TNFD Recommendations

Apply a materiality approach to determine nature-related issues for disclosure.

• breach notification template
• point of contact registry
• policy document
• technical file

• weak custody procedures
• no defined review cadence
• missing market abuse monitoring
• no independent audit
• no DPIA on file

Consider full scope of direct operations and value chains in disclosures.

• GHG emissions inventory
• control register
• consent record
• service level agreement
• CE marking evidence

• incomplete data subject response process
• missing mitigation evidence
• missing competent authority registration
• weak authentication
• missing single window submission evidence

Account for the location-specific nature of risks and dependencies.

• access log
• UDI registration record
• mechanical hazard assessment
• service level agreement
• reserve assets report
• risk register

• no exemption justification
• insufficient audit trail
• missing localisation
• no recall procedure

Ensure alignment and integration with other relevant sustainability disclosure frameworks.

• vendor due diligence questionnaire
• field safety notice
• carbon footprint methodology
• consent record
• transparency report
• sustainability disclosure

• unvalidated reserve assets
• missing mitigation evidence
• missing executive sign off

Consider short, medium and long-term time horizons for nature-related issues.

• test results report
• board diversity record
• marketing communication
• legal representative appointment letter
• control system safety report

• insufficient audit trail
• missing FSCA workflow
• no defined retention period
• missing mitigation evidence

Engage with affected stakeholders, including Indigenous Peoples and Local Communities.

• CE marking evidence
• clinical evaluation report
• validation protocol
• DPIA report
• data processing agreement

• no defined retention period
• weak minor protection measures
• inconsistent terminology
• scope ambiguity

Describe the board's oversight of nature-related dependencies, impacts, risks and opportunities, including the frequency of review, escalation routes, and how nature topics are integrated into existing governance arrangements.

• Board and committee charters referencing nature-related matters
• Board minutes evidencing review of nature topics
• Annual board calendar showing nature agenda items
• Board induction and training materials on nature-related issues
• Delegation of authority matrix covering nature risk decisions

• Nature topics bundled with climate without distinct treatment
• No documented escalation thresholds for material nature issues
• Board competency on nature not assessed or recorded

Describe management's role in assessing and managing nature-related dependencies, impacts, risks and opportunities, including positions accountable, reporting lines into the board, and cross-functional coordination across sustainability, risk, operations and finance.

• Organisational chart showing nature-related accountabilities
• Job descriptions for sustainability and risk leaders with nature scope
• Cross-functional steering committee terms of reference
• Management committee minutes addressing nature issues
• Remuneration policy linking incentives to nature-related performance

• No single accountable executive for nature
• Sustainability and enterprise risk functions disconnected
• Incentives not aligned to nature outcomes

Describe the organisation's human rights policies and engagement activities, including consultation with affected stakeholders such as Indigenous Peoples, Local Communities and other rights holders relevant to nature-related dependencies, impacts, risks and opportunities.

• Human rights policy aligned to UNGPs and ILO 169
• Stakeholder engagement plans for Indigenous Peoples and Local Communities
• FPIC procedures and records for site-level activities
• Grievance mechanism records and outcomes
• Community benefit-sharing agreements

• No FPIC process for activities in or near Indigenous lands
• Grievance mechanism inaccessible or not trusted
• Engagement records lack representativeness

Per TNFD Recommendations Governance pillar: governance over nature-related dependencies + impacts + risks + opportunities including Board oversight + Management's role + human rights considerations.

• TNFD evidence for TNFDREC-1

• LEAP + nature metrics partial

Apply the Locate phase of the LEAP approach to identify the organisation's interface with nature across direct operations and value chain, identifying which sectors, business units and locations interact with sensitive ecosystems and ecosystem services.

• Sector screening using SBTN materiality tools or equivalent
• Geospatial layers used (WWF Biodiversity Risk Filter, ENCORE, Aqueduct, IBAT)
• Site list with interface classifications
• Documentation of priority biomes
• Supplier traceability data

• Tier 2 and Tier 3 suppliers excluded
• Sensitive locations identified by country, not site
• Ecosystem services interface not assessed

Apply the Evaluate phase to identify dependencies on ecosystem services and impacts on nature for activities in priority locations, using accepted tools and methodologies and documenting the magnitude, scale and intensity of dependencies and impacts.

• ENCORE or equivalent dependency outputs by sector
• Impact driver assessment using SBTN or LEAP guidance
• Significance ratings with rationale
• Subject matter expert review records
• Internal sign-off on evaluation outputs

• Dependencies on ecosystem services overlooked
• Impact intensity not differentiated by location
• Indirect impacts via value chain not assessed

Apply the Assess phase to identify and measure nature-related risks and opportunities arising from the dependencies and impacts evaluated, including physical, transition, systemic and litigation risks and adjacent opportunities.

• Risk and opportunity register with TNFD typology fields
• Scoring methodology aligned to enterprise risk
• Financial materiality assessment outputs
• Opportunity business cases
• Cross-functional review records

• Systemic risks not considered
• Litigation and reputational risks underweighted
• Opportunities not quantified

Apply the Prepare phase to set strategy, take action and disclose nature-related dependencies, impacts, risks and opportunities, ensuring outputs feed governance, risk management, metrics and targets and external disclosure.

• Strategy and response plan referencing LEAP outputs
• Action tracker with owners and timelines
• Disclosure mapping showing how LEAP feeds each of the 14 recommended disclosures
• Internal review and management sign-off records
• External assurance scoping documents

• LEAP outputs not traceable to disclosed narrative
• Actions identified but not resourced
• Assurance scope excludes most material disclosures

Per TNFD: metrics + targets including core global + sector + nature-related impact + dependency + risk + opportunity metrics. Align with ISSB + SBTN.

• TNFD evidence for TNFDREC-4

• LEAP + nature metrics partial

Disclose the metrics used by the organisation to assess and manage material nature-related risks and opportunities in line with its strategy and risk management process, including metrics aligned to the core global indicators where applicable.

• Indicator catalogue mapped to TNFD core global indicators
• Data lineage for each indicator from source system to disclosure
• Reporting boundaries and methodology notes
• Time series of indicator values
• Internal control evidence over metric calculation

• Core indicators omitted without explanation
• Methodology changes not disclosed
• Boundaries inconsistent across indicators

Disclose the metrics used by the organisation to assess and manage dependencies and impacts on nature, covering the drivers of nature change such as land and sea use change, resource use, pollution, climate change and invasive alien species, where material.

• Water withdrawal and discharge data by basin
• Land and sea use change records by site
• Pollutant release inventories
• Plastic and waste flow data
• Invasive alien species risk records

• Water data not catchment-specific
• Pollutants tracked at parent company only, not site
• Plastic flows not measured

Describe the targets and goals used by the organisation to manage nature-related dependencies, impacts, risks and opportunities and its performance against these, including methodology, baseline, scope, time horizon and any verification or assurance.

• Target setting methodology document
• Baseline calculation records
• Annual performance reports against targets
• Independent assurance statement
• Board approval of targets

• Targets lack baseline or scope clarity
• Performance reporting changes scope without restatement
• No assurance over reported performance

Per TNFD: risk management via LEAP approach (Locate + Evaluate + Assess + Prepare). Integrate with ERM + identify priority locations + sensitive locations.

• TNFD evidence for TNFDREC-3

• LEAP + nature metrics partial

Describe the processes used to identify, assess and prioritise nature-related dependencies, impacts, risks and opportunities in direct operations and value chain, including the data, tools and methodologies used and how the LEAP approach or equivalent has been applied.

• Documented LEAP or equivalent assessment methodology
• Tool selection rationale and data quality assessment
• Records of Locate, Evaluate, Assess and Prepare workshop outputs
• Internal procedure for prioritisation criteria
• Sign-off records for assessment scope

• Methodology not consistently applied across business units
• Data quality and uncertainty not characterised
• No update cadence defined

Describe the processes used to manage nature-related dependencies, impacts, risks and opportunities, including avoidance, reduction, restoration, regeneration and transformation actions, and how these are prioritised through a mitigation hierarchy.

• Mitigation hierarchy procedure with decision criteria
• Site-level action plans documenting avoid, reduce, restore and offset steps
• Restoration project records and ecological monitoring
• Supplier engagement programmes
• Incident records and corrective action logs

• Reliance on offsets without prior avoid and reduce evidence
• Restoration outcomes not monitored long term
• Supplier risk treated only through code of conduct

Describe how the processes for identifying, assessing, prioritising and monitoring nature-related risks are integrated into and inform the organisation's overall risk management.

• Enterprise risk framework documenting nature integration
• Risk appetite statement covering nature where material
• Risk register with nature entries scored consistently with other risks
• Internal audit plan including nature topics
• Periodic risk reporting to board with nature content

• Nature risks managed in a separate sustainability silo
• Scoring methodology incompatible with other risk categories
• No internal assurance over nature risk data

Disclose the nature-related dependencies, impacts, risks and opportunities identified across the short, medium and long term, distinguishing physical, transition and systemic risk categories and the geographies and biomes involved.

• Nature materiality assessment report
• Register of dependencies, impacts, risks and opportunities by business unit
• Time horizon definitions consistent with strategy and capital cycles
• Heatmap by biome, location and value chain stage
• Linkage to enterprise risk management taxonomy

• Dependencies on ecosystem services not assessed
• Only direct operations covered, upstream and downstream omitted
• Time horizons inconsistent with climate disclosures

Describe the effects that nature-related dependencies, impacts, risks and opportunities have had and are expected to have on the organisation's business model, value chain, strategy and financial planning, including capital allocation and transition activities.

• Strategic plan referencing nature dependencies and impacts
• Capital expenditure and operating expenditure tagged for nature outcomes
• Product, service and market portfolio reviews
• Procurement and supplier strategy updates
• Financial planning model assumptions documenting nature impacts

• Nature not reflected in financial planning assumptions
• Capital allocation decisions not traceable to nature evidence
• Transition plans focused on climate only

Describe the resilience of the organisation's strategy to nature-related risks and opportunities, taking into account different scenarios that reflect plausible pathways for the state of nature and policy, market and societal responses.

• Scenario narratives covering ambitious and degrading nature states
• Quantitative or qualitative scenario assessment outputs
• Sensitivity analysis on key dependencies
• Documentation of scenario assumptions and data sources
• Strategic response options identified under each scenario

• Scenarios limited to single time horizon
• Scenario narratives lack credible policy and societal drivers
• Outputs not linked to strategic decisions

Disclose the locations of assets and activities in the direct operations and, where possible, the upstream and downstream value chain that meet the criteria for priority locations, being areas of sensitive biodiversity, water stress, ecosystem integrity decline or high ecosystem service materiality.

• Asset register with geolocation coordinates
• Overlay analysis with biodiversity, water stress and protected area datasets
• Priority location list with selection criteria
• Supplier mapping with origin-of-material data
• Documentation of LEAP Locate step outputs

• Geolocation data missing for supplier sites
• Priority location criteria not transparent
• Sensitive locations not refreshed annually

Per TNFD Strategy: nature-related dependencies + impacts + risks + opportunities + strategy effects + resilience under scenarios.

• TNFD evidence for TNFDREC-2

• LEAP + nature metrics partial

Demonstrate the scope and depth of value chain coverage in nature-related assessments, including upstream sourcing, downstream use of products and the traceability of materials linked to nature-sensitive commodities.

• Commodity traceability records to mill, farm or fishery as applicable
• Supplier disclosures and certifications
• Procurement policy excluding deforestation-linked sourcing
• Downstream product impact assessments
• Third party verification records

• Traceability limited to direct suppliers
• Certifications relied upon without verification
• Downstream impacts not assessed