Proposals are afloat to design and create guidelines and mechanisms for nature-related financial disclosure. The origins of this thinking come from similar efforts that have been ongoing for a number of years for climate. Care should be taken to learn from these efforts and ensure that the full range range of possible interventions at the intersection of finance and biodiversity are identified and evaluated, rather than blindly imitating a partially successful past initiative.
Context and limitations of the Task Force for Climate-Related Financial Disclosure and climate transparency
Between 2015-2017 the Financial Stability Board (FSB) created a set of recommendations on climate-related financial disclosures for companies. The FSB Task Force argued that access to genuine public information regarding the exposure of companies to climate risk would enable investors to reward those that acted to reduce this risk and punish those that did not. While the resulting framework is still largely voluntary, the thinking is that it should rapidly become an inescapable standard.
Transparency is a well-established tool for the improvement of corporate performance, and there are few downsides to understanding more about corporate strategy and responsibility. At the same time, it is only one of the arrows in a crowded quiver of measures to address the given public policy purpose – whether applicable to the transition to corporate climate responsibility, or to a no net harm position on biodiversity and ecosystems.
When Mark Carney, Governor of the Bank of England and Chair of the Financial Stability Board, determined that climate change represented a macro-prudential risk to the financial system – a risk to financial stability – he was keen to find ways to address that risk. He had several options, for example to explore strategic policy reforms that would give climate risk higher importance, or to explore the field of legal and moral liability for climate damage. In the end, a purely risk-based effort, based on the contribution that corporate transparency could bring, was the only consensus he could secure from the G20 and therefore the only mandate he could bring to the FSB. In alliance with Michael Bloomberg, the Task Force on Climate-Related Financial Disclosures (TCFD) was established in December 2015 and released its recommendations in June 2017.
TCFD is seen as an important step in inducing corporations to take climate seriously, but it represents a modest contribution when measured against what must happen if these corporations are genuinely to rise to the challenge. Nobody, including Carney himself, thinks that we can rest on our laurels and consider the job essentially done. Indeed, the latest IPCC report, coupled with the failure of the Madrid COP, suggests we are far from our goal.
It therefore seems odd that an initiative to strengthen genuine action for nature conservation should wish to imitate TCFD, proposing a Task Force that would examine standards for nature-related financial disclosures on the part of corporations.
Learnings to be applied to nature
While greater disclosure of how corporations are addressing nature-related risk would be a useful and welcome tool, there are several hesitations to be addressed in giving priority to this approach. We hope the development of any TNFD structure that may be proposed in the run up to the CBD COP in Kunming will be strengthened and improved as a result of these comments.
If a task force of this sort is to be established (let’s call it TNFD), it is presumably not working under the constraints that govern G20 consensus-building. Should key governments agree to champion it and a proper home found to house the Secretariat (i.e. TCFD was housed in FSB), a lighter form of intergovernmental approval process should be sufficient.
Circumstances require the pace of development to be rapid. It should be feasible to secure agreement of key players (e.g. UK, France, China), agree a Chair, and announce the creation of TNFD at Davos in January 2020. A Task Force should seek to present a preliminary report to the IUCN World Conservation Congress in Marseille in June, and a set of recommendations to the CBD COP 15 in October, even if these are not fully final.
Even the FSB is frustrated at the slow pace at which the TCFD guidelines are being picked up and implemented. Voluntary action provides little scope to exercise accountability.
A TNFD should aim to establish a standard – for example a “no net negative” or “net positive” (impact on biodiversity and ecosystem resilience) commitment in corporate value chains by a suitably early date. The TNFD should then agree on definitions, benchmarks, measures and indicators to put this in practice. In this way the expected transparency and disclosure serves a specific purpose and becomes a tool to achieve a wider goal. Transparency towards a commitment could then potentially move quickly towards becoming a required standard – one that investors insist upon and that governments legislate.
It is a frustration that corporations, investors and other private sector players are so fixated on often outmoded models to calculate risk and return from their activity. One way in which to secure better performance on biodiversity is to raise the risk of undermining it, ideally to the point at which it becomes more favourable for corporations to prevent damage rather than dealing with the consequences.
There are many ways to build liability pathways, including those that focus on corporate reputational risk. These include many forms of civic action – legal challenges, divestment movements, consumer action, shareholder action, etc. as well as shifts in insurance practice, norms, and policy change.
It would be useful for TNFD to explore the different liability pathways that would speed up the standard’s uptake, rather than simply to define a standard for corporate transparency and disclosure.
Strategic Policy Shift
Meeting the challenge of conserving nature and reversing the current negative trends ultimately requires putting in place a framework of policies, regulations and institutions that enable and favour nature conservation and improvement. This requires both taking positive action – e.g. new laws that give strong incentives to conserve – and reforming practices that, currently, provide an incentive to undermine natural resources – e.g. subsidies to clear virgin land or fishing technology that results in substantial by-catch death.
Success in nature conservation will require action on both these fronts. A TNFD could seek to identify the most urgent policy or regulatory reforms that, if implemented, could speed the adoption of the new standard and ensure its general implementation.
Better corporate disclosure of the impact on natural resources and ecosystems of activities within their value chains would be a welcome improvement and could lead to positive change in the international patterns of investment. On its own, however, proposals modelled on the TCFD would fall well short of what is needed – and what is possible – to begin turning around present trends in biodiversity loss. Without the political constraints of the G20, it should raise its ambition level and go beyond the confines within which TCFD was imprisoned.
Better Nature Together welcomes comments and responses to this thought-piece. In the first instance please respond using this form. As responses are received we’ll bring commentators together to continue discussion, refine and improve the proposals and discuss and agree on next steps.