Bunge and the Illusion of TNFD Disclosure as Progress 

Bunge, a US-headquartered agribusiness giant, is one of the largest soy traders and soybean processors globally, with extensive operations in the biodiverse Cerrado region of Brazil. The Cerrado, a savannah home to 5% of the world’s species,¹ is a key region for soy production but is increasingly threatened by deforestation, land grabbing, violations of Indigenous Peoples’ rights and violence against Human Rights Defenders.² Deforestation in the Cerrado is accelerating, driven in large part by massive soybean farms.³ 

Bunge’s links to deforestation and human rights abuses are not recent developments, but part of a persistent pattern dating back over a decade. Despite its public sustainability commitments, Global Canopy’s Trase database has consistently identified Bunge  as having the largest deforestation exposure for soy in Brazil since at least 2013, with exposure exceeding 60,000 hectares in 2020 alone.⁴ In 2018, Bunge was fined by Brazil’s environment agency, Ibama, for deforestation-related activities, further highlighting its repeated violations despite pledges to act sustainably.⁵

In 2023, Friends of the Earth US reported that Bunge had a near monopoly on soy trading in the Brazilian state of Piauí, where deforestation in areas linked to its operations has surged by almost 300% since 2021.⁶ This includes land grabbing and violence against local communities.⁷ Bunge also faced allegations from CSOs of sourcing soy from suppliers responsible for over 11,351 hectares of deforestation in the Cerrado, continuing after the December 2020 cut off date for the EUDR.⁸ Human rights abuses, including land theft from the Indigenous Guarani Kaiowá peoples, have been associated with a farm that Bunge sources from in Mato Grosso do Sul.⁹

With longstanding operations across the Americas, Europe, and Asia, Bunge has long been a dominant force in global food supply chains, historically recognized as one of the “ABCD” grain traders alongside Cargill, ADM, and Louis Dreyfus.¹⁰ Its influence is set to grow further as the European Commission has approved its planned merger with Glencore’s agribusiness subsidiary, Viterra, positioning the company to rival even the largest global players in agricultural commodities.¹¹

The TNFD Framework: A False Solution

Despite Bunge’s extensive track record of deforestation and Indigenous human rights violations, it was selected as one of 40 companies represented on the Taskforce on Nature-related Financial Disclosures (TNFD).¹² Bunge’s inclusion highlights broader flaws of the TNFD framework. Although co-founded by two UN agencies, Global Canopy and WWF, the TNFD is ultimately governed by a corporate taskforce. Launched in 2023, the TNFD claims to help businesses and financial institutions manage nature-related risks. However, it has been criticized by some civil society organizations, rights holders and academics for being corporate-driven rather than evidence-led, and for failing to equally involve civil society, Indigenous groups, women’s organizations or independent environmental experts in its decision-making process.¹³

Bunge and its financiers are now using the TNFD framework to report on nature-related risks, but the framework’s lack of enforceable standards allows companies like Bunge to disclose selectively, avoiding accountability for the full environmental and human rights impacts tied to their operations. Bunge’s adoption of TNFD exemplifies how corporations can exploit weak, voluntary frameworks to maintain the status quo while diverting attention from real underlying issues. The TNFD’s baseline “single materiality” approach recommends that companies disclose risks that are financially significant to their business, ignoring the broader impacts on biodiversity or local communities.¹⁴ In Bunge’s case, its first TNFD report in 2024 reflects this, offering a highly selective presentation of data that distracts attention from the more fundamental issues of deforestation and rights abuses, thus failing to address the systemic harm in its supply chains.¹⁵

For instance, Bunge’s TNFD-aligned report highlights internal operations and sustainability claims but omits key data, including full exposure to deforestation in the Cerrado,¹⁶ suppliers’ involvement in illegal land grabs, and displacement of Indigenous and Quilombola communities.¹⁷ While the company promotes traceability efforts, it is unclear if these account for deforestation and land grabbing that occurs in order to establish farms for soy production prior to entering Bunge’s supply chain. The company continues to lack adequate policies and due diligence procedures to ensure human rights abuses and FPIC violations are not linked to its operations.

The TNFD does not recommend grievance mechanisms or grievance lists, which track significant complaints against a company. This is another example of how TNFD ‘disclosure’ avoids some of the most meaningful and relevant forms of transparency, such as direct allegations of harm – and distracts from calls for accountability for its impacts. The framework also fails to challenge companies’ right to retain profits earned from environmental or human rights violations.

In its response to Friends of the Earth US’s 2023 report, Bunge contests that it has a near-monopoly on soy trading in Piauí, argues that data from the TRASE platform is imprecise, and requires suppliers to respect and protect human rights. Bunge states that it does not buy soybeans from commercial farms that overlap with Indigenous lands; however it is unclear if the company is only referring to titled lands or lands to which Indigenous Peoples and other traditional communities have customary claims and rights.

Greenwashing Through Disclosure and Ongoing Financial Support

Despite its track record of environmental violations, Bunge continues to receive substantial financial backing. From 2018 to June 2024, Bunge received US$ 676 million in credit and US$ 678 million in investment as of July 2024 for its forest-risk soy operations. Bunge’s financiers include TNFD-early adopters such as SMBC, Rabobank, Crédit Agricole, Mizuho, Standard Chartered, Bank of America, UBS and Fidelity International.

This ongoing financial support, including from financiers who serve on the TNFD taskforce or are TNFD members more broadly, highlights the disconnect between public sustainability commitments and actual business practices. The TNFD framework, which many of these financiers have adopted, allows them to claim to address biodiversity issues while continuing to finance companies responsible for biodiversity destruction.

The TNFD framework does not recommend public disclosure of independently verifiable data, nor does it have a process to exclude companies which have not addressed ongoing grievances.¹⁸ As a result, reports from Bunge and its financiers are more public relations tools than meaningful environmental disclosures, masking the true impacts of their operations. This illusion of progress is unsurprising given TNFD taskforce’s track record— according to The Canary over the past decade, they’ve faced nearly 300 allegations of rights abuses.¹⁹

This raises serious concerns about the opaque process of selecting the taskforce members who were the ultimate decision-makers of the TNFD framework for reporting, and based on what qualifications. While TNFD reporting is unlikely to be problematic in a scenario where a company has a track record of genuine commitment to ethical processes – for companies that have failed to meaningfully address past allegations of environmental and social harm, the framework is more likely to distract from, and undermine, existing calls for real accountability.

In fact, a quick online search reveals more about Bunge’s biodiversity harms than what is disclosed in its TNFD reports. This disparity is a damning indictment of the framework’s effectiveness. Far from driving meaningful change, TNFD allows corporations to continue profiting from environmental destruction while offering minimal transparency about the risks they pose to ecosystems and local communities.

Conclusion

Bunge’s participation in TNFD highlights the fundamental flaws of voluntary frameworks. Instead of addressing its systemic issues—decades of deforestation, land grabbing, and rights violations—Bunge uses TNFD to maintain the illusion of progress. Without enforceable standards and full transparency, TNFD fails to hold companies accountable for their environmental and human rights impacts.

Policymakers must move beyond voluntary disclosures like TNFD and enforce mandatory regulations requiring independently verified data on environmental and social impacts. Financial institutions supporting companies like Bunge must reject superficial frameworks and demand real accountability through comprehensive due diligence, supply chain traceability, independently verified impact assessments, and transparent disclosure of grievances and violations, and processes for remedy.

References:

1. Friends of the Earth. Land Grabbing and Ecocide. September 2023. https://foe.org/wp-content/uploads/2023/09/Land-Grabbing-and-Ecocide-Final-compressed.pdf. ↩︎
2. International La Croix. “Brazil’s Silent Crisis: Deforestation Shifts from Amazon to Cerrado.” May, 2024. https://international.la-croix.com/laudato-si/brazils-silent-crisis-deforestation-shifts-from-amazon-to-cerrado.
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3. Trase. Deforestation Risk in Green Finance: Brazil Soy Supply Chains. https://trase.earth/explore/supply-chain/brazil/soy?utm_source=explore_data_card&chartType=sankey&year=2020&indicator=volume&dimension=region_production_1&dimension=exporter_group&dimension=importer_group&dimension=country_of_import&hideDomestic=false. ↩︎
4. Reuters. “Brazil Fines Five Grain Trading Firms for Links to Deforestation.” May 2024. https://www.reuters.com/article/business/environment/brazil-fines-five-grain-trading-firms-farmers-connected-to-deforestation-idUSKCN1IO1NU/.
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5. Reuters. “Brazil Fines Five Grain Trading Firms for Links to Deforestation.” May 2018. https://www.reuters.com/article/business/environment/brazil-fines-five-grain-trading-firms-farmers-connected-to-deforestation-idUSKCN1IO1NU/. ↩︎
6. Friends of the Earth. Industrial Soy Expansion in Brazil. April 2022. https://foe.org/wp-content/uploads/2022/04/IndustrialSoyExpansion.Brazil.FoE-final.pdf ↩︎
7. Mighty Earth. Saving the Cerrado: Bunge’s Commitment. June, 2023. https://www.mightyearth.org/wp-content/uploads/BUNGE_Saving_the_Cerrado.pdf.
   Repórter Brasil. “Bunge promete desmate zero em 2025, mas seus fornecedores derrubaram 11 mil hectares de Cerrado em 2 anos.” May 2023 https://reporterbrasil.org.br/2023/05/bunge-promete-desmate-zero-em-2025-mas-seus-fornecedores-derrubaram-11-mil-hectares-de-cerrado-em-2-anos/.  ↩︎
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   Note. Bunge has been linked to sourcing from contested land for over a decade. In one example from 2013 Federal Prosecutors, Oxfam and others raised concerns regarding  Bunge sourcing sugar from Guarani Kaiowa lands at Jatayvary in Mato Grosso do Sul.
   Oxfam International. Sugar Rush. October 2013. https://oxfamilibrary.openrepository.com/bitstream/handle/10546/302505/bn-sugar-rush-land-supply-chains-food-beverage-companies-021013-en.pdf
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9. Oxfam. Cereal Secrets: The World’s Largest Grain Traders and Global Agriculture. August, 2012. https://www.oxfam.org/en/research/cereal-secrets-worlds-largest-grain-traders-and-global-agriculture. ↩︎
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    Forest & Finance. Joint CSO Letter to the TNFD. Forest & Finance, October 13, 2022. https://forestsandfinance.org/wp-content/uploads/2022/10/13October2022-Joint-CSO-Letter-to-the-TNFD.pdf.
    Savimbo. “Moving Beyond a Tokenistic Participation of Indigenous Peoples in Nature Financing.” Savimbo, August 2023. https://www.savimbo.com/blog/moving-beyond-a-tokenistic-participation-of-indigenous-peoples-in-nature-financing. ↩︎
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15. Business & Human Rights Resource Centre. “Bunge and Cargill Behind More Than 30% of Soy Exports to EU and UK Linked to Indigenous Rights Violations.” https://www.business-humanrights.org/en/latest-news/brazil-bunge-and-cargill-behind-more-than-30-of-soy-exports-to-eu-and-uk-allegedly-linked-to-indigenous-rights-violations/. ↩︎
16. Friends of the Earth. Land Grabbing and Ecocide. September 2023. https://foe.org/wp-content/uploads/2023/09/Land-Grabbing-and-Ecocide-Final-compressed.pdf.
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    Global Witness. “Global Commodity Traders Are Fuelling Land Conflicts in Brazil’s Cerrado.” Global Witness, August 10, 2023. https://www.globalwitness.org/en/campaigns/environmental-activists/global-commodity-traders-are-fuelling-land-conflicts-in-brazils-cerrado/.
    Friends of the Earth. “Bunge’s Corporate Climate Con.” Friends of the Earth, May 17, 2023. https://foe.org/blog/bunge-corporate-climate-con/. ↩︎
17. Friends of the Earth. Land Grabbing and Ecocide: An Analysis of Bunge and Cargill’s Impacts on Land and People in South America. September 2023. https://foe.org/wp-content/uploads/2023/09/Land-Grabbing-and-Ecocide-Final-compressed.pdf.
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    Global Witness. “Global Commodity Traders Are Fuelling Land Conflicts in Brazil’s Cerrado.” Accessed October 10, 2024. https://www.globalwitness.org/en/campaigns/environmental-activists/global-commodity-traders-are-fuelling-land-conflicts-in-brazils-cerrado/.
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18. Green Central Banking. “TNFD: Written by Corporations and It Shows.” November 2, 2023. https://greencentralbanking.com/2023/11/02/tnfd-written-by-corporations-and-it-shows/ ↩︎
19. The Canary. “The Corporations Making up the TNFD Hold a Prolific Record of Ecological and Human Rights Violations.” September 26, 2023. https://www.thecanary.co/global/2023/09/26/the-corporations-making-up-the-taskforce-on-nature-related-financial-disclosure-hold-a-prolific-record-of-ecological-and-human-rights-violations/. ↩︎