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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
PUBLIC DEVELOPMENT
BANKS AND
BIODIVERSITY
How PDBs can align with the Post-2020 Global Biodiversity Framework
Abridged Version - May 2021

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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
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
PUBLIC DEVELOPMENT BANKS AND BIODIVERSITY - How PDBs can align with the Post-2020 Global Biodiversity Framework Abridged Version - May 2021 - WWF
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
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Cover photography: © Copyright Adam Oswell / WWF-US

                                                                                                                          3
PUBLIC DEVELOPMENT BANKS AND BIODIVERSITY - How PDBs can align with the Post-2020 Global Biodiversity Framework Abridged Version - May 2021 - WWF
CONTEXT

    © James Morgan / WWF-International

WWF 2021
PUBLIC DEVELOPMENT BANKS AND BIODIVERSITY - How PDBs can align with the Post-2020 Global Biodiversity Framework Abridged Version - May 2021 - WWF
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
PUBLIC DEVELOPMENT BANKS AND BIODIVERSITY - How PDBs can align with the Post-2020 Global Biodiversity Framework Abridged Version - May 2021 - WWF
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
PUBLIC DEVELOPMENT BANKS AND BIODIVERSITY - How PDBs can align with the Post-2020 Global Biodiversity Framework Abridged Version - May 2021 - WWF
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
PUBLIC DEVELOPMENT BANKS AND BIODIVERSITY - How PDBs can align with the Post-2020 Global Biodiversity Framework Abridged Version - May 2021 - WWF
MAINSTREAMING
    BIODIVERSITY IN PUBLIC
    DEVELOPMENT BANKS

    © Juan Carlos Munoz / WWF-International

WWF 2021
PUBLIC DEVELOPMENT BANKS AND BIODIVERSITY - How PDBs can align with the Post-2020 Global Biodiversity Framework Abridged Version - May 2021 - WWF
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

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                                      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
PUBLIC DEVELOPMENT BANKS AND BIODIVERSITY - How PDBs can align with the Post-2020 Global Biodiversity Framework Abridged Version - May 2021 - WWF
• 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
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                                                                                                                         1
                                                                  0

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                                                                                                          -1
                                                                                    -s
                                                        la

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                                                                                                                         0,
                                                              10

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                                                                                  id

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                                                         r

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                                                                       $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

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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
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                                                                                                                              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
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                                                                    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
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                                                        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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