Disclosure LibraryPractitioner guidance for every reporting disclosure
Home Disclosure Library GRI GRI 304 GRI 304-1
GRI 304: Biodiversity · 2016
Disclosure GRI 304-1

Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.

Dr Ross Kurinko, GRI Certified Trainer
Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to identify which of its operational sites are located in, next to, or otherwise associated with protected areas or other places recognised for high biodiversity value. The focus is on the organisation’s footprint across its operations, not just a few well-known or flagship sites, so the report should reflect the full set of relevant locations it controls or uses.

In practice, the organisation should explain where these sites are, how many there are, and how they relate to the protected or high-value area concerned. The key point is to show the extent of operational exposure to sensitive biodiversity locations, so readers can understand whether the issue is limited to a small number of sites or spread across a wider part of the business.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner
Protected site footprint List each operational site the business owns, leases, manages, or operates next to where it sits within or beside a protected area or an area recognised for high biodiversity value outside protected areas. Site register, property records, lease schedules, GIS maps, environmental due diligence files, and biodiversity screening notes. Property / Environment
Site location Capture the exact geographic location for each relevant site, using the same location reference used in internal property or asset records. GIS coordinates, address records, site plans, land registry extracts, and asset master data. Property / GIS
Underground land rights Record any subsurface or underground land interests that the business owns, leases, or manages for each relevant site. Title deeds, lease agreements, easement documents, mining or tunnelling rights records, and legal property schedules. Legal / Property
Area relationship State how each site sits in relation to the protected area or the high-biodiversity area outside protection, such as inside it, next to it, or otherwise linked by location. GIS overlays, site boundary maps, protected-area boundary files, and environmental assessment maps. Environment / GIS
Operation type Describe the kind of activity carried out at the site, using the business’s own operational categories. Operational register, site descriptions, business unit records, and process flow documentation. Operations
Site area size Capture the physical size of the operational site in the unit used by the reporting process, and keep the measure tied to the same site boundary used elsewhere. Survey plans, lease area schedules, cadastral records, GIS measurements, and site master data. Property / Survey
Biodiversity attribute Record the biodiversity feature that explains why the protected area or high-biodiversity area is significant, using the attribute described in the source evidence. Conservation designation documents, ecological surveys, habitat assessments, and protected-area descriptions. Environment / Ecology
Protection status Capture the formal protection status attached to the area, using the status listed in the source evidence rather than a local shorthand. Legal designation notices, protected-area registers, conservation listings, and regulatory maps. Environment / Legal
+ Show GRI 304-1 sub-elements (LRA working checklist)

How to prepare it

1Start by setting the boundary for the report: list every site you control, lease, manage, or operate next to a protected place or a location with high biodiversity value outside protected areas.
2For each site in scope, decide what details you will treat as reportable: the site’s location, any subsurface or underground land you own, lease, or manage, the site’s position relative to the protected or high-biodiversity area, the kind of operation, the site’s size, the biodiversity attribute that explains its value, and the protected-status listing.
3Gather source records for each site so the information can be checked: maps, land or lease records, site registers, internal asset lists, and any documents that support the biodiversity classification and protected-status description.
4Compile the disclosure in a structured way, using one entry per site and including either the required figures or the narrative fields needed for each item in the scope.
5Record any site you leave out, any change in how you define the boundary, and any assumption used to classify a location or describe its biodiversity context, so the final disclosure is traceable.
6Before sign-off, compare the draft against the official source to confirm you have covered every required site detail and have not missed or altered any of the listed items.
Request the data

Request the site and biodiversity location data from Operations

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Which sites in our portfolio sit within, next to, or otherwise overlap with protected nature areas or other places we treat as especially sensitive for biodiversity, and what are their key site details?

Use your organisation’s own site, land and environmental terms first, then map them to the reporting categories. Ask for the records the operational owner already keeps for site registers, land files, GIS layers, permits or environmental reviews, rather than using framework wording in the first ask.

Weak request

Please provide the protected-area disclosure data for GRI 304-1, including all sites adjacent to protected areas and all biodiversity-value locations, with the required attributes.

Why it fails: This uses framework language that many operational teams do not use day to day, so it is easy to misread or answer inconsistently. It also does not point the owner to the records they already hold, the internal site terms they use, or the exact site-level details needed to build the extract.

Better request

Please send the site register extract for [reporting period] for [business unit / portfolio], covering any sites in or near environmentally sensitive areas. Use your normal site, land and map terms first, then we will map them for reporting. For each site, include the internal site ID, location, ownership or control basis, size, activity type, relationship to the sensitive area, any subsurface land, the sensitive-area description used in your records, and the source file or system.

Formal email template
Subject: Request for site and biodiversity location data for [reporting period]

Hi [name/team],

We are preparing the sustainability reporting pack and need a site-level extract for [business unit / portfolio]. Please share the records you hold for any sites that sit within, next to, or otherwise overlap with areas we treat as environmentally sensitive.

For each site, please include the fields listed below and attach the supporting source record where available. If your team uses different site or land terms, please use those first and we will map them during reporting.

Please include:
- internal site name / asset ID
- address or map reference
- ownership or control basis
- site size and the basis used
- site activity type
- relationship to the sensitive area
- description of the sensitive area and any protected-status label used in your records
- any subsurface or underground land included in the site boundary
- source system / file name / document reference
- date of the record

If there are no sites in scope, please confirm that as well and note the source checked.

Please send this by [date]. We will review the extract against the reporting source before sign-off.

Thanks,
[preparer name]
Short Teams / Slack version
Hi [name/team] — could you send the site list for [reporting period] for [business unit / portfolio]? We need any sites in or near environmentally sensitive areas, using your normal site/land terms. Please include site ID, location, ownership/control basis, size, activity type, relationship to the sensitive area, any subsurface land, source file/system, and the date of the record. If none, please confirm that too. Thanks — [name]
Industry examples
Manufacturing

Context. A multi-site producer with factories, warehouses and a small number of land parcels near conservation land

Adapted request. Please provide the site register extract for [reporting period] covering factories, depots and any land parcels that sit within, next to, or overlap with environmentally sensitive areas. Use the site names and land references your team already uses, and include coordinates, site size, control basis, activity type, the relationship to the sensitive area, any underground land, and the source plan or GIS layer.

Example response. Three sites returned: one factory inside a conservation buffer, one depot next to a wetland corridor, and one leased yard with no overlap. The extract included site IDs, coordinates, hectares, activity type, relationship label, underground land note, and GIS source references.

Utilities / Infrastructure

Context. An operator with substations, pipelines and easements crossing rural land

Adapted request. Please send the asset and land extract for [reporting period] for substations, pipeline corridors and easements in the [region] portfolio. We need any assets that are within, beside, or otherwise overlap with sensitive nature areas, using your normal asset and land-control terms. Include asset ID, route or site location, control basis, footprint size, asset type, relationship to the sensitive area, any subsurface or underground land, and the source register or survey.

Example response. Two pipeline segments and one substation were identified as overlapping sensitive land. The return listed asset IDs, route references, coordinates, footprint size, control basis, asset type, overlap description, underground land notes, and survey file references.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

Explain which sites were included, how the organisation defined a relevant site, and what basis was used to decide whether a place counted as protected or biodiversity-sensitive.

Context note

Set out what the figures show about the organisation’s footprint in or near sensitive natural areas, including where those sites are, what kind of operations they host, and how large they are.

Fluctuation statement

If the number or mix of sites changed, note whether this was driven by site openings, closures, changes in control, updated mapping, or a revised view of which locations meet the inclusion criteria.

Content index entry
GRI 304-1 Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for GRI 304-1 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

Free · Community members
Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We built the coverage figure from a site-by-site review of our own records, then checked which locations sat within or near sensitive nature areas before including them.The assurer will test whether the population of sites was complete and whether any relevant locations were left out or double-counted.Site register, property and lease records, map-based screening output, inclusion/exclusion log, and the working paper showing how the final count was compiled.
For each included location, we kept the place details needed to identify it clearly, including the geographic reference used in the working papers.The assurer may probe whether the location data are precise enough to support the claim and whether the same site is described consistently across documents.Address list, coordinates or map references, site master data, and reconciliation between the report table and underlying location records.
Where a site involved land below ground or under the surface, we checked the relevant tenure and management records before deciding whether to include it.The assurer will look for unsupported assumptions about underground rights or control and whether such areas were treated consistently.Title deeds, lease schedules, concession or management agreements, legal review notes, and any site-specific decision memo.
We recorded each site’s relationship to the nearby nature area using the mapped boundary and the shortest relevant distance or adjacency check we applied.The assurer may challenge whether the boundary test was applied consistently and whether the site’s position was classified correctly.GIS maps, boundary files, distance calculations, screenshots, and reviewer sign-off on the classification method.
We described the activity at each site using our internal operating categories, then checked that the wording matched the business function actually carried out there.The assurer will test whether the operational type was described accurately and whether similar sites were grouped on a consistent basis.Operational descriptions, business unit records, process flow notes, and a cross-check between the report wording and site-level operating data.
We measured the site area from the latest available property or survey information and kept the calculation file used to produce the figure.The assurer may question whether the size data are current, whether units were handled correctly, and whether the calculation is reproducible.Survey plans, cadastral records, lease plans, measurement worksheets, unit conversion checks, and approval of the final area figure.

Evidence pack to prepare

Common reporting gaps

Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps

Mistakes to avoid when collecting the data

Asking the wrong site owner
The data request goes to a central team that does not hold the site register, so the local property, estates, or operations team never confirms which locations are in scope.
Using framework language instead of site terms
The request is written in disclosure jargon, so the business cannot map it cleanly to its own depot, plant, office, or landholding records.
Leaving the boundary undefined
The team starts collecting locations before agreeing which owned, rented, run, or nearby sites count, so the list is incomplete or inconsistent.
Using the wrong reporting date basis
People pull a current map or a year-end snapshot without fixing the period cut-off, so the site list does not match the reporting period.
Mixing different counting bases
Some sites are counted by legal title, others by operational control or proximity, which makes the final population impossible to reconcile.
Dropping the original source labels
A spreadsheet copy strips out the map reference, land record ID, or conservation designation, so the team cannot trace each entry back to its source.
Combining separate site groups
Owned, rented, managed, and neighbouring locations are merged into one list too early, which hides differences that need to stay separate for review.
Missing evidence details
The file contains the site name but not the map extract, date, version, or other supporting metadata, so reviewers cannot test what was used.
No sign-off trail
The draft list is circulated without a named reviewer or approval record, so nobody can show who checked the data before it moved on.

Where judgement is often needed

Boundary shifts after buying or selling a site
Use the reporting cut-off you apply elsewhere in the report, explain when a newly acquired or disposed site first enters or leaves the list, and keep the same basis for the location, size and status fields.
Different country maps and local designations
Where national or local sources use different labels or boundary files, state which source you relied on for each site and describe any judgement used to decide whether it sits within or next to the relevant area.
Sites that only partly touch the sensitive area
If only part of a site falls within or beside the relevant area, explain whether you included the whole site or only the affected part, and make the basis consistent across all sites.
Underground or below-ground interests
Decide whether subsurface rights, tunnels or other below-ground holdings count as part of the site, then disclose that approach and identify any locations where the surface and below-ground footprints differ.
Choosing the site type label
When a location has more than one operational use or changes use during the year, pick the label that best reflects the main activity for the period and explain any mixed-use or transitional cases.
Estimating size versus using measured area
If exact area data are not available for every location, use a clearly described estimate method, say which sites are measured and which are estimated, and keep rounding consistent.
Listing the biodiversity feature behind the location
For each site, name the protected-status or habitat feature you used to classify it, and if several features apply, explain which one you treated as the main basis and why.
Aggregating sensitive location details
Where naming a site or giving exact coordinates could create confidentiality or security issues, group the information at a higher level, explain the aggregation rule, and make sure the summary still shows the geographic position and relationship to the relevant area.
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Renewable power

*Synthetic illustration only.* We would describe the sites we operate, lease or manage that sit in, or next to, protected land or other places recognised for high ecological value. In this example, our portfolio includes 3 operational sites: one 12 ha wind farm in Scotland, 2 km from a designated nature reserve; one 8 ha battery storage site in Wales, partly within a locally important wildlife corridor; and one 5 ha substation in England, adjacent to a protected wetland. We would also note any below-ground land under our control, such as 1.5 ha of underground cable routes beneath the wind farm and 0.4 ha beneath the substation, and explain the relevant conservation feature for each location, including the protected designation or other biodiversity attribute that makes the area sensitive.

Illustrative only: shows how to identify relevant sites, state where they are, describe the operation and site size, and explain both the conservation feature and any formal protection status without using a tabular format.

Illustrative (synthetic) example — Food processing

*Synthetic illustration only.* Our group would report the facilities we own and manage that are inside, beside, or close to areas valued for biodiversity. In this example, we have 2 operational sites: a 20 ha processing plant in northern Italy, 500 m from a protected riverbank habitat, and a 6 ha packaging depot in southern Spain, partly overlapping a high-value coastal dune area. We would also disclose the underground land we manage, such as 2.0 ha of buried service corridors at the plant and 0.2 ha of drainage works at the depot, together with the ecological feature that defines each area and whether it carries a formal protected listing.

Illustrative only: shows how a reporter can combine site location, operational footprint, below-ground land, proximity or overlap with sensitive habitat, and the reason the area is considered important for biodiversity.

Company reports

How companies report GRI 304-1

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Firstsource Solutions Limited
Professional Services · India · 2025
Open report →
Firstsource Solutions Limited’s ESG Report FY 2024-25 provides coverage on occupational health and safety management, including hazard identification, risk assessment, and safety audits, with specific data on workers covered by such systems found on page 226. The report also addresses human rights policies under its social impact section on page 210. However, several narrative items related to this disclosure, including further details on human rights implementation and numeric values, are not found or unclear in the report.
Companhia Paranaense de Energia - COPEL
Electric Utilities / IPP / Energy Traders · Brazil · 2024
Open report →
Companhia Paranaense de Energia - COPEL’s Integrated Report 2024 includes a covered datapoint on page 288 regarding areas managed in or adjacent to protected areas and areas of high biodiversity value outside protected areas, referencing GRI 304-1 Geographic. However, the report lacks any quotable evidence for several specific narrative items (a-i to a-vii) and numeric values related to this disclosure. Additionally, page 316 notes omissions of certain environmental commitment requirements, indicating gaps in biodiversity-related disclosures.
WuXi AppTec Co., Ltd.
Pharmaceuticals / Biotech / Life Sciences · China · 2024
Open report →
WuXi AppTec Co., Ltd.'s Environmental, Social and Governance Report 2024 shows that 89% of its operational sites have obtained ISO 14001 Environmental Management System certification and have submitted science-based targets (p.48). The report also references materials used by weight or volume and recycled content in a performance table related to GRI 301 standards (p.104). However, there is no evidence found in the report regarding other narrative items such as specific material disclosures, numeric values, or further environmental impact details.
✓ LRA AI Assistant · Human-in-the-loop
Dr Ross Kurinko
Ask Study Studio AI assistant about this disclosure
Get a practical answer for your reporting context. Your first answer is free — create a free account to continue the conversation.
TryHow do I prepare GRI 304-1?What data do I need to collect?Where can I see a real-report example?What mistakes should I avoid?
1 free answer
Check your understanding

Scenarios to work through

A logistics depot sits 300 metres from a wetland reserve boundary, and the company also leases a small underground cable corridor beneath the same plot. The site team is unsure whether the reserve’s status and the depot’s exact position need to be captured together.

QHow should the preparer decide what to include for this site entry?
Reveal model answer →

A quarry is partly on land owned by the business and partly on land it leases from a third party. The boundary touches a conservation area, but the operations team has only mapped the surface footprint so far.

QWhat should the preparer check before finalising the disclosure for this quarry?
Reveal model answer →

A processing plant is not inside a protected area, but it is next to a habitat recognised locally for high biodiversity value. The environmental manager has the habitat name and the plant size, but not the legal protection category.

QCan the preparer complete the entry with the information already held, or is more detail needed?
Reveal model answer →

A manufacturing site is managed by the company under a long-term contract, and a small underground service tunnel extends beyond the fenced boundary. The site is 1.8 hectares and sits beside a bird nesting area outside any formal reserve.

QWhat is the right judgement on whether this site belongs in the disclosure and what details should be recorded?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 304-1
within GRI 304: Biodiversity
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

How do I use the GRI 304-1 Biodiversity page to draft the disclosure from scratch?+
What data do I need to collect for GRI 304-1 Biodiversity before I can write the disclosure?+
How should I set the scope for GRI 304-1 Biodiversity in practice?+
Who should own the GRI 304-1 Biodiversity data collection and sign-off?+
What should go into the evidence pack for GRI 304-1 Biodiversity assurance?+
What are the common mistakes people make when reporting GRI 304-1 Biodiversity?+
How do I use the GRI 304-1 Biodiversity workbook and printable card?+
Can I use the synthetic example disclosure on the GRI 304-1 Biodiversity page as a template for my own draft?+
How do I turn the GRI 304-1 Biodiversity data into a narrative and content-index line?+
What should an assurance reviewer check first on a GRI 304-1 Biodiversity draft?+
How can I reuse GRI 304-1 Biodiversity data for ESRS E4 work?+
More questions this page can help with
GRI 304-1 Biodiversity checklist for site location, site area size and protection statusGRI 304-1 Biodiversity evidence pack items for assurance readinessGRI 304-1 Biodiversity common reporting gaps and mistakes to avoidGRI 304-1 Biodiversity workbook download how to use the .xlsx fileGRI 304-1 Biodiversity printable Library Card PDF what is it forGRI 304-1 Biodiversity synthetic example disclosure table how to read itGRI 304-1 Biodiversity narrative starters and content-index line examplesGRI 304-1 Biodiversity assurance claims claim risk evidenceGRI 304-1 Biodiversity underground land rights and area relationship data pointsGRI 304-1 Biodiversity operation type and biodiversity attribute what data owner needs to provideGRI 304-1 Biodiversity step-by-step preparation section how to follow itGRI 304-1 Biodiversity from company reports table where to find published examples