Consultation on the GRI Biodiversity Standard Exposure Draft

We refer to the Global Sustainability Standards Board (GSSB)’s public consultation on the exposure draft of the revised GRI Biodiversity Standard, published on 5 December 2022.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank (Norges Bank) and is responsible for investing the Norwegian Government Pension Fund Global. We work to safeguard and build financial wealth for future generations. As a long-term, global investor, we consider our returns over time to be dependent on sustainable development in economic, environmental and social terms.

We recognise and support the GRI’s intention to continue working together with other standard setters to facilitate harmonisation and interoperability of sustainability reporting standards. We encourage the GRI to ensure interoperability with other frameworks and standards, such as the forthcoming recommendations of the Taskforce on Nature-related Financial Disclosures (TNFD), which is developing a risk management and disclosure framework across all realms of the natural world (land, freshwater, oceans and atmosphere). As part of this, the TNFD is working on a methodology to assist companies in identifying and prioritising the location of their most significant biodiversity impacts and dependencies. We view the TNFD’s forthcoming framework as helpful guidance for companies in assessing biodiversity-related risks and opportunities, and complementary to the GRI’s Biodiversity topic standard.

We welcome the GRI’s intention to collaborate with the IFRS Foundation in creating an interconnected approach for sustainability disclosures, as outlined in the Memorandum of Understanding signed in March 2022. Interoperability among standards helps ensure comparability and consistency of disclosure across companies and reduce duplicative reporting requirements, in turn providing decision-useful information for investors and other stakeholders. It is also important to recognise that many companies will be reporting both on their dependencies (financial materiality) and their impacts. While our starting point as an investor in assessing companies’ sustainability information is financial materiality, we encourage companies to disclose the broader environmental and social consequences of business operations, and to use GRI standards in doing so. Such outcomes may themselves become financially material over time, especially for diversified investors with a long-term investment horizon like NBIM.

We welcome the revisions to the GRI Biodiversity Standard, notably the introduction of reporting on impacts in the supply chain, given this is where the most material biodiversity impacts and dependencies are often located. We do however note that collecting data from suppliers can be challenging, both due to complex supply chains and lack of direct control over business partners. We therefore support the intention to focus on the most important drivers of biodiversity loss, in line with IPBES guidance, and on priority locations, as it would be challenging for preparers to measure and report on every single driver and every single location. To help companies locate their interface with nature, the GRI could look to the LEAP approach (Locate, Evaluate, Assess, Prepare) under development by the TNFD. The LEAP approach will provide voluntary guidance intended to support companies in their nature-related risk and opportunity assessments and could help preparers in this prioritisation exercise.

Finally, we note that while the GRI defines impact as both positive and negative as per the Glossary definition, the Standard itself is focused on reporting of negative impacts. We would encourage the GRI to consider how the Standard can more fully take positive impacts and biodiversity gains into consideration.

We thank you for considering our perspective and remain at your disposal should you wish to discuss these matters further.

Yours sincerely,

Carine Smith Ihenacho,
Chief Governance and Compliance Officer 

Elisa Cencig,
Senior ESG Policy Adviser

Snorre Gjerde,
Lead Investment Stewardship Manager