Level 2 · Decision guide·TNFD · Disclosure guides
TNFD Locate Phase: Mapping Business Activities, Value Chains and Sensitive Locations
A practical guide to span, screening, geolocation, commodities, unknown origins and defensible map/register outputs
Published passport
Current as at 10 August 2026
Reviewed by
Dr Ross KurinkoLinkedIn
Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert
GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert
15+ years on FTSE 100 & Fortune Global 500 disclosures
Canary Wharf, London
LRA educational guidance · Not issued or endorsed by TNFD
Edition written against
TNFD (August 2026)
Technical limitation: This article explains a cross-sector implementation approach. It does not prescribe one universal tool, …
Published
10 Aug 2026
Knowledge Hub guide
Last reviewed
10 Aug 2026
Short answer
The answer, before the reasoning
The Locate phase converts a broad view of the business into a spatially explicit set of assessment locations. Start by defining the span of sectors, activities, products, commodities and value chains; screen where dependencies and impacts may be moderate or high; geolocate those interfaces at the best defensible precision; and overlay sensitive-location criteria.
Unknown origins should remain visible as controlled data gaps rather than disappearing from scope. The practical outputs are an assessment-location map, a controlled location register and a traceability improvement queue.
Educational practitioner material. TNFD recommendations and LEAP guidance should be applied to the organisation’s facts, stated materiality approach and reporting context.
Quick orientation
Quick orientation
- Quick orientation
- Practical answer
- Applies to
- Organisations beginning or refreshing a TNFD-aligned nature assessment across direct operations and upstream/downstream value chains.
- Primary decision
- Where should the organisation Evaluate dependencies and impacts in detail?
- Key TNFD components
- Scoping, L1 Span, L2 screening, L3 interface with nature and L4 interface with sensitive locations.
- Core outputs
- Potentially material activity list; assessment-location map/register; sensitive-location flags; data-quality and unknown-origin actions.
Technical status
Current technical position
<p>The TNFD Recommendations are voluntary recommendations. LEAP is guidance designed to support identification and assessment; TNFD does not require an organisation to use LEAP in one prescribed sequence or to achieve perfect value-chain traceability before starting. The organisation should explain the scope, geographic specificity, data quality, proxies and improvement plans relevant to its assessment and disclosures.</p>
1. What Locate is designed to achieve
Nature-related dependencies and impacts occur in particular ecosystems, watersheds, landscapes and seascapes. A corporate group can therefore have the same activity in two locations but face very different dependencies, impacts and business consequences. Locate is the bridge between a high-level business inventory and the detailed causal analysis performed in Evaluate.
The phase is a prioritisation process, not a final materiality decision. A screening score indicates where detailed work is warranted; it does not by itself prove that a dependency, impact, risk or opportunity is material. The output should preserve enough context for the next phases to understand the activity, location, nature interface, evidence quality and reason for selection.
In practice
| LEAP component | Question the team must answer | Controlled output |
|---|---|---|
| Scoping | What parts of the business, value chain and geography are within the assessment? | Approved span, objectives, reporting lens, time horizons and exclusions. |
| L1 - Span | What activities, sectors, products, commodities and value-chain elements are involved, and where are direct operations? | Business/value-chain inventory linked to entities, activities and known geographies. |
| L2 - Screen | Which activities are associated with potentially moderate or high dependencies and impacts? | Screening heat map and rationale; high-impact commodity/activity flags. |
| L3 - Interface | Where do those activities interface with biomes and specific ecosystems? | Coordinates, polygons, catchments, landscapes, origin regions or other defensible spatial units. |
| L4 - Sensitivity | Which interfaces occur in sensitive locations? | Sensitivity overlays, source dates, thresholds, uncertainty and priority for deeper assessment. |
2. Set the span before building the map
A credible map begins with a controlled span. The team should identify the legal entities and business units covered, but it must also describe the economic activities, products, processes and value chains that connect the reporting entity to nature. For a financial institution, the span can include financed, facilitated, investment or insured activities; for a corporate, it normally includes direct operations and relevant upstream and downstream activities.
Business model: principal revenue streams, operating processes, major assets, products and services.
Sectors and activities: use a consistent industry/activity classification and retain the mapping to internal business units.
Upstream value chain: raw materials, commodities, processing stages, strategic suppliers, contract manufacturers, energy and logistics.
Downstream value chain: distribution, customer use, product impacts, maintenance, disposal and end-of-life pathways where relevant.
Geographic scope: countries alone are rarely sufficient for location-sensitive questions; identify the intended progression towards sites, basins, landscapes or seascapes.
Assessment purpose: clarify whether the first pass is a whole-group screen, a commodity deep dive, a portfolio heat map, a disclosure readiness exercise or a decision on a specific investment.
Rule
Control point
<p>Document why any business unit, geography or value-chain stage has been excluded. “No data” is a data-quality finding, not automatically a scope conclusion.</p>
3. Screen activities and commodities without mistaking screening for materiality
L2 screening narrows the span to activities with potentially moderate or high dependencies and impacts. Sector and commodity tools can provide a useful starting point because they reveal typical interfaces that may not yet be visible in internal risk registers. The organisation should combine these external indications with its own scale, location, sourcing pattern, production method, incident history and stakeholder evidence.
High-impact commodities and unknown origins
Where a commodity is likely to carry significant nature interfaces, the organisation should not wait for perfect supplier traceability before including it. Record the commodity, volume or spend, supplier tier, known processing country, probable origin range, applicable ecosystem and sensitivity indicators, and the confidence attached to each field. Then decide whether a country, subnational region, landscape or facility is the best current spatial unit.
Unknown origin should be coded explicitly. A practical register can distinguish exact coordinates, verified polygon, supplier-declared site, catchment, landscape, subnational region, country, modelled origin and unknown. This prevents a country proxy from being presented as site-specific evidence and allows the team to target supplier engagement where improved traceability could change a decision.
In practice
| Screening input | What it can show | What it cannot prove on its own |
|---|---|---|
| Sector/activity dependency-impact profiles | Typical ecosystem services and impact drivers associated with an activity. | The actual dependency, impact or materiality at a particular site. |
| Commodity lists and supply-chain studies | Commodities that often carry land, water, pollution or biodiversity exposure. | The origin, production practice or supplier performance for the organisation’s own purchases. |
| Spend or revenue concentration | Where commercial scale may justify investigation. | Ecological severity; a low-spend ingredient can still be critical or damaging. |
| Incident, permit and grievance data | Known local issues, response failures and affected stakeholders. | Completeness across locations or earlier value-chain tiers. |
| Remote-sensing and modelled data | Spatial patterns and potential hotspots. | Ground truth without validation, especially at coarse resolution. |
4. Geolocate the nature interface at the right ecological scale
For direct operations, asset-level coordinates or polygons are normally the starting point. The map should also capture the ecological unit relevant to the issue: a water withdrawal may need a catchment or basin; habitat fragmentation may require a landscape corridor; marine impacts may require a seascape; air or water pollution can move beyond the facility boundary. The relevant geography is therefore not always the legal property line.
In practice
| Precision code | Illustrative spatial unit | Appropriate use — Required caveat |
|---|---|---|
| G1 | Verified coordinates or asset polygon | Direct site assessment, proximity and local sensitivity overlays. — Record source, date and whether the operational footprint extends beyond the polygon. |
| G2 | Catchment, landscape or seascape | Issues governed by ecological flows or cumulative pressures. — Explain why this unit is decision-useful and how the activity is linked to it. |
| G3 | Supplier site or origin region | Upstream sourcing where supplier/location evidence exists. — Distinguish verified, supplier-declared and third-party-estimated data. |
| G4 | Subnational area or country | Early-stage screening or uncertain Tier N origins. — Do not represent national averages as local conditions; retain uncertainty. |
| G5 | Unknown | Origin cannot yet be established. — Keep in scope, apply a defensible proxy where useful and assign an improvement action. |
5. Overlay sensitive-location criteria
The TNFD Recommendations describe sensitive locations through five non-exclusive criteria: areas important for biodiversity; areas of high ecosystem integrity; areas of rapid decline in ecosystem integrity; areas of high physical water risk; and areas important for ecosystem-service provision, including benefits to Indigenous Peoples, Local Communities and other stakeholders. A location can meet one or several criteria.
Sensitivity screening should therefore use more than a protected-area layer. It can include Key Biodiversity Areas and species information, ecosystem integrity and trend data, basin-level physical water risk, and evidence of ecosystem services that support communities and rights-holders. The selection rule, data date, spatial resolution and threshold should be preserved in the register.
Figure 1. Locate screening funnel and minimum location-register outputs. London Reporting Academy visual.
6. Build a location register that can survive review
A map is a presentation layer; the register is the controlled analytical record. Each point, polygon or aggregated area should be linked to the underlying business activity and evidence. The register should allow a reviewer to understand why the location entered the assessment, which data were used, how precise the geography is and what needs to improve.
In practice
| Field group | Minimum fields |
|---|---|
| Identity | Location ID; legal entity; business unit; asset/activity; value-chain stage; supplier/customer or portfolio reference where permitted. |
| Activity and commodity | Sector/activity code; product/process; commodity; volume/spend/exposure; reporting period. |
| Geography | Coordinates/polygon or spatial unit; country/subnational area; biome/ecosystem; catchment/landscape/seascape; precision code. |
| Nature interface | Potential dependencies; impact drivers; environmental assets; ecosystem services; known incidents or stakeholder concerns. |
| Sensitivity | Each criterion tested; tool/dataset; version/date; threshold; result; uncertainty. |
| Evidence and controls | Source owner; evidence link; primary/secondary/modelled; quality grade; reviewer; last updated. |
| Action | Reason selected; Evaluate priority; traceability gap; supplier or site data request; target completion date. |
In practice
7. Step-by-step implementation workflow
| Step | Action | Owner/input — Output/control |
|---|---|---|
| 1 | Approve the assessment span and objective. | Nature lead, strategy, risk, procurement, finance. — Scope memorandum, exclusions and reporting lens. |
| 2 | Create the activity, asset, product and commodity inventory. | ERP, fixed-asset register, procurement, portfolio and product data. — Controlled inventory with stable IDs. |
| 3 | Run sector/activity and commodity screening. | LEAP team and subject-matter specialists. — Potential moderate/high dependency-impact flags with rationale. |
| 4 | Geolocate direct operations. | Operations, GIS, property, EHS. — Coordinates/polygons and ecological units. |
| 5 | Map value-chain origins at the best available precision. | Procurement, suppliers, customers, due diligence teams. — Verified and proxy geographies plus unknown-origin queue. |
| 6 | Overlay sensitive-location data. | GIS/data analyst and ecology/water specialists. — Criterion-by-criterion results and source metadata. |
| 7 | Select assessment locations and quality-review the register. | Cross-functional LEAP team. — Map/register approved for Evaluate; false positives and gaps recorded. |
| 8 | Publish only the granularity appropriate to disclosure. | Reporting, legal, security and technical reviewer. — List/map, aggregation rationale and improvement statement. |
Hypothetical scenario
Illustrative scenario
<p>A beverage group has three bottling sites with verified coordinates, 120 direct suppliers and several agricultural ingredients bought through traders. Water-risk data show one bottling site in a high-risk basin. Citrus and sugar have country-of-processing data but incomplete farm origins. The team screens the commodities as potentially high-dependency/high-impact, maps known mills and probable sourcing regions, flags the water-stressed basin and biodiversity-sensitive landscapes, and keeps unknown farm origins in a traceability queue. Evaluate then focuses on the bottling basin, the most sensitive sourcing landscapes and the highest-volume uncertain origins. No farm-level conclusion is claimed until evidence improves.</p>
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
In practice
9. Weak versus stronger Locate outputs
| Weak output | Why it fails | Stronger output |
|---|---|---|
| A world map of owned sites with red dots. | It omits value-chain interfaces, the ecological unit, screening rationale and data quality. | A controlled register and map linking activities, commodities, precision, sensitive criteria, evidence and Evaluate priority. |
| “Supplier origin unavailable, therefore out of scope.” | The data gap is converted into an exclusion and hides likely exposure. | Unknown origin retained with proxy geography, confidence grade, engagement action and review date. |
| Country water-risk score applied to every site. | National averages can obscure basin differences. | Site linked to the relevant basin; proxy use and limitations stated where local data are unavailable. |
| All protected areas treated as the complete definition of sensitivity. | TNFD sensitive-location criteria are broader. | Criterion-by-criterion overlay including biodiversity, integrity/decline, water and ecosystem-service importance. |
In practice
10. Common mistakes and corrections
| Mistake | Why it happens | Correction |
|---|---|---|
| Mapping only direct operations | Asset data are easier than value-chain data. | Use a phased approach, but state breadth/depth and keep priority commodities and value-chain gaps visible. |
| Treating screening as a materiality conclusion | Heat maps look definitive. | Use screening to select where Evaluate and Assess are needed; record that status. |
| Hiding unknown origins | Teams fear a weak-data disclosure. | Create an explicit unknown-origin category and improvement plan. |
| Using one geographic scale for every issue | Administrative boundaries are convenient. | Choose site, catchment, landscape, seascape or region according to the causal pathway. |
| No version control for map layers | External datasets update asynchronously. | Retain dataset name, version/date, resolution, threshold and extraction date. |
| Publishing exact sensitive coordinates without review | Internal analytical maps are copied into public reports. | Apply legal, security and confidentiality review while preserving decision-useful disclosure and aggregation rationale. |
Readiness
11. Locate readiness checklist
- The assessment span identifies direct operations and relevant upstream/downstream value chains.
- Activities, products, processes and commodities are linked to stable internal IDs.
- Screening sources and thresholds are documented and not described as final materiality tests.
- Direct assets have coordinates or polygons, with ecological units added where relevant.
- Value-chain locations distinguish verified, declared, estimated and unknown origins.
- Unknown origins remain in scope and have owners, actions and review dates.
- All five TNFD sensitive-location criteria have been considered, not only protected areas.
- Data source, date, spatial resolution, assumptions and quality grade are retained.
- Assessment locations are selected with a documented rationale and passed to Evaluate.
- Public map/list granularity and any aggregation are reviewed against material-information needs.
- The organisation has a credible plan to improve location specificity and value-chain traceability over time.
Take it with you
The checklists as a working spreadsheet
Every checklist and table on this page, with empty status, owner and evidence columns for your team to fill in and keep.
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