Nature Positive Corporate Assessment Guide for Financial Institutions 2025

CASE STUDY 5 Emirates National Bank of Dubai (ENBD) ENBD is adapting its current risk management approach to address nature risk by integrating the Kunming-Montreal GBF. The approach seeks to capture physical, transitional and broader macroeconomic risks that manifest as risks to clients, such as stranded assets, supply chain disruptions, and capital and profit reductions. To do this, ENBD engages with clients directly to gather primary data on their business’ interfaces with nature and support the transition towards nature-positive core operations. For example, in the shipping industry, ENBD works with shipping clients to understand their impact on protected environmental sites as well as the location of port facilities. In the agricultural sector, ENBD shares materiality assessment questionnaires with clients to better understand impacts and dependencies, and discuss adoption of regenerative agriculture practices. This direct client engagement informs discussions about how ENBD can support their clients to reduce impacts and mitigate risks affecting their dependencies. ENBD complements this assessment with analysis on regulatory shifts, changing standards and developments on key nature themes such as: –Impact on mandatory nature regulations such as CSRD, Nature Restoration Law, Biodiversity Net Gain –Impact on UN-protected habitats, Ramsar wetlands, nationally protected sites, protected sites beyond national jurisdictions such as BBNJ –Impact on Sustainable Development Goals (SDGs) 14 and 15 –Impact on pollution regulations Furthermore, ENBD has conducted materiality assessments on its portfolio to identify significant portfolio-level risks and has made strategic decisions to limit financing for palm oil, coal and arctic oil extraction. ENBD also assesses loans and investments using the Partnership for Biodiversity Accounting Financials (PBAF) methodology, measuring clients’ biodiversity footprints and deepening understanding of the impact of investments on biodiversity within the broader value chain. Emirates NBD nature risk approach Exclusionary policyKunming- Montreal impactNature risk assessmentSustainability tracking and reporting Is the financing dedicated to a restricted type of project?What is the project’s Kunming-Montreal and nature/biodiversity impact?How are nature risks assessed? How are nature risks and benefits evolving? Types of nature restrictions are checked, including: Does the project finance coal? Does the project finance palm oil? Does the project finance activities in an environmentally protected space (i.e. Ramsar, UN restricted site, site of scientific interest)? Does the project finance activities in a location of environmental degradation as graded by environmental impact assessment?Nature risks and benefits are tracked on an ongoing basis, including: Ongoing thematic reviews of nature risks for client and projects Ongoing reputational risk review of nature risks Ongoing tracking of Kunming Montreal protocol alignment Ongoing reporting and analysis of nature risks and benefits from financing Reporting through annual reporting channels, for example sustainable finance reports, annual ESG reportsNature risks are assessed in forums as well as through risk review, including: Assessment of nature risk exclusionary policies at group level Assessment from ESG team of restricted covenants and nature policies in country of operation and locality Nature risk assessment by risk and ESG team Approval of project at Sustainable Finance Forum Approval of project at ALCONature finance checklist is completed, including: Complete alignment to nature finance checklist and highlighted nature finance benefits Highlight alignment to UN SDGs, with focus on SDGs 13, 14, 15 Highlight any restricted environmental covenants or alignment to national biodiversity strategies and action plans in countries of operation Source: ENBD. Nature Positive: Corporate Assessment Guide for Financial Institutions 36