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Biodiversity: pension funds
A new climate in fund management
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George Graham looks at the difficulties of assessing the risk that biodiversity loss represents to pension fund investments and asks how the UK pension industry might respond to regulatory pressure to quantify those risks
It has taken years to get asset owners to focus their attention on the risks that climate change could pose to their portfolios. Yet some are now starting to worry that, in our efforts to combat this threat, we are heightening an even more immediate risk: the startling decline in biodiversity, with species becoming extinct at an accelerating pace.
“Sadly, the singular focus on solving climate change has led to the neglect of biodiversity. The alarming result is that many climate efforts inadvertently accelerate nature’s destruction,” warned Henry Paulson, former US Treasury Secretary and chair of the Paulson Institute, in a recent Financial Times column.
The scale of the problem is daunting. Summarising the scientific evidence, the Institute and Faculty of Actuaries note significant impacts on biodiversity across 75% of the global land surface and 66% of the global ocean area. Vertebrate species population declines averaged 69% over the period from 1970 to 2018, with around a quarter of all known animal and plant species threatened with extinction.

Close links to climate change

Some pension funds and asset owners have started to pay attention to the value of natural capital in their portfolios, but most are not considering biodiversity as a concern separate to climate change.
But biodiversity loss is not (just) about having fewer pandas. It and climate change are interlinked and self-reinforcing. Functioning ecosystems are carbon stores that can help regulate the climate and damage to them can release carbon dioxide and impair their ability to act as carbon sinks. At the same time, climate change is one of the key drivers of biodiversity loss. For example, extreme weather events, rising temperatures, ocean acidification and rising sea levels all disrupt natural habitats. But the starting point in many funds’ thought processes has been the need to address climate change.
“To date the level of interest in biodiversity and natural capital solutions has been driven by pension funds implementing climate change mitigation strategies. For most funds, natural capital investment is part of their journey towards net zero,” says Karen Shackleton, founder of Pensions for Purpose and co-author of a June 2023 report, ‘Natural Capital and Biodiversity: where are UK asset owners on their journey?’ , commissioned by Gresham House, a specialist alternative asset manager.
That means that asset owners’ journeys towards integrating biodiversity is in some cases different from the path they travelled with climate change. There, the primary focus was on risk, as outlined by the Bank of England in its work on climate change. The stated climate change risks were: physical risks to assets exposed to more extreme weather conditions; transition risks as sectors of the economy face big shifts in asset values or the costs of doing business; and liability risks as people seek compensation for losses they may have suffered from those physical or transition risks.
Most asset owners are not considering biodiversity as a concern separate to climate change
But nature-related risks are more complex than climate risks. As the report from the Institute and Faculty of Actuaries points out, there is no single benchmark, such as greenhouse gas emissions, against which to measure it, and ‘offsetting’ damage in one area by improvements elsewhere is much more challenging because biodiversity is a function of a particular geographical space.
In the response to climate risk, early adjustments to investment strategy might have included exclusion of industries with high carbon emissions, as well as shareholder pressure on portfolio companies to reduce their carbon footprints. Positive investments, part of whose purpose was their potential impact on climate change, tended to come later. Many of these positive investments in areas such as forestry, sustainable agriculture and habitat banks can contribute to a biodiversity strategy. For some investors, too, the carbon credits that may be derived from them play an important role in the investment case.
Unfortunately, not all of these investments that were intended to make a positive contribution to a sustainable investment portfolio have turned out to be problem-free. Paulson identified felling forests in Virginia to build solar power facilities and bird deaths from wind farms as some of the problems.
Some pension funds in the UK have viewed anaerobic digesters, which generate biogas from agricultural waste, as assets with attractive returns that also contribute to their sustainability credentials. But digestate spread on fields has contributed to pollution of some important river systems such as the Wye, causing algal blooms and damage to fish stocks. Fish Legal, the environmental litigation association I chair, spends a significant amount of its time pursuing compensation for fish kills caused by spillages from malfunctioning anaerobic digesters.

Assessing the risks of biodiversity loss

Work is under way, however, to explore the financial risks posed by deteriorating nature conditions. For example, investment consultants Aon partnered with the Cambridge Institute for Sustainability Leadership to map the exposure of the MSCI All World Index to nature-related risks, with water security coming out as the greatest risk across the index.
Aon’s Mette Charles, one of the authors of that report, notes that the analysis only captured direct influences. “Food security doesn’t register, though every company needs its workers to be able to eat,” she says.
Although measuring and managing nature-related risks is likely to prove more complex than tackling their climate-related counterparts, disclosure standards are being developed. The Taskforce on Nature-Related Financial Disclosures (TNFD) produced its fourth beta framework for reporting in March this year and recently finalised the framework.
Fund managers have found some of the generic metrics concerning biodiversity to be of little practical use
The proposals build on the same four pillars as the Taskforce on Climate-Related Financial Disclosures (TCFD): governance, strategy, risk management, and metrics and targets. The Taskforce has adapted the notion of ‘Scopes’ (Scope 1, 2 and 3 in climate reporting) to the nature context as ‘direct’ operations, ‘upstream’, ‘downstream’ and ‘financed’, and has produced draft guidance for four sectors – Agriculture & Food; Mining & Metals; Energy; and Financial Institutions – and for four biomes, including tropical forests.

Limited scope for action

Fund managers have found some of the generic metrics favoured by scientists working on biodiversity, such as mean species abundance, to be of little practical use. Instead, they are focusing on more localised measures such as water consumption and land use.
Given the difficulty many pension funds have had in producing their first mandatory climate-related disclosures (these have been widely criticised for including unreasonably rosy assumptions in the obligatory scenario analysis), it seems unlikely that many will be rushing to include nature-related disclosures unless the Occupational Pension Schemes reporting regulations are expanded.
A handful of countries have moved further down this regulatory path. France, for example, has required biodiversity disclosures from asset managers for some years, and this has helped to spur managers to develop more products addressing biodiversity issues. “We don’t have silver bullets but we do have more solutions available,” says Robert-Alexandre Poujade, Lead Biodiversity Analyst at BNP Paribas Asset Management.
For UK defined benefit pension schemes, many of which are in run-off, the scope for action is likely to be limited. Illiquid investments such as forestry become less attractive as a fund comes closer to buyout by an insurance company, as these assets tend to be less readily accepted by insurers because of their Solvency II weightings. But the steady inflows into defined contribution funds mean these could become increasingly important investors in natural capital. That could be of interest to trustees seeking to anticipate future regulation by adding biodiversity disclosures to those already mandated on climate change.
George Graham
After 20 years at the Financial Times, where he was banking editor, fishing commentator and head of the Lex column, George Graham joined the strategy team at RBS, where he led the bank’s work on competition, ring-fencing and financial stability issues. He is a pension fund trustee and chair of Fish Legal, a campaigning association of anglers