PUBLIC DEVELOPMENT BANKS AND BIODIVERSITY - How PDBs can align with the Post-2020 Global Biodiversity Framework Abridged Version - May 2021 - WWF
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PUBLIC DEVELOPMENT BANKS AND BIODIVERSITY How PDBs can align with the Post-2020 Global Biodiversity Framework Abridged Version - May 2021 WWF is working with this partner to protect global environments.
Authors Leon Bennun, Renaud Lapeyre, Camille Maclet, Teja Chalikonda, Adrien Lindon, David Meyers, Robin Mitchell, Cheryl Ng, Nikki Phair, Tami Putri, Helen Temple, Thomas White, Guy Williams and Malcolm Starkey. Citation WWF & The Biodiversity Consultancy 2021. Public development banks and biodiversity. How PDBs can align with the Post-2020 Global Biodiversity Framework. Paris, WWF France. Use and attribution Material in this report may be used and shared subject to a Creative Commons Attribution-ShareAlike 4.0 International license. In summary, this requires that users credit this report appropriately, indicate if changes were made, and distribute any derived material under the same license and with no additional restrictions. Citations or attributions to other sources in this report should be maintained in any further use or sharing. Disclaimer This report includes interpretation of interview conversations and survey responses from Public Development Bank staff and subject matter experts. The views expressed do not necessarily correspond to those of specific Public Development Banks, WWF or The Biodiversity Consultancy. Acknowledgements This study was conducted by The Biodiversity Consultancy (TBC) under contract to WWF (World Wide Fund for Nature) France, with funding support from WWF Germany and Agence Française de Développement (AFD). Renaud Lapeyre (WWF- France) steered and co-ordinated the study and finalized the report. We are grateful to members of the WWF Steering Committee for the study and other partners for contributing valuable insights, guidance and review: Celine Beaulieu, Hugo Bluet, Kai Dombrowski, Fanny Gauttier, Kenan Hadzimusic, Sergiu Jiduc, Matthias Kopp, Margaret Kuhlow, Bruce Liggitt, David McCauley, Antoine Maudinet, Beatriz Merino, Florian Titze, Ray Victurine, and Helena Wright. We sincerely thank all the Public Development Bank staff and subject matter experts who generously made time available for interviews and for completing the online survey. © Antonio Busiello / WWF-US WWF 2021
TABLE OF CONTENTS CONTEXT 4 MAINSTREAMING BIODIVERSITY IN PUBLIC DEVELOPMENT BANKS 8 GREENING FINANCE: REDUCING HARM TO BIODIVERSITY 13 FINANCING GREEN: SCALING UP NATURE-POSITIVE INVESTMENTS 17 THE ROAD TOWARDS NATURE-POSITIVE FINANCE FOR PDBS 20 RECOMMENDATIONS 25 CONCLUSION 34 REFERENCES 36 Design Muscade WWF® and World Wide Fund for Nature® trademarks and ©1986 Panda Symbol are owned by WWF-World Wide Fund For Nature (formerly World Wildlife Fund). All rights reserved. Document published in June 2021 Any reproduction in full or in part must mention the title and credit the opposite-mentioned publisher as the copyright owner. WWF France, 35-37 rue Baudin - 93310 Le Pré Saint-Gervais Cover photography: © Copyright Adam Oswell / WWF-US 3
PRELIMINARY NOTE This document summarizes the key findings and recommendations from a study carried out between September 2020 and February 2021. For further detail, please refer to the published main study report. STUDY BACKGROUND AND RATIONALE Science has never been clearer about the unprec- cussions on the framework highlight that a coherent edented extent and rate at which biodiversity is and concerted approach across the whole of society being lost1, pushing vital ecosystems like oceans, will be essential if we are to achieve global goals for forests and rivers to dangerous tipping points. This nature. Mainstreaming biodiversity within economic erosion of global biodiversity is essentially caused by decision-making remains an urgent priority: while human activities. The issue currently features high on this was central to Aichi Biodiversity Target n°2 in the agenda of crucial international negotiations on the Strategic Plan for Biodiversity 2011-20204, this climate, sustainable development and biodiversity, Target was far from being met5. including the Convention on Biological Diversity’s (CBD) post‑2020 global biodiversity framework2. Dis- Transition risk Biodiversity Finance Impact (stock of natural sector capital) Financing and investing in companies De pe Ecosystem nd en cy services (flows of natural capital) Physical risk Systemic risk Figure A. Relationship between financial sector, economy, biodiversity and ecosystem services, and resulting risks3. 1 IPBES 2019; WWF 2020; WEF 2021 2 https://www.cbd.int/conferences/post2020 3 Partially adapted from van Toor et al. 2020 4 https://www.cbd.int/sp/targets/rationale/target-2/ 5 Secretariat of the Convention on Biological Diversity (2020) 5
More than half of the world’s total gross domestic urban development, not to mention the harmful product (GDP) is moderately or highly dependent on effects on ecosystems of human-induced climate nature and its services6. Yet in our globalized economy change. Only a fraction of this global investment is damaging impacts to nature are not accounted for in being mobilized under appropriate conditions for the valuation of goods and services, nor in the share environmental safeguarding and nature protection. prices of the companies that are responsible for that damage. Financial flows to conserve nature are hugely However, recently published studies have highlighted outbalanced by financing targeted to activities that how harming nature also translates into tangible and are directly harmful to biodiversity7. pervasive risks for investors and businesses, including physical, transition and systemic risk (Figure A). In turn, Financial institutions are funding activities destruc- these biodiversity risks translate directly into impacts tive to nature in many sectors such as agribusiness on finance (Figure B). and fisheries, extractive industry, infrastructure and Biodiversity risk Impacts on business Impacts on finance PHYSICAL RISK Input scarcity, higher Loss of biodiversity or more volatile prices and ecosystem services: Disruption of production processes Ecosystem and value chains conversion and degradation Deteriorating operating conditions Climate change Decline of site Overexploitation attractiveness Market risk (losses on shares Pollution Need for relocation and bonds) Invasive species Assets and collateral Credit risk impaired (losses on corporate loans) Liquidity risk TRANSITION RISK Project delays Reduced (refinancing constraints) Increased mitigation profitability Current and future requirements Operational risk regulation Sourcing restrictions (liabilities, reputation, Financing legal costs) requirements Stranded assets Societal expectations Damage to brand Changing consumer Reduced market preferences appeal SYSTEMIC RISK Economic and Large-scale disruption social crises to natural systems Figure B. Relationship between financial sector, economy, biodiversity and ecosystem services, and resulting risks8. 6 World Economic Forum (WEF) 2020, Deutz et al. 2020 7 OECD 2020 8 Partially adapted from van Toor et al. 2020 WWF 2021
In response to this, it is imperative that the finance roots in [...] respective economic and social fabrics, sector addresses the impacts of its investments on [they] build bridges between governments and the nature. This requires two inter-linked approaches: private sector; between domestic and international agendas; between global liquidity and microeconomic • Greening finance: so that investment decisions solutions; and between short-term and longer-term include better consideration of nature-related risks priorities. [They] can significantly contribute to and impacts, to avoid, minimise, restore and when reorienting global finance towards climate and SDGs.” necessary offset negative impacts to biodiversity. Building on the two linked but complementary aspects • Financing green: through investments that can of ‘greening finance’ and ‘financing green’, the study create a positive impact on nature, for example aimed to: through protection and restoration of degraded habitats, or by supporting economic and social • Review and assess how PDBs currently integrate development that reduces the pressures on biodi- nature in their processes versity. Such investments are increasingly termed and business models ‘nature-positive’. • Outline constructive and PDBs provide 10% of all Public Development Banks9 have a unique role to play practical recommendations yearly private and public financing and have a unique in shifting financial flows towards sustainability. PDBs for how this could be im- themselves provide finance of around $ 2.3 trillion proved, to strengthen the annually, a significant component (10%) of all yearly private and public financing10. But PDBs also have role of PDBs in support- ing the post-2020 global role to play in shifting much greater influence than this share would suggest. As stated in the 2020 Joint Declaration of all PDBs biodiversity framework and the 2030 Agenda for financial flows towards in the World, “with [their] public mandates and Sustainable Development. sustainability. METHODS Relevant information was compiled through: • Thirty-four in-depth semi-structured interviews involving 32 PDB staff from 17 institutions and • Identifying and listing PDBs, reviewing docu- seven subject matter experts, followed by thematic mentation for a sample of 98 institutions, and analysis extracting information in AFD’s11 global database of Public Development Banks12 • Compiling and rapidly reviewing around 150 further relevant reports and other documents. • Developing and circulating a detailed online survey questionnaire 9 Public Development Banks (PDBs) are defined as in Xu et al. (2020), who outline five qualification criteria for PDBs. This is an inclusive definition that captures a wide diversity of institutions, including multilateral, bilateral, regional, national and sub-national development banks. Multilateral, bilateral and regional PDBs are sometimes called ‘International Financial Institutions’ (IFIs). Another term is ‘Development Finance Institutions’ (DFIs), which is often used to refer to a subset of PDBs that focus on private sector lending. Importantly, the study acknowledges, and characterizes, the great diversity inside the common definition of PDBs. See below. 10 Basu et al. 2020 11 Agence Française de Développement (AFD) 12 AFD 2020 7
MAINSTREAMING BIODIVERSITY IN PUBLIC DEVELOPMENT BANKS © Juan Carlos Munoz / WWF-International WWF 2021
Although PDBs all share some key features, they are a very diverse group in terms of size, shareholding, geographical scope and financing focus. Below are main study results in this regard, which are important elements to account for when advocating for further mainstreaming biodiversity within PDBs. PUBLIC DEVELOPMENT BANKS: COMMON DEFINITION, DIVERSE INSTITUTIONS • Public Development Banks (PDBs) are finan- • For this study, PDBs were categorised (based on cial institutions with a mandate to finance a ownership, geographic scope and beneficiaries) public policy on behalf of the State. They have as multilateral, bilateral, regional, national or independent financial and legal status but sub-national banks. The vast majority of PDBs operate under the authority and supervision are national development banks (Figure C). of government. • PDBs are fairly evenly spread across continents, • PDBs are a very diverse set of institutions. In with a particularly large number in the Asia-Pacific. total, 552 institutions were identified as PDBs, The Americas have a notably high number and pro- based on membership of industry forums and/ portion of sub-national banks, which are unusual or representation in AFD’s recently developed in Africa, while bilateral PDBs are concentrated PDBs database13. in Europe. 400 300 Number of Institutions 200 100 0 l l al al l na a na er r n te io io io at la at eg at til Bi N bn ul R M Su Institution type Figure C. Number of PDBs of different categories in the global dataset (N = 552 institutions; 11 multilateral, 30 bilateral, 38 regional, 397 national and 76 sub-national) 13 For further details on this, refer to the main study report 9
• PDBs range in size over six orders of magnitude. • There is a broad range of size in each PDB category, The smallest have assets of US $2-3 million and the but average (mean) assets for both multilateral largest, the China Development Bank, has assets of and bilateral banks (US$ 149 and US$ 139 billion US $2.4 trillion. Small and mid-size banks (assets respectively) are around ten times larger than for between US $100 million and US $10 billion) make regional (US $12 billion), national (US $ 15 billion) up the majority (c. 61%) of or subnational (US $ 12 billion) banks. The largest seven PDBs, PDBs (Figure D). While most multilateral development • Globally, most PDB assets are held by a few very including three Chinese banks, banks (MDBs) are large (assets over US $ 10 billion) or very large banks (Figure E). The largest seven PDBs, including three Chinese banks, together hold together hold over half of large (assets over US $ 100 bil- over half of global PDB assets, compared to only 0.05% held by the smallest 100 banks. Small global PDB assets. lion), regional banks tend to be smaller. PDBs (assets < US $1 billion) and very small PDBs (< US $100 million) are concentrated in low and lower-middle income countries. 150 Number of Institutions 100 50 0 bn bn bn bn bn l e e e l al al rg rg iz Sm sm 1 0 0 0 -1 -s la La 0, 10 10 -1 ,1 id $ 0- $0 y M r r $1 Ve Ve Institution size Figure D. The number of PDBs of different size classes , based on total assets (N = 454; 98 institutions in the dataset do not have a size class assessed). Source: AFD PDBs Database 2020 PDBS are perfectly placed Given their public mandates, authority and supervision, governments, clients and private capital, to further mainstream biodiversity in all relevant public and to contribute actively to the combined with their signif- icant scale of assets and fi- private decision-making. post-2020 global biodiversity nancing, public development The current draft of the post-2020 global biodiversity framework includes the goal that “nature is valued framework. banks are perfectly placed to contribute actively to the through green investments, ecosystem service val- post-2020 global biodiversity uation in national accounts, and public and private framework agreed at CBD COP15. PDBs can play sector financial disclosures”14. PDBs have a critical a catalytic role both in setting ambitious targets role to play in achieving this. toward a nature-positive global goal, and support- To better understand this potential contribution, ing the implementation of agreed actions. Beyond the study first took stock of current PDB practices. simply mobilizing resources by unlocking public Progress, constraints and challenges are outlined finance and leveraging private finance, PDBs can below, based on interview discussions, survey re- strongly influence all sectors of society, including sponses and document review. Updated Zero Draft, dated 17 August 2020, Goal B, Sub-Goal B.2. See https://www.cbd.int/article/zero-draft- 14 update-august-2020 WWF 2021
12,000,000 10,000,000 Cumulative assets USD millions 8,000,000 6,000,000 4,000,000 2,000,000 0 0 100 200 300 400 500 Cumulative number of PDBs Figure E. Cumulative institutional assets across PDBs (N = 454), sorted by asset size. A small number of institutions hold the bulk of total assets. Data source: AFD PDBs Database 2020 STRATEGIC-LEVEL INTEGRATION OF BIODIVERSITY For PDBs, ‘mainstreaming’ biodiversity15 into all limit for climate16. On the other hand, climate public and private decisions requires first, and fore- commitments represent an opportunity to scale most, a pro-active, anticipatory approach at strategic up nature-positive investment via nature-based and political levels. solutions17 and experience already gained. MAINSTREAMING ENVIRONMENTAL • A few prominent PDBs, multi-and bilateral, are leading the way to improve biodiversity main- CONSIDERATIONS: BIODIVERSITY streaming. However, at present biodiversity is poorly integrated into the strategies of most larger LAGGING BEHIND CLIMATE banks, and is not even on the radar for most smaller ones. • Many PDBs made commitments to align their activities with the goals and principles of the Paris agreement and have now made significant progress SUSTAINABILITY AND PDBS: in integrating climate risks in their investments. This is nevertheless proving a significant organiza- MANDATES AND COMMITMENTS tional challenge. Efforts needed to integrate climate • PDBs’ formal mandates are established in legal considerations may thus be constraining PDBs from founding documents (Articles of Association) starting on a similar process for nature. Another and mostly focus on economic and social constraint is the lack of a single overarching goal goals. Only an exceptional few mention envi- for biodiversity corresponding to the 1.5°C warming ronmental protection as part of their mandate. 15 The CBD defines the mainstreaming of biodiversity as “integrating or including actions related to conservation and sustainable use of biodiversity at every stage of the policy, plan, programme and project cycle, regardless whether international organizations, businesses or governments lead the process”. 16 The recent proposal of a succinct Global Goal for Nature (Locke et al. 2021) could usefully contribute to this discussion 17 IUCN defines nature-based solutions (NbS) as “actions to protect, sustainably manage, and restore natural or modified ecosystems, that address societal challenges effectively and adaptively, simultaneously providing human well-being and biodiversity benefits.” 11
PDBs derive direction from their government own- with environmental funds or standards, and for ers and shareholders and are typically supervised representation of environmental SDGs in PDBs’ by finance ministries. PDBs’ supervisors may not reports19. Stated commitments for general sus- have a clear understanding of nature-related risks, tainability were more common than for climate, which can hinder mainstreaming of nature and and still fewer PDBs had stated commitments environmental sustainability in PDBs’ investment for biodiversity. decisions. However, conversely PDBs are also often able to influence and guide government on Beyond this (still limited) political and strategic sustainability issues. integration of biodiversity by PDBs, biodiversity issues also need to be mainstreamed in PDBs’ finan- • The proportion of reviewed PDBs with stated cial and technical operations. Findings presented sustainability commitments18 decreases from thereafter take stock of biodiversity integration at multilaterals through bilateral and regional to the operational level, through the complementary national PDBs (Figure F). A similar pattern was aspects of ‘greening finance’ and ‘financing green’. evident for specific accreditations or engagements A: Sustainability B: Climate 1.00 1.00 Proportion of Institutions Proportion of Institutions 0.75 0.75 0.50 0.50 0.25 0.25 0.00 0.00 l l al l l al l l na na ra na ra na er er te te io io io io at at la la eg eg at at til til Bi Bi N N R R ul ul Legend M M Institution type Institution type Commitment ? No C: Biodiversity Yes 1.00 Proportion of Institutions 0.75 0.50 0.25 0.00 l al l l na ra na er te io io at la eg at til Bi N R ul M Institution type Figure F. The proportion of reviewed PDBs of different types that had stated commitments on (A) sustainability, (B) climate, and (C) biodiversity. Number of PDBs reviewed: Multilateral N = 11, Bilateral N = 21, Regional N = 9, National N = 57 18 Commitments may be stand-alone statements, included in strategic documents, or expressed through adoption of environmental and social safeguards frameworks. 19 For 236 PDBs in AFD’s global PDB database. WWF 2021
GREENING FINANCE: REDUCING HARM TO BIODIVERSITY © Peter Chadwick / WWF-International 13
To ensure that financing at minimum does no harm to nature, biodiversity must be accounted for when identifying, preparing, appraising, negotiating, approving and finally implementing and evaluating projects and programs. Study findings show that PDBs implement several processes and practices to reduce harm to biodiversity, but major challenges remain. UPSTREAM PLANNING • Upstream planning20 (sometimes incorporated in and many other stakeholders; the responsibility of Strategic Environmental Assessment - SEA) is a individual PDBs and remit for their involvement highly valuable and important tool for enabling may not be clear; it requires significant resources impact avoidance, and (which are not guaranteed to return from future Upstream planning is a highly reducing project risks and mitigation costs. investment) and can be a lengthy and contentious process. Nevertheless, some banks are leading the valuable and important • However, it is still little de- way through pro-active engagement in upstream tool for enabling impact planning, such as the International Finance Cor- ployed by PDBs and there poration’s (IFC) work at country and sector level avoidance. are many barriers that pre- to de‑risk potential investments. vent it happening. It involves working with government SAFEGUARDS FOR BIODIVERSITY • Environmental safeguards21 are the main mech- Resources (dating from 2012, with guidance anism used by PDBs for managing biodiversity updated in 2019) is widely influential among both risk. Each MDB has its own environmental and public and private banks, and adopted by the social safeguard framework, including standards 115 Equator Principles Financial Institutions22. for biodiversity, while most bilateral development banks have adopted IFC’s Performance Standards. • There is extensive conceptual and practical con- Some banks only reference Environmental Im- vergence between the major MDBs’ respective pact Assessments (EIAs), thus relying on (often biodiversity standards, expected to be enhanced weak) national regulatory processes. further by current revisions. Key features of most include: • However, around half of regional development banks and a large majority of national development – A risk-based approach banks have no formal biodiversity safeguards – Application of the Mitigation Hierarchy to (Figure G). avoid, minimize, restore and (as a last resort) • IFC’s Performance Standard 6 on Biodiversity offset impacts and Sustainable Management of Living Natural 20 In the context of this study, upstream planning refers to systematic, pro-active sectoral planning that can guide future project development, taking into account technical and economic feasibility and environmental and social constraints across a large spatial scale. 21 Policies, standards and operational procedures designed to identify and mitigate adverse environmental impacts that may arise in the implementation of development projects (see e.g. http://assets.worldwildlife.org/ publications/844/files/original/SafeguardsonepagerFINAL.pdf ) 22 The Equator Principles (EPs) is a risk management framework, adopted by financial institutions, for determining, assessing and managing environmental and social risk in projects and is primarily intended to provide a minimum standard for due diligence and monitoring to support responsible risk decision-making. See https://equator- principles.com/wp-content/uploads/2021/02/The-Equator-Principles-July-2020.pdf WWF 2021
1.00 0.75 Proportion of Institutions Legend Safeguard Type None 0.50 Referencing EIA IFC PS6 Own framework 0.25 0.00 l al l l na ra na er te io io at la eg at til Bi N R ul M Institution type Figure G. Safeguard status of 98 reviewed banks, as proportion of each bank type (Multilateral N = 11, Bilateral N = 21, Regional N = 9, National N = 57) – Criteria to identify biodiversity features of and checkpoints that force consideration and high concern management of risk. Well-applied safeguards strongly encourage developers to apply the mit- – Requirements for measurable outcomes (e.g. igation hierarchy, especially to avoid potential no net loss or net gain) for priority features project impacts through early planning and alternatives analysis. – Requirements for planning, implementing and monitoring mitigation actions and (if necessary) offsets. RISK SCREENING • The requirements of MDBs’ biodiversity standards • Especially in the absence of upstream planning, go well beyond those of typical EIAs. In many risk-screening is an essential step in the applica- countries, EIAs are likely to fall well short of tion of safeguards, that identifies projects with international good practice for managing biodi- potentially high biodiversity risk. Many PDBs versity risk. screen for biodiversity risks and may decide on this basis not to proceed further with high-risk • Safeguards are essentially a reactive mechanism projects. However, risk screening is not uni- to avoid risks and reduce harm. This contrasts versally or consistently applied and important with the more ‘upstream’ proactive approach impact avoidance opportunities may thus be of integrated strategic planning (see above). missed. The Integrated Biodiversity Assessment Nevertheless, safeguards are considered to have Tool (IBAT) is by far the most widely applied great value, not least in defining a clear process risk screening tool, but many PDBs lack access to it. 15
CHALLENGES IN SAFEGUARD – Difficulty in applying to financial intermedi- aries and corporate funding IMPLEMENTATION – Not applicable to public policy loans • Overall, PDBs’ implementation of biodiversity – Inconsistent interpretation and application safeguards is variable and patchy, although with of requirements performance generally improving among those using formal safeguard frameworks. Larger banks – Poor consultant performance in particular are aware of deficiencies in safeguard application and are taking steps to address them. – Perceived complexity and cost, causing reduced Identified challenges with implementing biodi- competitiveness versity safeguards include: – Data gaps and lack of simple, widely applicable – Limited internal PDB capacity metrics. – Capacity limitations among clients, regulators and stakeholders BIODIVERSITY OFFSETS • Biodiversity offsets are an important element of – Considering avoidance too late in the safeguard frameworks. Offsets represent the final project timeline step in the mitigation hierarchy, a last resort to – Inadequate budget provision for compensate for residual impacts that cannot be mitigation costs avoided, minimized or restored. However, they face many design and implementation challenges. – Inadequate monitoring and supervision Many PDB staff and experts are sceptical about the feasibility of implementing offsets successfully; and – Inadequately addressing indirect and cumu- offsets being implemented under PDBs’ safeguards lative impacts frameworks are mostly too recent for their actual – Difficulty in applying to agricultural projects success to be determined. and to supply chains DISCLOSURE • All MDBs have disclosure requirements for project • Improved disclosure will be important in driving assessments both before and once funding is up standards. The emerging Task Force for approved. Routine disclosure is far less common Nature-related Financial Disclosures (TNFD) among other types of PDBs, practiced by around is a significant development, anticipated to a fifth of the bilateral development banks and support and encourage PDBs to analyse, report around 6% of national banks reviewed. on and address nature-related risk in investment portfolios. Reporting on project • Reporting on project out- comes for biodiversity (i.e. outcomes for biodiversity the implementation and ef- fectiveness of mitigation and remains generally weak. offset measures) remains generally weak. WWF 2021
FINANCING GREEN: SCALING UP NATURE- POSITIVE INVESTMENTS © Mazidi Abd Ghani / WWF-Malaysia 17
There is need to go beyond a safeguard approach to contribute to an overall nature-positive economy. Achieving global biodiversity targets will require major scaling-up in positive investments that conserve and restore nature, and also mitigate climate change. PDBs are centrally positioned to play a role in this and influence the finance sector. The study findings outlined below present the opportunities and challenges. OPPORTUNITIES FOR NATURE-BASED SOLUTIONS • Most multilateral, bilateral and regional de- proportion of such finance. Climate finance itself velopment banks, though only a few national is still a small fraction of overall PDB lending development banks, are making investments that portfolios that is not yet proportionate to the Paris indirectly benefit nature, e.g. via climate funding Agreement. (Figure H). • Although still a small fraction of overall investment • Far fewer PDBs are making direct investments portfolios, there is a rapidly growing demand for in nature. Around two-thirds of MDBs do make impact investing focused on nature-positive out- direct nature-positive investments, using a wide comes. But the ‘supply side’ of investment-ready, range of financial mecha- bankable nature-positive projects is not yet well The nature-based solutions nisms. However, this financ- ing remains very small-scale developed enough to enable societal or bank aspirations to scale up nature-positive financing. (NbS) sub-set of climate relative to other investments. • PDBs have a clear potential role as matchmakers finance presents the largest • The nature-based solutions between nature-positive projects and a range opportunity for nature- (NbS) sub-set of climate of investors, e.g. as enablers of blended finance finance presents the largest mechanisms. positive finance. opportunity for nature-pos- itive finance. • The establishment of Natural Capital Lab units within PDBs as incubators for innovative financ- • Despite evidence and international declarations ing for nature (e.g. IDB followed by ADB, and to increase funding for NbS as an integral part of EIB’s23 Natural Capital Financing Facility24) is climate solutions finance (e.g. in France and the a promising development that could have large UK), NbS projects currently form a very small leverage potential. CHALLENGES TO SCALING-UP FINANCING GREEN • Scaling-up is a major challenge facing biodiver- • There are technical challenges in measuring sity positive investments. They are not direct, and demonstrating biodiversity value, and in traditional business for PDBs and are widely aggregating small investment units and bundling perceived as risky, low return, entailing high benefits, with, as yet, limited data or scalable transaction cost, and with long lead-times for metrics. Intermediaries are needed to help identify financial returns due to socio-ecological dynamics. and cluster projects, streamline assessment and There are presently no markets for many of the reduce transaction costs. biodiversity stocks and ecosystem services flows that make up natural capital. • NbS is the biggest single nature-positive invest- ment opportunity class. However, expertise, skills 23 Respectively the Inter American Development Bank (IDB), the Asian Development Bank (ADB) and the European Investment Bank (EIB) 24 EIB nd WWF 2021
A: Investments directly benefiting Nature B: Investments indirectly benefiting Nature 1.00 1.00 0.75 0.75 Proportion of Institutions Proportion of Institutions Legend 0.50 0.50 Investment ? N Y 0.25 0.25 0.00 0.00 l l al l l al l l na na ra na ra na er er te te io io io io at at la la eg eg at at til til Bi Bi N N R R ul ul M M Institution type Institution type Figure H. The proportion of 98 reviewed banks conducting (A) direct investment in biodiversity25, and (B) investment that might indirectly benefit biodiversity26, split by type of bank. (Multilateral N = 11, Bilateral N = 21, Regional N = 9, National N = 57) and technical capacity to identify and assess NbS and metrics could limit biodiversity mainstream- opportunities are limited, and an appropriately ing at operational level and slow the scaling-up of tailored risk appraisal and rating process is lacking. nature-positive investments. Yet there have been significant recent advances in available datasets • Interviewees were generally circumspect about and methods. With biodiversity conservation now the possibility of rapid scaling up in nature-pos- an increasing priority in the political, diplomatic itive finance, given the substantial constraints and business arena there is scope to accelerate the to overcome. development and use of these new approaches. In both these complementary aspects of ‘greening finance’ and ‘financing green, findings also high- lighted that gaps in biodiversity data, analytical tools 25 Financing where the main or a significant aim is to improve the status of biodiversity (e.g. through ecosystem protection or development of relevant capacity) 26 Financing that is not directly aimed at improving biodiversity status, but likely to be positive for biodiversity (e.g. through measures to mitigate climate change) 19
THE ROAD TOWARDS NATURE-POSITIVE FINANCE FOR PDBS © Jame Morgan / WWF-International WWF 2021
Findings highlight several striking elements. They call for a differentiated engagement strategy, where PDBs should aim at ambitious progress, but considering their starting baseline. TOOLS AND METHODS TO SUPPORT GREENING FINANCE AND FINANCING GREEN An increasingly large range of biodiversity metrics help PDBs to integrate biodiversity considerations and tools is now available to help PDBs improve the in their strategic approaches. At the operational biodiversity performance of their activities. project level, tools and metrics (e.g. IBAT, STAR28) and improved spatial datasets can significantly The study identified six key ongoing trends: improve risk-screening processes and support better application of the mitigation hierarchy, including 1. More varied, more precise and more useable through upstream planning. Metrics and tools fo- data layers; cusing on opportunities (e.g. STAR) and integrating 2. Practical tools for portfolio- and corporate‑scale nature and climate elements (e.g. NatureMap, FAO’s biodiversity assessment; EX-Ante Carbon-balance Tool) can help to focus nature-positive investments and the standardization 3. Practical metrics for assessing biodiversity op- of nature-based solutions, reducing risk and cost portunities as well as impacts; and facilitating their development at scale. Finally at the disclosure and reporting level, harmonized 4. Integrated availability of climate and biodiversity metrics (e.g. the Global Biodiversity Score - GBS, data; and STAR) can help PDB teams and boards, experts 5. Standardised tools and processes for demonstrat- but also importantly civil society, to monitor PDBs’ ing alignment with societal goals for biodiversity; progress against their stated commitments and strategies. 6. Standardised tools for reporting and disclosure of biodiversity performance. Overall, the rapid develop- ment of data, metrics, meth- The rapid development Taken together, these trends should allow PDBs to better mainstream biodiversity at different levels. ods and tools in the field of biodiversity provides PDBs of data, metrics, methods At the strategic level, science-based methodologies with the technical means for and tools in the field of biodiversity provides PDBs (e.g. the Science-based Targets Network27) can pro- deep mainstreaming; but vide PDBs and their public supervisory authorities this will come with greater with possible means to align their portfolios with targets agreed upon in the CBD post-2020 global responsibility and scrutiny, including by civil society with the technical means for biodiversity framework. Better tools to assess risks and dependencies (e.g. ENCORE, Trase Project) can organizations. deep mainstreaming. 27 See https://sciencebasedtargetsnetwork.org/ 28 Species Threat Abatement and Recovery (STAR) Metric (Mair et al. 2021) 21
BIODIVERSITY MAINSTREAMING MID-SIZE PDBS: EMERGING PDBs are a big and diverse group, and different PDBs are at very different stages in mainstreaming biodiversity. Considering PDBs by overall size of assets is therefore useful here. COMMITMENTS BUT LIMITED CAPACITY LARGE PDBS: CHAMPIONS BUT CAN DO Mid-size PDBs (predominantly the members of STILL BETTER EDFI or IDFC29) present a varied picture. Their attention to biodiversity relates in part to how far Several of the large MDBs are leading the way in they are commercially versus policy focused. A few, ‘greening finance’, although the focus mainly remains following strong government direction, are at the on safeguards for now rather than a deeper integra- global cutting edge of thinking and action. However, tion of nature into strategy and process. Some are most are much more reactive regarding nature. While actively innovating on nature-positive investments signed up to strong safeguards (and sometimes and promoting policy reform, though at relatively other strong commitments) on paper, there are small scale. In contrast to climate financing, hardly evidently large gaps in capacity and implementation. any of these PDBs as yet have clear stated investment Few have biodiversity specialists on staff, relying targets for biodiversity. on a generalist E&S function and external advice. They do not appear to have clear internal targets Capacity is growing, These leading banks have a cadre of committed and expe- on climate or biodiversity investment, with very few exceptions. standards and guidance are rienced staff and are working actively to address gaps and being refined, and there is a challenges in safeguard imple- SMALL PDBS: ENVIRONMENT BARELY generally improving picture. ON THE RADAR mentation. Capacity is grow- ing, standards and guidance are being refined, and there is Among smaller banks, there are a few outstanding a generally improving picture. However, the problems examples of commitment and positive activity, are hard to crack and environment-focused staff are though focused more on climate than on biodi- also busy with project work and may have limited versity. For most others the environment is barely power to convene processes and influence decisions on their radar. Some are engaging with climate in their organisations. issues, but the vast majority have very limited or Even among the leaders, there remain some signif- no commitments, processes or staffing in place to icant gaps between stated ambition and implemen- address biodiversity concerns, beyond the standard tation reality, and some large PDBs are lagging well regulatory mechanisms for project approval that are behind. China has several of the world’s largest PDBs, weak in many countries. but these lack stated biodiversity commitments or well-developed safeguards, relying on the EIA process to manage risk. BIODIVERSITY SAFEGUARDS: PRACTICAL CHALLENGES AND PATCHY REPORTING ON IMPLEMENTATION Safeguards remain a very valuable if imperfect tool despite net gain requirements in some instances. for reducing harm. However, they still have very Effective application of safeguards requires a robust limited effect in promoting nature-positive financing, framework, significant resourcing for ensuring and 29 Respectively the the Association of European Development Finance Institutions (EDFI) and the International Development Finance Club (IDFC) WWF 2021
verifying implementation, internal systems and a PDBs face practical challenges applying safeguards culture to make sure that biodiversity concerns are in contexts of financial intermediaries and public considered in project appraisal and approval, a robust policy loans, and where the regulatory framework is disclosure and reporting framework that encourages weak and governments (as clients) have not bought both clients and banks to meet the standards, and into safeguard provisions. In addition, budgetary a powerful ombudsman or similar oversight mech- constraints and commercial competition still tend anism. Only a few PDBs have such a well-specified to create an uneven playing field – favouring finance approach in place. that has less rigorous environmental requirements. Most PDBs (and particularly the smaller national and PDBs’ reporting on how safeguards are implement- sub-national banks) do not have formal safeguard ed, and the outcomes, remains very patchy and frameworks at all for biodiversity, and may not see incomplete. biodiversity as a major issue, even though their financing may be causing damage to nature. FINANCING GREEN: TOWARDS A NATURE-POSITIVE ECONOMY THE WAY AHEAD: BIODIVERSITY nature‑positive investments could either be linked to sustainability criteria in recovery lending, or be PIGGYBACKING ON CLIMATE embedded in potential debt relief and restructuring mechanisms (e.g. debt swaps). For PDBs, and the finance sector as a whole, climate is far ahead of biodiversity as a concern for both INVESTING IN NATURE: UNLOCKING greening finance and financing green. So-called ‘green’ investment is nearly entirely climate-focused, PRIVATE FINANCE VITAL BUT NOT STRAIGHTFORWARD mainly on technology. Hence, climate progress forms a platform for biodiversity progress, both in process and substance. While investment remains at very Direct nature-positive investment by PDBs (and small scale, and there are mixed opinions about the the finance sector generally) is still very small-scale potential to scale up, nature-based solutions are a real and patchy. It appears that much of current PDB potential bridge between climate and biodiversity, nature-positive financing is which need to be promoted. not really commercial but in the nature of grants and facili- Post covid-19 economic POST COVID-19 RECOVERY tation of external funding (e.g. stimulation packages should NATURE-POSITIVE FINANCE: from the Global Environment Facility - GEF). be re-directed at nature- THE WEAK LINK Private finance must be un- based opportunities. locked to scale up nature-pos- Financing for COVID-19 recovery, including in itive investment significantly. massive infrastructure investments, has so far paid A large suite of finance tools is available for this, but little attention to nature30. This both misses an there are many practical challenges. Study respondents opportunity and potentially does significant harm. had mixed opinions about the feasibility of scaling up Economic stimulation packages should be re-directed investment, and the role of ‘blended finance’ approach- at nature-based opportunities – such as sustainable es. Nevertheless, for PDBs that can access or provide agriculture and fisheries, ecosystem-based coast- concessionary funding, blended finance does hold al protection and watershed management. Here, potential as a catalyst for private investment – which PDBs could play a central role. To this end, such is the key for going to scale. 30 Vivid Economics & F4B (2021) 23
A TIERED APPROACH TIER A: BIODIVERSITY Overall, PDBs can be classed in three tiers in relation to their level of biodiversity mainstreaming, how they manage biodiversity risk and how far they invest in nature. MAINSTREAMING BEGUN, BUT FURTHER WORK NEEDED TIER C: NO CONSIDERATION OF NATURE Most MDBs, some other larger PDBs (especially those Most small PDBs, including most national and with a public-sector focus) and a very few small PDBs sub-national banks, as well as some larger PDBs, at regional to sub-national scale have clear stated currently do not recognise either biodiversity risks or commitments to biodiversity. They consistently opportunities. They do not have stated environmental apply biodiversity safeguards, supported by relatively commitments, rely on regulatory EIA processes robust (if not always fully adequate) structures and rather than safeguard frameworks to manage risk, capacity. They have climate investment targets, and and have no investments in nature. a few are developing targets for investment in nature as a component of these. Their investments in nature TIER B: SOME CONSIDERATION OF are still at a low level, but increasing and driven by institutional policy. BIODIVERSITY RISK, LITTLE NATURE PDBs in all tiers can take steps towards greening INVESTMENT OR MAINSTREAMING finance and scaling-up financing green, but for each tier different steps are appropriate and feasible. Many mid-sized PDBs, including most regional and bilateral banks, do recognise the need to manage biodiversity risk. They typically have at least general environmental commitments and apply biodiversity safeguards (IFC’s PS6, or in their own frameworks) though with limited supporting structures or capacity. They usually have few if any direct investments in nature, and these are not driven by institutional policy. 31 Document CBD/SBI/3/5/Add.3 WWF 2021
RECOMMENDATIONS © James Morgan / WWF-International 25
RECOMMENDED ACTIONS FOR PDBS Measures needed Constraints identified Policy Organisational Technical Mainstreaming Methods to assess Develop and implement Integrate biodiversity Develop investment biodiversity risk not and report on risks and nature-positive across PDB processes assessment approaches a priority for PDB impacts are not well institutional commitments, and performance that integrate climate and supervisory authorities developed, spatial data and update mandates indicators nature Fully integrate on investments often biodiversity risk into lacking investment decisions PDBs are currently Assess biodiversity- Establish joint PDB co- Assess biodiversity risk preoccupied with related financial risks and ordination mechanism and footprint across mainstreaming climate integrate into decision- to catalyse work on portfolios issues making technical challenges Upstream planning perceived as difficult, unclear who should lead Improve spatial Support effective country investment data and Improve upstream platforms for sustainable SOLUTION: Reduce biodiversity metrics for planning and early risk finance the harmful impacts finance screening to enable of investments impact avoidance Patchy application of risk screening tools and datasets Continuously improve risk Most PDBs do not apply Identify opportunities and Secure collective access screening by identifying biodiversity safeguards, pro-actively take lead on to risk-screening tools and deploying new rely on often inadequate upstream planning across all PDBs datasets and tools EIAs Gaps in safeguard implementation for agriculture/commodities, Apply effective intermediaries, Support policy reform Strengthen internal and Limited implementation Require data sharing from PROBLEM: safeguards to reduce supervision, indirect by governments to external capacity for capacity among PDBs, clients’ environmental Investment in and compensate for and cumulative impacts, strengthen regulatory biodiversity safeguard clients and consultants assessments activities that harm harm to biodiversity reporting frameworks implementation nature (by PDBs and others) far outweighs Biodiversity safeguards investment in Biodiversity offsets hard Develop standards and seen as too stringent Support development Strengthen biodiversity activities that benefit to implement, often implementation toolkits for and impacting cost of target-based elements in financing nature not linked to broader biodiversity safeguards competitiveness where compensation schemes agreements regulation is weak conservation plans useable by all PDBs Scale up investment in NBS often overlooked in Incorporate explicit Specify investability Develop shared green nature-based solutions favour of technological nature-positive goals into criteria for nature-positive taxonomy for nature- to meet climate and approaches climate and Covid-19 projects positive financing other development goals recovery finance SOUTION: Increase Individual projects financial flows into Narrow range of viable typically small-scale, investments positive business models, inefficient to structure Support a collective Set clear targets Identify landscapes with for nature perception of high risks, for investment and not platform for natural for nature-positive potential for clustering low returns, long lead coherent at landscape capital ‘accelerators’ and investment nature-positive projects Scale up direct times level investment funds investment in nature conservation and restoration Enabling environment Metrics and methods Encourage cadre of Test, innovate and requires socio-political Engage with governments to assess biodiversity skilled intermediaries promote financial and policy interventions to create an enabling outcomes not well bridging conservation and instruments for scaling-up that are outside scope policy environment developed finance sectors investment in nature of PDBs Figure I. Summary of problem statement, actions needed, constraints identified and recommendations to address these
PDBs are an integral part of the larger, complex community of finance institutions. While many recent reports on biodiversity and finance have already put forward a range of recommendations, this study focuses on actions particularly relevant to PDBs – with the emphasis on practical actions that can be started immediately. A PROPOSED THEORY OF CHANGE Figure I (page 26) summarizes the overall problem, 4. Scale up investment in nature-based solutions to necessary actions, constraining factors and recommen- meet climate and other development goals dations identified in this study. Within the framework of the complementary approaches of greening finance 5. Scale up direct investment in nature conservation and financing green, and building on the third report and restoration. of the CBD panel of Experts on resource mobilization31, Outlined below are the measures needed, the con- five key PDBs’ actions are identified: straints to implementing these key actions, and finally 1. Fully integrate biodiversity risk into investment the ways that these constraints could be addressed. decisions Recommendations are at policy, organisational and technical levels and aimed at PDBs, some are 2. Improve upstream planning and early risk screen- also relevant for governments, Non-Governmental ing to enable avoidance of impacts Organisations (NGOs) and researchers. Prioritized recommendations are then presented for the different 3. Apply effective safeguards to reduce and compen- tiers of PDBs. sate for harm to biodiversity GREENING FINANCE ACTION 1: FULLY INTEGRATE BIODIVERSITY RISK INTO INVESTMENT DECISIONS CONSTRAINTS IDENTIFIED sustainability, with a public commitment to overall pos- Civil society organizations • Mainstreaming biodiversity risk is often not a itive outcomes for nature as part of a holistic set of could play an important role priority for PDBs’ supervisory authorities. Often these are state treasuries or finance ministries social and environmental in advocating to shareholders and supervisory authorities. imperatives. Preferably, with a strongly economic focus. this would be established in • PDBs are currently preoccupied with mainstream- an updated legal mandate. ing climate issues, which constrains their capacity Here, well-capacitated civil society organizations to integrate nature as well. could play an important role in advocating to shareholders and supervisory authorities (gov- • Methods to assess and report on risks and impacts ernments, parliaments, ministries), and ensuring exist but are not well developed. Spatial data on that biodiversity commitments, plus disclosure of investments is often lacking which is a challenge progress towards these, are requested from PDBs for assessing risks and impacts. (e.g. as part of their mandate). POLICY RECOMMENDATIONS • Assess the economic benefit of managing biodiver- sity risk. PDBs could recognize the need to assess and act on financial risks related to biodiversity, • Develop and implement specific nature-positive and start the processes to begin such assessments. institutional commitments. PDBs can engage with This would make the business case for better supervisors and shareholders to re-align the in- mainstreaming of biodiversity within PDBs. stitutional remit and investment strategy towards 27
• Support effective country platforms for sustainable finance. Country platforms that bring together a TECHNICAL RECOMMENDATIONS range of finance institutions can help to create • Establish a joint PDB co-ordination mechanism to common standards (and thus a level playing field) catalyse work on technical challenges. PDBs could for sustainability in financing. PDBs are well placed set up and resource a co-ordination mechanism for to lead or support such initiatives. collective technical work to allow sharing experi- ence and learning, and co-ordinated follow-through ORGANISATIONAL RECOMMENDATIONS with governments, partners and stakeholders. Although some PDBs’ working groups already • Integrate biodiversity across PDB processes, per- exist on biodiversity issues, they mainly concern formance indicators, reporting and disclosure, sub-sets of PDBs (federations, clubs) and remain including for sectors that are particularly high rather internal. There is need for a larger platform risk (e.g. agriculture). To mainstream nature in catalysing technical work with partners. decision-making there is need to review internal processes to ensure that nature considerations • Develop investment assessment approaches that are integrated with all stages and elements of integrate climate and nature. To fulfil the poten- investment decision-making and monitoring. tial of nature-based solutions, tools are needed By supporting The Task Force for Nature-related to consider climate and nature together, not in Financial Disclosures (TNFD), PDBs can also separate silos, when assessing investments. help develop an effective common framework • Improve spatial investment data and biodiversity for nature-related risk analysis, reporting and metrics for finance. PDBs could proactively engage disclosure in the financial sector. with and further support initiatives and processes to • Assess biodiversity risk and footprint across improve spatial data and metrics for finance that can portfolios. Using existing tools, PDBs could support scaleable assessment, mitigation, monitoring develop at least an initial understanding of the and reporting of biodiversity risk in future. potential biodiversity risks present in their current investment portfolios. GREENING FINANCE ACTION 2: IMPROVE UPSTREAM PLANNING AND EARLY RISK SCREENING TO ENABLE IMPACT AVOIDANCE CONSTRAINTS IDENTIFIED up collaborative efforts for upstream planning in landscapes and sectors of strategic interest, an effective way to ‘de-risk’ future projects with as- • Upstream planning perceived as difficult, and sociated time and cost savings. Strategic planning unclear who should lead. For PDBs, upstream is also an opportunity to design a compensation planning is generally seen as ‘someone else’s job’, framework (for residual impacts to biodiversity, with concern about the cost, time required and after rigorous mitigation) that is as effective as the potentially burdensome need to work closely possible for conservation. with governments and many other stakeholders. • Play a stronger role in supporting policy in partner • Patchy application of risk screening tools and countries (through policy loans or grants to sup- datasets. Many PDBs do not apply screening, or do port mainstreaming) and build best practice and not fully use the range of relevant and up-to-date standards into national regulation, including in tools available. helping to establish policies for no net loss (NNL) and net gain (NG) at a national scale. In turn, this POLICY RECOMMENDATIONS also entails necessary support for capacity building for governments to implement these policies and • Identify opportunities and pro-actively take ensure compliance. lead on upstream planning. PDBs could ramp WWF 2021
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