Research Article |
Corresponding author: Karen Maas ( maas@ese.eur.nl ) Academic editor: Annemarie Oord
© 2024 Karen Maas, Thomas Thijssens, Kavita Nandram.
This is an open access article distributed under the terms of the Creative Commons Attribution License (CC BY-NC-ND 4.0), which permits to copy and distribute the article for non-commercial purposes, provided that the article is not altered or modified and the original author and source are credited.
Citation:
Maas K, Thijssens T, Nandram K (2024) For the sake of nature – a study on biodiversity reporting by Dutch listed companies. In: Oord A, Verhoek H (Eds) Het jaar 2023 verslagen. Maandblad voor Accountancy en Bedrijfseconomie 98(6): 325-338. https://doi.org/10.5117/mab.98.138230
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As the attention for climate change has grown in recent years, the topic of biodiversity loss has become increasingly relevant. The importance of biodiversity is reflected in the requirements stated in the Corporate Sustainability Reporting Directive (2022). 2024 is the year in which CSRD and ESRS are effective, implying that the first reports that must be compliant (by large listed companies) will be published in 2025. This article reflects on how and to what extent Dutch large listed companies already address the topic of biodiversity in their annual reports one year before they must comply with the CSRD (2024). Our research shows that many companies are aware of biodiversity issues. However, many companies have to further specify their policy, strategy, actions and targets by next year.
CSRD, ESRS, EU Taxonomy, reporting, biodiversity
With the CSRD content finalized and draft ESRSs now delegated decisions, companies should better understand their obligations. However, transparency on biodiversity impact is still lacking. Despite this, the CSRD demands extensive information on companies’ biodiversity impacts. The Netherlands struggles with addressing biodiversity loss, as shown by the ‘Nationaal Dashboard Biodiversiteit’, which indicates the country is off track for its 2030 goals.
The continuous global deterioration of the natural environment has been documented in various studies, maybe most prominently in the concept of planetary boundaries (
In contrast to these findings, recent surveys among companies find that biodiversity receives least priority among all sustainability issues (
Biodiversity risks are different per sector. Companies could have a direct impact on biodiversity and natural capital loss through their own operations or a secondary impact through their supply chain. Companies with a tertiary impact on biodiversity include financial institutions that have an impact on biodiversity through their lending and investment portfolios. The main direct drivers are climate change, overexploitation, habitat conversion and destruction, and invasive species. More indirect drivers of biodiversity loss are infrastructure, tourism, overconsumption, and urbanisation.
By means of information requirements on sustainability impact through the Corporate Sustainability Reporting Directive (CSRD) (European Commission 2022), the Sustainable Finance Disclosure Regulation (
The aim of these regulations is increased transparency. Transparency provides insight into the approach of companies on biodiversity in terms of objectives, strategy, management and performance related to biodiversity impact. As the financial consequences of biodiversity loss are also becoming increasingly relevant, the CSRD also requests information on the financial aspects of biodiversity. Given that companies are inclined to show progress, transparency is expected to lead to continuous improvement of sustainability performance.
This article examines the extent to which Dutch listed companies include information on biodiversity in their annual report. In section 2, we briefly discuss developments in legislation and regulations that are relevant in the context of reporting on biodiversity, as well as ongoing international literature. In section 3, we discuss the results of the empirical research into the transparency on biodiversity of 75 listed companies (25 AEX, 25 AMX and 25 AScX). This article also describes promises made and ambitions ventilated as well as examples of current practices Concluding remarks are provided in section 4.
For all companies that are required to draw up an annual report, article 391 BW2.9 stipulates that companies must report on non-financial information in their management report, including environmental and personnel matters, to the extent that this affects the position and performance of the company. This article is applicable since 2005, when Directive 2003/52/EC was included in the Dutch Civil Code (Titel 9 BW2) and via the implementation of Directive 2013/34/EU in 2015, reporting on ESG matters culminated in the Dutch implementation of the European Non-Financial Reporting Directive (NFRD) (Directive 2014/95/EU) in 2017, requiring more detailed information from certain companies (
For the reporting year 2023, companies that fall under the Non-Financial Reporting Directive must comply with the European Taxonomy Regulation and provide further information on the financial implications of biodiversity in the management report. This regulation, together with the associated delegated legislation, defines what is meant by ‘sustainable economic activity’. Article 8 describes the transparency requirements for the management report. For the reporting year 2023, this concerns transparency on the part of their turnover, capital expenditure (CAPEX) and specific operational expenditure (OPEX) that can be qualified as ‘sustainable’ (‘eligibility’) (
According to the CSRD, all large companies (exceeding at least two of the following three criteria: € 25m balance sheet total, € 50m net turnover, and 250 employees) and all companies listed on regulated markets within the EU (with the exception of listed micro-enterprises), as well as specific non-European companies, must include sustainability information in the management report of their annual reports. Large listed companies will have to comply first in their 2024 reports, which will be published in 2025, followed by all large companies in 2026 and SME Public Interest Enterprises in 2027. Currently, all companies in the main Dutch indexes (AEX, AMX and AScX) are large companies under the CSRD, implying that their 2025 reports must be compliant with the CSRD. The main points of what must be reported are set out in the directive, the details are set out in the European Sustainability Reporting Standards (ESRS). The ESRS were issued as ‘delegated acts’ in mid-2023 on the basis of the CSRD. The European Commission indicates that it has adhered as much as possible to the international sustainability guidelines of the International Sustainability Standards Board (ISSB) and the now longer-standing guidelines of the Global Reporting Initiative (GRI).
Table
Biodiversity topics covered in ESRS E4 (Source: ESRS 1 General requirements, AR 16).
ESRS E4 | Biodiversity and ecosystems | Direct impact drivers of biodiversity loss | • Climate Change |
• Land-use change, fresh water-use change and sea-use change | |||
• Direct exploitation | |||
• Invasive alien species | |||
• Pollution | |||
• Others | |||
Impacts on the state of species | Examples: | ||
• Species population size | |||
• Species global extinction risk | |||
Impacts on the extent and condition of ecosystems | Examples: | ||
• Land degradation | |||
• Desertification | |||
• Soil sealing | |||
Impacts and dependencies on ecosystem services |
If biodiversity is identified based on ESRS2 as a material topic
In the Netherlands, companies are subject to mandatory biodiversity regulations, primarily resulting from national laws and EU directives. The main national law, that includes biodiversity requirements, is The Environment and Planning Act (the successor of the Nature Conservation Act, as per January 2024). It requires companies to avoid disturbing or harming protected species, assess and mitigate any potential impacts on protected Natura 2000 areas
Companies that are involved in large-scale development, energy, infrastructure, and industrial projects are also subject to the Environmental Management Act (‘Wet Milieubeheer’). These companies must integrate biodiversity impact assessments in their projects and mitigate or compensate biodiversity loss.
These mandatory regulations, and particularly the provisions regarding the EIAs, are in line with the Kunming-Montreal Global Biodiversity Framework. This framework, developed during the 2022 meeting of the Convention on Biological Diversity (CBD), states that CBD-signatories (such as the Netherlands), must implement biodiversity requirements for business. The CBD, originating from the UN Environmental Program (UNEP), also directly invites businesses to become a signatory to the Business and Biodiversity Pledge and stimulates the use of Natural Capital Accounts by businesses, to optimise their use and reduce their impact on nature. The Align project also aims at providing businesses with biodiversity measurement tools. Another voluntary initiative is the Taskforce for Nature-Related Financial Disclosures framework (TNFD), aimed at helping organisations with their nature-related disclosures, with the ultimate goal of nature-positive outcomes. The GRI-guidelines form a further significant source of biodiversity guidelines for companies.
On a national level, the Netherlands is characterized by several voluntary initiatives related to biodiversity and businesses, both sector-specific (e.g., in the agriculture, infrastructure and banking sectors) as well as initiated by the national government, such as green deals with companies including biodiversity.
The European Commission defined biodiversity in Annex 2 as:
“The variability among living organisms from all sources including terrestrial, marine and other aquatic ecosystems and the ecological complexes of which they part. This includes variation in genetic, phenotypic, phylogenetic, and functional attributes, as well as changes in abundance and distribution over time and space within and among species, biological communities and ecosystems.”
Biodiversity is currently under severe threat. In 2020, biodiversity loss was ranked among the top five global risks (
Also, the 15th edition of the World Economic Forum’s Global Risk Report (2020) already mentions that biodiversity loss has critical implications for humanity, from the collapse of food and health systems to the disruption of entire supply chains. The Forum’s multistakeholder network rates “biodiversity loss” as the second most impactful and third most likely risk for the next decade.
The protection of biodiversity has become a focal point in the field of environmental accounting. As significant contributors to society, organizations are accountable for their actions and thus play a vital role in the planet’s overall sustainability. Biodiversity accounting and reporting plays a crucial role in shaping organizational practices aimed at sustainability, fostering cleaner management policies with reduced environmental impact (
They report that there are only a few studies that pay attention to the auditing/assurance of biodiversity information in environmental reports. Therefore, more research on auditing practices by external professionals or NGOs could benefit the biodiversity accounting field.
Companies disclose information about biodiversity for a variety of reasons, primarily driven by regulatory demands, reputational concerns, and financial considerations (
Research on disclosure of biodiversity and circular economy by companies (
In British and German context
In a Scandinavian context a study by
In an Australian context a study by
Between 2018 and 2021 a study conducted across the EU examining 170 listed companies from the EU’s five largest economies revealed a growing but uneven level of biodiversity disclosures among these companies (
Another recent article (
Growing public awareness of climate change and biodiversity loss has placed companies under greater scrutiny, compelling them to measure and disclose their impact on biodiversity to maintain social legitimacy. However, in this context measurement is difficult, especially when biodiversity loss needs to be attributed to specific companies. Also, many organizations face challenges in reporting biodiversity due to insufficient knowledge and expertise. Critics argue that existing reporting frameworks fall short in addressing the deterioration of natural ecosystems, underscoring a critical gap in accounting for biodiversity loss (
Research (
For this study, the annual reports of 75 companies that were listed on the AEX (25), the AMX (25) and the AScX (25) as of 31 December 2023 were examined. An overview of the companies examined is included in the Appendix
The annual reports of the 75 listed companies were analysed by the researchers based on an assessment sheet. The criteria in the assessment sheet are prepared based on certain requirements as noted in the ESRS and checked on internal and external validity. The researchers performed a test round based on the initial assessment sheet. This test round was evaluated and provided input to further define the assessment criteria. The researchers analysed the annual reports based on the assessment criteria, next a cross check was performed on each other’s analysis and to make sure everyone evaluated the data in the same manner.
Looking at the number of employees, there are two AMX companies (WDP and Eurocommercial properties) and nine AScX companies (Accsys Technologies, Avantium, Ebusco Holding, Fastned, NSI, Pharming Group, Vastned, Vivoryon Therapeutics and Wereldhave) that have fewer than 500 employees. These companies did not fall under the NFRD regulation (15%), and therefore less detailed non-financial information needs to be provided in the reporting year 2023. It should also be noted that biodiversity is not always identified a material topic for listed companies.
The following paragraphs report on the research results from reporting year 2023.
Transparency about biodiversity starts with identifying biodiversity as a material topic. For CSRD a double materiality assessment is required. This year most of the companies already provide a materiality assessment. However only a few of these companies use a double materiality assessment. Most of these firms use a single materiality assessment either focussing on financial risks or on their sustainability impact. If biodiversity is material companies are expected to further specify the relevant biodiversity topics and include where in the value chain biodiversity is relevant. Table
The annual report of Royal BAM Group n.v. shows a level of depth in their approach and reporting which is exemplified by addressing all three above elements in their reporting. BAM – who is founding signatory of the Nature Positive Business Pledge – not only recognizes biodiversity loss as a material topic, but also specifies topics and elements (subtopics) that are important for their consideration. They explain the use of a biodiversity scorecard to assess the maturity of its processes around biodiversity in which relevant biodiversity indicators are reflected, such as habitat creation and enhancement, Biodiversity Net Gain, inclusion of facilities for wildlife, biosecurity and pollution avoidance protocols. Finally they indicate where in the value chain risk/ potential biodiversity loss can be identified. |
“The construction industry relies heavily on natural resources” (Royal BAM Group annual report 2023, p. 45) and “The potential impact on biodiversity (through land use change) and the contribution to ecosystem services (benefits to humans provided by the natural environment and healthy ecosystems) can impose environmental risks, but also opportunities to the construction business.” (Royal BAM Group annual report 2023, p. 45) |
Biodiversity as material topic, specification and position in the value chain.
AEX (n) | AEX (%) | AMX (n) | AMX (%) | AScX (n) | AScX (%) | Total (n) | Total (%) | |
---|---|---|---|---|---|---|---|---|
Materiality | ||||||||
Biodiversity material topic | 6 | 24% | 10 | 40% | 7 | 28% | 23 | 31% |
Biodiversity not mentioned as a material topic | 19 | 76% | 15 | 60% | 18 | 72% | 52 | 69% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
Specification (topics) | ||||||||
Biodiversity topics specified | 1 | 4% | 2 | 8% | 4 | 16% | 6 | 8% |
Biodiversity topics not specified | 24 | 96% | 23 | 92% | 21 | 84% | 69 | 92% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
Specification towards position value chain | ||||||||
Value chain position specified | 2 | 8% | 6 | 24% | 3 | 12% | 11 | 15% |
Value chain position not specified | 23 | 92% | 19 | 76% | 22 | 88% | 64 | 85% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
AEX (n) | AEX (%) | AMX (n) | AMX (%) | AScX (n) | AScX (%) | Totaal (n) | Totaal (%) | |
---|---|---|---|---|---|---|---|---|
Information on biodiversity in strategy | ||||||||
Biodiversity in Strategy | 7 | 28% | 8 | 32% | 2 | 8% | 17 | 23% |
Biodiversity not in strategy | 18 | 72% | 17 | 68% | 23 | 92% | 58 | 77% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
Transition plan | ||||||||
Biodiversity transitionplan* | 2 | 8% | 1 | 4% | 0 | 0% | 3 | 4% |
No biodiversity transitionplan | 23 | 92% | 24 | 96% | 25 | 100% | 72 | 96% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
If biodiversity is material for a company, the next step is to be transparent about how biodiversity is included in the strategy of the company. Not all companies that have identified biodiversity as a material topic have provided information about the role of biodiversity in their strategy. Nevertheless 17 companies (23%) have provided information on biodiversity in their strategy. The AMX scores best with 32% of the companies including biodiversity in their strategy. For AEX companies this is 28% and for the AScX it is only 8%, while 28% of the AScX companies have identified biodiversity as material. This means that companies are not in all cases already capable to provide information on what their strategy is to reduce their negative impact or increase their positive impact on biodiversity. The management reports also show that companies sometimes provide information about a separate biodiversity strategy, but it often forms part of the climate change strategy or the broader sustainability strategy of the company. It is striking that nine companies that have not identified biodiversity as material still include information about biodiversity in their strategy as described in the management report. However, we also see that several companies that have identified biodiversity as a material topic do not yet provide any information about their approach on biodiversity in their strategy. This is the case for four AEX companies, six AMX companies and five AScX companies. Alignment between materiality of issues and strategy is still weak.
Companies are expected to provide a transition plan how they expect to fulfil their ambitions, targets and strategy. There are only very few companies that actually do provide a transition plan for biodiversity. Two AEX companies, ArcelorMittal and ASR Nederland and one AMX company, AirFrance KLM do provide such a transition plan. Of all companies only ASR Nederland has identified biodiversity as material, further specified which biodiversity topics are relevant and where in the value chain these occur, incorporated biodiversity in their strategy and provided information on their transition plan (see Box
A.s.r. reports extensively in their annual report on biodiversity. They mention that investing in activities that aim to ‘restore biodiversity’ is one of the targets within a.s.r.’s strategic scope of ‘Sustainable Living’. They recognize that restoring biodiversity helps to reduce climate risk. “A.s.r. signed the Finance for Biodiversity Pledge, committing ASR, along with other financial institutions, to protect and restore biodiversity in its investment portfolio. In 2023, ASR conducted an analysis of biodiversity and ecosystem impacts, dependencies, opportunities and risks.” (ASR Annual report 2023, p. 24) A.s.r. commits to taking biodiversity loss seriously by signing pledges and taking initiatives that bind them towards concrete targets. Interesting aspect is that a.s.r. incorporates climate pathways- illustrating scenarios from an orderly transition ‘Net Zero’ in 2050 to failed transition according to Paris. |
Within the strategy a.s.r. uses ‘The LEAP approach’ – a tool made available by the Taskforce on Nature-Related Financial Disclosure (TNFD). The tool distinguishes four steps (locate, evaluate, assess and prepare) that help to assess a companies’ interaction with nature. A.s.r. adds weight to their claims by setting specific targets. “In 2020, by signing the Finance for Biodiversity Pledge, a.s.r. is committed to providing insight into its own impact on biodiversity by 2024 and to set concrete targets for this relating to its investments. With the results of the LEAP assessment at the end of 2023, further work will be done in 2024 to set metrics and targets.” (ASR Annual report 2023, p. 144) |
The companies were also assessed on the extent to which they have set concrete objectives and to what period these objectives relate. The Sustainable Development Goals (SDG) will come to an end in 2030. Biodiversity is an important theme (SDG 6: clean water and sanitation, SDG 13: climate action, SDG 14: life below water, SDG 15: life on land). The
Table
AEX (n) | AEX (%) | AMX (n) | AMX (%) | AScX (n) | AScX (%) | Totaal (n) | Total (%) | |
---|---|---|---|---|---|---|---|---|
Targets | ||||||||
Biodiversity targets | 9 | 36% | 7 | 28% | 1 | 4% | 17 | 23% |
Quantitative targets | 4 | 44% | 5 | 71% | 1 | 100% | 10 | 59% |
…Qualitative targets | 5 | 56% | 2 | 29% | 0 | 0% | 7 | 41% |
No biodiversity targets | 16 | 64% | 18 | 72% | 24 | 96% | 58 | 77% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
Timeframe | ||||||||
Timeline specified | 2 | 8% | 4 | 16% | 1 | 4% | 7 | 9% |
Timeline not specified | 23 | 92% | 21 | 84% | 24 | 96% | 68 | 91% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
In total, 9% of the companies have specified a timeline to achieve their biodiversity target. Two companies have set targets for 2025, AholdDelhaize and Corbion. Next to the 2025 target, Corbion has also specified a biodiversity target for 2030 as well as Arcadis, B&S Group and Van Lanschot Kempen. Van Lanschot Kempen also has set targets for 2050. Heineken has set targets for 2040 and CTP for 2028. Some of these companies link biodiversity directly to their climate change actions. For example, Heineken “Our aim is to reduce emissions and conserve the natural world we all depend on. Achieving it requires us to find solutions that connect carbon, water, biodiversity and people’s livelihoods and to reshape the way we do business globally” (Heineken annual report 2023, p. 148). Other companies implicitly link biodiversity to actions. B&S Group for example has set targets that products sold are ‘a more sustainable choice’ implicitly including attention paid to biodiversity issues or using a supplier code of conduct including the protection of biodiversity loss (B&S Group annual report 2023, p. 68). Some examples of how firms use biodiversity targets are provided in Box
Example qualitative indicator |
“Philips aims to restore and enhance biodiversity and ecosystem services (BES) at our industrial sites and to actively promote ecosystem restoration activities through partnerships with, among others, NGOs, local communities, and governments.” (Philips annual report, p.51) |
Example quantitative targets |
AholdDelhaize has set a target on a deforestation-free supply chain. “By 2025 Ahold Delhaize and its brands aim to have 100% of own-brand products containing soy, palm oil, cacao, coffee, wood fiber and tea certified against an acceptable standard that provides for no deforestation or land conversion as defined by the Accountability Framework Initiative or the Forest Resources Assessment.” (AholdDelhaize annual Report 2023, p. 120) |
Examples timeline |
Van Lanschot Kempen - who also signed the Finance for Biodiversity pledge - states: “Our strategy to align our business model with the goal of zero net loss of biodiversity by 2030, net gain from 2030, and full recovery by 2050 in accordance with the Global Biodiversity Framework and EU Biodiversity Strategy for 2030.” (Van Lanschot Kempen annual report, p. 27) |
Arcadis “After completing a biodiversity impact assessment of all our office locations around the world, Arcadis established two biodiversity targets: |
• No net biodiversity loss will occur at Arcadis sites |
• For Arcadis sites with > 20% opengreenspace, Arcadis will deliver a biodiversity net gain of 10% by 2030.” (Arcadis annual report 2023, p. 65) |
Most of the listed companies, 77%, do not include a biodiversity target (64% AEX, 72% AMX and 96% AScX). A timeline is used even less, 91% of the companies do not use a timeline (92% AEX, 84% AMX and 96% AScX).
Strategy should lead to actions and results in practice. To do this companies set out policies and define actions linked to this policy. Table
Policy and actions on biodiversity, specification of issues and roadmap.
AEX (n) | AEX (%) | AMX (n) | AMX (%) | AScX (n) | AScX (%) | Total (n) | Total (%) | |
Biodiversity policy | ||||||||
Biodiversity policy and actions | 12 | 48% | 15 | 60% | 4 | 16% | 31 | 41% |
No biodiversity policy and actions | 13 | 52% | 10 | 40% | 21 | 84% | 44 | 59% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
Biodiversity policy issues specified | ||||||||
Issues specified | 8 | 32% | 10 | 40% | 1 | 4% | 19 | 25% |
No issues specified | 17 | 68% | 15 | 60% | 24 | 96% | 56 | 75% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
Biodiversity roadmap | ||||||||
Roadmap available | 4 | 16% | 3 | 12% | 0 | 0% | 7 | 9% |
No roadmap available | 21 | 84% | 22 | 88% | 25 | 100% | 68 | 91% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
It is interesting to see that most of the companies report on biodiversity in general terms and do not further specify the biodiversity issues relevant for their company. Eight of the AEX listed firms specify biodiversity issues, while ten AMX and one AScX company, Royal BAM Group, do so. Some examples of how firms specify biodiversity are provided in Box
JDE Peets |
“Working towards a deforestation-free supply chain in our sourcing of green coffee and paper & pulp. Anticipating and managing biodiversity and deforestation-related risks across the value chain by tackling region-specific issues at community and landscape levels”. (JDE Peets annual report 2023, p. 18) |
Van Lanschot Kempen |
“The intensification of agriculture in recent decades has played a critical role in increasing biodiversity loss. We aim to limit and reverse biodiversity loss, primarily by advancing the food transition and by focusing on halting deforestation. For instance, we invest in farms that deploy regenerative or nature-inclusive techniques through our SDG Farmland Fund”. (Van Lanschot Kempen annual report 2023, p. 45) |
Fugro |
“The main impacts of Fugro’s operations are threefold: the emission of greenhouse gasses, underwater noise pollution from geotechnical drilling and survey operations, and the risk of transporting species between different habitats, most prevalent in marine operations.” (Fugro annual report 2023, p. 39) |
Although 41% of companies includes information about climate policy, only 9% of companies provides information about a timeline for the intended actions. Without this information it is impossible for the reader to determine whether companies are able to achieve their objectives.
The CSRD explicitly calls for transparency about the inclusion of material topics in the remuneration of the (non)-executive board. Previous research shows that information about the linking of remuneration to sustainability in the long-term strategy needs to be reported in more concrete terms (
This link is meant to encourage companies to take biodiversity seriously within their risk management and sustainability strategies. The aim is to make biodiversity objectives concrete and measurable by linking them to the financial interests of executives. Table
“For the long-term incentive, the weighting for CO2 intensity reduction will be increased and the two objectives on CDP Climate and construction and office waste intensity reduction, as included in previous years, will be replaced by a sustainability scorecard of 5 targets on circularity, climate adaptation, biodiversity, inclusion & diversity and social value. This scorecard will better enable BAM to steer and reward on performance delivered against the specific objectives reflected in the sustainability strategy.” (Royal BAM Group 2023, p. 77). |
Biodiversity risks can have a major impact on the company. This may concern physical risks, but also transition risks. The risks can relate to the company itself or the value chain in which the company operates. In addition, the company itself can cause a significant negative impact on society through negative impacts on biodiversity through its own processes or throughout the entire value chain.
It is interesting to see if companies have identified loss of biodiversity as a potential risk in their risk management section. Of the companies examined, 24% reports on biodiversity risks in the general risk section in the annual report (Table
“KPN may fail to meet rising stakeholder expectations relating to energy, emissions, sustainability and biodiversity. This could lead to loss of customers, loss of profitability in the future and reputational damage. Together with Groene Netten and Naturalis Biodiversity Center KPN is working on the mapping of opportunities to enhance biodiversity. This could affect the land use, air quality, water use and soil at our own operations and in our supply chain sustainability and biodiversity.” (KPN annual report 2023, p. 223) |
“The Vopak Sustainability Roadmap sets out clear sustainability ambitions and priorities and integrates them into annual budget cycles, business agendas, work programs and daily activities. The Roadmap clearly sets Vopak’s ambition to be climate neutral by 2050. It also addresses the challenges that are posed by the dual objectives of limiting climate change on the one hand, and Vopak’s key role in providing access to affordable, acceptable and sustainable energy and feedstocks for all on the other hand. Also the protection of biodiversity is part Vopak’s Sustainability Roadmap.” (Vopak annual report 2023, p. 207) |
AEX (n) | AEX (%) | AMX (n) | AMX (%) | AScX (n) | AScX (%) | Total (n) | Total (%) | |
Biodiversity risks | ||||||||
Biodiversity risk in risk paragraph | 9 | 36% | 6 | 24% | 3 | 12% | 18 | 24% |
No biodiversity risk in risk paragraph | 16 | 64% | 19 | 76% | 22 | 78% | 57 | 76% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
Scenario analysis is an important starting point for identifying possible risks (and opportunities). The CSRD and ESRSs have adopted the scenario analysis information requirements from the TCFD recommendations. Table
Heineken links biodiversity to climate change scenario’s (Heineken annual report 2023, p. 138). |
“At Heineken, we depend on nature for essential raw materials such as water, barley, hops, yeast, and fruit extracts. At the same time, our activities have both direct and indirect impacts on biodiversity through our use of land and water, GHG emissions, pollutants to the environment and waste generation. Understanding this delicate balance of dependencies and impacts shapes our approach and demonstrates the importance of having a holistic strategy to protect the natural world.” |
“We aim to strengthen our biodiversity approach by carrying out a comprehensive assessment of our supply chain and direct operations in 2024.” (Heineken annual report 2023, p. 157) |
Specific attention was also paid to analyse if companies provide information on the potential financial impact of biodiversity on their company. Results show that only five companies provide some information on this and even those companies almost all describe this in a very general way. None of the companies provided actual numbers related to the financial impact expected. Financial impact is mainly captured by financial organisations, ASR, ABNAMRO (see for further description Box
ABNAMRO |
“We have undertaken efforts in various areas with regard to our impact on biodiversity. To address our responsibility regarding this topic sufficiently and create synergy in our actions on biodiversity, we prepared a biodiversity roadmap in 2023 consisting of several actions to perform in 2023 and 2024, and we will continue beyond this period. As part of the roadmap, we are working to determine what actions we will need to take in order to align with the Kunming-Montreal Global Biodiversity Framework (GBF). Financing is clearly mentioned in this framework in order, for example to align financial flows to biodiversity targets, as well as to monitor, assess and disclose risks, to increase financial resources for strategies and action plans, and to identify and discontinue – or change – financial incentives that are harmful to biodiversity. Moreover, some of the GBF targets are more directly relevant to our clients, for example agriculture clients, and therefore indirectly to us as well. Our work on biodiversity can be divided into several areas: |
• Supporting our clients’ environmental transition. To achieve this, we have chosen to focus on two areas: |
agriculture, as the nature of agricultural activities means they have a relatively high biodiversity impact, and built environment, as this comprises the largest part of our portfolio. For these focus areas, we translate our internal sector vision for our position in the coming years into concrete actions and targets, with which we can support the transitions. |
• Integrating biodiversity into the core of ABN AMRO’s business and strategy. This involves working with several units at the bank to improve our knowledge on the topic so that we can align financial flows better with nature. |
• Further strengthening our risk management approach |
• Being transparent on our impact, risks and progress, to be evidenced, for instance, by delivering on the Finance Biodiversity Pledge by 2024.” |
(ABNAMRO annual report 2023, p. 260) |
AEX (n) | AEX (%) | AMX (n) | AMX (%) | AScX (n) | AScX (%) | Total (n) | Total (%) | |
---|---|---|---|---|---|---|---|---|
Financial impact | ||||||||
Potential financial impact mentioned | 4 | 16% | 0 | 0% | 1 | 4% | 5 | 7% |
Potential financial impact not mentioned | 20 | 84% | 25 | 100% | 24 | 96% | 70 | 93% |
Total | 25 | 100% | 25 | 100% | 25 | 100% | 75 | 100% |
The research results show that all Dutch listed companies are active to implement the CSRD. Although biodiversity is mentioned in all reports, it is not material for all companies and it is not further elaborated on in strategy, policy and actions. In general we see that larger firms report more, however transparency on biodiversity is still limited. Specifically the information about risks, scenarios and financial impact has not yet been fully developed.
Most companies speak generically about biodiversity but do not specify which issues are mostly relevant for them. Biodiversity is a broad concept and can include different things, the number of animal and plant species, but also diversity of species or the introduction of invasive species. Many of the companies that report on biodiversity link this to climate change. The reasoning here is that climate change has a major impact on biodiversity through drought, excessive rain or the increase in temperature. This can have a major impact on many organizations, such as JDE Peets, Heineken, and Ahold Delhaize. It seems that biodiversity is integrated within the company management structures if it poses a (financial) risk to the company. Explicit linking of biodiversity to remuneration is only done by one company, Royal BAM Group.
This first study into reporting on biodiversity by Dutch listed companies provides a good overview of the current state of affairs. A limitation of this study is that only the information in annual reports was examined. There are some companies that choose to include more detailed information in other reports, this information has not been included in this study. Many companies have indicated in their 2023 report that they will start working on further analysis of biodiversity, associated risks and plans in 2024. It can therefore be expected that in the coming years information on biodiversity will become more detailed but also will increase in volume.
Prof. dr. Karen Maas is endowed professor of Accounting & Sustainability of the department Accounting and Finance of the Open University, Heerlen, and Academic Director of Impact Centre Erasmus at Erasmus Universiteit Rotterdam.
Dr. Kavita Nandram RA is ESG reporting manager at Ahold Delhaize, Programme Director of the ESG Academy at the University of Amsterdam, and Board Member of the Faculty Audit and Assurance at The Royal Netherlands Institute of Chartered Accountants (NBA).
Dr. Thomas Thijssens is Associate Professor of the department Accounting and Finance of the Open University, Heerlen.
With thanks to Ignace Breemer (Impact Center Erasmus, Erasmus University Rotterdam) for his contribution to the analysis of the reports.
The Nationaal Dashboard Biodiversiteit (National Biodiversity Dashboard) compiles and visualizes data on biodiversity and influencing factors from the Compendium for the Living Environment (CLO) to present biodiversity issues in a clear manner. The CLO is a public data source that processes and validates information about the Dutch living environment, using strict protocols developed by Planbureau voor de Leefomgeving (PBL), Centraal Bureau voor de Statistiek (CBS), Rijksinstituut voor Volksgezondheid en Milieu (RIVM) and Wageningen University & Research (WUR) (
Many companies already used materiality assessment before the CSRD requirement of performing a double materiality assessment. In this article we have indicated biodiversity or biodiversity related issues as material as it is indicated by the organisation as a material topic.
AEX | AMX | AScX | ||||||
---|---|---|---|---|---|---|---|---|
Company name | Sector | Revenu millions | Company name | Sector | Revenu millions | Company name | Sector | Revenu millions |
ABN AMRO | Financials | 15,849 | Aalberts | Industrials | 3,324 | Accsys Technologies | Industrials | 162 |
Adyen | Industrials | 1,600 | Air France - KLM | Consumer discretionary | 30,000 | Acomo | Consumer staples | 1,300 |
Aegon | Financials | 12,970 | Alfen | Industrials | 504 | Avantium | Basic materials | 20 |
Ahold Delhaize | Consumer staples | 95,945 | Allfunds Group | Financials | 2,781 | Azerion | Consumer discretionary | 515 |
Akzo Nobel | Basic materials | 16,668 | AMG | Industrials | 1,626 | B&S Group | Consumer discretionary | 2,220 |
ArcelorMittal | Basic materials | 68,275 | Aperam | Basic materials | 7,135 | Bam Group | Industrials | 6,270 |
ASM International | Technology | 2,600 | Arcadis | Industrials | 3,800 | Brunel International | Industrials | 1,300 |
ASML | Technology | 27,600 | Basic-Fit | Consumer discretionary | 1,047 | CM.com | Technology | 266 |
ASR Nederland | Financials | 8,095 | Corbion | Consumer staples | 1,443 | Ebusco Holding | Industrials | 102 |
Besi | Technology | 579 | CTP | Real estate | 673 | Fastned | Consumer discretionary | 60 |
DSM | Consumer staples | 12,310 | Eurocommercial | Real estate | 579 | ForFarmers | Consumer staples | 2,975 |
Exor | Financials | 35,500 | Fagron | Health care | 763 | Heijmans | Industrials | 2,100 |
Heineken | Consumer staples | 36,400 | Flow Traders | Financials | 304 | Kendrion | Consumer discretionary | 519 |
IMCD | Basic materials | 4,442 | Fugro | Industrials | 2,200 | Nedap | Industrials | 262 |
ING Group | Financials | 58,833 | Galapagos | Health care | 783 | NX Filtration | Industrials | 8 |
KPN | Telecommunication | 5,439 | Inpost | Industrials | 8,860 | NSI | Real estate | 71 |
NN Group | Financials | 578 | JDE Peet’s | Consumer staples | 8,200 | Pharming Group | Health care | 245 |
Philips | Health care | 18,200 | Just Eat Takeaway | Technology | 5,167 | PostNL | Industrials | 3,200 |
Prosus | Technology | 5,765 | OCI | Basic materials | 5,022 | Renewi | Utilities | 1,892 |
Randstad | Industrials | 25,400 | SBM Offshore | Energy | 4,532 | SIF Holding | Energy | 454 |
RELX | Consumer discretionary | 9,161 | Signify | Industrials | 6,700 | Sligro Food Group | Consumer staples | 2,859 |
Shell | Energy | 316,620 | TKH group | Industrials | 1,847 | TomTom | Technology | 585 |
UMG | Consumer discretionary | 11,108 | Van Landschot Kempen | Financials | 347 | Vastned retail | Real estate | 72 |
Unilever | Consumer staples | 59,604 | Vopak | Industrials | 1,425 | Vivoryon Therapeutics | Health care | NA |
Wolters Kluwer | Consumer discretionary | 5,584 | WDP | Real estate | 337 | Wereldhave | Real estate | 158 |