Quiet progress on nature

The second Global Nature Positive Summit concluded on Wednesday last week (15 July) in Kumamoto, Japan, with participating organisations adopting the Kumamoto Declaration. Since then I’ve been listening for chatter, excitement, news…and instead the relative silence that has followed it is surprising.

That declaration has all the good stuff, to quote:

• Urging companies to apply the mitigation hierarchy then contribute to the restoration and regeneration and compensating for unavoidable impacts while applying high-level integrity safeguards.
• Mobilising governments, regulators, companies and financial institutions around standardised, science-based, practical and decision-useful metrics and methodologies to measure corporate impacts and dependencies on nature and the state of nature, accelerating corporate action.
• Aligning markets around a globally consistent, standards-based approach to assessment, target-setting, transition planning and corporate reporting on nature-related issues
• Recognising natural capital as a vital asset and that nature-based solutions, circularity and decarbonisation efforts must be integrated to jointly secure global climate, water and food security, and human health and wellbeing.
• Embracing a Just Transition where climate and nature conservation safeguards and enhances local livelihoods, promote social equity, and empowers marginalised communities.

For more, check out the Declaration, and also Record private sector participation in Global Nature Positive Summit.

As someone who spends my days in discussions on nature, I’m struck by how limited the social media and mainstream commentary has been, given the hum of ambition and nature-positive agendas elsewhere. To me it suggests many organisations are thinking hard about nature, though are not yet ready to talk publicly while they grapple with implications, tools and data.

The Nature Positive Initiative is this year developing a State of Nature Metrics framework aimed at helping governments and businesses track progress in a more standardised way. Details remain thin and consultation quiet to date, in Australia at least. My working hypothesis is that boards and executives are in a reflective phase – working through climate disclosures then tacitly connecting nature to existing climate and risk frameworks, and trying to understand where their material exposures sit – rather than racing to make new announcements. That may be no bad thing if it buys time for more grounded action rather than glossy commitments.

At the same time, the International Sustainability Standards Board’s decision to not proceed with a dedicated S3 standard for nature, instead dealing with nature‑related disclosures under the general requirements in S1, has still sent an important signal. Nature is firmly in scope, but companies will be encouraged to integrate it into their overall sustainability reporting rather than responding to mandated standards. That framing will matter for how seriously boards take nature in their mainstream risk and strategy conversations, which is where it ultimately belongs. More here: Treasury Laws Amendment (Financial Reporting System Reform) Act 2026 No. 61, 2026

More substantive progress on modern slavery

In 2023 many of us read the McMillan Report on Australia’s modern slavery act – and supported Professor McMillan’s view that while the Act had lifted awareness of modern slavery, there was no hard evidence of creating change for victims.

Last week, Attorney-General, Michelle Rowland responded – and Australia’s Modern Slavery Act is moving from disclosure to enforcement. Entities with annual revenue above $100 million will now face criminal liability for failing to take reasonable steps to identify, prevent and address modern slavery in their supply chains, alongside new civil penalties for inadequate reporting. A defence is available where companies can show they took reasonable steps, with penalty amounts to be determined by further consultation.

Rowland’s approach is broader and blunter than the approach put forward by Australia’s Anti-Slavery Commissioner, Chris Evans, calling for mandatory risk-based due diligence – a position supported by many human rights advocates, including myself at Pure and Applied. It imposes criminal liability and a general reasonableness threshold rather than the structured, risk-based, more granular due diligence Evans outlined.

Reactions are split. The Business Council of Australia warned the reforms add excessive paperwork to an already demanding regime; the Human Rights Law Centre and Anti-Slavery Commissioner Chris Evans welcomed the shift as overdue.

Australia is now inching towards the due diligence regimes evident across the European Union and emerging globally, moving away from a transparency-only framework. The Greens have signalled support, meaning the government appears to have the numbers in the Senate.

For entities currently reporting under the Act, the practical implication is direct: companies with statements that describe risk without demonstrating action will be exposed. Strengthening risk assessment methodologies, grievance mechanisms and remediation processes – and documenting the reasonable steps taken – are now a priority, ahead of legislation being introduced.

The changing shape of sustainability leadership

Another trend I’ve been tracking is the reshaping of senior sustainability roles. As more ASRS work is completed, the implications for jobs in the sustainability sector is quite interesting.

Over the past year, we’ve seen long‑standing chief sustainability officers (CSOs) leave their posts and the role itself increasingly merged with other domains – for example, “chief sustainability and corporate affairs”, “chief risk and sustainability” or “chief strategy and sustainability”. That shift is visible both in Australia and globally, including in large multinationals in consumer goods and financial services.

Rather than touch on Australian examples, here’s what I’ve seen globally… Unilever folded its CSO into a combined sustainability and corporate affairs role in 2025, and when Rebecca Marmot departed in November, sustainability passed to a chief corporate affairs and communications officer rather than a new CSO. Starbucks, Procter & Gamble and Coca-Cola have each moved through a version of the same story this year: the title dissolves into risk, strategy, operations or corporate affairs.

Apple went further still: when Lisa Jackson, its environment and policy chief for over a decade, retired in January, the company named no successor at all. They instead split her portfolio between the chief operating officer and the incoming general counsel. Worryingly, they dropped the ESG criteria from executive pay in the same proxy season. That is not a reshuffle. That is a diminution.

Ok, for some businesses this will reflect the embedding of sustainability across the enterprise. Accountability is spreading into risk, strategy, finance, HR and technology, which is essential for delivery.

On another level, there is a real risk that organisations move too quickly to a distributed model without sufficient internal governance, capability and coordination. When a senior CSO leaves because disclosures are done – with ELTs assuming that the job is done – boards may only realise in a year or two that they are missing a seasoned voice to interpret evolving sustainability risks, regulatory expectations and stakeholder pressures.

Before too long I expect we’ll see another wave of senior leaders – a second generation of CSOs – responding to El Nino with climate adaptation action plans, and supporting executives and boards grappling with the ethics, energy/climate and human rights implications of the AI transition. In an environment of these kinds of real risks being played out in real time, the absence of a highly experienced sustainability leader reporting at group executive level may be felt acutely, and not only during an assurance review.

For firms contemplating changes to their senior sustainability roles, the question I’ve been asking myself is simple – who is the coordinating leader? Distributed accountability models can work, but only when there is a clear locus of expertise and integration, and when internal governance provides muscle, not just structure.

Strong sustainability leaders bring lived experience of cross‑functional delivery, a feel for emerging external expectations before they crest the wave, and the ability to translate complex sustainability issues into strategic questions a board can act on. The lesson from other domains – risk, safety, cyber – is that you can embed responsibilities widely, but you still need someone at the top with a clear mandate to connect dots, and with sufficient clout to call out emerging threats. Sustainability will be no different.

Do you still need a sustainability strategy?

That leads to a related question I’ve been giving myself: will organisations still recognise the need for a sustainability strategy if they no longer have a senior sustainability leader? In my experience, most sustainability strategies emerge because someone – often a CSO – has advocated for an integrated plan, the executive has seen the business case, and the board wants a coherent story that aligns financial, operational and stakeholder commitments.

It is unusual for an organisation to pursue a comprehensive sustainability strategy without at least some dedicated leadership in place. Strategies of substance typically involve choices about business models, supply chains, capital allocation and workforce, not just a list of initiatives. International guidance – such as that of the World Benchmarking Alliance – on corporate sustainability and transition planning reinforces this, stressing that credible plans require clear governance, senior accountability and integration with core strategy – overlaid with a culturally-aligned compelling narrative of what sustainability means. Disclosure: I’ve recently joined WBA’s Supervisory Board.

If senior sustainability roles are pared back or merged without clarity, we may see a drift towards fragmented sustainability activity – pockets of climate, nature or social projects – rather than a cohesive strategy. That fragmentation is risky in an environment where regulators, investors and civil society are increasingly assessing companies on the integrity and integration of their transition pathways. Strategies that emerge by accident rarely withstand scrutiny.

Integration moves from slogan to practice

Finally, I’m encouraged by the way integration is starting to show up not just in slogans but in emerging tools. Integration has been a theme in sustainability for at least four or five years, yet practice has often lagged behind – with separate workstreams for climate, nature and human rights. The reality in boardrooms is different. Problems rarely arrive neatly labelled as “climate” or “social”. They land as multifaceted issues that cut across emissions, ecosystems, labour, technology and community.

Within the World Benchmarking Alliance, this recognition is shaping work on the Integrated Transition Assessment – a framework designed to assess corporate transition progress in a way that reflects the interconnected realities of climate change, nature loss and social inequality. The Alliance’s methodologies for climate and just transition already point towards metrics that link emissions trajectories, investment, governance and social equity. The next step is to bring these strands together so that assessments – and ultimately corporate plans – reflect an integrated view of sustainability performance. I’m glad to be part of this.

What excites me is the potential for integrated tools to inform transition planning in companies. Climate transition plans that ignore nature, social impacts or First Nations rights will quickly run into implementation barriers, whether in permitting, community trust or supply chain resilience. Integrated assessment frameworks can help boards see how choices in one domain reverberate through others and can encourage more coherent, system‑aware transition pathways. If we can make that integration practical rather than conceptual, the quality of corporate transitions may improve markedly.

Something to think about

If you’re sitting on a board or executive team, the question I’d be most interested in hearing your answer on is this: who is genuinely accountable, in your organisation, for integrating climate, nature and social risks into the heart of your transition strategy?

This is the thread running through most of our work at Pure and Applied right now: helping sustainability capability sit closer to business leadership, even as the org chart around it keeps shifting. If any of this resonates, we would love to hear from you – please get in touch.