Disclosure focus
This disclosure asks an organisation to explain the policies it has in place to address biodiversity and ecosystems impacts, dependencies, risks and opportunities. In practice, the report should show whether those policies are formal, who they apply to, and what areas they cover, rather than only describing a few isolated initiatives or a flagship site.
The practical focus is on the breadth and substance of policy coverage across the business. Readers should be able to see whether the policies apply to the whole organisation, specific operations, sites, supply chains or activities, and how they guide day-to-day decisions and management. The aim is to understand how biodiversity and ecosystems considerations are built into governance and operations, not just stated as a general commitment.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show E4-2 sub-elements (LRA working checklist)
State which ecosystems and species are included.
Set out the aims of the policy.
Give the policy a clear name.
Explain the boundaries of the policy.
Identify the materials it covers.
Describe how far up and down the supply chain it applies.
Explain the systems used to trace those materials.
Set out the geographic area the policy affects.
State what the policy applies to.
Identify any sites in or close to sensitive areas.
Say whether deforestation is covered.
Say whether land-use change is covered.
Say whether oceans are covered.
List the outputs that are used.
Identify the type of scenario used.
Say whether scenario analysis is used.
List the sites affected.
State the buffer distance applied.
Describe the method used.
How to prepare it
1Set the boundary first. Identify the policy by name, then state what it is meant to achieve and where it applies. Make clear whether it covers land use, marine matters, and forest loss, and note the business areas, sites, or activities included in the review.
2Define the coverage terms you will use. Explain which ecosystems and species are counted, and record the supply chain reach, the materials in scope, and any traceability methods used to follow them through the chain.
3Gather the supporting records before drafting. Pull together site lists, maps, internal policy documents, supplier records, monitoring outputs, and any other source material that shows which locations are inside or close to sensitive areas and which operations are affected.
4Prepare the figures and narrative in a single working file. Enter the required yes/no responses, then write the supporting text for the policy scope, the area of influence, the scenario use details if relevant, the scenario type, the outputs relied on, and any buffer distance and method used to identify affected sites.
5Explain any exclusions, assumptions, or changes in approach. If a site, material, ecosystem, or species is left out, or if the method differs from a prior period, state that clearly so the reader can see what changed and why the reported coverage is what it is.
6Check the draft against the official source before sign-off. Confirm that every required item is answered, the wording matches the underlying evidence, and the final submission reflects the source material rather than a reworked summary.
Request the data
Request the biodiversity policy details and supporting evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What policy wording, coverage and supporting methods do we need to describe how the organisation manages nature-related impacts and dependencies?
Use your organisation’s own policy and site-management language first, then map it to the reporting fields. If your teams use different terms for habitats, protected areas, sourcing controls, or site screening, keep those terms in the request and in the evidence pack, and only translate them at the reporting stage. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.
Weak request
Please provide the ESRS E4:E4-2 policy disclosures, including all required datapoints and the relevant narrative for the standard.
Why it fails: It uses framework language instead of the organisation’s own operational terms, so the owner has to translate the ask before they can respond. It also does not tell them which systems, site lists, policy documents, or screening methods to pull from, so the response is likely to be incomplete or inconsistent.
Better request
Please send the current nature or land-stewardship policy and the supporting evidence for [period]: policy name, what it covers, what it is trying to achieve, which habitats/species or site types it applies to, how you track relevant materials, which sites sit in or near sensitive areas, what those sites are covered by, how far your screening reaches, what method you use, whether you use any scenario work and what outputs feed decisions, and the list of affected sites. Use your team’s own terms and include the source file or system for each item.
Industry examples
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
We based the draft on the collected policy and coverage fields, using the reporter’s own definitions for the policy, the materials and supply-chain boundary, the site and area-of-influence scope, and the yes/no flags for land, marine and deforestation topics, plus scenario use.
Context note
Taken together, these datapoints show how far the policy reaches across operations, supply chains and sensitive locations, and whether the organisation has identified coverage for land, ocean and deforestation-related matters.
Fluctuation statement
If any of these fields change from one period to the next, explain whether the shift reflects a broader policy scope, a revised boundary for sites or supply chains, or a change in how the organisation classifies the environmental topics it tracks.
Content index entry
E4-2 Policies — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for E4-2 — 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.
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Assurance readiness
For each claim, check the evidence
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
Wrong owner
The team asks the sustainability lead for a policy detail that sits with operations, procurement, or site management, so the answer comes from the wrong part of the business.
Framework language only
People ask for answers in ESRS-style terms instead of the organisation’s own wording, which makes staff guess how to translate the policy into day-to-day language.
No scope set
The data pull starts before everyone agrees which business units, sites, products, or activities belong in the population, so the figures and text are built on different boundaries.
Wrong timing basis
Someone uses the latest policy version or a different reporting cut-off than the one used for the period being reported, so the collected data does not match the reporting window.
Mixed counting basis
One source counts every site while another counts only sites with a direct policy link, and the two bases are merged without being separated first.
Source labels lost
During consolidation, the original file names, field labels, or system tags are stripped away, so no one can trace each answer back to its starting record.
Populations merged
Sites in sensitive areas, supply-chain coverage, and other distinct groups are rolled into one combined list even though they should be kept separate for collection.
No evidence trail
The team captures the answer but not the supporting note, version, date, or approver, so there is no clear sign-off path for review.
Where judgement is often needed
Set the cut-off date for newly bought or sold operations
Choose one reporting date for the policy map, then explain whether newly acquired or disposed sites are included from the deal date, the period start, or the period end, and keep that approach consistent.
Handle different local meanings for the same habitat or species label
Where country teams use different legal or technical labels, map them to one internal business definition, state the mapping used, and note any places where the local meaning does not line up exactly.
Decide how to treat sites that sit partly inside the policy perimeter
If a site, supplier, or project only partly falls within the area covered by the policy, explain the rule used to include it, exclude it, or split it, and show how that rule was applied.
Choose the basis for counting coverage across ecosystems and species
State whether coverage is counted by site, asset, contract, hectare, or another internal unit, and explain any estimate used where a direct count is not available.
Explain how far the supply chain review reaches
If the policy extends beyond direct suppliers, set out how many tiers or links are reviewed, what triggers inclusion, and where the review stops when data are not available.
Use a clear rule for sensitive-area proximity
When deciding whether a location is near a sensitive area, disclose the distance or buffer used, the method for measuring it, and whether the same rule is applied across all regions.
Separate measured information from modelled or estimated information
If some policy coverage figures come from site records and others from estimates or models, label each basis clearly and explain why the estimate was needed.
Round figures in a way that does not distort the picture
State the rounding rule used for counts, percentages, or area figures, and make sure the rounded totals still reconcile to the underlying numbers.
Aggregate sensitive location data to protect privacy and security
Where exact site details cannot be shown, group them into broader categories, explain the aggregation rule, and say how this affects the level of detail in the disclosure.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food processing
We keep a named biodiversity policy that applies across our own operations and the parts of our value chain where we can influence outcomes, with the aim of reducing pressure on habitats and species while improving restoration planning. It covers terrestrial and freshwater ecosystems, plus the species most exposed to our sourcing footprint; we also use traceability checks for palm oil, soy, cocoa and timber, apply them from direct suppliers back to the first tier of origin, and extend our site review to 18 locations, of which 6 sit in or close to sensitive areas and are covered by the policy’s controls across a 25 km area of influence. - We report that our policy addresses land, marine and forest impacts, and we use scenario analysis to test how our approach could perform under different nature-risk pathways. - For the synthetic figures: 18 sites reviewed, 6 in or near sensitive areas, 12 outside; 4 material groups under traceability, all 4 covered by first-tier supplier checks.
Illustrative only; shows how a reporter might describe a biodiversity policy, traceability, sensitive-area coverage and scenario use without naming the organisation.
Illustrative (synthetic) example — Consumer electronics assembly
Our nature policy is set for our manufacturing sites and the upstream materials we can influence, with the practical aim of limiting harm to habitats, water systems and vulnerable species while improving supplier controls. It focuses on freshwater and coastal ecosystems, covers species affected by mineral extraction and packaging inputs, and uses traceability for aluminium, copper, lithium and paper-based packaging from direct suppliers to smelter, mill or equivalent origin point; we reviewed 9 sites, including 2 in or near sensitive areas, and those 2 are within the policy’s active coverage across a 15 km influence zone. - We also state that the policy addresses land, ocean and forest impacts, and we test it with scenario work. - Synthetic figures: 9 sites total, 2 sensitive-area sites, 7 other sites; 4 material groups traced, all 4 covered through the stated supply-chain boundary.
Illustrative only; shows a different sector describing the same datapoints in a separate, internally consistent way.
How companies report E4-2 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Sanoma Oyj
Education Services · Finland · 2025
Sanoma Oyj's 2025 Annual Report provides partial coverage of biodiversity-related actions, noting that these apply to its own operations and upstream value chain, specifically concerning all paper used (p.101). The report references policies related to biodiversity and ecosystems and mentions actions and resources allocated, but does not clearly disclose specific targets or headline values (p.99-101). Several expected narrative and numeric disclosures on biodiversity are not found or remain unclear, indicating limited detailed reporting on this topic.
Assicurazioni Generali S.p.A.
Banks / Diverse Financials / Insurance · Italy · 2024
Assicurazioni Generali S.p.A.'s 2024 Annual Integrated Report and Consolidated Financial Statements provides limited direct evidence on the disclosure, with no quotable narrative or numeric data explicitly addressing the topic throughout the report. Some references to policies related to biodiversity and ecosystems appear on pages 106, 139, 141, and 142, but these are not detailed in the evidence map. Additionally, there are mentions of greenhouse gas emissions data on page 123 and sustainability statements on page 177, yet no clear connection to the specific disclosure is found, indicating notable gaps in coverage.
Snam S.p.A.
Gas Utilities · Italy · 2025
Snam S.p.A.’s 2025 Annual Report includes a reference to biodiversity and ecosystems policies and guidelines, specifically mentioning the Health, Safety and Quality Policy (HSEQ Policy) of Bioenerys Ambiente on page 252. The report also notes the allocation of financial resources related to biodiversity and ecosystems, with a figure of €4 million mentioned on page 347. However, the report lacks detailed narrative or numeric disclosures on biodiversity impacts, dependencies, or specific management actions beyond these points, with multiple sections showing no quotable evidence.
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Scenarios to work through
A manufacturer has one biodiversity policy covering its own sites, but the draft note only names the policy and says it applies group-wide. The team has not yet described what the policy is meant to achieve or whether it also reaches suppliers and contractors.
QWhat should the preparer do before finalising the policy note?
Reveal model answer →Hide answer ↑They should add a plain description of the policy’s name, what parts of the business it covers, and the environmental aims it is meant to support. If the policy also reaches the supply chain, that wider reach should be stated clearly rather than left implied.
Why this matters · A policy summary should let a reader see what it is called, what it is for, and where it applies.
A food company sources raw materials from several countries and has a nature policy that mentions traceability, but the draft only says 'we track materials' without saying which materials or how far back the checks go. The sustainability team is unsure whether to mention suppliers beyond tier 1.
QHow should the preparer decide what to include about traceability?
Reveal model answer →Hide answer ↑They should explain the tracking approach in practical terms, identify the materials it covers, and state the part of the supply chain included. If the process reaches beyond direct suppliers, that broader scope should be described so the reader can understand how far the checks run.
Why this matters · When traceability is part of the policy, the note should show both the materials in scope and the supply-chain depth covered.
A port operator has sites close to wetlands and coastal habitats. The draft policy note says the company 'supports nature protection' but does not say whether the policy covers those nearby locations or the wider area that could be affected by operations.
QWhat judgement should the preparer make about the policy coverage description?
Reveal model answer →Hide answer ↑They should spell out whether the policy applies to sites in or near sensitive locations and whether it also extends to the surrounding area that could be influenced by those sites. The wording should make clear which locations are included, rather than relying on a general statement about nature protection.
Why this matters · For sensitive locations, the policy note should show both the relevant sites and the wider area that may be affected.
A forestry business has a policy on land management and deforestation, and the draft includes a yes/no flag for land use but leaves the other nature topics blank because the team thinks they are 'covered elsewhere'. The same draft also mentions that scenario analysis was used, but gives no detail on the type or outputs.
QWhat should the preparer check before sign-off?
Reveal model answer →Hide answer ↑They should make sure each relevant topic is addressed consistently: if the policy touches land use, marine impacts, or forest loss, the note should reflect that clearly and not leave the related fields unsupported. If scenario work was used to shape the policy, the team should also describe whether it was used, what kind of scenario work it was, and what outputs informed the policy choices.
Why this matters · Keep the policy note aligned with the topics it covers and explain any scenario work that fed into it.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
What should I collect for ESRS E4-2 before I start drafting the disclosure?+−
Use the page’s datapoint list as your starting checklist: policy title, coverage, aims, ecosystem and species coverage, traceability controls, tracked materials, supply chain reach, sensitive-area sites, policy reach, influence area, land use, ocean impact, deforestation, scenario analysis, buffer settings and impacted sites. The page also gives a step-by-step preparation flow, so you can turn that list into a practical data request and draft plan.
How do I set the scope for ESRS E4-2 in a way that is usable for reporting?+−
The page points you to scope items such as policy coverage, supply chain reach, sensitive-area sites, policy reach and the relevant impact flags. In practice, that means agreeing which sites, materials, ecosystems and species are in scope before you start writing the disclosure.
What does the ESRS E4-2 workbook help me do?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is there to help you organise the datapoints, evidence and assurance checks. It is designed to support preparation rather than replace your own judgement or internal review.
How do I use the printable Library Card for ESRS E4-2?+−
The page says there is a printable Library Card in PDF format in the Download Centre. Use it as a quick reference while you gather data, check the assurance claims and build the draft disclosure.
What evidence should I keep ready for assurance on ESRS E4-2?+−
The page includes an evidence pack with five items and six assurance claims to verify, each framed around claim, risk and evidence. That means you should be able to show where each datapoint came from, how it was checked, and what supports the final draft.
What are the common mistakes to avoid when preparing ESRS E4-2?+−
The page has a section on common reporting gaps and mistakes, so it is meant to help you spot missing scope, weak traceability, incomplete site coverage or unclear scenario analysis inputs. A good use of that section is to compare your draft against the listed datapoints and evidence pack before sign-off.
How do I turn the ESRS E4-2 data into a draft disclosure?+−
The page includes a draft-output section with visualisation ideas, narrative starters and a content-index line. Use those to turn your collected datapoints into a structured draft, then check it against the evidence pack and assurance claims.
What should I ask the data owner for on ESRS E4-2?+−
Ask for the specific datapoints listed on the page, plus the underlying evidence that supports them. In practice, that means getting the policy details, site and supply-chain scope, impact flags, scenario analysis outputs and any traceability records needed for review.
How do I make ESRS E4-2 assurance-ready without overcomplicating it?+−
Use the page’s step-by-step preparation section, then test your draft against the six assurance claims and five-item evidence pack. That gives you a simple way to check whether the disclosure is supported, traceable and ready for reviewer questions.
Are there example disclosures for ESRS E4-2 I can learn from?+−
Yes. The page includes synthetic illustrative example disclosures, including a quantitative table, so you can see how the datapoints might be presented in a draft without treating the example as a real company report.
More questions this page can help with
ESRS E4-2 policy title and policy coverage: what exactly should I capture?How do I document ecosystem and species coverage for ESRS E4-2?What is meant by traceability controls in the ESRS E4-2 datapoint list?How should I record tracked materials and supply chain reach for ESRS E4-2?How do I handle sensitive-area sites and impacted sites in ESRS E4-2?What do the land use, ocean impact and deforestation flags mean for drafting ESRS E4-2?How should scenario analysis use, scenario type and scenario outputs be captured for ESRS E4-2?What is the buffer distance and buffer method datapoint in ESRS E4-2 used for?How do I use the from company reports table on the ESRS E4-2 page?What should go into the ESRS E4-2 evidence pack for assurance review?How do I use the visualisation ideas and narrative starters on the ESRS E4-2 page?What are the most common ESRS E4-2 reporting gaps the page warns about?
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