Opinion: Biodiversity is now on the ballot, are you ready?

The members of the Finance for Biodiversity (FfB) Foundation developed this Op-Ed under a subgroup of the working group ‘Engagement with Companies’. It is co-authored by Arthur van Mansvelt (Achmea IM), Sonya Likhtman (Federated Hermes Limited), Claudia Ravat (La Française AM), and Mary Beth Gallagher (Domini Impact Investments LLC).

Investors hold shareholder rights, which they can exercise to communicate their expectations to companies, and the proxy ballot is a key opportunity. As nature engagement ramps up across different initiatives, investors are signalling to companies that this issue is a priority and they expect actions to halt and reverse biodiversity loss in this decade.

Investors are increasingly aware that the alarming rate of biodiversity loss is generating a systemic risk for the financial system. Physical and transition nature-related risks are financially material for companies. These risks emerge from companies’ dependence on nature, with physical risks translating into potential disruptions in supply chains, and transition risks spurred by increased regulatory pressure.

The goals of the Global Biodiversity Framework (GBF) for 2030 ask for urgent action, including from the private sector. And of course, investors can support this in their stewardship. With the season of Annual General Meetings of Shareholders (AGMs) well underway, investors can consider how to use their voting to call on their investee companies to undertake more robust efforts to assess and address nature-related risks.

Increasing attention on biodiversity on the ballot

In the past, the number of resolutions on biodiversity has been highlighted as very low. In the report ‘Voting Matters 2023’, ShareAction identified only two resolutions that addressed biodiversity loss directly, through topics of sustainable materials procurement and deforestation, and a further eight resolutions on plastic use and pollution. The average support for the ten resolutions was 22%, with notably higher average support for the plastics resolutions. Planet Tracker also produced a helpful analysis in its blog post of February 2023, ‘Biodiversity proposals – A rare species’, which identified that, from 2018 to 2022, there were 15 proposals related to biodiversity, compared with 174 proposals requesting a climate change report.

Fortunately, this year, things are beginning to shift. Considering the systemic risk caused by biodiversity loss, the topic is beginning to gain increasing attention from investors, who want to see it rise to the top of companies’ agenda. While the rules vary across markets, filing resolutions can often act as an escalation, to help focus Board and Management attention on emerging issues, and help prompt increased disclosure or policy change, often at a faster pace than dialogue.

Shareholders’ resolutions can accelerate impact

Even with only a limited number of examples available, some recent engagement successes demonstrate that proposals play an important role in helping companies accelerate their biodiversity work.

  • In August 2022, Vancity Investment Management filed a shareholder proposal with Costco Wholesale Corporation that requested the company to map its supply chain and report on the risks associated with biodiversity loss. Through conversations with Costco’s leadership and sustainability teams, VCIM secured commitments that were requested in the shareholder proposal, including confirmation that the disclosure report will be in line with the Taskforce for Nature-Related Financial Disclosures (TNFD) framework. Costco is also working closely with the World Wildlife Foundation (WWF) on its biodiversity impact analysis.
  • In 2024, Domini Impact Investments filed a proposal that requested International Paper to conduct and disclose a biodiversity impact and dependency assessment, including supply chain impacts on the degradation of high-integrity forests. The resolution was withdrawn after the company agreed to become an early adopter of the TNFD and produce the requested impact and dependency assessment. A similar proposal was withdrawn at Starbucks after an agreement.


Ready to vote?

In 2024, biodiversity resolutions going to a vote generally fall into a few categories: (1) governance and impact assessment; (2) biodiversity pressure-specific, focusing on drivers of biodiversity loss, such as plastic pollution or deforestation, and (3) biome or location-specific. Biodiversity resolutions can also be strategic and sector-agnostic.

With the emergence of biodiversity frameworks and standards, such as the recommendations of the TNFD, GRI 101: Biodiversity, and the European Sustainability Reporting Standard (ESRS) new possibilities appear to ask companies to perform impacts and dependencies assessments, including disclosure on the presence of assets in sensitive locations. Then, investors are asking companies to commit to using and implementing TNFD recommendations within a determined timeline, to define science-based targets (SBTN), and to contribute to the goals of the GBF. For example, proposals filed with Home Depot and PepsiCo request a biodiversity impact and dependency assessment, including the full value chain and use of sold products.

On pressure-specific drivers of biodiversity loss, a group of proposals has been filed by As You Sow, asking automotive companies to clarify their approach to sourcing from deep-sea mining before the risk materialises. Also, a proposal filed with Kellanova asks the company to disclose the risks of pesticide use in the agricultural supply chain, which may have negative biodiversity and water impacts. These resolutions are key to raising awareness about material issues for companies.

On high-risk projects or location-specific issues, a few examples include a proposal filed with Travelers Companies on the human rights and biodiversity risks associated with underwriting activities in the Arctic National Wildlife Refuge and a proposal filed with Granite Construction about its high-risk quarries that can have water and ecological impacts.

Calling for investors and proxy advisors’ mobilisation on biodiversity

Several barriers and challenges are prominent in the development of biodiversity escalation strategies. Most financial institutions are still at the initial stages of building their understanding of nature-related impacts, dependencies, risks, and opportunities. Some may have not yet incorporated biodiversity into their stewardship priorities, proxy voting guidelines, and board expectations.

The Finance for Biodiversity (FfB) Foundation and the members of its working group on ‘Engagement with Companies’ will develop guidance for investors on biodiversity voting policies. As initial insights, the key conditions identified for getting more proposals on biodiversity are the following: investors reviewing their guidelines to have the option to vote and file on the topic in their policies; investors identifying the high-risk companies in their portfolios; investors asking companies for reporting and building a strategy on nature; asking questions at AGMs questions and filing proposals as an engagement tactic or as an escalation, if needed.

Proxy advisors are an essential player in providing robust research and analysis in their advice to financial institutions on biodiversity. We encourage them to ensure they have adequate expertise and capacity to respond to the increasing interest of financial institutions.

Finally, investors who have prioritised nature, and even those who are newer to this work, should see it as relevant in their proxy voting responsibilities. They can also consider how they might file proposals as part of their engagement with companies to raise visibility and communicate their increasing expectations on biodiversity. For the 2024 AGM season, we encourage investors to exercise their voting rights and seize opportunities to support biodiversity on the ballot.



For further details and identification of upcoming votes, investors can find information on the following platforms:




This document solely serves as voluntary guidance for financial institutions. The members of the Finance for Biodiversity Foundation (FfB) have not specifically verified the information contained herein, nor can they be held responsible for any subsequent use that may be made of this information by any party. FfB Foundation and its members are committed to complying with all laws and regulations that apply to them. This includes, amongst others, antitrust and other regulatory laws and regulations and the restrictions on information exchange and other collaborative engagements they impose. Further, each FfB member is responsible for their own strategies and policies, making unilateral decisions as designed and guided by their business activities, assessments and country context.

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