem to be the best-fit for purpose as halting biodiversity loss does not necessarily require large capital investments, while transformation in business models, operational processes and tools are more at stake.
Yet, we notice a growing interest among sustainability-focused issuers for biodiversity conservation. According to Sustainable Fitch[17], about 16% of GSS bonds issued in 2023 included biodiversity conservation as an eligible category of expenditure, up from just 5% in 2020. However, this figure does not demonstrate an increase in funds’ allocation towards biodiversity conservation, but only an increase in the number of frameworks integrating biodiversity category. As an order of magnitude, in 2019, only 0.5-1.0% of green bonds’ proceeds were allocated to direct or indirect biodiversity protection measures[18].
However, sustainable finance instruments, although they went unnoticed, already integrated nature-related components without highlighting their benefits on nature or biodiversity. As mentioned in our previous article (here), around 20% of sustainability-linked bonds and loans integrated KPIs related to:
- Pressures[19] on biodiversity: be it resource exploitation (water, waste, recycling rates), Pollution (air or water pollution), etc.,
- Practices proven to be reducing pressures on biodiversity: product mix evolution or % of certified commodities (RSPO, FSC, organic) sourced.
- Ecosystems state and condition measurement which can be (i) risk exposure metrics (commodities sourced from priority ecosystems) not necessarily leading to impact on an ecosystem or (ii) impact-related such as deforestation rates (essentially for countries).
Nonetheless, the link between these KPIs and their direct or indirect nature-related benefits has rarely been highlighted in financings’ documentations. If it is commonly admitted that these are beneficial, their benefits have hardly ever been quantified nor demonstrated material from a nature/biodiversity perspective. Sovereigns, regions and municipalities have been contributing the most to biodiversity management financing through green bonds. Uruguay used the native forest area indicator in its SLB framework (available here) as a biodiversity-related KPI to contribute to SDG 15 “Life on Land”.
Now that investors use synthetic indicators to monitor their footprints, it is up to issuers to better demonstrate how their funding and corporate strategies contribute to reducing their biodiversity footprints. Indeed, 66% of respondents consider pressure-related KPIs demonstrated material on biodiversity to be the right way to integrate nature in sustainability-linked bonds.
Our key recommendations for nature-related sustainability-linked bonds are to (i) use pressure-related or practice-based KPIs demonstrated material for the corporate, (ii) monitor impacts and progress through a biodiversity footprint and (iii) align instruments with EU Taxonomy non-climate-related objectives when possible.
Offsetting measures[20] seem to be avoided by investors, aware of controversies raised: among 21 investors, 71% would not invest in biodiversity offsets to compensate their portfolio negative impacts on biodiversity. It seems that investors don’t believe in offsetting as an efficient and reliable way of managing the issue but more of a “last resort option”. It does not mean they would not invest in underlying nature-based solutions although they remain to be convinced of the usefulness and feasibility of offsetting when it comes to biodiversity.
Strong commitments to biodiversity related coalitions, market initiatives
We also notice the strong commitment towards initiatives related to biodiversity. Among 18 investors, 15 (83%) are members of the TNFD, which develops a set of disclosure recommendations and guidance that encourage and enable business and finance to assess, report and act on their nature-related dependencies, impacts, risks and opportunities, 2 mentioned their commitments to Act4Nature, which consists on mobilising companies in favour of biodiversity through pragmatic commitments supported by their managers and 2 (11%) are members of B4B+, created by CDC Biodiversité to build and test the Global Biodiversity Score (GBS). Other initiatives are Finance for Biodiversity, NA100, PRI Nature Group, Ceres Nature Group, FAIRR, ChemSec, PBAF.
Is the plurality of initiatives undermining or supporting concrete actions? We notice that biggest investors cumulate involvements in numerous initiatives while others struggle to make commitments.
Nature-related initiatives proliferation underscores the desire to better integrate biodiversity in investment decisions and also demonstrates the complexity of the matter, each initiative having its own purpose (by actor typology, engagement / voting policies, nature-related strategies, measurement, etc.).
Integrating biodiversity into governance: a “Say on Nature”?
One might question when will biodiversity be integrated at governance level (as for climate) in investment decision or variable compensation for example. On the same basis than “Say on Pay” and “Say on Climate”, could we imagine a “Say on Nature” where shareholders would be consulted on biodiversity-related governance policies? Would biodiversity rather be integrated into Climate Plan or get its own plan and vote?
Footnotes
[1]Taskforce on Nature-related Financial Disclosure, International Sustainability Standards Board, Global Reporting Initiative, Science Based Target Network, Cambridge Institute of Sustainability Leadership, European Central Bank, European Financial Reporting Advisory Group)
[2] “Climate is dead, long live biodiversity”, February 8th, 2023, Natixis GSH, available here
[3] Article 29 LEC concerns financial players (portfolio management companies, insurance, provident institutions, credit institutions and investment firms providing investment advice; reinsurers; investment funds, supplementary occupational pension funds, Caisse des dépôts et des consignations). The threshold for application is €500m of assets under management and/or balance sheet.
[4] The Partnership for Biodiversity Accounting Financials (PBAF) defines a biodiversity footprint as the ‘quantified impact of a portfolio, asset class, project or company measured in terms of biodiversity change as a result of production and consumption of particular goods and services’. PBAF adapted this definition from the Institute for European Environmental Policy (IEEP) definition to specify the importance of a quantified impact. The lack of consensus on the definition of biodiversity footprinting creates ambiguity for those trying to understand the landscape. Mainly, biodiversity footprints are just one way to provide decision useful insight into an organisation’s interface with nature (TNFD).
[5] Defined as 'the share of investments in companies with sites or operations located in or near to biodiversity-sensitive areas, which negatively affect those areas. ‘Biodiversity-sensitive areas’ means Natura 2000 network of protected areas, UNESCO World Heritage sites and Key Biodiversity Areas (‘KBAs’), as well as other protected areas.
[6] See in the “Decarbonizing is easy: beyond market neutrality in the ECB’s corporate QE” paper published by The New Economics Foundation, UK universities, Greenpeace in October 2020 here.
[7] Companies falling under the scope would have to report on (i) transition plan and consideration of biodiversity and ecosystems in strategy and business model, (ii) processes to identify and assess material biodiversity and ecosystem-related impacts, (iii) policies, (iv) actions and resources and (v) targets and impact metrics related to biodiversity and ecosystems and (vi) anticipated financial effects from biodiversity and ecosystem-related risks and opportunities.
[8] 2023 technical guidance (here) targets include: zero conversion of natural ecosystems by [target year], compared with a 2020 baseline, will source 100% of volumes of commodities from areas known to be conversion-free from 2020*, commits to reduce absolute agricultural land footprint, commits to reduce agricultural land footprint intensity.
[9] (i) Halting conversion of natural ecosystem; (ii) Land footprint reduction; (iii) Landscape engagement.
[10] It established a set of core disclosure metrics to help comparability within and across sectors on areas of high priority. These are divided into: (i) core global metrics on climate change, land, freshwater, ocean-use change, pollution, resource use and (ii) core sector metrics (draft available for agriculture and food sector) on nature-related risks and opportunities.
[11] Biodiversity funds top $1 billion for first time, Feb 2024, Environmental Finance, available here.
[12] Biodiversity funds pass $1.5 bln in 2023 with eight fund launches, Mar 2024, Carbon Pulse, available here.
[13] The Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) identifies five main pressures on biodiversity, which are (i) Land/sea use change, (ii) Overexploitation, (iii) Climate change, (iv) Pollution and (v) Invasive alien species.
[14] Precision agriculture (PA) is the science of improving crop yields and assisting management decisions using high technology sensor and analysis tools.
[15] See our previous article here on the matter for a definition of the Mean Species Abundance metric (MSA).
[16] Mean Species Abundance (MSA) and Potentially Disappeared Fraction (PDF) are used to assess the state of an ecosystem in the cases of impact assessment and Life Cycle Analysis. They can be used at product, corporate or global level. Number of individuals and Species Threat Abatement and Restauration (STAR) are used to measure the richness, evenness and heterogeneity of living organisms in an area when trying to implement compensation measures the impacts on species or restoration actions. Biodiversity Intactness index (BII) and Biodiversity Impact Metric (BIM) are used to rank an area according to rarity, diversity, fragmentation, habitat condition, resilience, threats, and ecosystem processes in the cases of impact assessment and Life Cycle Analysis or supply chain and impact assessments. Other indicators$ exist but more oriented on thematic such as deforestation free commodities, surface of regenerated or restored land, palm oil free products.
[17] Sustainable Fitch, “Biodiversity in ESG: State of the Sustainable Finance Market”, October 2023, available here.
[18] Deutz et al. (2020), Financing Nature : Closing the global biodiversity financing gap, available here.
[19] Definition of pressure-related KPIs based on IPBES pressures.
[20] Biodiversity offsets are measurable conservation and restoration outcomes designed to compensate for adverse and unavoidable impacts of projects, in addition to prevention and mitigation measures already implemented. (IUCN, here).
