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E4.IRO-1 - Description of procedures for the identification and assessment of Impact materialities, Risks, Dependencies and Opportunities related to biodiversity and ecosystems

Updated over 5 months ago

ESRS Standard

ESRS 2 - General disclosures

8 The requirements in this section should be read in conjunction with the disclosure requirements in Chapter 2 Governance, Chapter 3 Strategy and Chapter 4 Management of Impacts, Risks and Opportunities of ESRS 2.

9 The resulting disclosures are presented together with the disclosures required by ESRS 2, with the exception of ESRS 2 SBM-3, where the entity has the option to combine the disclosures with the topic-related disclosures.

10 In addition to the ESRS 2 requirements, this standard also includes the topic-related disclosure requirement E4-1 Transition plan and consideration of biodiversity and ecosystems in strategy and business model.


17 The entity describes its process for identifying material impacts, risks, dependencies and opportunities. The description of the process includes information on whether and how the company

  • a) Identified and assessed the actual and potential impacts on biodiversity and ecosystems at its own sites and within the upstream and downstream Value chain, including the assessment criteria used,

  • b) Dependencies on biodiversity and ecosystems and their services at its own sites and within the upstream and downstream Value chain have been identified and assessed, including the assessment criteria used, and whether this assessment has taken into account Ecosystem services that are or are likely to be affected by disturbances,

  • c) has identified and assessed Transition risks and Physical risks and Opportunities related to biodiversity and ecosystems, including the assessment criteria used based on its Impacts and Dependencies,

  • d) has considered Systemic risks,

  • (e) has carried out consultations with affected communities on sustainability assessments of shared biological resources and ecosystems; in particular, the following shall apply:

    • i. Where a Site or the production or sourcing of Raw materials is likely to have negative impacts on biodiversity and ecosystems, the company shall identify the specific Sites or production or sourcing of Raw materials with negative or potentially negative impacts on Affected Communities,

    • ii. where impacts on affected communities are likely to occur, the company shall indicate how these communities have been included in the materiality analysis; and

    • iii. in relation to the impacts of its own activities on Ecosystem services relevant to Affected Communities, the company shall indicate how negative impacts can be avoided. If these impacts are unavoidable, the company may indicate its plans to minimize these impacts and implement mitigation measures to maintain the value and functionality of priority services.

18 The company can indicate whether and how it has used Scenario analysis for biodiversity and ecosystems as a basis for identifying and assessing Material risks and Opportunities over short, medium and long-term time horizons. If the company has used such Scenario analysis, it may provide the following information:

  • (a) why the Scenarios considered were selected,

  • b) how the Scenarios considered are updated to reflect changing conditions and new trends; and,

  • (c) whether the Scenarios are based on expectations published by relevant intergovernmental bodies such as the Convention on Biological Diversity and, where appropriate, scientific consensus such as those expressed by the Intergovernmental Platform on Science-Policy for Biodiversity or Ecosystem Services (IPBES).

(19) In particular, the company shall indicate the following:

  • (a) whether it has sites in or near Biodiversity sensitive areas and whether activities associated with these sites negatively Impacts these areas by causing degradation of natural habitats and species habitats and disturbance to the species for which the Protected area has been designated; and,

  • (b) whether it has concluded that biodiversity mitigation measures need to be taken, such as those set out in the following legal acts: Directive 2009/147/EC of the European Parliament and of the Council on the conservation of wild birds, Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora, Environmental Impact Assessment (EIA) in accordance with Article 1(2)(g) of Directive 2011/92/EU of the European Parliament and of the Council (83) on the assessment of the effects of certain public and private projects on the environment, for activities in third countries assessments in accordance with relevant national provisions or international standards such as International Finance Corporation (IFC) Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources.


Application Requirements (AR)

AR 4 The materiality analysisaccording to ESRS E4 includes

  • a) the contribution to the direct drivers of Biodiversity loss: (88)

    • i. Climate change,

    • ii. Land use change (e.g. denaturation of Soil), Freshwater and marine changes,

    • iii. direct use,

    • iv. Invasive or alien species,

    • v. Pollution, and

    • vi. other.

  • b) Impacts on the status of species (i.e. population size, risk of global extinction of species),

  • (c) Impacts on the extent and condition of ecosystems, including through Land degradation, Desertification and Soil sealing; and

  • d) Impacts on and dependencies on Ecosystem services.

AR 5 When analyzing the materiality of Impacts, Dependencies, Risks and Opportunities, the company shall consider the provisions in ESRS 2 IRO-1 and Chapter 3 Double materiality as the basis for disclosing sustainability information in ESRS 1 and explain its considerations.

AR 6 The company analyzes the Materiality of biodiversity and ecosystems within its own operations and within its upstream and downstream Value chain and can conduct its Materiality analysis in line with the first three phases of the LEAP approach: localize (section AR 7), evaluate (section AR 8) and assess (section AR 9).

AR 7. Phase 1 involves locating relevant sites in terms of their interface with biodiversity and ecosystems. To identify these relevant sites, the company can:

  • (a) make a list of sites where direct assets are located and where activities are carried out, as well as the associated upstream and downstream Value chain relevant to the company's operations. In addition, the company may provide information on sites for which future activities have been officially announced,

  • b) a list of biomes and ecosystems with which it interfaces, based on the list of sites referred to in Section AR 7(a),

  • (c) identify the current biodiversity and ecosystem integrity and importance of each site, taking into account the information referred to in paragraphs 16 and 17,

  • (d) establish a list of sites where the company interfaces with sites in or near Biodiversity sensitive areas, taking into account the information referred to in paragraphs 16 and 17; and

  • (e) identify the sectors, business lines, value chains or asset classes that interface with biodiversity and ecosystems in those material sites. Instead of identifying these interfaces for each Site, the company may choose to identify them by weight in tons for each Raw material sourced or sold, if such practice provides greater transparency.

AR 8 In Phase 2, the company may assess the actual or potential impacts and dependencies on biodiversity and ecosystems for relevant sites by:

  • (a) identifying the business operations and activities that interface with biodiversity and ecosystems,

  • b) identifying actual and potential Impacts and Dependencies,

  • (c) indicating the magnitude, extent, frequency of occurrence and timeframe of impacts on biodiversity and ecosystems, taking into account the information provided in accordance with paragraphs 16 and 17. In addition, the company shall disclose the following:

    • i. the percentage of its Suppliers' facilities that are located in risk-prone areas (with Threatened species according to the IUCN Red List of Threatened Species, the Birds and Habitats Directives or a national list of Threatened species, or in officially recognized Protected Areas, Natura 2000 protected areas and Key Biodiversity Areas),

    • ii. the percentage of its procurements from Suppliers with facilities located in risk-prone areas (with Threatened species according to the IUCN Red List of Threatened Species, the Birds and Habitats Directives or a national list of Threatened Species, or in officially recognized Protected Areas, Natura 2000 protected areas and Key Biodiversity Areas); and

  • d) the scope and extent of dependencies on biodiversity and ecosystems, including Raw materials, Natural resources and Ecosystem services. The company may rely on international classifications such as the Common International Classification of Ecosystem Services (CICES).

AR 9 In Phase 3, the company may consider the following categories to assess its Material risks and Opportunities based on the results of Phases 1 and 2:

  • (a) Physical risks:

    • i. acute Risks (e.g. natural disasters exacerbated by loss of coastal ecosystem protection leading to costs due to storm damage to coastal infrastructure, diseases or pests affecting the species or variety of crops on which the business relies, particularly in the case of lack of or low genetic diversity, loss of species and damage to ecosystems), and

    • ii. chronic Risks (e.g. loss of crop yield due to decline in pollination services, increasing scarcity or variable production of key natural inputs, damage to ecosystems due to activities such as coastal erosion and fragmentation of forest areas, ocean acidification, land loss due to Desertification and Soil degradation and the resulting decline in soil fertility and species loss);

  • b) Transition risks, including in the following areas:

    • i. Policy and law: e.g. introduction of legislation or policy actions (e.g. changes such as increased soil protection), exposure to sanctions and litigation (e.g. discharge of Pollutants that harm human and ecosystem health or violations of rights, permits or allocations related to biodiversity or neglect or killing of Threatened species), increased reporting requirements related to biodiversity, ecosystems and related services,

    • ii. Technology: e.g. introduction of products or services with lower impacts on biodiversity or lower dependency on Ecosystem services, lack of access to data or access to poor quality data hampering biodiversity-related assessments, transition to more efficient and cleaner technologies (e.g. with lower impacts on biodiversity), new monitoring technologies (e.g. satellites), requirements related to the use of certain technologies (e.g. climate resilient crops, mechanical pollinators, water purification, flood control),

    • iii. Market: e.g. shift in supply, demand and financing, volatility or increased cost of Raw materials (e.g. biodiversity-intensive inputs for which the price has increased due to ecosystem degradation ),

    • iv. Reputation: e.g. changing perceptions of society, customers or communities as a result of an organization's role in Biodiversity loss, violation of nature-related rights through business activities, negative media coverage due to Impacts on critical species and/or ecosystems, social conflicts related to Biodiversity due to endangered species, Protected areas, resources or Pollution;

  • c) Systemic risks, including

    • i. the risk that an ecosystem collapses or that a critical natural system ceases to function, for example if tipping points are reached and the collapse of ecosystems leads to geographical or sectoral wholesale losses (aggregate Physical risks),

    • ii. aggregate risks related to the fundamental impacts of Biodiversity loss on the level of transition risk and physical risk in one or more sectors of a portfolio (corporate or financial), and

    • iii. Contagion risks, which consist of financial difficulties of certain companies or financial institutions spilling over to the economic system as a whole due to the failure to address biodiversity-related Risks;

  • d) Opportunities, including for example

    • i. Categories of business performance: resource efficiency, products and services, markets, cash flow and financing, reputational capital; and

    • ii. Sustainability performance categories: Ecosystem protection, restoration and recovery, sustainable use of natural resources.

Presentation of information:

AR 10. the company may consider the tables below to simplify its analysis of Materiality of Material Sites in accordance with section AR 7:

In relation to section AR 7(e), the company may consider using the table below:


Examples from past practice

Examples are provided only as an indication of how a disclosure requirement has been reported by other companies to date. Audited ESRS reports are not yet available. There is no guarantee of accuracy and completeness.

E4.IRO-1 - Description of processes related to biodiversity and ecosystems

Sensitive Sites and their Assessment

We are aware that our activities have an impact on nature and that we are also dependent on natural resources. We have therefore started to monitor the state of the ecosystems in which we operate directly or indirectly. Although we have not yet conducted a comprehensive assessment of prioritized sensitive sites, we use the methods and tools recommended by TNFD to collect and analyze data on the health, stability and viability of these ecosystems. This allows us to better understand the impacts our operations have on the environment and how we can manage our dependence on intact ecosystems.

Criteria for assessing sensitive sites

Several criteria were used to assess sensitive sites, including biodiversity. For example, it is checked whether Threatened species are present in the ecosystems concerned. Data sources such as the Red List of Threatened Species (IUCN Red List) and the Integrated Biodiversity Assessment Tool (IBAT) are used to collect and analyze global biodiversity data. Indicators such as the number of endangered species occurring within a 50 km radius of a site are documented.

Analysis of Sites

IBAT was used to analyze all warehouses, including distribution and logistics centers in Poland, Romania and Slovakia. A 50 km radius around each site was considered. The analysis included three main criteria and showed how the warehouse locations could potentially affect neighboring ecosystems.

This article has been machine translated. In case of errors, please contact [email protected].

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