Short answer
The answer, before the reasoning
Build a complete inventory of sites, material products and sourcing relationships, then identify the locations linked to the most significant biodiversity impacts. Use site-level data for own operations and the best available geographic precision for the supply chain.
Map ecological sensitivity, direct drivers, ecosystem condition and affected services. Where primary data are unavailable, use transparent secondary or modelled evidence, state the uncertainty and maintain a phased improvement plan.
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Source-grounded educational draft. Final LRA technical sign-off is required before publication.
PUBLIC ARTICLE
In practice
FORMAT
| FORMAT | LANGUAGE | VERSION |
|---|---|---|
| Deep Guide | British English | 1.0 • 1 August 2026 |
What location-specific evidence means under GRI 101
GRI 101 does not ask an organisation to publish a decorative map of its facilities. It asks the reporting team to connect significant biodiversity impacts to the places, activities, products and business relationships through which those impacts occur. The practical challenge is therefore not only geographic: it is a controlled evidence problem involving site master data, ecological context, impact assessment, procurement information, specialist judgement and transparent uncertainty.
The strongest data architecture starts with a complete universe and then narrows it. First, identify all potentially relevant sites, products, services and sourcing relationships. Second, determine which of them are associated with the organisation’s most significant actual or potential impacts. Third, gather the location, driver, ecosystem and affected-stakeholder evidence needed for the applicable GRI 101 disclosures. The published information can be proportionate, but the internal decision trail must explain why certain locations were prioritised and others were not.
Figure 1. The data process runs in two connected lanes: own operations and the value chain. Both feed a controlled location-data register and an impact-based selection decision.
Quick orientation
- APPLIES TO Organisations preparing GRI 101 data, especially multi-site groups an
- PRIMARY DECISION Which sites, products, services and supply-chain locations require location-specific evidence and what level of geographic precision is defensible.
- KEY SOURCES GRI 101: Biodiversity 2024, particularly Disclosures 101-4 to 101-8,
- COMMON CONFUSION Assuming that every site needs public coordinates, or that a supplier spend list is sufficient evidence of biodiversity impacts.
Rule
EFFECTIVE DATE
GRI 101: Biodiversity 2024 is effective for reports or other materials published on or after 1 January 2026. Earlier biodiversity datasets and disclosures should therefore be checked for compatibility with the new location-specific architecture.
In practice
The five evidence questions behind Disclosures 101-4 to 101-8
| Disclosure | Core question | Evidence output — Typical owner |
|---|---|---|
| 101-4 | How did the organisation identify the sites and supply-chain products or services associated with its most significant biodiversity impacts? | Selection method, impact inventory, screening criteria, prioritisation record and approval. — Sustainability lead with site, procurement and specialist input. |
| 101-5 | Where are the relevant sites and supply-chain locations, and what activities or products are associated with them? | Site name and location; site size and activities; supply-chain product/service and country or jurisdiction; higher precision where available. — GIS or property data owner; procurement and supplier-management teams. |
| 101-6 | Which direct drivers of biodiversity loss are relevant at those locations? | Driver register covering land- or sea-use change, resource exploitation, pollution, invasive species and other relevant drivers; methods and assumptions. — Environmental specialists and operational owners. |
| 101-7 | What ecosystems are affected and how has their condition changed? | Ecosystem type, extent, base-year and current condition, methods, assumptions and limitations. — Ecologist, GIS specialist or qualified environmental consultant. |
| 101-8 | Which ecosystem services and beneficiaries are affected or potentially affected? | Service-beneficiary map linking ecological change to people, communities, users and economic activities. — Biodiversity, community and human-rights teams. |
Step 1 — Build the complete site and sourcing universe
Do not begin with the locations that the sustainability team already knows. Begin with controlled master data. For own operations, the site inventory should reconcile to legal entities, property records, permits, environmental-management systems, finance cost centres and operational reporting. For the value chain, the universe should cover products, commodities, services and business relationships that could create or be linked to significant impacts, including upstream tiers beyond direct suppliers where the impact pathway demands it.
In practice
| Register field | Why it matters | Minimum control |
|---|---|---|
| Record ID and version | Prevents duplicate or orphan locations and supports change tracking. | Unique ID; effective-from and effective-to dates. |
| Entity / supplier / business relationship | Links the location to the reporting organisation and to GRI 3 impact pathways. | Reconcile to legal entity and supplier masters. |
| Site, facility, farm, mine, route or sourcing unit | Defines the operational object being assessed. | Use a stable name and site type. |
| Activity, product or service | Explains the pressure pathway rather than treating location as a standalone risk. | Controlled taxonomy and operational description. |
| Geographic precision | Shows whether the record is a polygon, point, municipality, subnational region, country or jurisdiction. | Precision code, source and confidence rating. |
| Area or spatial extent | Supports site-specific reporting and ecological analysis. | Hectares or other appropriate unit with method. |
| Operating status and period | Avoids mixing active, closed, acquired or disposed locations without explanation. | Status, acquisition/disposal date and reporting-period coverage. |
| Data owner and reviewer | Makes the evidence maintainable and verifiable. | Named role, review date and sign-off. |
Rule
BOUNDARY CONTROL
The site inventory used for reporting is not automatically the same as the financial consolidation list. Biodiversity impacts can arise through business relationships outside the reporting entities. Record the relationship and the impact pathway even when the organisation does not own or control the location.
Step 2 — Choose and disclose a defensible location precision
Location precision should follow the decision need and the evidence available. For an owned industrial site, a boundary polygon may be available from property or permitting systems. For a supplier farm, the organisation may only know a municipality or sourcing region. GRI 101’s official guidance favours more precise spatial information where possible, but the reporting team should not invent accuracy. A country-level supply-chain location can be a legitimate current state when the organisation explains the limitation and the plan to improve it.
In practice
| Precision level | Suitable use | Risk if overstated — Improvement action |
|---|---|---|
| Polygon / site boundary | Owned or controlled locations with GIS, cadastral or permit records. | Boundary excludes associated infrastructure or leased areas. — Reconcile GIS layer to site master and operating footprint. |
| Point coordinates | Site known but reliable polygon unavailable. | A single point is treated as the full area of influence. — Record coordinate source and create buffer or area-of-influence method separately. |
| Municipality / subnational region | Supplier or logistics location known at regional level. | Regional averages conceal local ecological variation. — Request supplier site evidence for high-significance relationships. |
| Country / jurisdiction | Supply-chain product or service linked to a country but no finer information is currently available. | Country-level risk is mistaken for evidence of a specific impact. — Disclose uncertainty; combine with product, driver and sourcing evidence. |
| Unknown / incomplete | Relationship is relevant but location has not yet been obtained. | The record disappears from the assessment. — Keep in the gap log; assign owner, deadline and interim screening method. |
Step 3 — Overlay ecologically sensitive locations
A location becomes decision-useful only when it is compared with ecological context. The reporting team should establish a controlled overlay process covering the categories and datasets relevant to GRI 101 and the organisation’s geography. Depending on the impact pathway, this can include protected and conserved areas, Key Biodiversity Areas, threatened-species ranges, high-integrity ecosystems, important freshwater or coastal systems and locally recognised areas of ecological or cultural importance.
GIS is valuable, but it does not replace ecological judgement. A site outside a protected-area boundary may still affect the area through water abstraction, pollution, fragmentation, access roads or downstream hydrological change. Conversely, proximity alone does not prove a significant impact. The register should therefore distinguish three separate facts: the location of the activity, the ecological feature potentially affected and the mechanism by which the impact occurs.
Rule
SPECIALIST ROLE
A GIS specialist can establish coordinates, polygons, buffers and spatial joins. An ecologist should interpret ecosystem type, condition, sensitivity and likely pathways. Community or human-rights specialists may be needed where ecosystem services support livelihoods, cultural practices or access to land and water.
Step 4 — Record direct drivers, ecosystem condition and affected services
GRI 101 requires the organisation to move beyond a generic statement that an operation is ‘near nature’. The evidence should explain the pressure on biodiversity. At minimum, the working register should identify the relevant direct driver, whether the impact is actual or potential, whether it is positive or negative, the ecosystem affected, available condition evidence and the ecosystem services and beneficiaries that may be affected.
In practice
| Evidence layer | Illustrative data fields | Key review question |
|---|---|---|
| Direct driver | Land- or sea-use change; exploitation of natural resources; pollution; invasive species; other locally relevant pressure. | Is the driver specific to the activity and location, or copied from a sector list? |
| Impact character | Actual / potential; positive / negative; scale, scope, irremediable character; likelihood for potential impacts. | Does the record support the significance conclusion under GRI 3? |
| Ecosystem type and extent | Terrestrial, freshwater or marine ecosystem; mapped extent; base year and current period. | Are ecosystem units and spatial boundaries consistent over time? |
| Ecosystem condition | Field survey, remote sensing, monitoring indicators, recognised datasets or modelled proxy. | Does the metric genuinely represent condition and is uncertainty disclosed? |
| Ecosystem services | Water provision, erosion control, pollination, cultural value, flood regulation or other relevant services. | Which beneficiaries are affected and how was this determined? |
| Management response | Avoidance, minimisation, restoration, rehabilitation, compensation or other action. | Is the action connected to the identified impact and location? |
Step 5 — Treat upstream and downstream impacts as evidence problems
The supply-chain analysis should not stop at the first invoice. For products associated with land conversion, water stress, deforestation, overexploitation or pollution, the significant impact may occur several tiers upstream. The organisation should therefore define the product and impact pathway first, then determine how far upstream it needs to trace. A strategic direct supplier with low spend can be more relevant than a high-spend service supplier if it is linked to severe biodiversity impacts.
Downstream impacts can also matter. Product use, infrastructure operation, disposal, leakage, introduced species, water use or land-use change by customers may create significant impacts. The location-data register can include downstream use geographies, customer segments or application contexts even where exact coordinates are unavailable. The important control is to label the inference and avoid presenting a broad market geography as a precise site impact.
In practice
A practical data hierarchy for incomplete evidence
| Level | Evidence source | How to use it — Disclosure treatment |
|---|---|---|
| 1 — Primary site data | Coordinates, polygons, field surveys, permits, environmental monitoring and supplier site records. | Use as the preferred basis when quality and coverage are sufficient. — State method, period, boundary and quality controls. |
| 2 — Verified supplier or third-party data | Certification records, audit data, traceability platforms, specialist studies. | Use after checking definitions, site coverage and currency. — Identify source, coverage and residual gaps. |
| 3 — Authoritative secondary datasets | Protected-area and KBA databases, land-cover data, species records, water and ecosystem datasets. | Use for screening and, where appropriate, reporting evidence. — Explain dataset date, resolution and limitations. |
| 4 — Modelled or proxy data | Commodity-country risk models, remote-sensing proxies, industry factors or scenario models. | Use when primary evidence is unavailable and the model is decision-useful. — State assumptions, uncertainty, affected records and improvement plan. |
| 5 — Expert judgement | Documented specialist interpretation of incomplete or conflicting evidence. | Use to reach a conditional conclusion, not to create false precision. — Record expert, criteria, caveat, approval and review date. |
Location-data register: recommended structure
The following register is an LRA implementation tool rather than a GRI-prescribed template. It is designed to preserve the evidence trail from location selection to published disclosure.
In practice
| Field group | Recommended fields |
|---|---|
| Identity | Record ID; entity or supplier; site/product/service; relationship type; operating status; reporting period. |
| Geography | Latitude/longitude; polygon reference; municipality; subnational region; country/jurisdiction; precision level; spatial source; area. |
| Ecological context | Ecosystem type; sensitive-area category; distance or hydrological connection; dataset and extraction date. |
| Impact pathway | Activity; direct driver; actual/potential; positive/negative; impact description; severity and likelihood evidence; involvement. |
| Condition and services | Base-year condition; current condition; indicator/method; ecosystem services; beneficiaries; community evidence. |
| Data quality | Primary/secondary/modelled; coverage; assumptions; uncertainty rating; limitation wording; planned improvement. |
| Governance | Data owner; specialist reviewer; approval status; evidence location; retention period; disclosure and Content Index mapping. |
Supplier questionnaire structure
A supplier questionnaire should collect only information that serves the impact pathway and can be reviewed. Asking every supplier for a full biodiversity study creates low-quality responses and unnecessary burden. A modular questionnaire is more effective.
In practice
| Module | Core questions | Evidence requested |
|---|---|---|
| A. Supplier and product identity | Which legal entity and production or sourcing sites supply the relevant product or service? Which tiers and subcontractors are involved? | Supplier/site IDs, product codes, tier information and contact owner. |
| B. Location | Provide site coordinates or polygon. If unavailable, provide municipality, region and country and explain the limitation. | GIS file, map, address, traceability-platform record or jurisdiction declaration. |
| C. Land, water and ecosystem context | What land or marine use, ecosystem type and nearby sensitive areas are relevant? | Permits, environmental assessment, land-cover map, water-basin or ecological study. |
| D. Direct drivers | Which land-use change, resource extraction, pollution, invasive-species or other pressures occur? | Monitoring data, production records, chemical use, water and waste data. |
| E. Impacts and incidents | What actual or potential biodiversity impacts, grievances, enforcement actions or restoration needs have been identified? | Impact assessments, incidents, complaints, corrective-action plans. |
| F. Condition and monitoring | What indicators are used to assess ecosystem extent or condition and over what period? | Survey results, remote-sensing output, monitoring methodology. |
| G. Management response | What avoidance, minimisation, restoration or other actions are implemented and how is effectiveness tracked? | Policies, plans, targets, monitoring and outcome evidence. |
| H. Data quality and consent | Which data are estimates? What is the coverage period? May location data be shared publicly or only in restricted evidence? | Method note, confidence level, confidentiality flag and authorised sign-off. |
In practice
Phased collection plan
| Phase | Priority actions | Output / gate |
|---|---|---|
| 0–30 days | Reconcile site and supplier universes; identify priority products and impact pathways; define location-precision codes; appoint GIS and ecology reviewers. | Controlled universe, source register and high-risk data-request list. |
| 31–60 days | Collect own-site coordinates and boundaries; run initial sensitivity overlays; obtain country/region data for priority supply chains; record direct drivers. | First location-data register and preliminary GRI 101-4/101-5 evidence. |
| 61–120 days | Commission specialist review for significant locations; add ecosystem condition and service-beneficiary evidence; challenge modelled data and supplier responses. | Reviewed significant-location set, limitation note and disclosure draft. |
| Next reporting cycle | Increase supplier-site precision; improve field or remote-sensing monitoring; integrate acquisitions and new products; automate version control and review triggers. | Data-remediation plan linked to owners, budget and next disclosure date. |
Hypothetical example — a food manufacturer with incomplete traceability
The team does not treat the lack of farm coordinates as a reason to omit the supply-chain pathway. It records the product-country relationship, the supporting commodity and land-use evidence, the current geographic precision and the uncertainty. It selects the three highest-significance sourcing pathways for supplier engagement, requests subnational and farm-level data from strategic suppliers, and commissions an ecologist to review the own-site water and habitat impacts. The report explains that farm-level coverage is incomplete and sets a time-bound improvement plan.
Hypothetical scenario
ILLUSTRATIVE SCENARIO
A food manufacturer operates six processing plants and sources cocoa, palm-derived ingredients and packaging from several regions. Its own plants have reliable coordinates, but most agricultural production locations are unknown. Screening indicates that two cocoa sourcing countries and one palm supply chain may be linked to significant land-use and ecosystem impacts.
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
In practice
| Weak wording | Stronger, fact-based wording |
|---|---|
| “Our suppliers are located globally and we monitor biodiversity risk.” | “We identified cocoa sourced from Country A and Country B and palm-derived ingredients sourced from Country C as the supply-chain products associated with our most significant potential biodiversity impacts. Current location data cover country for all three pathways, subnational region for 62% of relevant purchase volume and farm coordinates for 18%. We used commodity-land-use datasets and supplier records to screen direct drivers. The principal limitation is incomplete farm-level traceability; priority suppliers are required to provide site data during 2027.” |
Common mistakes
• Starting with a map of owned facilities and ignoring products, services and business relationships.
• Selecting supply-chain locations by spend or supplier size without testing the significance of impacts.
• Publishing exact-looking coordinates generated from a postcode or headquarters address and presenting them as production-site evidence.
• Treating proximity to a protected area as proof of an impact without identifying the activity, pathway and ecological feature affected.
• Using a global biodiversity-risk score without disclosing dataset resolution, assumptions or the records to which it was applied.
• Collecting supplier policies but no location, driver, condition or incident evidence.
• Removing unknown locations from the assessment instead of retaining them in a controlled gap log.
Rule
MYTH VERSUS REALITY
Myth: GRI 101 requires exact coordinates for every supplier. Reality: the reporting focus is on locations associated with the most significant impacts. Supply-chain information can be reported at country or jurisdiction level when that is the best available precision, but the organisation should disclose limitations and improve traceability where it affects the quality of the impact conclusion.
Readiness
Reviewer checklist
- • ☐ The site and sourcing universe reconciles to controlled corporate and procurement data.
- • ☐ The selection of significant sites and supply-chain products is traceable to the impact assessment.
- • ☐ Geographic precision is coded consistently and never overstated.
- • ☐ Sensitive-location screening uses current, documented datasets and specialist review.
- • ☐ Direct drivers are connected to specific activities and locations.
- • ☐ Ecosystem condition evidence distinguishes baseline, current period, method and uncertainty.
- • ☐ Ecosystem services and beneficiaries are considered where relevant.
- • ☐ Primary, secondary, modelled and expert evidence are labelled separately.
- • ☐ Supplier responses have completeness, plausibility and approval checks.
- • ☐ Public wording states coverage gaps and a credible improvement plan.
Bottom line
Location-specific biodiversity reporting is not a request for perfect global traceability on day one. It is a request for a disciplined connection between significant impacts and places. A credible first-year system preserves unknowns, uses the best available evidence without overstating precision, brings GIS and ecological expertise into the review, and converts data gaps into a phased collection programme with named owners and dates.
Official source anchors
The source set below should be rechecked as part of the pre-publication update control. Normative conclusions in this article are based on the current official editions listed here.
1. GRI 101: Biodiversity 2024. Official requirements and guidance for biodiversity impacts, location-specific information, direct drivers, ecosystem condition and ecosystem services. Open official source
2. GRI 101: Biodiversity 2024 — Frequently Asked Questions. Official clarification on significant sites, supply-chain geography and implementation questions. Open official source
3. GRI 3: Material Topics 2021. Official process for identifying and assessing impacts and determining material topics. Open official source
4. GRI Standards — English language. Official access point for current Standards, effective dates and publication versions. Open official source
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