Appendix G: Disclosure Templates --- TNFD and ISSB

This appendix provides template disclosures pre-filled for the proposed NbS Impact Term Deposit product. The templates demonstrate how the Issuer (the bank offering the NbS Impact Term Deposit) would present its nature-related and sustainability-related disclosures in compliance with the Taskforce on Nature-related Financial Disclosures (TNFD) recommendations and the International Sustainability Standards Board (ISSB) IFRS S1 and S2 standards. All data is illustrative, based on a hypothetical bank operating the NbS Impact Term Deposit in both Australia and Singapore with a total NbS deposit pool of AUD 150 million / SGD 160 million allocated across eight NbS projects in five ASEAN countries.

1. TNFD Disclosure Template

The TNFD framework comprises 14 recommended disclosures organised across four pillars: Governance, Strategy, Risk & Impact Management, and Metrics & Targets [1]. The following template addresses each disclosure as it relates to the NbS Impact Term Deposit product and the Issuer's broader nature-related financial risk management.

Governance

Disclosure A: Board Oversight of Nature-Related Dependencies, Impacts, Risks and Opportunities

The Board of Directors maintains oversight of the Bank's nature-related dependencies, impacts, risks and opportunities through the following governance arrangements:

• The Board Risk Committee has responsibility for overseeing the Bank's environmental risk management framework, including nature-related financial risks. The committee reviews the Bank's NbS lending portfolio quarterly, with particular attention to the NbS rating distribution, diversification compliance, and any projects flagged for condition deterioration through the Bank's remote sensing early-warning system.

• The Board approved the NbS Impact Term Deposit product in [year], following a full product risk assessment that considered nature-related risks to the ring-fenced NbS lending pool, reputational risk associated with nature-positive claims, and the Bank's capacity to manage a portfolio of NbS-rated project exposures across ASEAN jurisdictions.

• Nature-related matters are a standing agenda item at quarterly Board Risk Committee meetings. The committee receives a Nature Portfolio Dashboard that reports: total NbS deposits outstanding, total NbS lending deployed, weighted-average NbS rating of the portfolio, number of projects at or near the NbS-BBB investment-grade threshold, and any projects under enhanced monitoring or remediation.

• Two Board members have relevant expertise: [Director A] brings experience in environmental management and sustainable finance from a career in development banking, and [Director B] holds qualifications in environmental science and serves on the advisory board of [a relevant environmental research institution].

• The Board has approved a Nature-Related Risk Appetite Statement that establishes quantitative limits for the NbS lending pool, including the geographic concentration limit (40% per country), typological concentration limit (30% per NbS type), and minimum weighted-average rating requirement (NbS-A or above).

Disclosure B: Management's Role in Assessing and Managing Nature-Related Dependencies, Impacts, Risks and Opportunities

• The Chief Sustainability Officer (CSO) has direct accountability for the NbS Impact Term Deposit programme, including product design, project origination, NbS rating commissioning, impact reporting, and regulatory compliance. The CSO reports to the Chief Risk Officer and has a standing invitation to Board Risk Committee meetings.

• An NbS Lending Committee, chaired by the CSO and comprising the Head of Credit, Head of Treasury, and an external ecological adviser, meets monthly to review the NbS project pipeline, assess new project rating results, approve allocation decisions, and monitor portfolio compliance with diversification and rating quality requirements.

• The Sustainability Team (8 full-time equivalents) manages day-to-day NbS portfolio operations, including commissioning and reviewing independent NbS ratings, processing quarterly satellite monitoring updates, coordinating annual on-ground verification visits, and preparing the annual NbS Impact Statement for depositors.

• Nature-related risk assessments are integrated into the Bank's standard credit assessment process through a TNFD LEAP-aligned overlay. All NbS lending proposals include a nature-risk assessment covering location-specific physical risks (climate exposure, extreme weather probability), project-specific risks (execution risk, permanence risk, regulatory risk), and transition risks (carbon market price sensitivity, policy changes in host jurisdictions).

Disclosure C: Organisation's Human Rights Policies, Engagement Activities, and Oversight by the Board and Management

• The Bank's Environmental and Social Risk Policy requires that all NbS projects funded through the ring-fenced lending pool demonstrate compliance with Free, Prior and Informed Consent (FPIC) protocols for projects affecting Indigenous or local community lands. FPIC compliance is a mandatory component of the NbS rating (Rights and Governance sub-indicator, Social Domain) and is assessed by independent rating agencies during the field verification phase.

• The Bank requires that NbS project sponsors establish accessible grievance mechanisms for affected communities. The existence and functioning of grievance mechanisms is assessed during annual verification visits. In the reporting period, [number] grievances were raised across the NbS portfolio, of which [number] were resolved, [number] are under active investigation, and [number] were escalated to the Bank's Environmental and Social Risk team for follow-up.

• The Bank engages with the communities affected by NbS projects through annual community consultation visits conducted as part of the on-ground verification process. Consultation findings are reported to the NbS Lending Committee and, where material, to the Board Risk Committee.

• Land tenure security is assessed for every NbS project in the portfolio. The Bank's policy requires that projects demonstrate clear and uncontested tenure arrangements, or document a credible pathway to tenure resolution, before lending is approved. As of the reporting date, [number] of [total] projects have fully secured tenure; [number] have tenure arrangements in progress with documented government commitment; and zero projects have contested or disputed tenure.

Strategy

Disclosure A: Nature-Related Dependencies, Impacts, Risks and Opportunities Identified

The Bank has identified the following nature-related dependencies, impacts, risks and opportunities relevant to the NbS Impact Term Deposit product:

Dependencies: The NbS lending pool's financial performance depends on the continued ecological integrity of the funded projects. Ecosystem degradation (through fire, flood, encroachment, or climate change) could impair the carbon credit revenue streams that many NbS projects rely upon, potentially increasing credit risk within the ring-fenced portfolio. The Bank's nature-positive product claims depend on the ability to demonstrate verifiable improvements in ecosystem extent, condition, and service delivery across the portfolio.

Impacts: The Bank's NbS lending generates positive nature impacts, measured through the SEEA EA-compatible rating methodology. As of the reporting date, the NbS portfolio:

• Supports 42,600 hectares of ecosystem under active management across five ASEAN countries.
• Has contributed to a weighted-average Ecosystem Condition Index improvement of +0.28 across the portfolio (from 0.34 at portfolio-level baseline to 0.62 at latest assessment).
• Delivers an estimated 87,500 tCO2e per year in carbon sequestration and avoided emissions.
• Protects 14.3 km of coastline through mangrove and seagrass restoration.
• Supports 8,400 community households with measurable livelihood improvements.

Risks: The primary nature-related risks are: (a) physical risk from climate change impacts on NbS project sites (sea-level rise affecting mangrove projects, drought increasing fire risk for peatland projects, temperature changes affecting agroforestry productivity); (b) transition risk from carbon market price volatility and regulatory changes in ASEAN host countries; (c) reputational risk if NbS projects underperform against the nature-positive claims communicated to depositors.

Opportunities: The NbS Impact Term Deposit represents a first-mover opportunity in the nature-positive banking product space. Neither the Australian nor the Singaporean banking market currently offers a deposit product specifically linked to independently rated NbS projects. The product positions the Bank to attract sustainability-conscious depositors (particularly high-net-worth individuals, family offices, and institutional investors with nature-positive mandates), to build expertise in nature-related risk assessment that will be valuable as nature-related disclosure requirements expand, and to develop an NbS project pipeline that may support future product offerings (e.g., NbS-linked green bonds, nature-positive managed funds).

Disclosure B: Effect on Business Model, Value Chain, Strategy, and Financial Planning

• The NbS Impact Term Deposit is currently a niche product within the Bank's deposit portfolio, representing approximately [0.3]% of total customer deposits. It does not materially affect the Bank's overall business model or balance sheet composition.

• The product's ring-fenced lending pool creates a specialised asset class within the Bank's credit portfolio, managed under the same prudential framework as other lending but with an additional NbS rating overlay. The NbS lending pool is treated as a separate sub-portfolio for monitoring and reporting purposes, with its own concentration limits and rating quality requirements.

• Financial planning incorporates growth projections for the NbS deposit pool, with an internal target to increase total NbS deposits to AUD 500 million / SGD 530 million within three years. Achieving this target requires expanding the pipeline of investment-grade (NbS-BBB or above) rated projects, which in turn depends on the development of NbS project origination capacity in ASEAN.

• The Bank's sustainable finance strategy identifies nature-positive products as a growth area, reflecting the expectation that mandatory nature-related disclosure (currently voluntary under TNFD, but anticipated to become mandatory as ISSB develops nature standards) will increase institutional demand for products with verifiable nature outcomes.

Disclosure C: Resilience of Strategy Under Different Scenarios

The Bank has assessed the resilience of the NbS Impact Term Deposit product under three nature-related scenarios:

Scenario 1: Accelerated ecosystem degradation (physical risk scenario). Under this scenario, climate change impacts intensify across ASEAN, resulting in a 20% increase in extreme weather events, a 15 cm rise in sea level by 2040 (affecting coastal mangrove projects), and a 2-degree C increase in mean temperature (increasing fire risk for peatland projects and reducing productivity for some agroforestry crops). Under this scenario, the Bank estimates that 2--3 of the 8 current NbS projects could experience NbS rating downgrades below the NbS-BBB threshold, requiring replacement within the ring-fenced pool. The diversification requirements (geographic, typological, and minimum three typologies) mitigate the risk of correlated failures.

Scenario 2: Carbon market disruption (transition risk scenario). Under this scenario, voluntary carbon credit prices decline by 50% due to regulatory tightening, methodological challenges, or demand contraction. Five of the eight NbS projects in the portfolio currently rely on carbon credit revenue as a primary or secondary income stream. Under this scenario, 2 projects would experience negative NPV under base-case assumptions, potentially triggering NbS rating downgrades from the Economic Domain. However, the Bank's diversification requirements and the rating methodology's emphasis on revenue diversification (Financial Viability sub-indicator) mean that projects with diversified revenue models (e.g., the agroforestry project with four income streams) are less exposed to this scenario.

Scenario 3: Nature-positive regulatory acceleration (opportunity scenario). Under this scenario, mandatory nature-related disclosure is adopted in both Australia and Singapore by 2028 (aligned with the ISSB's anticipated biodiversity standard), creating a regulatory incentive for financial institutions to demonstrate nature-positive portfolios. Demand for the NbS Impact Term Deposit doubles as institutional investors seek verified nature-positive allocations to support their own disclosure requirements. The Bank's first-mover position and established NbS rating infrastructure provide a competitive advantage.

Disclosure D: Locations of Assets and Activities in Priority Areas

The Bank's NbS lending pool is allocated to projects in the following locations. The table identifies priority areas for biodiversity, including Key Biodiversity Areas (KBAs), as recommended by the TNFD for location-specific disclosure [1]:

Risk & Impact Management

Disclosure A: Processes for Identifying and Assessing Nature-Related Dependencies, Impacts, Risks and Opportunities

The Bank identifies and assesses nature-related dependencies, impacts, risks and opportunities through a structured process aligned with the TNFD LEAP approach:

Locate: For each prospective NbS project, the Bank's Sustainability Team maps the project boundary against globally recognised spatial datasets, including the World Database on Key Biodiversity Areas (KBA), the World Database on Protected Areas (WDPA), the IUCN Red List of Ecosystems, and the WWF Ecoregions classification. This spatial analysis identifies the nature-related context of the project, including proximity to biodiversity-sensitive areas, ecosystem type classification, and baseline extent data.

Evaluate: The independent NbS rating process evaluates the project's dependencies on ecosystem services (e.g., a mangrove project's dependency on tidal connectivity and sediment supply for long-term viability) and its impacts on ecosystem condition (measured through the Ecosystem Condition Index, a composite of biotic and abiotic indicators normalised on a 0--1 scale against reference condition benchmarks). The Evaluate phase also identifies the project's contributions to ecosystem service delivery, quantified in biophysical units.

Assess: Nature-related risks are assessed through the credit assessment overlay described in Section 5.2 of the main report. Physical risks (climate exposure, extreme weather, ecosystem fragility) are assessed using climate projection data for the project location (IPCC AR6 downscaled projections, national climate assessments). Transition risks (carbon market price volatility, regulatory changes, demand shifts) are assessed through scenario analysis. Project-specific risks (execution, permanence, social conflict) are assessed through the NbS rating's Social and Economic Domain scores.

Prepare: The Bank prepares for nature-related disclosure and strategy response through: (a) the annual NbS Impact Statement (depositor-facing); (b) integration of NbS portfolio data into the Bank's TNFD and ISSB sustainability reports (regulator and investor-facing); (c) scenario analysis (three scenarios as described in Strategy Disclosure C above); and (d) internal capacity building (training of credit analysts in nature-related risk assessment, engagement with external ecological advisers).

Disclosure B: Processes for Managing Nature-Related Dependencies, Impacts, Risks and Opportunities

• Pre-lending: All NbS projects must achieve an independent NbS rating of NbS-BBB or above before lending is approved. The rating assessment covers environmental integrity (50% weight), social outcomes (25% weight), and economic viability (25% weight). Projects that do not meet the investment-grade threshold are not eligible for the ring-fenced NbS pool.

• Ongoing monitoring: Quarterly satellite monitoring tracks ecosystem extent and condition proxies (NDVI, canopy cover, water body integrity) for all projects in the portfolio. Projects experiencing unexpected condition deterioration are flagged in the early-warning system and escalated to the NbS Lending Committee for review.

• Annual verification: Independent on-ground verification visits assess ecological condition, community outcomes, governance and FPIC compliance, and financial performance. NbS ratings are updated annually.

• Remediation: Projects downgraded below NbS-BBB are placed under enhanced monitoring. The Bank engages with the project sponsor to develop a remediation plan. If the project is not upgraded to NbS-BBB within 12 months, it is replaced in the ring-fenced pool with a newly rated eligible project.

• Exit: In extreme cases (project abandonment, irreversible ecological damage, evidence of human rights violations), the Bank may accelerate repayment of the NbS loan and remove the project from the pool. Exit decisions are approved by the NbS Lending Committee and reported to the Board Risk Committee.

Disclosure C: Integration into Overall Risk Management

Nature-related risk management for the NbS portfolio is integrated into the Bank's enterprise risk management framework through:

• Credit risk: NbS ratings are mapped to the Bank's internal risk grade framework, with the NbS rating informing the environmental risk component of the overall credit assessment. NbS-specific provisions and expected loss modelling are maintained for the ring-fenced portfolio.

• Market risk: Carbon price exposure in the NbS portfolio is monitored as part of the Bank's market risk framework. The Bank does not take direct carbon price positions but recognises that changes in carbon prices affect the revenue models (and therefore the NbS ratings) of projects in the portfolio.

• Operational risk: The NbS product introduces operational risks associated with satellite monitoring infrastructure, independent rating commissioning, community engagement in remote ASEAN locations, and multi-jurisdictional regulatory compliance. These risks are captured in the Bank's operational risk register and subject to standard operational risk management processes.

• Reputational risk: Nature-positive claims made in connection with the NbS Impact Term Deposit are subject to the Bank's Sustainability Claims Review Process, which requires substantiation of all environmental claims with verifiable evidence. The process is designed to ensure compliance with ASIC INFO 271 (Australia) and MAS fair dealing guidelines (Singapore) and to mitigate greenwashing risk.

Metrics & Targets

Disclosure A: Metrics Used to Assess Nature-Related Dependencies, Impacts, Risks and Opportunities

The Bank uses the following metrics to assess its nature-related position through the NbS Impact Term Deposit programme:

Disclosure B: Metrics Used to Manage Dependencies and Impacts

Disclosure C: Targets and Goals

The Bank has established the following nature-related targets for the NbS Impact Term Deposit programme:

Disclosure D: Performance Against Targets

2. ISSB IFRS S1 and S2 Disclosure Template

The following template addresses the Bank's disclosures under IFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information) and IFRS S2 (Climate-related Disclosures) [2] as they relate to the NbS Impact Term Deposit product. The template also incorporates forward-looking elements aligned with the ISSB's Research Project on Biodiversity, Ecosystems and Ecosystem Services [3].

2.1 Governance (IFRS S1 paragraphs 26--27)

Governance body oversight: The Board Risk Committee oversees sustainability-related risks and opportunities, including those arising from the NbS Impact Term Deposit programme. The committee reviews the NbS portfolio quarterly, with particular attention to nature-related financial risks (physical, transition, and reputational) and the Bank's nature-positive impact claims. The committee's terms of reference explicitly include "nature-related and biodiversity-related financial risks" as within its scope of oversight. The committee comprises five non-executive directors, two of whom have relevant expertise in environmental management and sustainable finance.

Management's role: The Chief Sustainability Officer (CSO) has direct accountability for the NbS programme and reports quarterly to the Board Risk Committee on portfolio performance, risk metrics, and impact outcomes. The NbS Lending Committee (chaired by the CSO) exercises delegated authority for project origination, rating review, and allocation decisions. Management's competence in nature-related matters is supported by an external ecological advisory panel comprising three independent scientists with expertise in tropical forest ecology, coastal ecosystems, and peatland hydrology.

Controls and procedures: The Bank's internal audit function conducts annual reviews of the NbS programme, covering allocation compliance, rating integrity, diversification adherence, and impact reporting accuracy. Internal audit findings are reported to the Audit Committee and, where material, to the Board Risk Committee.

2.2 Strategy (IFRS S1 paragraphs 28--35; IFRS S2 paragraphs 13--22)

Sustainability-related risks and opportunities: The NbS Impact Term Deposit creates both nature-related risks (described in the TNFD Strategy Disclosure A above) and climate-related risks and opportunities:

Climate-related risks:

• Physical risks (chronic): Gradual changes in temperature and precipitation patterns across ASEAN project locations may affect ecosystem productivity, species composition, and carbon sequestration rates. The Bank's NbS portfolio is exposed to these risks through the dependence of project financial models on ecosystem service delivery.
• Physical risks (acute): Extreme weather events (tropical cyclones, floods, droughts, El Nino-driven fires) may cause acute damage to NbS project sites, resulting in ecosystem extent loss, condition deterioration, and carbon reversal. The portfolio's geographic diversification across five countries and three ecosystem types mitigates correlated acute physical risk.
• Transition risks: Regulatory changes in ASEAN carbon markets (e.g., tightening of carbon credit methodologies, introduction of Article 6 Corresponding Adjustments reducing the supply of tradeable credits), changes in voluntary carbon market demand, and shifts in sustainability product regulation in Australia and Singapore may affect the economic viability of NbS projects and the Bank's ability to substantiate nature-positive product claims.

Climate-related opportunities:

• The NbS portfolio generates carbon sequestration and avoided emissions of 87,500 tCO2e per year, contributing to the Bank's Scope 3 (financed emissions) reduction objectives.
• Growing regulatory and market demand for nature-positive financial products positions the NbS Impact Term Deposit as a differentiated offering that attracts sustainability-conscious depositors and supports the Bank's sustainable finance growth targets.

Impact on financial position and performance: As of the reporting date, the NbS lending pool represents AUD 138 million / SGD 147 million in credit exposures. The portfolio's expected credit loss (ECL) provision reflects the NbS rating distribution and the nature-related risk overlay. No NbS loans are in default. One project (Kalimantan Peatland Rewetting) is rated at the NbS-BBB threshold and is subject to enhanced monitoring; the Bank holds an elevated ECL provision for this exposure to reflect the heightened risk of rating downgrade.

Scope 3 financed emissions: The Bank reports Scope 3 Category 15 (investments) emissions for the NbS portfolio. The portfolio's net carbon impact is negative (i.e., carbon-positive): the 87,500 tCO2e per year of sequestration and avoided emissions attributable to the NbS portfolio exceeds the estimated 2,100 tCO2e per year of operational emissions associated with the projects (fuel for patrol vehicles, construction materials, transport). The net carbon benefit of -85,400 tCO2e per year is reported as a footnote to the Bank's Scope 3 disclosure, with a methodological note explaining that avoided emissions and sequestration are reported separately from the Bank's total financed emissions, consistent with the GHG Protocol's guidance on avoided emissions accounting.

2.3 Risk Management (IFRS S1 paragraphs 36--39; IFRS S2 paragraphs 23--24)

Identification and assessment: The Bank identifies sustainability-related risks through its enterprise risk management framework, supplemented by nature-specific identification processes for the NbS portfolio. The TNFD LEAP approach (Locate, Evaluate, Assess, Prepare) provides the structured methodology for nature-related risk identification, as described in the TNFD Risk & Impact Management disclosures above.

Climate-related risks are identified through the Bank's Climate Risk Assessment Framework, which applies IPCC AR6 climate scenarios (SSP1-2.6 and SSP3-7.0) to assess physical risk exposure across the Bank's lending portfolio, including the NbS sub-portfolio. Nature-related risks are identified through the NbS rating process, which assesses ecosystem condition trajectory, permanence risk, and social risk as part of the standard rating assessment.

Management: Nature-related and climate-related risks in the NbS portfolio are managed through:

1. Pre-lending screening: All NbS projects must achieve an independent NbS rating of NbS-BBB or above, ensuring minimum standards for environmental integrity, social outcomes, and economic viability.
2. Portfolio diversification: Geographic (max 40% per country), typological (max 30% per NbS type), and rating quality (weighted average at or above NbS-A) limits reduce concentration risk.
3. Ongoing monitoring: Quarterly satellite monitoring and annual on-ground verification provide continuous risk surveillance.
4. Remediation and exit: Defined processes for managing projects that deteriorate below the investment-grade threshold.

Integration: Nature-related and climate-related risks are integrated into the Bank's overall risk management through the credit risk, market risk, operational risk, and reputational risk frameworks described in the TNFD Risk & Impact Management Disclosure C above. The Bank's risk appetite framework includes quantitative limits for nature-related exposures, managed alongside credit concentration limits, liquidity requirements, and capital adequacy targets.

2.4 Metrics and Targets (IFRS S1 paragraphs 40--49; IFRS S2 paragraphs 25--36)

GHG emissions: The Bank reports greenhouse gas emissions in accordance with IFRS S2 paragraph 29. The following metrics relate to the NbS Impact Term Deposit portfolio:

Climate-related targets:

NbS-specific metrics (forward-compatible with anticipated ISSB biodiversity standard):

Cross-industry metric disclosures (IFRS S2 paragraph 29(a)): The Bank discloses the following cross-industry metrics for the NbS portfolio as required by IFRS S2:

References

[1] Taskforce on Nature-related Financial Disclosures, Recommendations of the Taskforce on Nature-related Financial Disclosures (September 2023). The 14 recommended disclosures are organised across four pillars: Governance (A, B, C), Strategy (A, B, C, D), Risk & Impact Management (A, B, C), and Metrics & Targets (A, B, C, D).

[2] IFRS Foundation, IFRS S1: General Requirements for Disclosure of Sustainability-related Financial Information (London: IFRS Foundation, June 2023); IFRS Foundation, IFRS S2: Climate-related Disclosures (London: IFRS Foundation, June 2023).

[3] ISSB, "ISSB Work Plan 2024--2026: Research Project on Biodiversity, Ecosystems and Ecosystem Services," IFRS Foundation, September 2023.

[4] United Nations et al., System of Environmental-Economic Accounting --- Ecosystem Accounting (SEEA EA), White Cover Publication (New York: United Nations, 2021).

[5] GHG Protocol, Corporate Value Chain (Scope 3) Accounting and Reporting Standard (Washington, D.C.: World Resources Institute and World Business Council for Sustainable Development, 2011). Category 15: Investments.

[6] APRA, Prudential Practice Guide CPG 229 Climate Change Financial Risks (Sydney: Australian Prudential Regulation Authority, November 2021).

[7] MAS, Guidelines on Environmental Risk Management for Banks (Singapore: Monetary Authority of Singapore, December 2020).

[8] ASIC, Information Sheet 271: How to avoid greenwashing when offering or promoting sustainability-related products (INFO 271) (Canberra: Australian Securities and Investments Commission, June 2023).

[9] IUCN, IUCN Global Standard for Nature-based Solutions: A User-Friendly Framework for the Verification, Design and Scaling Up of NbS, 1st edition (Gland: IUCN, 2020).

[10] TNFD, Additional Guidance on Assessment of Nature-related Issues in Specific Sectors and Biomes: Financial Institutions (March 2024).