NA100 aims to propel corporate action on natural capital through investor engagement similar to the work of initiatives like Climate Action 100+.
On June 26, 2023, the Secretariat and Launching Investor Group behind Nature Action 100 (NA100) announced a set of focus areas and priority sectors for engagement with companies on biodiversity and broader nature-related matters (hereinafter, natural capital). Natural capital has rapidly climbed the list of environmental, social, and governance (ESG) priorities for many investors and regulators, with a series of initiatives being set up to parallel influential regimes on climate.
This post provides an overview of NA100 and its priorities, along with initial guidance for companies looking to integrate natural capital considerations into their ESG programs.
What Is NA100?
NA100 is a global investor engagement initiative focused on promoting corporate action on natural capital. Current members are primarily asset managers in Europe and the United States, collectively managing over $3 trillion, with the Secretariat co-led by Ceres and the Institutional Investors Group on Climate Change (IIGCC).
The initiative builds on the growing recognition of global economic dependency on natural capital by noting the significant risk of loss to investors and businesses alike if greater action is not taken to halt and reverse the degradation of nature. As such, NA100 works to promote investor engagement with companies to drive action on natural capital.
NA100’s engagement priorities focus on two main parts: (1) priority actions for companies to take, and (2) priority sectors for NA100 to engage with. Although structured differently, the priority actions share substantial overlap with certain draft Taskforce on Nature-related Financial Disclosures (TNFD) recommendations.
NA100’s list of “investor expectations” is as follows:
- Ambition: Publish commitments to minimizing contributions to nature loss and conserving and restoring biodiversity in corporate operations and value chains.
- Assessment: Assess and publicly disclose nature-related dependencies, impacts, risks, and opportunities to operations and value chains.
- Targets: Establish time-bound, context-specific, science-based targets.
- Implementation: Publish company-wide plans to reach targets while prioritizing rights-based approaches, developed in collaboration with Indigenous peoples and local communities affected by these plans.
- Governance: Integrate board oversight and disclose management’s role in assessing and managing nature-related dependencies, impacts, risks, and opportunities.
- Engagement: Engage with intermediaries in value chains, trade associations, policymakers, and other stakeholders.
These expectations apply regardless of sector. However, NA100 has also developed a list of eight key sectors deemed systemically important in reversing natural capital loss by 2030. The eight sectors are:
- Biotechnology and pharmaceuticals
- Chemicals (including agricultural chemicals)
- Household and personal goods
- Consumer goods retail (including e-commerce and specialty retailers and distributors)
- Food (ranging from meat and dairy producers to processed foods)
- Food and beverage retail
- Forestry and paper (including forest management and pulp and paper products)
- Metals and mining
NA100 has also indicated that it will finalize a list of particular companies to focus on engagement with later in 2023.
Four Considerations for Companies
As natural capital continues to rise in priority for a range of capital providers (and regulators), companies should not wait for the finalization of NA100’s list to start considering their approach to the topic. Below are four items to help companies get started.
- Understand where NA100 fits into the broader constellation of natural capital initiatives. As noted earlier, NA100 is one of multiple initiatives that aim to address risks related to natural capital. While NA100 is focused on investor engagement with companies, other initiatives can provide frameworks to be responsive to those investor concerns. In particular, Ceres has highlighted both TNFD and the Science Based Targets Network, a natural capital-focused analog to the Science Based Targets Initiative’s work on climate change.[i]
These civil society efforts sit alongside developing actions by governments, such as the Global Biodiversity Framework agreed in December 2022 and the EU’s draft reporting standard and biodiversity strategy. As such, understanding the full map of potential expectations can help companies identify gaps and synergies between different frameworks that may impact them.
- Identify how important natural capital is to the organization’s business model. While natural capital is rising in priority among ESG topics, that rise is not commensurate across industries or geographies. As with ESG matters generally, companies will need to consider how natural capital interacts with their particular business and its relative importance compared to other topics. As an initial matter, companies can look to the priority sectors identified by initiatives such as NA100 and TNFD to understand how stakeholders are weighing this topic for businesses like theirs. However, even for companies that do not believe natural capital poses a significant risk to their operations, some additional investigation and analysis will likely be necessary to demonstrate that conclusion to stakeholders’ satisfaction.
- Recognize that natural capital is more complex than climate. Climate is one system within the broader fold of nature. As such, even the natural capital initiatives designed to mirror their climate-focused counterparts are needing to adapt their frameworks to reflect the difference in scope. One of the key considerations for these revisions is natural capital’s multi-dimensionality. The various systems and complexes that comprise natural capital cannot be boiled down to a single risk vector or key impact metric, such as GHG emissions. A robust consideration of natural capital will require companies to assess a variety of indicators in order to develop a complete picture — and these indicators may change based on a company’s particular business activities.
Similarly, many aspects of natural capital are much more localized. While GHG emissions mix in the global atmosphere in a manner that makes any particular ton of CO2e emissions fungible with another, a decline in one ecosystem or species cannot necessarily be remedied by fostering a different ecosystem or species. As such, companies may need to assess natural capital matters in a series of geography-specific buckets instead of relying on organization-wide figures. And this complexity compounds when it is expanded to consider the various permutations within a company’s value chain.
- Consider how to leverage the company’s existing work on ESG. Despite some of the distinct challenges associated with natural capital, many of the core management considerations are similar as for other ESG matters. In particular, companies that have taken steps to address climate change may already have systems in place that can help them respond to these newer expectations on natural capital. For example, companies may consider providing their board committees tasked with ESG oversight some form of training on natural capital to mirror any work they are doing on climate. Similarly, companies may consider incorporating nature-related risks into their enterprise risk management exercises and/or expanding data collection efforts to include additional nature-related indicators. While these items will form only part of the picture of any ultimate strategy, they can give companies a place to start.
As with many ESG issues, expectations around natural capital are evolving quickly. Latham & Watkins will continue to monitor developments in this space.
For more information on natural capital developments, see these Latham-authored articles:
[i] Leslie Cordes, “Now is the Time for Investors to Engage with Companies on Nature,” Ceres (May 5, 2023), https://www.ceres.org/news-center/blog/now-time-investors-engage-companies-nature.