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TAC Public Meeting September 2026 Paper 4c: Nature research – current reporting review draft report
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- Introduction
- Research questions
- Approach
- Tagging
- Analysis
- Findings
- Nature-related impacts and dependencies
- Nature-related risks and opportunities
- Environmental resources and ecosystem services
- Climate and nature nexus
- Scale
- Stakeholders
- Maturity
- Other findings
- Metrics & targets
- Different perspectives from AI and human analysis
- Summary conclusions
- Appendix 1: Full list of FTSE 100 entities as of 11 February 2026
Introduction
1This analysis was carried out as part of the TAC's research into the current state of nature-related disclosures in the UK, in advance of the International Sustainability Standards Board (ISSB) publishing an Exposure Draft of a Practice Statement on nature-related disclosures in October 2026.
2This research workstream (Workstream 2) undertook a review of current UK reporting practices for nature-related disclosures as seen in the annual reports and accounts of the FTSE 100. The findings from this review have been incorporated into the Research Findings Report, and presented in full in this report.
Research questions
3This analysis focuses on answering the following research questions:
- Location: Where are disclosures located?
- Frameworks:
- What, if any, frameworks are referred to?
- If the Taskforce on Nature-related Financial Disclosures (TNFD) is referred to, to what extent is reporting aligned to its framework?
- Impacts and dependencies:
- Does the reporting consider the entity's dependencies on nature?
- Does the reporting consider the impacts on nature that could lead to nature-related risks and opportunities?
- Risks and opportunities:
- What, if any, nature-related risks are reported? And what are the most commonly reported nature-related risks?
- What, if any, nature-related opportunities are reported? And what are the most commonly reported nature-related opportunities?
- Environmental assets and ecosystem services: What, if any, environmental assets and ecosystem services are recognised as material?
- Climate and nature nexus: Does nature-related reporting overlap with climate reporting?
- Scale: Is nature understood more in a global context or local/place-based context?
- Stakeholders: Which stakeholders are referenced in relation to nature?
- Maturity:
- How mature is reporting?
- Is any assurance provided on nature-related reporting?
Approach
Scope
4The constituents of the FTSE 100 change continuously. For the purposes of this research, the constituents are as of 11 February 2026, when this research commenced.
5In this research, individual entities are not identified by name but referred to by their sector (or, if relevant to the analysis, industry) as classified under SASB's Sustainable Industry Classification System (SICS). This classification system was selected because it is proprietary to the IFRS Foundation, and this research has been undertaken as part of the TAC's preparation for an IFRS Exposure Draft.
6The FTSE 100 entities for the purpose of this research, and their corresponding SASB SICS sector and industry, are listed in Appendix 1. A summary of SICS Sector and Industry coverage is shown in the table below. There are some instances where entities' operations cut across multiple sectors, and these have been catalogued. More commonly, there is overlap between industries within sectors, but given the large majority of this analysis is at the sector-level, these have been assigned to the best-fit industry.
| Sector | Industry | Number of entities |
|---|---|---|
| Consumer Goods | Total | 11 |
| Multiline and Specialty Retailers & Distributors | 6 | |
| Household & Personal Products | 2 | |
| Apparel, Accessories & Footwear | 1 | |
| Building Products & Furnishings | 1 | |
| Toys & Sporting Goods | 1 | |
| Extractives & Minerals Processing | Total | 9 |
| Metals & Mining | 6 | |
| Oil & Gas: Exploration & Production | 2 | |
| Oil & Gas: Refining & Marketing | 1 | |
| Financials | Total | 23 |
| Asset Management & Custody Activities | 10 | |
| Insurance | 7 | |
| Commercial Banks | 5 | |
| Security & Commodity Exchanges | 1 | |
| Food & Beverage | Total | 9 |
| Food Retailers & Distributors | 2 | |
| Non-Alcoholic Beverages | 2 | |
| Tobacco | 2 | |
| Alcoholic Beverages | 1 | |
| Processed Foods | 1 | |
| Restaurants | 1 | |
| Health Care | Total | 6 |
| Biotechnology & Pharmaceuticals | 4 | |
| Medical Equipment & Supplies | 2 | |
| Infrastructure | Total | 12 |
| Real Estate | 4 | |
| Home Builders | 3 | |
| Electric Utilities & Power Generators | 2 | |
| Water Utilities & Services | 2 | |
| Gas Utilities & Distributors | 1 | |
| Infrastructure/Extractives & Minerals Processing | Total | 1 |
| Electric Utilities & Power Generators/Metals & Mining | 1 | |
| Resource Transformation | Total | 11 |
| Industrial Machinery & Goods | 5 | |
| Aerospace & Defence | 3 | |
| Chemicals | 1 | |
| Containers & Packaging | 1 | |
| Electrical & Electronic Equipment | 1 | |
| Services | Total | 10 |
| Professional & Commercial Services | 4 | |
| Media & Entertainment | 3 | |
| Hotels & Lodging | 2 | |
| Casinos & Gaming | 1 | |
| Technology & Communications | Total | 5 |
| Telecommunication Services | 3 | |
| Internet Media & Services | 1 | |
| Software & IT Services | 1 | |
| Technology & Communications/Services | Total | 1 |
| Internet Media & Services/Media & Entertainment | 1 | |
| Transportation | Total | 2 |
| Airlines | 2 |
7This research considers only the annual reports and accounts (and no other published information) published by these entities for the financial year ending in 2025. At the time of completing this research, depending on the timing of each entity's financial year, this may not necessarily have been the most recent annual report published by the entity.
Tagging
8Every report was read in its entirety by staff (“reviewers”). Reports were “tagged”, allowing excerpts to be categorised under key words which aligned with the research questions detailed in paragraph 3.
9While reviewers endeavoured to be consistent with their interpretation of the key words, there is a level of subjectivity to the tagging process. Multiple reviewers were involved in reading the 100 reports, and each will have applied some judgement in applying the "tags".
10Where information was not clearly labelled or identified as pertaining to one of the "tags" (e.g. whether a matter was considered to be a 'nature-related risk'), the reviewers used their own interpretation to tag it as such. This is based on the understanding that if the entity is already producing and reporting on the information, they have developed an understanding of their relationship to nature which demonstrates readiness to report under a future framework even if they have not explicitly indicated this awareness themselves. For example, reporting that an entity has a dependency on water extraction which exposes it to water scarcity and extreme weather risks illustrates a grasp of the entity's nature-related risks, even if the entity has not explicitly identified these disclosures as nature-related dependencies and risks. Similarly, reviewers applied judgement to "tag" information about climate where this intersects with nature, for example extreme weather events worsened by climate change. This interconnection is explored further throughout the report, especially in the climate and nature nexus section (paragraphs 57 to 64).
Analysis
11The tagged excerpts were then analysed to produce the findings in this paper. An AI assistant (Microsoft Copilot) was trained as an analyst to help synthesise the data to assist in identifying key themes and to calculate statistics based on the tagged excerpts. However, it was not used to generate the write up of findings in this paper and findings derived from the AI output where manually validated against the primary dataset.
Findings
Location
Q: Where are disclosures located?
A: Findings show that nature-related disclosures in annual reports are found in multiple different locations across annual reports, leading to a fragmented approach, duplication and a lack of consistency.
12As noted in paragraph 7, this research looked only at the contents of the annual report and accounts and therefore is limited in its understanding of the location of disclosures across all documents published by entities. Many entities publish separate sustainability reports or statements, and/or sometimes separate nature reports or TNFD Statements. However, paragraph 60 of IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) requires entities to disclose their sustainability-related information as part of their general purpose financial reports (i.e. annual reports and accounts in the UK), and we can also view inclusion in the annual report as a proxy for assumed decision-usefulness for investors. That being said, all but one entity (in the Financials sector) in the FTSE 100 had some nature-related disclosure within their annual report.
13Most annual reports contained a distinct sustainability (or equivalent, e.g. corporate responsibility or ESG) report or section within the strategic report, containing disclosures on a broad range of topics. Often, nature was noted as a distinct category within these sections. However, it was also not uncommon to see nature considered only in relation to climate, for example, under the entity's Taskforce on Climate-Related Financial Disclosures (TCFD) report (see more in paragraph 42).
14Beyond dedicated sustainability sections, further nature-related disclosures were scattered across the strategic report and governance report. For example, throughout the Chief Executive's review, risk report, Sustainability Committee (or equivalent) report, and directors' remuneration report. Practice on where to place nature-related information lacked consistency, and also gave rise to a high level of duplication of information within reports, particularly between the sustainability report within the strategic report, and the Sustainability Committee report within the governance report.
1571 entities included nature-related considerations within their principal risks section, though this is most commonly related to physical climate risks such as disruptions to the supply chain due to extreme weather events.
Frameworks
Q: What, if any, frameworks are referred to?
A: Entities used a different frameworks and standards to report on nature-related matters, including the TNFD, the Corporate Sustainability Reporting Directive (CSRD) or the European Sustainability Reporting Standards (ESRS), and the SASB Standards. The use of these frameworks and standards was inconsistent, with many entities using all or part of one or more.
TNFD
Q: If TNFD is referred to, to what extent is reporting aligned to its framework?
A: Most reports which mention TNFD demonstrate, or at least state, intention to meaningfully apply the framework or fully align with it, though using the framework to produce financially material decision-useful information is less common.
16One third of the FTSE 100 entities reference the TNFD by name. Of that third, only a few entities mention TNFD in passing as a framework which they are aware of or monitoring, with the majority evidencing the application of TNFD's LEAP (Locate, Evaluate, Assess, Prepare) framework, if not substantial movement towards TNFD-alignment.
17Key language from the TNFD framework around the LEAP framework was found in 20 annual reports, while the phrase DIRO (Dependency, Impacts, Risks and Opportunities) was found in 22. This is representative of the entities who are making meaningful action towards TNFD-alignment either by completing LEAP and DIRO assessments, or going further to present full TNFD reports (either within the annual report itself, or signposting to a separate report).
18In some reports, DIRO assessments carried out within the LEAP framework are linked directly to financial effects. One Financials sector entity, for example, maps their credit exposure to sectors with meaningful nature-related DIROs. Another entity in the Food & Beverage sector states that carrying out a LEAP assessment supported the identification of both financial and impact-related risks as part of the double materiality assessment they had also carried out. However, even in reports where the link between nature-related DIROs and financial impact was referenced, there were no explicit links made to financial valuations following a DIRO or LEAP assessment.
19A small number of entities used the four pillars of TNFD—governance, strategy, risk management, and metrics and targets—explicitly to structure their nature-related disclosures. This was most common for entities where nature is evidently operationally important such as Water Utilities & Services entities and Food & Beverage entities reliant on agricultural supply chains.
20Reporting integrating TNFD and TCFD has been presented by a small number of entities, a further discussion on which can be found in the climate and nature nexus section (paragraphs 57 to 64).
21Some entities extended the use of core TNFD dependency and impact metrics beyond their own operations to the suppliers in their value chain.
22Overall, there is a relatively high level of recognition of the TNFD framework within the reports. These references generally go beyond general signalling and demonstrate some level of action towards using the assessment tools detailed within the framework, or even state intention to fully align with the framework. However, this is not necessarily translating into the creation and reporting of financially material, decision-useful nature-related financial disclosures.
CSRD and ESRS
2357 of the annual reports referenced CSRD or ESRS. These references were not restricted to explicit mentions of nature in relation to CSRD, since complying with CSRD would necessitate considering nature-related disclosures across ESRS E2 (Pollution), ESRS E3 (Water), ESRS E4 (Biodiversity and Ecosystems), and ESRS E5 (Resource Use and Circular Economy). However, where references to CSRD are vague within the annual reports, it is not possible to assess how thoroughly an entity may have considered nature-related topics.
24The majority of the 57 entities which referenced CSRD or ESRS are not providing full CSRD reports, but rather are mentioning a level of awareness of the development of the Directive, and/or that they are beginning to prepare for, or build readiness for, reporting under it. Four entities did state full compliance with CSRD within their annual report.
25The large majority of nature-related risks and opportunities identified under CSRD-aligned reporting were impact material rather than financially material.
26A number of entities within the FTSE 100 are either already reporting, or are expecting to report, under CSRD due to dual UK/EU listing or other eligibility. However, some entities which are not captured have still referenced or evidenced a double materiality assessment covering nature-related topics within their annual report. Double materiality assessments are a popular readiness tool for any nature-related reporting, to aid in their identification of nature-related dependencies, impacts, risks and opportunities. One Infrastructure entity, for example, noted that despite not being captured by or voluntarily adopting CSRD, they believe that a double materiality assessment helps to ensure that they report on the most important issues to their key stakeholders.
SASB
27Over a third of the entities referenced the use of the SASB Standards, but only seven evidenced that they had used SASB to understand nature-related topics. The extent of the use of SASB varies enormously. Some reports merely state awareness of relevant SASB Standards, while others state that SASB Standards have been used for reference in identifying relevant nature-related topics. Additionally, some reference the use of SASB Standards in a separate sustainability report outside of the annual report.
28The nature-related topics mentioned in relation to SASB Standards most commonly included water management and scarcity, and waste generation and management. It was more common to see cherry-picked metrics from SASB Standards referenced or utilised, as opposed to reporting against a complete SASB Standard, and without an explanation as to how or why those metrics were selected for use. In this way use of SASB Standards appears generally ad hoc.
29SASB is often being cited as a recognised user-oriented reporting framework, but less often being adopted as a wholesale framework for identifying and reporting material information about nature-related risks, dependencies, impacts or opportunities.
Nature-related impacts and dependencies
Impacts
Q: Does the reporting consider the impacts on nature that could lead to nature-related risks and opportunities?
A: Reporting on entities' impacts on nature is widespread, but evidencing causal pathways from impacts to nature-related risks and opportunities is far less common.
30Before beginning an analysis on nature-related dependencies, impacts, risks and opportunities, it should be noted that a low level of conceptual distinction between these terms was observed in their usage within the FTSE 100 reports. The relationship between these concepts was not clear and the terms were sometimes used interchangeably, and sometimes not explicitly used to flag disclosures of each category at all.
31Beyond this caveat, entities frequently report examples of their impacts on nature. These disclosures most commonly centre around waste and pollution, or less frequently but still often on land use including natural resource extraction, water usage, and habitat disturbance or loss. In most cases, reporting of an entity's impact on nature focuses on management strategies the entities have put in place, as opposed to details of the impact on nature. However, in one example, a Health Care entity identifies a specific pharmaceutical ingredient used in its products as its most material impact on nature due to its water polluting effects, and then also explains how the entity is using environmental risk assessments, discharge limits and monitoring to control this impact.
32Linking the entity's impact on nature to risks and opportunities to the business is carried out inconsistently. A lot of coverage of impacts ends at the point of discussing management of the impact. However, there is evidence of entities understanding that their impacts on nature can then create nature-related risks downstream. For example, one Food & Beverage entity identifies that single-use plastic packaging that is not collected for recycling in its downstream supply chain can pollute or damage nature, which then creates regulatory and reputational risks for the entity. There are also a number of entities who lay out a causal pathway from their own water usage (nature-related impact) to intensifying scarcity, to increased water costs (nature-related risk).
33Rarely, an explicit link between nature-related impacts and financial effects to the entity's prospects is then made. There are references, for example, to rising water costs due to increased scarcity following own or supply chain water usage from entities across multiple sectors, or regulatory costs due to fines from spills from Extractives & Minerals Processing entities. But overall, it is rare that any of the entities were able to clearly link nature-related impacts to financially material information.
34Where positive impacts are disclosed, these are usually within the category of 'avoided harms', such as restoration efforts or mitigations for negative impacts through the use of technology. On occasion, these impacts are then linked to opportunities for the entities through cost-saving efficiencies or reputational benefits.
Dependencies
Q: Does the reporting consider the entity's dependencies on nature?
A: Around half of the reports demonstrate some understanding of the entity's dependencies on nature. Amongst those that do, there is a broad range in the level of specificity of these disclosures.
35Around half of the FTSE 100 entities reported on nature-related dependencies, based on the reviewers' interpretation. The disclosure of dependencies correlates with entities whose own operations or supply chains rely directly on environmental resources and ecosystem services such as water or agricultural products.
36Dependencies on environmental resources such as specific bodies of water, natural resources or agricultural products are more commonly noted than ecosystem services. It is easier and more tangible for entities to identify direct inputs into operations or the supply chain, rather than the contextual conditions and processes that ecosystems provide that enable operations. In rare instances, entities were able to identify the ecological services that these resources rely on to exist (e.g. biodiverse ecosystems for soil health from Food & Beverage entities which rely on agricultural supply chains). However, within the reports themselves there is limited distinction between environmental resources and ecosystem services.
37The most common dependency is water. This is referred to in different ways across the value chain: as an ingredient in products, as an industrial input, as an agricultural input, as a cooling medium, as a receiving environment for treated wastewater, and as an enabler of product use by consumers. Water may be either a resource or a service (e.g. rainfall or as a regulating service for soil erosion and pollutants), although entities rarely distinguish between these use categories. However, many Food & Beverage and Water Utilities entities do note dependencies of both types.
38There is a wide range of disclosures of dependencies; from broad and vague references (e.g. an entity "depends on the natural environment to operate"), to detailing specific critical environmental resources and the connection of these resources to the ecosystem services they exist within and/or rely on, and even the interrelation of these dependencies with the entity's impact on nature. Entities which have undertaken a LEAP analysis under the TNFD framework tend to evidence more detailed dependency analysis. One Food & Beverage entity uses ENCORE, an online tool designed to help entities identify nature-related impacts and dependencies, to support their LEAP analysis. This allowed them to categorise their economic activities by level of dependency, and report that a specific percentage of their economic activities are associated with “high” or “very high" dependencies on nature.
39The large majority of disclosures of dependencies lack an evaluation of financial effects. The clearest examples of linking dependencies to financial materiality is where causal pathways are drawn from dependencies to risks. For example, one Health Care entity lays out a direct causation from water dependency to the risk of increasing levels of water stress, to a scenario analysis of water-supply interruption at two different time horizons quantified in a monetary value.
40Some entities also infer connections between dependencies and opportunities. For example, one Services entity begins by noting dependency on forests for paper production in its supply chain, and then consequently identifies an opportunity to diversify its sourcing to suppliers using sustainably managed forests.
Nature-related risks and opportunities
Risks
Q: What, if any, nature-related risks are reported? And what are the most commonly reported nature-related risks?
A: Reporting on nature-related risks is widespread, but is most commonly seen in physical climate risks such as extreme weather, with independent nature-related risks being disclosed far less often.
41Almost all FTSE 100 entities reported nature-related risks, with references noted across 96 annual reports. The four entities with no notable risk disclosures were all within the Financials sector, all falling under the Asset Management & Custody Activities industry.
42The most commonly reported nature-related risks relate to physical climate risks e.g. extreme weather risks including wildfires, drought and flooding. Indeed, this was often the only type of nature-related risk disclosure. This finding means that many entities understand their nature-related risks primarily through a climate-risk lens, rather than from a direct assessment of nature-related risks. This information is largely housed in the entity's TCFD disclosures. Further analysis on this can be found in the climate and nature nexus section (paragraphs 57 to 64).
43The most common topic for these climate-originated but nature-related risks is water. Multiple reports note water stress as the entities' most significant physical climate risk due to prevalence and trajectory, and note material financial effects from water stress to the entity's prospects.
44Financial valuation of risks is exceedingly rare. However, two clear examples of where entities have provided financial valuation of risks also come from water-related climate and nature nexus risks. One Health Care entity completed a financial valuation of risks within their TCFD disclosure, for both short- and long-term time horizons, in monetary value. Risks valued included extreme weather events (specifically floods and storms) and water stress and so fell within the climate and nature nexus. This was the clearest example observed of direct financial valuation of nature-related risks. One Food & Beverage entity's principal risk section offers financial quantification of the estimated increase of cost of water due to climate change, and states that this increase in operating and capital expenditure is financially material to the entity.
45There are fewer entities which explicitly reference nature-related risks independent of physical climate risks. However, where they do, these risks include:
- transition risks – including regulatory changes and changes in stakeholder expectations/market change;
- supply-chain risks – relatively common, especially in sectors such as Food & Beverage which often rely on agricultural supply chains;
- water risks - commonly noted in relation to climate, as discussed in paragraph 43 above, but also disclosed in regard to water scarcity and quality;
- waste risks – most commonly related to packaging, plastic pollution, and also sometimes to water; and
- biodiversity and ecosystem risks – less commonly disclosed but often linked to the entity's land use, particularly in the Extractives & Minerals Processing sector.
46As explored further in the scale section (paragraphs 65 to 71), risks were often disclosed on a site-level or asset-level basis, which appear to present more tangible risks than broader entity-level assessments.
Opportunities
Q: What, if any, nature-related opportunities are reported? And what are the most commonly reported nature-related opportunities?
A: The majority of reports contain disclosures of nature-related opportunities, even if not explicitly recognised as such. Most commonly these relate to product or service innovations.
47Two thirds of reports contained information about nature-related opportunities to some extent.
48The most common type of opportunity identified was product or service innovations. Opportunities of this kind were noted in over half of the reports, making it the most common category. These opportunities may relate to:
- the creation of products or services to support customers in facing nature-related risks, such as environmental analysis services or water management technology products, or assurance services for regulatory compliance.
- the creation of products or services to respond to customer demand for more 'environmentally friendly' options. Sustainable sourcing, for example, for agricultural supply chains for Food & Beverage entities, could be understood as part of this category. In the Financials sector, developing products such as green (or blue, in regard to water) bonds, nature-related investment frameworks, and nature solutions funds also fall into this category.
49Where linked to customer demand or revenue growth, these opportunities were identifiable as material. For example, one Resource Transformation entity identified the percentage increase in monetary value for the year-on-year revenue and profit for its environmental analysis services, citing increased demand for analysis of air and water quality, and increased demand to build sustainable food systems.
50Opportunities relating to waste were noted in 41 reports, often framed as action towards 'circularity'. Examples of entities using circularity to reduce their own costs by reducing waste include use of by-products created by their own operations in different processes, and the use of biogas and biosolids as fuels. Other examples see entities providing products and services which allow customers to avoid waste, such as operating rental business models, and retailing refurbished or recycled products. Again, these opportunities were identifiable as material when tied to increased consumer demand for more environmentally-friendly, waste-conscious choices, or creating efficiencies within the entities' own operations.
51Other opportunities identified were focussed on reputational benefit with less tangible financial materiality. Some of the reporting on nature-related conservation or restoration programmes carried out in partnership with charities and Non-Governmental Organisations (NGOs) were recorded as opportunities in this analysis for this reason.
52In general, opportunities were referenced in narrative and were not commonly quantified. The sector with the clearest translation of opportunities into financial value was Financials, with clear monetary values placed against nature-related products.
53In fact, opportunities were not often explicitly referenced as such within the reporting. For this reason, there is some blurring between risk mitigation and opportunity disclosure. For example, an entity which is exposed to water stress risks may disclose a water replenishment project without clarifying if this is seen as a risk mitigation or as an opportunity due to the improvement in operational efficiency it may represent.
54Further to this, sometimes a single nature-related topic presents both risks and opportunities to an entity. For example, one Resource Transformation entity specialising in industrial machinery listed extreme weather as both a physical risk and an opportunity, since it could lead to increased demand for some of its products and services.
Environmental resources and ecosystem services
Q: What, if any, environmental assets and ecosystem services are recognised as material?
A: It is difficult to evaluate whether information about environmental assets/ resources and ecosystem services within the reports is assessed to be material.
55Identification of the environmental resources (the term now preferred by the ISSB in place of environmental assets) and ecosystem services important to the FTSE 100 entities has been discussed above in relation to the identification of dependencies, impacts, risks and opportunities.
56As covered in paragraph 36, within the reports there is limited distinction between environmental resources and ecosystem services by the entities. The recognition of the use of resources and ecosystem services is generally implicit in the reporting on risks and opportunities, rather than separately identified within the reports. Findings here would suggest that entities are not prepared to separately identify and assess the importance of the environmental resources and ecosystem services that they use in their operations and supply chains.
Climate and nature nexus
Q: Does nature-related reporting overlap with climate reporting?
A: Yes, to a large extent, with reporting on nature often only present due to its relevance to climate reporting.
57There is evidence across 95 of the reports that entities have recognised a nexus between climate and nature reporting. References to this nexus may include explicit integration of climate and nature reporting, or, more commonly, instances where nature is a necessary facet of climate reporting—for example within topics such as water or pollution—without the conscious goal of producing integrated nature and climate reporting.
58There is a spectrum to the types of overlap between nature and climate reporting shown in the reports. On one end, there is presentational overlap where nature and climate information is simply found on the same page or in the same section under a general “sustainability” heading, but the connection is not explored at any further depth. Then there is conceptual overlap, where interconnections between climate and nature are explicitly recognised at the general level, but with no further investigation of specifics. This is usually a general statement noting that "climate change and nature loss are linked", for example. Beyond this, there are examples of substantive overlap where the mechanism linking climate and nature is explained (e.g. climate change increasing water stress, or extreme weather impacting agricultural yields). Less commonly, on the far end of this spectrum, is an integrated approach where the interactions between climate and nature are fully recognised and the approach to managing their relationship to the entity is holistic. This is seen in the most successful joint TNFD/TCFD reports, and, very rarely, in holistic scenario analysis (seen in one Consumer Goods entity's report).
59The most common type of interaction between nature and climate information is climate-led. This is when climate has an effect on nature—primarily, the impact of climate change on water, ecosystems, or natural resources. Most often, this centres around water-related risks, such as drought and flooding creating water stress or worsening water quality. These types of disclosure fall under the "substantive overlap” category, but are often implicit. However, there are some examples of entities explicitly describing the chain of reactions from climate change to nature loss. These types of disclosures are where the financial materiality of the climate and nature nexus is clearest (see the examples in paragraph 44).
60Aside from water, the other most common interconnections referenced relate to agriculture in the supply chain, where increasingly extreme weather due to climate change presents significant risks to yields, and resultingly to upstream supply chain costs to Food & Beverage and some Consumer Goods entities. Recognition of this nexus does lead to integrated management strategies in some reports, where this risk is then linked to diversified sourcing strategies or investment in drought-resistant crops and regenerative agriculture technologies within the supply chain.
61Where, rarely, the interconnection is understood in the other direction—that is, nature impacting climate—this tends to be in relation to climate change mitigation activities being carried out or supported by the entity, such as afforestation efforts.
62Reporting more often focuses on synergies between nature and climate, than on trade-offs. The most commonly and clearly identified synergies include: forests and other ecosystems providing carbon sequestration and storage; circularity reducing demand for raw natural resources; and waste. Meanwhile evidence that trade-offs are understood is rare, though in one example in an Infrastructure entity's report, the Chief Sustainability Officer notes that methods for tackling climate change may be unsustainable for people or nature, though this is not explained further.
63Even within reports which integrate nature and climate information, for example joint TNFD/TCFD reports, there is a range of maturity. The less mature of these reports will simply display nature and climate information side-by-side, whereas the more mature will note causal pathways, feedback loops, and joint strategies and targets, as well as linking these disclosures clearly to financial effects.
64The nexus is most commonly noted in relation to risks and impacts, followed by opportunities. Explicitly identified climate and nature nexus dependencies are very uncommon.
Scale
Q: Is nature understood more in a global context or local/place-based context?
A: Nature is most often reported on with a local/place-based framing, though research identified multiple levels of scale, which are sometimes used in conjunction with one another.
65References to specific locations were noted far more often than references to nature on a broader scale. This is with the caveat of potential methodological bias as it was easier to identify references to specific named places, whereas general references to nature on a broad scale may not have been noticed and tagged under the scale category during the analysis process.
66However, the finding that nature is more often referred to on a local scale is a logical one, as nature is necessarily vested within a physical geographical place. Ecosystems vary in size but are tied to their location. As such, reporting on nature necessitates recognition of place.
67A case study approach to reporting on nature was common within the reports, with examples pulled out focusing on specific sites or assets. Arguably this is helpful in presenting a compelling narrative within the report, which helps to ground nature disclosures in tangible, real-world examples that also allow the details of the dependencies, impacts, risks and opportunities, strategies and stakeholders related to a specific site/asset to be illustrated.
68However, presenting individual case studies alone, as some reports did, does not help to draw a picture of the overall entity-level importance of nature to an entity. Therefore, more mature reporting combined case studies with disclosures at multiple other scales to provide a holistic understanding of the importance of nature to the entity. Different scale levels identified included:
- named site or asset level;
- named region/country level or named water basin level;
- landscape or ecosystem e.g. “forests”, “wetlands”, “water basins”;
- value-chain, which in itself may be made up of disclosures at different scales;
- portfolio or financing, in reporting from the Financials sector; and
- global or entity-level, including all aggregated information.
69Disclosures on different scales are suitable in different instances. For example, disclosures made at named region/country or water basin level are helpful for understanding the social and political context of the nature-related activities. In some reports, disclosures at different scale levels are combined to create a multi-scale understanding of the entity's relationship to nature.
70The FTSE 100 entities are more advanced in recognising local exposure and impact of nature than explaining how local matters translate to entity-level risks or opportunities. A notable impact of this is that it makes defining entity-level financial relevance of nature harder, which may lead to less decision-useful information in the annual report. However, one Financials entity makes the point that top-down entity-level data does not include context about asset or supply chain exposures, which may lead to an understatement of these exposures. Therefore, they argue that there is a risk of over-aggregation in nature-related reporting.
71Asset or location level data may be more useful if its relevance is illustrated and explained. Where a case study approach is currently common, these examples often lack the identification of significant dependencies, impacts, risks and opportunities. Adding this information to the case-study style disclosures may help in the provision of decision-useful information.
Stakeholders
Q: Which stakeholders are referenced in relation to nature?
A: A range of stakeholders were referenced, most commonly in relation to the value-chain, especially suppliers. Notably, investors were not often referenced.
72The majority of reports reference stakeholders in relation to nature.
73Most common were broad references to the entire value-chain, with reference to suppliers which were in particular evident across the majority of sectors (especially Consumer Goods, Food & Beverage, Infrastructure and Resource Transformation). Entities which rely on farmers within their upstream value chain were particularly notable for coverage of stakeholder engagement and value chain disclosure around nature, often linking stakeholders to water stewardship, biodiversity, and soil health and referencing sustainable farming initiatives and community projects including supporting educational projects around regenerative agriculture. The entities generally displayed a good level of awareness about the connection between the stakeholders in their value chain and their nature-related dependencies. In select reports, information about stakeholders in the supply chain became notably extensive and was the primary focus of the nature-related disclosures.
74Other referenced stakeholders include:
- employees and workforce – often referenced as agents of the entity's nature-related strategy, for example in relation to volunteering for nature-related programmes, training for disaster responses (including extreme weather events);
- customers and consumers as downstream value-chain stakeholders, often referenced in relation to waste. In some more developed examples, these references included descriptions of consumer behaviour change strategies, designed to encourage recycling or the choice of more sustainable products that tie back to nature-related opportunities;
- local communities – particularly in relation to the entity's nature-related impacts such as water access and scarcity, as well as land use;
- NGOs – often tied to references of communities, for example, where the entity has partnered with charities to implement programmes supporting local communities' access to nature, such as through restoration and conservation. On occasion, NGOs also appeared as partners for programmes supporting regenerative agriculture in the value chain;
- regulators and governments – referenced occasionally in relation to transition risks, mostly in heavily regulated sectors e.g. Utilities industries under the Infrastructure sector, and the Financials sector;
- investors – less frequently referenced, primarily in Financials sector reports in relation to capital allocation. It is notable that while the annual report has, for all intents and purposes, been written for the use of primary users, their interests are not often referenced in relation to nature (although this may be common across other areas of sustainability reporting); and
- technical experts – e.g. academic partners, data providers. Less often referenced, but occasionally noted as supporters in producing, assessing and monitoring decision-useful nature-related information.
75More developed disclosures move beyond identifying stakeholders, to explaining the strategy behind engagement and how this engagement has informed nature-related strategies, or supported risk or opportunity management, in turn. For example, one Infrastructure entity reported the creation of an Independent Advisory Panel consisting of representatives from NGOs representing different community groups and interests for the purpose of improving performance transparency, and then detailed how the Panel's input led to the enhancement of their Storm Overflow Map by adding details of planned and completed investments for each overflow.
76As discussed above in the section on scale (paragraphs 65 to 71), nature is most commonly and arguably best understood as place-based—and so are people and societies. Therefore, it makes sense that there are strong ties between the management of nature and the management of stakeholders, and this is evident in the reports.
Maturity
Previous reporting
Q: How mature is reporting?
A: Maturity could be understood through a number of perspectives, and this is considered throughout the research. However, using previous reporting as an indicator for maturity since it demonstrates year-on-year disclosure, under half of the reports evidenced that they have been carrying nature-related reporting for multiple years.
7741 of the FTSE 100 entities indicated that they had completed prior nature-related reporting, assessment, or target-setting and tracking in their annual reports.
78Evidence of previous reporting seems highly correlated to the level of dependency within the entities' value chains; for example Food & Beverages and Consumer Goods entities, due to their agricultural supply chains; and Extractives & Minerals Processing and Resource Transformation entities, due to reliance on natural resources within physical landscapes. Financials entities, meanwhile, very rarely demonstrated previous nature-related reporting.
79The earliest multi-year metrics go back to 2017, from a Food & Beverage entity, providing eight years of reporting against operational waste and water withdrawal baselines.
80One Extractives & Minerals Processing entity related previous nature-related reporting to their use of the TNFD framework, noting progress against a water recycling target and stating that they will conduct a gap assessment for water reporting against TNFD.
81The most common types of metrics and targets evidencing previous reporting were water and waste, appearing within 29 and 33 reports respectively.
Assurance
Q: Is any assurance provided on nature-related reporting?
A: There is evidence in some reports of limited assurance being carried out over some nature-related information by external assurers.
8221 FTSE 100 entities indicated that they had externally assured nature-related information, either by directly noting the assurance of stated data or by referencing a separate, assured, sustainability report.
83Assurance was generally limited, and was generally over selected (usually operational) metrics rather than wholesale. Where frameworks were identified, references were to ISAE 3000 or ISAE (UK) 3000.
84The most commonly assured data related to water, such as metrics on water use, discharge and recycling. It is understandable that water would be a popular choice for assurance given it is quantitative, easy to define scope within operational boundaries, and subject to higher levels of regulation. Similarly, metrics on waste and recycling were common. By contrast, disclosures around biodiversity and ecosystems were far less commonly assured (although it should be noted that they were also less often disclosed in the first place), perhaps due to added complexity around boundaries.
Other findings
Strategy
85While nature-related strategies (as identified by the reviewers, as opposed to explicitly identified by the entity) are widely reported across the FTSE 100, the primary focus of this is impact management rather than a fully articulated approach to financial evaluation of risk and opportunity management.
86The strategies noted largely focus on avoiding or mitigating impacts, such as reducing waste and pollution, improving water stewardship, avoiding the over-exploitation of environmental resources, and conserving and restoring habitats. While these impacts may lead to risks, this is not often clearly linked (as discussed in paragraph 32), and as such strategies do not go beyond managing the impact the entity has on nature, rather than considering management of nature-related risks or opportunities on the entity.
87Nature-related strategies are most commonly embedded within broader sustainability sections, with dedicated nature strategies appearing much less commonly. Examples do exist, however one Food & Beverage entity presents a comprehensive strategy on water alone covering its operations, supply chain, communities and advocacy, with the stated aim of enabling commercial resilience and growth.
88There are further examples of nature-related strategies explicitly aligned with core business model and growth strategies. For example, “circular” product design to avoid waste was detailed by one Resource Transformation entity as a long-term cost saving strategy. Another Consumer Goods entity integrates circularity into their product design strategy, as does a different Resource Transformation entity with resource efficiency.
89Links between nature-related strategies and financial quantification were found in some reports. One Consumer Goods entity, for example, reports on the money invested in its sustainable sourcing strategy, nature fund commitments and expenditure against this commitment. The Food & Beverage entity mentioned in paragraph 87 provides a commitment in billions of US dollars against the aforementioned water strategy (in conjunction with their emissions reduction strategy).
90Nature-related scenario analysis is uncommon. Only a small number of reports evidence any, and those that were seen included examples of climate scenario analysis with nature-related considerations in their assessment of climate physical risks meaning even fewer were dedicated nature scenarios. Of those that were seen, water tended to be the focus (see paragraph 39).
Governance
91Three-quarters of the reports include information on the governance processes, controls, and procedures that the entity uses to monitor, manage, and oversee nature-related risks and opportunities. This suggests that the majority of the FTSE 100 entities are integrating nature-related matters into their governance processes, though the level of disclosure about how this governance is being carried out is highly variable and ranges from broad statements around the responsibilities of the Board or Committees, through to evidence of accountability and controls, and links to remuneration, strategy and risk management.
92Governance of nature-related matters is generally embedded within broader sustainability or ESG structures, and/or through risk structures, rather than through structures dedicated to nature alone (though there is some evidence of dedicated forums, particularly within the Food & Beverage sector). A dedicated Sustainability/ESG Committee at Board level was evidenced in a third of the reports, while at Executive management level the number falls to six.
93Often, where a Sustainability/ESG Committee is pointed to, there is a low level of information about how nature factors into the Committee's work alongside climate while nature may be mentioned alongside climate as an area of responsibility, it is rare to see the distinction or differences in management being drawn out.
94Active oversight at the Board level (through receiving updates on nature-related matters, reviewing and approving nature-related strategies, and reviewing and monitoring risks, for example) was identified in a significant number of reports around a third of the FTSE 100.
95A minority of reports connect nature-related matters to enterprise risk management structures, for example, through Board reviews of risk registers, or Committee oversight of principal risks.
96Reporting around governance was rarely explicitly linked to nature-related strategy, dependencies, impacts, risks and opportunities, largely as it tended to sit separately in the governance, and sometimes remuneration, reports rather than in the strategic report. However, some entities did explain, within the governance report, the Board and/or Committees roles in overseeing and managing the entity's nature-related strategies, dependencies, impacts, risks and opportunities e.g. by reviewing TNFD LEAP assessments, approving strategies, or by noting defined responsibilities for monitoring nature-related risks and opportunities.
97There are a small number of clear examples of the effect of Board intervention, evidencing the efficacy of governance structures. For example, one Infrastructure entity details a situation where the Board was provided with data regarding the entity's pollution, and following scrutiny a revised pollution strategy was created and backed with multi-million pounds investment and operational resourcing, which is now subject to ongoing monitoring by the Board.
98In some relevant sectors, operational governance due to standards and regulations is evidenced. While important disclosures, these are operational controls as opposed to evidence of strategic integration of nature into the entity's governance structure.
9920 entities detailed the frequency of Board or management reporting on nature-related matters.
10016 entities disclosed that they have linked nature-related targets to Executive remuneration and incentives, across a broad range of sectors. These are generally tied to nature-related impacts. Examples include a Food & Beverage entity linking food waste reduction to 5% of the annual bonus plan for Executives and senior management. They reported that progress is reviewed at each meeting of their Corporate Responsibility Committee and noted that controls and dashboards had been developed to improve the data.
Metrics & targets
101Nature-related target-setting was identified in over two thirds of the reports.
102Consistent with the finding that strategy disclosures were largely impact-focussed, target-setting generally focussed on operational impacts. This includes, for example, quantified water withdrawal, waste generation, deforestation or pollution incidents. As such, sectors with less direct operational impacts, such as Financials and Technology & Communications, tend to report fewer nature-related targets.
103Direct linkage of targets to nature-related risks and opportunities was less common, but still evidenced across multiple reports. These included risk reduction targets around, for example, water stress, pollution exposure, and reliance on scarce natural resources. Examples of opportunity targets seen included targets on resource efficiency, nature-related green finance investments, and ecosystem restoration.
104The most common nature-related topic on which targets are set is water. While some of these focus solely on total aggregated volume of water, for example, withdrawn/consumed, replenished, reduction in leaks, or recycled, there were other examples of target-setting taking into consideration geographical context – in particular, differentiating between levels of water stress across impacted sites. Other common topics for target-setting included biodiversity (including biodiversity net gain for those in mandated industries), deforestation, and waste.
105Only a small number of the targets identified included baseline data, which may affect the decision-usefulness of the disclosure.
Different perspectives from AI and human analysis
106One interesting finding from the research process itself has been the different perspectives formed by the AI assistant and the reviewers respectively.
107While the reviewers read the entire annual report from front to back, the AI assistant (CoPilot) was provided with spreadsheets containing tagged excerpts on specific themes (e.g. all quotes evidencing the disclosure of risks) and asked to complete an analysis of the quotes against the relevant research question. As such the materials being assessed by reviewers versus AI were different in both substance and format. However, ultimately, the information analysed by both was the same: all relevant information to nature-related disclosures across the FTSE 100 annual reports.
108Despite this, there was a notable difference in subjective opinion of the reports formed across the reviewers compared to the AI assistant. Notably, the AI assistant consistently flagged specific reports as examples of the most mature practice across the different themes it analysed. A number of these same reports had been noted by reviewers as difficult to read due to the extent and density of the information provided. Having noted this pattern, at the end of the AI analysis process it was asked to identify the entities most commonly identified as having good practice with nature-related disclosures. Of the five entities it returned as “consistently strong”, two had been identified by the team as the most difficult reports to read and analyse, frequently leaving reviewers with a lack of certainty around the materiality and decision-usefulness of the information provided.
109It should be noted that other reports included by the AI assistant within its "top five” also included examples noted positively by the reviewers. What these reports held in common was the extent of their reporting, though some read well to the human eye and others read confusingly.
110While anecdotal and based only on one use case from one AI assistant, from this it might be inferred that AI assistants have a preference for quantity of data over anything else, including, arguably, quality. This could have important implications for the way that nature-related reporting is factored into decision-making by primary users, should the primary users employ the use of AI assistants in their assessment of entity reports—and particularly if AI is used to form subjective judgements on the quality or maturity of the disclosures. It appears, in this instance at least, that AI may judge coverage positively without necessarily discerning the value of concise, decision-useful reporting. This may also increase the risk of obscuring material information, should entities aim to simply report the most information possible to suit the preferences of AI.
Summary conclusions
111.1Nature-related information is widespread in the FTSE 100's annual reports, with all but one of the reports demonstrating some nature-related disclosure.
111.2The financial materiality of nature-related information is not generally clear, reducing the decision-usefulness of these disclosures for primary users. Reporting focuses primarily on impacts and strategies that are focussed on operational activities and metrics. It is less common to see clear links from identified impacts on nature into risks and opportunities. Even when risks and opportunities are identified, causal links between them and their financial effects are uncommon though examples do exist.
111.3The way nature-related information is presented lacks consistency and comparability. A number of different frameworks (TNFD, CSRD, SASB) have been used, sometimes in tandem, by subsections of the FTSE 100. The location of these disclosures, even only looking within the annual report, is fragmented and also often duplicated, making it hard for users to draw out key comparable disclosures even within the same sectors or industries.
111.4Nature is primarily viewed through a climate lens, with the most common type of nature-related risks being identified being physical climate-related risks which implicate nature, such as extreme weather events. This relationship between climate and nature is largely one-directional.
111.5Reporting on some nature-related topics is more developed than others. Water is by far the most commonly reported nature-related topic and consistently emerged as the topic of the most mature disclosures through a number of lenses.
Appendix 1: Full list of FTSE 100 entities as of 11 February 2026
| Entity name | Market cap (m) | SASB SICS sector | SASB SICS industry |
|---|---|---|---|
| 3i GROUP PLC | 33,722.86 | Financials | Asset Management & Custody Activities |
| ADMIRAL GROUP PLC | 8,398.87 | Financials | Insurance |
| AIRTEL AFRICA PLC | 12,251.79 | Technology & Communications | Telecommunication Services |
| ALLIANCE WITAN PLC | 4,834.47 | Financials | Asset Management & Custody Activities |
| ANGLO AMERICAN PLC | 42,185.98 | Extractives & Minerals Processing | Metals & Mining |
| ANTOFAGASTA PLC | 35,964.05 | Extractives & Minerals Processing | Metals & Mining |
| ASHTEAD GROUP PLC | 20,746.07 | Resource Transformation | Industrial Machinery & Goods |
| ASSOCIATED BRITISH FOODS PLC | 13,890.07 | Food & Beverage | Processed Foods |
| ASTRAZENECA PLC | 219,675.79 | Health Care | Biotechnology & Pharmaceuticals |
| AUTOTRADER GROUP PLC | 4,010.40 | Technology & Communications / Services | Internet Media & Services / Media & Entertainment |
| AVIVA PLC | 19,110.86 | Financials | Insurance |
| BABCOCK INTERNATIONAL GROUP PLC | 6,812.24 | Services | Professional & Commercial Services |
| BAE SYSTEMS PLC | 57,709.16 | Resource Transformation | Aerospace & defence |
| BARCLAYS PLC | 65,541.43 | Financials | Commercial Banks |
| BARRATT REDROW PLC | 5,535.53 | Infrastructure | Home Builders |
| BEAZLEY PLC | 7,367.98 | Financials | Insurance |
| BERKELEY GROUP HOLDINGS (THE) PLC | 4,041.04 | Infrastructure | Home Builders |
| BP PLC | 70,391.05 | Extractives & Minerals Processing | Oil & Gas - Exploration & Production |
| BRITISH AMERICAN TOBACCO PLC | 95,096.60 | Food & Beverage | Tobacco |
| BRITISH LAND CO PLC | 4,105.49 | Infrastructure | Real Estate |
| BT GROUP PLC | 19,835.58 | Technology & Communications | Telecommunication Services |
| BUNZL PLC | 7,022.42 | Consumer Goods | Multiline and Specialty Retailers & Distributors |
| BURBERRY GROUP PLC | 4,387.88 | Consumer Goods | Apparel, Accessories & Footwear |
| CENTRICA PLC | 8,783.78 | Infrastructure | Gas Utilities & Distributors |
| COCA-COLA EUROPACIFIC PARTNERS PLC | 31,795.65 | Food & Beverage | Non-Alcoholic Beverages |
| COCA-COLA HBC AG | 16,278.73 | Food & Beverage | Non-Alcoholic Beverages |
| COMPASS GROUP PLC | 35,760.06 | Food & Beverage | Restaurants |
| CONVATEC GROUP PLC | 4,378.87 | Health Care | Medical Equipment & Supplies |
| CRODA INTERNATIONAL PLC | 4,469.73 | Resource Transformation | Chemicals |
| DCC PLC | 4,231.86 | Extractives & Minerals Processing | Oil & Gas - Refining & Marketing |
| DIAGEO PLC | 40,387.60 | Food & Beverage | Alcoholic Beverages |
| DIPLOMA PLC | 7,414.32 | Consumer Goods | Multiline and Specialty Retailers & Distributors |
| EASYJET PLC | 3,647.54 | Transportation | Airlines |
| ENDEAVOUR MINING PLC | 10,681.04 | Extractives & Minerals Processing | Metals & Mining |
| ENTAIN PLC | 4,014.15 | Services | Casinos & Gaming |
| EXPERIAN PLC | 22,668.21 | Services | Professional & Commercial Services |
| F&C INVESTMENT TRUST PLC | 5,998.42 | Financials | Asset Management & Custody Activities |
| FRESNILLO PLC | 28,001.96 | Extractives & Minerals Processing | Metals & Mining |
| GAMES WORKSHOP GROUP PLC | 5,600.90 | Consumer Goods | Toys & Sporting Goods |
| GLENCORE PLC | 58,260.17 | Extractives & Minerals Processing | Metals & Mining |
| GSK PLC | 88,369.51 | Health Care | Biotechnology & Pharmaceuticals |
| HALEON PLC | 35,662.81 | Health Care | Biotechnology & Pharmaceuticals |
| HALMA PLC | 13,765.94 | Resource Transformation | Electrical & Electronic Equipment |
| HIKMA PHARMACEUTICALS PLC | 3,439.24 | Health Care | Biotechnology & Pharmaceuticals |
| HISCOX LD | 4,726.67 | Financials | Insurance |
| HOWDEN JOINERY GROUP PLC | 4,665.37 | Consumer Goods | Building Products & Furnishings |
| HSBC HLDGS PLC | 224,308.63 | Financials | Commercial Banks |
| ICG PLC | 4,935.07 | Financials | Asset Management & Custody Activities |
| IMI PLC | 7,044.67 | Resource Transformation | Industrial Machinery & Goods |
| IMPERIAL BRANDS PLC | 25,811.21 | Food & Beverage | Tobacco |
| INFORMA PLC | 10,927.68 | Services | Media & Entertainment |
| INTERCONTINENTAL HOTELS GROUP PLC | 16,213.00 | Services | Hotels & Lodging |
| INTERTEK GROUP PLC | 6,997.74 | Services | Professional & Commercial Services |
| INTL CONSOLIDATED AIRLINES GROUP SA | 19,922.22 | Transportation | Airlines |
| JD SPORTS FASHION PLC | 4,003.56 | Consumer Goods | Multiline and Specialty Retailers & Distributors |
| KINGFISHER PLC | 5,980.60 | Consumer Goods | Multiline and Specialty Retailers & Distributors |
| LAND SECURITIES GROUP PLC | 4,898.58 | Infrastructure | Real Estate |
| LEGAL & GENERAL GROUP PLC | 15,144.43 | Financials | Insurance |
| LLOYDS BANKING GROUP PLC | 60,607.62 | Financials | Commercial Banks |
| LONDON STOCK EXCHANGE GROUP PLC | 37,261.53 | Financials | Security & Commodity Exchanges |
| LONDONMETRIC PROPERTY PLC | 4,698.19 | Infrastructure | Real Estate |
| M&G PLC | 7,468.85 | Financials | Asset Management & Custody Activities |
| MARKS & SPENCER GROUP PLC | 7,856.49 | Consumer Goods | Multiline and Specialty Retailers & Distributors |
| MELROSE INDUSTRIES PLC | 8,052.09 | Resource Transformation | Aerospace & defence |
| METLEN ENERGY & METALS PLC | 4,473.68 | Infrastructure / Extractives & Minerals Processing | Electric Utilities & Power Generators / Metals & Mining |
| MONDI PLC | 4,133.39 | Resource Transformation | Containers & Packaging |
| NATIONAL GRID PLC | 64,229.08 | Infrastructure | Electric Utilities & Power Generators |
| NATWEST GROUP PLC | 48,309.66 | Financials | Commercial Banks |
| NEXT PLC | 15,613.11 | Consumer Goods | Multiline and Specialty Retailers & Distributors |
| PEARSON PLC | 5,738.14 | Services | Media & Entertainment |
| PERSHING SQUARE HOLDINGS LTD | 8,114.96 | Financials | Asset Management & Custody Activities |
| PERSIMMON PLC | 4,595.80 | Infrastructure | Home Builders |
| POLAR CAPITAL TECHNOLOGY TRUST PLC | 5,548.63 | Financials | Asset Management & Custody Activities |
| PRUDENTIAL PLC | 29,745.16 | Financials | Insurance |
| RECKITT BENCKISER GROUP PLC | 40,722.63 | Consumer Goods | Household & Personal Products |
| RELX PLC | 38,955.61 | Services | Media & Entertainment |
| RENTOKIL INITIAL PLC | 11,902.70 | Services | Professional & Commercial Services |
| RIGHTMOVE PLC | 3,381.81 | Technology & Communications | Internet Media & Services |
| RIO TINTO PLC | 88,854.50 | Extractives & Minerals Processing | Metals & Mining |
| ROLLS-ROYCE HOLDINGS PLC | 104,837.41 | Resource Transformation | Aerospace & defence |
| SAINSBURY(J) PLC | 7,646.51 | Food & Beverage | Food Retailers & Distributors |
| SCHRODERS PLC | 7,525.24 | Financials | Asset Management & Custody Activities |
| SCOTTISH MORTGAGE INV TST PLC | 13,361.77 | Financials | Asset Management & Custody Activities |
| SEGRO PLC | 10,327.17 | Infrastructure | Real Estate |
| SEVERN TRENT PLC | 9,068.77 | Infrastructure | Water Utilities & Services |
| SHELL PLC | 160,892.35 | Extractives & Minerals Processing | Oil & Gas - Exploration & Production |
| SMITH & NEPHEW PLC | 10,937.08 | Health Care | Medical Equipment & Supplies |
| SMITHS GROUP PLC | 8,192.98 | Resource Transformation | Industrial Machinery & Goods |
| SPIRAX GROUP PLC | 4,946.35 | Resource Transformation | Industrial Machinery & Goods |
| SSE PLC | 30,909.68 | Infrastructure | Electric Utilities & Power Generators |
| ST. JAMES'S PLACE PLC | 7,638.64 | Financials | Asset Management & Custody Activities |
| STANDARD CHARTERED PLC | 40,343.78 | Financials | Commercial Banks |
| STANDARD LIFE PLC | 7,365.98 | Financials | Insurance |
| TESCO PLC | 29,269.68 | Food & Beverage | Food Retailers & Distributors |
| THE SAGE GROUP PLC | 7,979.50 | Technology & Communications | Software & IT Services |
| UNILEVER PLC | 114,371.92 | Consumer Goods | Household & Personal Products |
| UNITED UTILITIES GROUP PLC | 8,752.04 | Infrastructure | Water Utilities & Services |
| VODAFONE GROUP PLC | 26,025.39 | Technology & Communications | Telecommunication Services |
| WEIR GROUP PLC | 9,039.69 | Resource Transformation | Industrial Machinery & Goods |
| WHITBREAD PLC | 4,590.21 | Services | Hotels & Lodging |