The Taskforce on Nature-related Financial Disclosures: Greenwash by corporations, for corporations
A letter from 62 organisations and networks highlights what’s wrong with the TNFD
The Taskforce on Nature-related Financial Disclosures was launched in June 2021. Its members are 40 senior staff from financial institutions, corporations, and market service providers. Its mission is,
To develop and deliver a risk management and disclosure framework for organisations to report and act on evolving nature-related risks, with the ultimate aim of supporting a shift in global financial flows away from nature-negative outcomes and toward nature-positive outcomes.
Needless to say, a voluntary initiative focussing on self-reporting by corporations is an open invitation to greenwash.
As is often the case with corporate-led greenwashing exercises, scratch the surface and you’ll find WWF. The TNFD was set up by a partnership between WWF US, Global Canopy, the UN Development Programme, and the UN Environment Programme Finance Initiative.
Among the funders of the TNFD are the three governments that have thrown the most money at REDD over the years: Norway (Norway’s International Climate and Forest Initiative), Germany (Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection), and the UK (Department for Environment Food & Rural Affairs), among others.
On 31 May 2023, 62 civil society organisations and networks sent an open letter to the TNFD. The letter was also signed by three Goldman Environmental Prize winners: Tarcísio Feitosa from Brazil; Dmitry Lisitsyn from Russia; and Craig Williams from the USA.
In a statement, Feitosa says,
“Who is the TNFD for? Certainly not the environmental defenders and everyday people who are standing up against abusive corporate practices. Many global corporations – including many who sit on the TNFD – have persistently ignored the actual change that the real leaders on biodiversity are calling for.”
The Forests & Finance Coalition aims “to prevent financial institutions from facilitating environmental and social abuses common in forest risk commodities”. The Coalition has a detailed critique of the TNFD on its website.
A statement by the Forests & Finance Coalition about the letter to TFND highlights the weaknesses in the TFND’s final draft:
TNFD reports will not have to include information on where companies are facing allegations of harming biodiversity or environmental defenders.
The data in reports will also be unverifiable and companies will not need to report their lobbying against new laws that help protect nature.
The framework will not allow communities affected by biodiversity harms to even know the name of companies who are buying from, or financing, activities in their area.
The letter highlights that the TNFD has failed to respond to academic research that re-pricing biodiversity risks is more likely to impact lower and middle-income countries, not richer countries.
Here is the letter to the TNFD it is also available in Spanish, Portuguese, Bahasa Indonesia, French and Chinese.
To: David Craig, TNFD Co-Chairs
Elizabeth Maruma Mrema, TNFD Co-ChairCC: Tony Goldner, TNFD, Executive Director
Malika Bhandarkar, TNFD Lead, Stakeholder Engagement & MandatesJoint open letter to the TNFD: Your work is undermining the real solutions to the nature crisis
31 May 2023
Dear TNFD Co-Chairs,
We, the undersigned organizations, write to you to express our profound concern with the work of the Taskforce on Nature-related Financial Disclosures (TNFD). We also note that many of the points we raise have been previously emphasized - at length - to the TNFD but have not been addressed.
As dozens of rights holder organizations and CSOs stated in October 2022, “those working on the frontlines of the nature and biodiversity crisis - Indigenous Peoples, Afro-descendant communities, women’s organizations, rural youth, peasants and land and environmental defenders, among others - have been incredibly clear on the steps needed to stop corporate-led nature harms. This includes placing human rights at the center, states working together to regulate businesses at the national and international level, holding businesses publicly accountable for their impacts on nature and people, and ensuring that corporations have a legal obligation to provide full disclosure and remedy to people or ecosystems harmed. The framework that TNFD is developing, on how a business should report on nature-related risks, is distracting from, and undermining, real and sustainable solutions.”
It is disappointing that the TNFD has presented its fourth and final draft while still failing to provide any examples of what a proposed company TNFD report would look like. This is yet another example of how abstracted the TNFD’s work is from the urgent real-world concerns and needs of those on the frontlines of protecting biodiversity. Some groups are already pointing to examples of how the TNFD’s work is undermining community-led calls for strong, meaningful laws on corporate accountability.1 The solutions to the biodiversity crisis will not come from processes that completely sideline the voices of those doing most to protect nature.
We also find little evidence behind claims that the TNFD is ‘science-based’. In 2022, the world’s leading biodiversity scientists stressed that to solve the biodiversity crisis we need diverse voices in decision-making, to look beyond market-based perspectives and justice is critical.2
A taskforce led by some of the very actors destroying nature
The TNFD taskforce is made up of 40 global corporations and there is no objective criteria for how the taskforce members are appointed.3 These members include many businesses that stand accused of serious environmental and human rights harms and that have persistently failed to respond to environmental defenders to change their ways. This includes some of the world’s largest fossil fuel financiers and businesses persistently linked to deforestation or human rights harms.
The TNFD has sought, by our best estimate, at least USD$50 million in funding from governments, UN agencies and philanthropic funds - which serves to amplify the voices and preferences of global corporations. It is the latest iteration of a familiar pattern of initiatives that repeat the same mistakes because corporations simply do not want to take the bold, transformative action actually needed to change our broken markets and the broader power relations that they represent. We already have many of the solutions to the nature crisis. What is needed is for the powerful interests who prevent these from being enacted to step out of the way.
Reliance on flawed processes
The TNFD has failed to show any evidence of how a TNFD report would lead to changes in company behavior, and is thus contributing to and repeating the same flawed processes of other initiatives and distracting from the true solutions to the nature crisis.
It also proposes reporting on ‘biodiversity credits’ - yet the premise of such credits is scientifically invalid, as harming the specific community of ecosystems and biodiversity in one place cannot be ‘offset’ by activities elsewhere.4
Much of the TNFD’s processes remain shrouded in secrecy - including a failure to disclose the minutes of meetings or lists of who is taking part in ‘national’ consultation groups.
What is worse are the persistent statements from the TNFD members, co-chair or others that promote or legitimize a view that a framework written by global corporations could form the basis of future laws.5 This fundamentally violates the Escazú Agreement and other international agreements and obligations.6 Those benefiting from the status quo have the least invested in truly changing it - and the TNFD is again evidence of this.
While TNFD describes how a company should report on biodiversity, it fails to include even such crucial elements as recommending that a company publicly report on:
Meaningful reporting on biodiversity impacts. This includes a company’s actual and potential negative impacts and harms to Mother Nature. The TNFD process relies on highlevel and abstract information that cannot be tested or scrutinized, it also does not let us compare with how landscapes would fare if a corporation was not involved in that area at all. The TNFD’s proposed reporting is not in a form that is useful or relevant to environmental defenders or other local people who have done the most to protect and safeguard biodiversity and the rights of people who protect it.
Transparency of the supply and investment chain. The TNFD does not recommend that a business disclose the name of companies it is purchasing from or financing and the geo-location of its operations, supply chains and financing. The lack of these disclosures means that the public has little chance of knowing if a business is linked to risks and harms in their local area. This is fundamentally incompatible with Indigenous Peoples’ right to Free, Prior and Informed Consent - as any consideration of consent must first require them to be ‘informed’ of which businesses are financing, or buying from, proposed activities on their territories.
Human rights risks and negative impacts. The TNFD fails to put human rights at the center. There is no obligation to disclose if a business is linked to violations of Indigenous and local communities’ rights, violations of the right to Free, Prior and Informed Consent (FPIC), impacts on local livelihoods and modes of sustainable production, threats against people trying to protect nature and to the forceful removal of peoples from their traditional territories. The TNFD’s work has also failed to seek or act on the voices of grassroots women’s organizations or undertake any gender analysis of its work. It has failed to include, or respond to, the voices of youth and children on intergenerational equity.
Complaints or grievances. It is astounding that the TNFD has persistently failed to state that a business should report complaints or accusations that it is causing, contributing to or directly linked to environmental or human rights harms. This means it has no requirement to acknowledge where it stands accused of breaking its own biodiversity policies.
Lobbying against new laws or regulations to better protect our planet, nature and people. The Kunming-Montreal Global Biodiversity Framework clearly mandates governments to create new laws and policies to safeguard biodiversity. These span issues such as curbing subsidies to global corporations in harmful industries such as fossil fuels, to needing to redirect public and private financial flows from harmful activities to positive ones. The TNFD has ignored the abundance of evidence that shows the devastating impact that industry lobbying has on undermining such laws - protecting the interests of the powerful rather than the public at large.
Justice is crucial, but the TNFD ignores justice
Under the TNFD framework, a business can pick or choose what disclosures it chooses to report against and which it chooses to ignore. There is no requirement for a TNFD report to be publicly or even privately verified. The TNFD also ignores the systemic issues with sustainability auditing - including the conflict of interests that abound and the reliance on company-supplied data. The TNFD has also failed to respond to the academic research on economic inequity - that any re-pricing of financial risk on nature is more likely to increase the cost of finance in low and middle-income countries - not former colonizers made rich off the back of exploiting nature and people.
The TNFD is creating a framework that amplifies half-truths, misinformation or outright lies that are a textbook case of greenwashing and which stand in the way of legitimate solutions to the nature crisis. We also believe it is morally reprehensible for anyone associated with the TNFD to suggest or entertain the prospect that an initiative decided on by 40 global corporations should be considered as the blueprint of future laws.
We also reiterate the points raised in an open letter where rights holder and CSO groups expressed their concern “about the role of UN agencies that have co-founded, backed or funded TNFD, as their involvement would seem to violate their duties and obligations to respect human rights and fair decision-making.”
In fact, in limiting itself only to ‘disclosures’ the TNFD does not address justice at all. Those harming biodiversity and the people who protect it should face meaningful consequences for these actions under the law and those harmed or placed at risk should be provided remedy and redress to the full extent possible.
For more detail on these points we refer you to the various submissions, statements and other resources prepared by rights holder and civil society organizations available on the Forests & Finance coalition website here: https://forestsandfinance.org/tnfd/#1-5.
Signed,
Tarcísio Feitosa, Goldman Environmental Prize winner, Brazil
Dmitry Lisitsyn, Goldman Environmental Prize winner, Russia
Craig Williams, Goldman Environmental Prize winner, United States of America1. AbibiNsroma Foundation
2. Accountability Counsel
3. Amazon Watch
4. Bank Climate Advocates
5. BankTrack
6. Biodiversity Conservation Center
7. Biomass Action Group
8. Blue Dalian, China
9. Boreal Action
10. Both ENDS
11. Bruno Manser Fonds
12. Castlemaine Residents Against Biomass
13. Center for International Environmental Law (CIEL)
14. CESTA - Friends of the Earth El Salvador
15. Coastal Plain Conservation Group
16. Colectivo VientoSur
17. Comite Schone Lucht (Clean Air Committee)
18. Dogwood Alliance
19. Environmental Paper Network
20. Environmental Justice Foundation
21. Facing Finance
22. Fair Finance International (FFI)
23. Feedback Global
24. Forest Peoples Programme
25. Friends of Bonobos
26. Friends of the Earth United States
27. Global Forest Coalition
28. Global Witness
29. Green Finance Observatory
30. Green Longjiang
31. Greenpeace International
32. Idec - Instituto Brasileiro de Defesa do Consumidor
33. Inclusive Development International
34. Instituto de Referência Negra Peregum
35. Jubilee Australia Research Centre
36. Knitting Nannas Hunter Loop
37. Kyogle Environment Group
38. Leefmilieu
39. London Mining Network
40. Mobilisation for the environment
41. Nature Nova Scotia
42. North East Forest Alliance
43. Pakaid
44. Profundo
45. Rainforest Action Network
46. Rainforest Information Centre
47. Re_Generation
48. Rinascimento Green
49. Sahabat Alam Malaysia
50. Scholar Tree Alliance
51. Socio-ecological Union International
52. Southern Forest Conservation Coalition
53. The Development Institute, Ghana
54. The Rachel Carson Council
55. The Wilderness Society Australia
56. Third Act North Carolina
57. Third World Network
58. Tipping Point UK
59. TuK INDONESIA
60. WALHI/Friends of the Earth Indonesia
61. Water Justice and Gender
62. Women’s Earth and Climate Action Network
For example, on the UK deforestation finance regulation as well as the watering down of what became Target 15 in the Kunming-Montreal Global Biodiversity Framework - resources at https://forestsandfinance.org/tnfd/#1-5
5 For examples, see p.31 & 32 of Rainforest Action Network’s February 2023 submission
https://forestsandfinance.org/wp-content/uploads/2023/03/20Feb2023-RAN-submission-to-TNFD-.pdf
This includes, for example, Article 7 on the state’s responsibility to ensure public participation in decision-making processes on environmental issues, whose implementation should be guided by principles such as equality and non-discrimination, intergenerational equity, transparency and accountability and maximum disclosure. As a framework decided on by a taskforce with solely corporate members and which as an initiative that has specifically targeted corporate actors - for example - the TNFD is not in step with the Escazu Agreement’s focus on ‘inclusive’ decision-making, nor is it consistent with the agreement’s text related to accountability, the precautionary principle, full disclosure and justice.
The Taskforce on Nature-related Financial Disclosures: Greenwash by corporations, for corporations
I would sign that letter also!
Yes the propsal for biodiversity "credits" is absurd and is shameless greenwashing. Unlike the mindless proposals of the Kunming-Montreal Global Biodiversity Framework, shouldn't the first step toward biodiversity be NOT ONE NEW SACRIFICE ZONE? That means what it says. Meanwhile, look at this link and see the infographic on biodiversity by _mass_. The first critical step in improving biodiversity should be reducing the numbers of humans and/or cattle. You choose.
"Humans and livestock mammals far outweigh wild mammals, which account for just 6% of Earth’s mammal biomass. The weight of all house cats combined is nearly twice that of all African elephants, and pigs’ biomass is twice that of all wild land mammals. Almost half of the wild-mammal biomass is made up by even-hoofed mammals, such as deer and boar. Of wild mammals, most species, and most individual animals, are bats. (PNAS Commentary: https://www.pnas.org/doi/10.1073/pnas.2301652120 ) (L. Greenspoon et al./PNAS (CC BY-NC-ND))"