Today, 10 rights-holders and civil society organizations are publicly responding for the first time to the UN Environment Program (UNEP)’s decision to dismiss their complaint about its role in the controversial Taskforce on Nature-related Financial Disclosures (TNFD). The 39-page complaint was filed to UNEP’s Stakeholder Response Mechanism (SRM) on 24 October 2024. TNFD is a self-described ‘disclosure initiative’ on corporate reporting that has also been called ‘the next frontier in corporate greenwashing.’ UNEP co-founded the TNFD, serves on its stewardship council and actively promotes the TNFD in its advocacy, reports, programs and events. 

The 10 complainant organizations span five continents and include groups representing Indigenous Peoples, grassroots women, forest communities and the victims of mine disasters. It also includes groups working on international biodiversity negotiations, corporate accountability and ending the finance behind deforestation. 

In February 2025, UNEP dismissed the complaint with a single email and a link to a pamphlet for financial institutions. Complainants then spent months compiling a 20-page statement on UNEP’s handling of the complaint – agreed on by all 10 organizations and networks. They sent this privately to UNEP on 6 June with a call that UNEP: 1. Overturn its decision to dismiss the complaint and proceed with an investigation into UNEP’s role in the TNFD; and 2. Publish the Statement – in full – in its complaint database. As UNEP has not yet provided any substantive response, complainants are now publicly releasing the statement. 

The statement notes: 

“some complainant organizations are now considering that UNEP may constitute a direct threat to our work. A UN agency that promotes the right of corporations to write their own regulations, that ignores the victim-survivors of corporate environmental harms and elevates corporate groups accused of harm to leadership positions and that undercuts, and fails to communicate the minimum standards and duties for business and governments outlined in core international agreements such as the Escazu Agreement, relevant human rights law and the Kunming-Montreal Global Biodiversity Framework is not working in service of nature or environmental defenders.”

The TNFD is a taskforce of 40 corporations that make recommendations on how corporations should report on nature. It has never been disclosed who appointed taskforce members. At least 45% of TNFD members face serious environmental or human rights concerns – including legal cases, formal complaints or investor bans. Its convoluted and hard to understand ‘disclosure’ framework is a far cry from actual transparency. TNFD’s reporting baseline does not recommend that companies disclose their impacts on nature. Nor does it recommend that companies disclose complaints they face; allow communities to know if they are sourcing from or financing activities in their area; or disclose data in a way that can be independently verified. 

The June 2025 Complainant Statement is accessible here.

The original complaint to UNEP (24 October 2024) is accessible here.

Key points raised in the Statement: 

• UNEP’s dismissal of the complaint did not address any of the 11 key complaints raised.
• At times UNEP misrepresented the nature of the complaint, the outcome sought and ignored information provided. 
• The public summary of the complaint in the SRM database omitted the names of 8 of the 10 groups involved and failed to list gender as a key concern raised. 
• UNEP’s handling of the complaint met 0 of the 7 relevant criteria for effective grievance mechanisms advocated for by UN agencies. 
• It was inappropriate for UNEP to promote the TNFD while assessing the complaint – especially without any reference to criticism of it. 
• UNEP’s response suggests a failure to grasp basic concepts of good governance and rights-based approaches. 
• In dismissing the complaint, UNEP did not make any reference to its own complaint policy. The stated reasons for dismissing the complaint do not accord with its own policy which states that complaints should proceed unless ruled out by very specific ineligibility criteria – that do not apply in this case. 
• There is no impediment to UNEP investigating its own actions – irrespective of whether TNFD cooperates or not. UNEP can also formally request TNFD’s co-operation into an investigation. UNEP should investigate the actions of UNEP staff and leadership from the early conception of the TNFD. This should include, for example, its failure to do due diligence on corporations or to engage with rights-holders and civil society organizations publicly speaking out about the TNFD over a period of 18 months. UNEP’s own role on the TNFD includes co-founding the TNFD, serving on its stewardship council, being the executing agency on its seed grant and work on the TNFD in its advocacy, programs, research and events. 

Quotes: 

“UNEP’s decision to co-found and promote the TNFD taskforce likely didn’t arise from a single bad decision, but a thousand. Did no-one google the environmental or human rights record of companies like BlackRock, Anglo American, Suzano or HSBC? Did no one ask – why aren’t we lifting up the survivors of corporate environmental and human rights harms and their solutions, rather than the corporations that hurt them? An investigation into UNEP’s role in the TNFD scandal is desperately needed – not only to know what happened at UNEP, but how to fix it.”

– Shona Hawkes, Senior Advisor on Forests and Bank Accountability, Rainforest Action Network

“UNEP’s role in TNFD has extremely serious real-world consequences for communities that we work with, trying to defend their rights against corporations – including those appointed to the TNFD taskforce. Why is a UN agency standing on the side of multi-billion dollar corporations – rather than the communities harmed by them?”

– Ola Janus, Banks and Nature Lead, BankTrack  

“Indigenous peoples, local communities, grassroots women’s groups, youth and Afrodescendant communities have always been at the forefront of the fight to protect nature and to build a future where nature and people thrive. This work is resilient and enduring, surviving many challenges. UNEP’s failure to investigate its role in the TNFD scandal regrettably puts the UN agency tasked with protecting the environment on the side of the large corporations hostile to these efforts.” 

– Lim Li Ching, Coordinator, Biodiversity Programme, Third World Network

“If any government today announced that it would assemble a group of 40 corporations and ask them to write their own regulations, there would be uproar. Yet, this is exactly what UNEP is advocating for, by co-founding the TNFD taskforce and then promoting its recommendations as public policy. UNEP’s failure to investigate its own role in the TNFD scandal should be setting off alarm bells across the ESG community.”

– Danielle van Oijen, Programme Coordinator Forests, Milieudefensie (Friends of the Earth Netherlands)

“It is really concerning that UNEP is supporting the fox to guard the henhouse while dismissing complaints from civil society voices, who are warning about the conflict of interests.”

– Merel van der Mark, Forests & Finance Coalition.

“It’s not too late for UNEP to do the right thing and investigate how UNEP got it so terribly wrong in the TNFD case. UNEP’s own policy is that complaints should be investigated unless it meets very specific ineligibility criteria – it has a duty to find out what happened.”

– Tarcísio Feitosa da Silva, 2006 Goldman Prize Winner