TNFD’s toxic relationship with Vale

In June 2025, the Taskforce on Nature-related Financial Disclosures (TNFD) and the Global Reporting Initiative (GRI) released a new report with seven case studies of companies. It claims to show how the TNFD is helping companies to “identify risks and opportunities to organizations arising from dependencies and impacts on nature”. 

This cements a new turning point in the TNFD scandal. 

TNFD chose notorious mining company Vale as one of the seven case studies. The source material appears to be an interview with Vale itself and its TNFD report. The references to Vale are mostly short – but it gives the impression of an earnest company eagerly learning about biodiversity. 

In 2019, Vale’s Brumadinho mine tailings dam collapse killed more than 270 people in Minas Gerais state, Brazil. In 2015, the collapse of the tailing dam in Mariana, also in the state of Minas Gerais, killed 19. The collapse of this dam at a mine joint-owned by Vale was, in environmental terms, the world’s largest tailing dam disaster and the industrial disaster with the largest environmental impact in Brazil.

If a company that has killed 300 people in environmental disasters can drive a truck through the loopholes in TNFD, anyone can. And with the endorsement of TNFD no less. 

Since at least February 2023, civil society organizations have warned TNFD about Vale. During the drafting of TNFD’s framework on corporate reporting on biodiversity groups used Vale as a worst case example of how systemic issues would enable greenwashing. 

Next, groups showed how Vale was actively using its TNFD report to greenwash its reputation. 

Now TNFD is going a step further by actively greenwashing Vale’s reputation itself – promoting Vale in its own materials and events. 

This is not careless, but cruel.  

Currently, 117 investors have exclusions or bans on Vale. In 2023, Vale paid USD$55.9 million to the SEC to settle a complaint on misleading disclosures. The company faces ongoing protests from Indigenous Peoples and Quilombola communities. Vale continues to fight legal actions by victim-survivors of its environmental disasters, and others opposing new mines. In Minas Gerais alone, as of June 2025 Vale has seventeen tailings dams identified as at maximum risk of failure. A 2019 report pointed out that Vale itself identifies that 66 of 84 its tailings dams globally (78%) are at ‘high risk’ of causing catastrophic damage to nearby communities if they crumble. 

In objective terms Vale has lied, it has killed people and it’s at risk of doing it again. 

But it’s still paying dividends. 

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TNFD knows the risks of greenwashing Vale 

In February 2023, Rainforest Action Network raised a case study about Vale in its submission to TNFD on its third draft (p.20-21), warning TNFD about the risks if it failed to fix its framework’s worst loopholes for greenwashing. This pointed to a particularly telling incident that foretold what was to come.

In 2022 emergency services were still searching for bodies in Brumadinho, yet later that same year the World Benchmarking Alliance (WBA) ranked Vale the 5th best company on nature. It is currently ranked 12th. Six of the seven expert reviewers for the 2022 WBA nature ranking are from groups closely linked to the TNFD, including the TNFD secretariat. The lack of outcry signals how far removed corporate reporting is from reality. 

RAN wrote: “It is abhorrent that a company accused of causing the deaths of hundreds of people across multiple incidents, constituting a level of environmental and other abuse so extreme as to justify murder charges being filed was described as a top performing company on nature…” It also quoted from the SEC and its allegations against Vale that “beginning in 2016, Vale manipulated multiple dam safety audits…and regularly misled local governments, communities, and investors about the safety of the Brumadinho dam through its environmental, social and governance (ESG) disclosures’” and that ‘“Vale’s public Sustainability Reports and other public filings fraudulently assured investors that the company adhered to the “strictest international practices.” 

In June 2023 Vale was then highlighted in a blog ahead of TNFD’s last draft.

In January 2024 Vale was raised in a civil society press release calling out the environmental and human rights reputations of ‘early adopters’ of the TNFD. 

Since October 2024 Vale has featured as a greenwashing case study in presentations about the TNFD at civil society events – available online here or here. 

In October 2024, Vale was referenced multiple times in a complaint filed by 10 organizations to the UN Environment Programme about its role in the creation and ongoing promotion of the TNFD. The Movimento pelar Soberania Popular na Mineracao (MAM) – a nation wide social movement of communities affected by mining in Brazil – is part of the complaint. At a press conference about the complaint at the COP biodiversity talks in Colombia, MAM spoke powerfully. 

(The UN Environment Programme later dismissed the complaint without investigation, in an apparent violation of its own complaint policy. It has been urged to overturn this decision). 

The escalations in October were in response to TNFD ignoring earlier warnings.

Months before the case study report, in October 2024 TNFD featured Vale as a speaker at a key TNFD event during the biodiversity COP. Shirley Krenak – whose people are survivors of the 2015 Mariana disaster – directly led a protest against Vale and TNFD. Shirley spoke directly to those attending the event, describing the harrowing impacts on the environment and communities of the disaster, calling it ecocide and TNFD a ‘false solution’. Several people in the room were crying. Parts of Shirley’s powerful speech can be found here or read about here or here.

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The real-world costs of greenwashing

In October 2024, TNFD’s comment to DeSmog about the detailed 39-page complaint appeared to be that the groups protesting greenwashing were actually showing how useful TNFD was, because they saw the value in companies doing better reporting over time. This appears to suggest, generously interpreted – that groups are misguided, or less generously – that they are stupid. 

If TNFD believes that the victims of mining disasters are unqualified to know their own rights and interests it would certainly explain their ignoring a direct protest from Shirley Krenak on Vale and the concerns expressed by MAM and others. 

In terms of who TNFD does view as qualified, it appears unphased that at least 45% of the corporate groups that were the ultimate decision-makers on the TNFD framework are facing serious environmental and human rights concerns. This includes legal cases, OECD complaints and not one, but two, corporate groups each facing 20 or more investor bans. Despite formal greenwashing cases still being rare, at least 10% of TNFD members are facing current, or recent, complaints. This includes cases filed to multiple regulators (HSBC and BlackRock). BNP Paribas is facing a legal case that includes allegations of misleading disclosures and S&P Global is facing an OECD complaint alleging greenwashing human rights issues in its ESG indexes.

In sum, it’s a so-called ‘solution’ to the corporate role in driving biodiversity collapse that views victim-survivors as misguided, and elevates companies accused of greenwashing as experts on company reporting. 

Just two months before the TNFD and GRI case study report, three organizations released a report on Vale. It is one of many efforts by academics, scientists, Indigenous Peoples, mine disaster victim-survivors and others advocating on the issues with Vale. 

Focused on Minas Gerais, the report highlights that in 2024 Vale made an indemnity agreement with the government. Vale has defended victim-survivors being excluded from this process – who argue that the agreement won’t deliver reparations to worst affected communities and worst of all – the indemnity may shut down dozens of legal cases against Vale. In fact, according to the Association of Family Members of Fatal Victims of the Tragedy (AVABRUM) Vale had refused to even change its uniforms – despite Brumadinho victims’ requests that they are a distressing reminder of loved ones killed. 

The report emphasizes the multitude of Vale dams at maximum risk of failure and that their collapse would threaten the water supply of millions of people. According to the report, decommissioning work hasn’t begun and may not for years. Hundreds of families have been uprooted from their homes in areas at risk from Vale’s other shoddily built dams. It states that almost a thousand families are living in temporary rented accommodation – with no land to carry out subsistence farming. The report also highlights, at various points, how Vale omits key information or context in its corporate disclosures – including on biodiversity. Most chillingly, Vale is opening a new mine in Minas Gerais.

It’s in sharp contrast to Vale’s 2023 TNFD report, which includes lots of pretty graphics and such claims that for every hectare of land they impact, they save 11. 

If a company kills 300 people in environmental disasters, kills an entire river and is at risk of further environmental disasters – corporate reporting isn’t really the problem. 

Holding Vale up as a nature leader cruelly undermines its crimes against nature, its victim-survivors and others protesting Vale. It’s hard enough for traumatised people to seek justice from a multi-billion dollar company. Greenwashing is a form of misinformation that is highly effective in muddying the message that this is a bad company doing bad things. 

Put bluntly, having Vale as a poster child for the TNFD is equivalent to marketing how well your fox can guard chickens.