📝 usncan Note: Supermarkets, Biodiversity And Species Loss
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Climate risk once dominated the ESG agenda. Now biodiversity risk is fast becoming the next corporate flashpoint. At the center of this shift is an unlikely symbol: the “Save the Skate” campaign, launched by investors, NGOs, and community groups in Tasmania to protect a critically endangered species from supermarket supply chains.
The Maugean skate, a ray that has survived for 60 million years, lives only in Macquarie Harbour on Tasmania’s rugged west coast. Scientists warn that the population is collapsing and could be gone within a decade. It’s decline has been linked to salmon farming in the harbour, which reduces oxygen levels in an already fragile ecosystem.
For investors and campaigners, the connection is clear: Coles and Woolworths, Australia’s two dominant supermarkets, are the largest buyers of salmon from the harbour. Both retailers have marketed it under their own-brand labels as responsibly sourced.
A local question about how to address the problem has now leapt onto the global stage. Environment Tasmania has filed a complaint against Woolworths under the OECD Guidelines for Multinational Enterprises, the most widely recognized international standards for responsible business conduct. This will be the first case worldwide to test the OECD’s newly revised biodiversity provisions, which call for heightened due diligence in relation to endangered species and protected areas.
While the process is not legally binding, it is backed by government-run National Contact Points that can investigate complaints, mediate disputes, and issue findings with significant reputational weight. If accepted, it would set an important precedent for how international frameworks hold companies accountable for biodiversity risk.
For campaigners, it marks an escalation from shareholder advocacy into the realm of international grievance processes. For investors, it signals that biodiversity risk is no longer peripheral but tied to global frameworks in the same way climate and human rights issues already are.
Shareholders Escalate Biodiversity Risk To The Board
The campaign has moved beyond NGO advocacy into the heart of shareholder activism. In 2024, resolutions calling on Coles and Woolworths to address the risks their salmon sourcing posed to the Maugean skate achieved votes of 39% and 30% respectively. These were the largest shareholder votes on biodiversity risk anywhere in the world that year.
“Shareholder resolution votes act as a barometer for investor sentiment,” said Kelly Roebuck, vice chair of Environment Tasmania and Sustainable Seafood campaign director at Living Oceans. “Last year, Woolworths faced one of the largest votes for a nature-risk resolution ever. Numerous institutional funds from Australia and abroad, representing millions of members, called for Woolworths to act for the skate. If Woolworths had listened to their shareholders it may not have been necessary to lodge a complaint with the OECD.”
Despite the results, neither company committed to exit Macquarie Harbour. Coles has quietly stopped using the responsibly sourced label on its Tasmanian salmon, though it still references third-party certifications in product details — a move critics say creates a green halo without addressing biodiversity risks. Woolworths has made little visible progress.
That refusal prompted a second wave of resolutions in 2025. Business leader and environmental advocate Geoff Cousins joined Tasmanian NGOs and ethical share trading platform SIX as a lead filer at Coles. “It’s a complete failure of their risk management if Coles needs to be dragged by their shareholders into stopping an extinction caused by their salmon supply,” said Phoebe Rountree, campaigns manager at SIX.
Woolworths now faces even higher stakes. The OECD complaint argues that the company failed to disclose foreseeable biodiversity risks, misled consumers with its responsibly sourced label, and neglected its obligation to conduct heightened due diligence in a World Heritage area – as the skate is listed as an outstanding value of the Tasmanian Wilderness World Heritage Area. If accepted, it would also be the first OECD case globally to test biodiversity provisions against a major retailer.
A Woolworths spokesperson said the company’s “commitment to sustainability is intrinsic to the business and its operations” and pointed to its seafood sourcing policy, which requires all own-brand seafood to be certified or independently verified as ecologically responsible. Woolworths said it had undertaken a detailed risk and impact assessment in 2025 for all farmed species, including potential impacts on threatened species, and that the assessment “confirmed no new material risks exist outside those already being actively managed by our seafood sourcing standards.”
The spokesperson also noted steps by the federal government to enable salmon farming to continue in Macquarie Harbour and highlighted recent University of Tasmania research suggesting a rebound in skate numbers. For Woolworths, the challenge may be that acting on biodiversity risk means navigating scientific uncertainty, supplier relationships, certification standards, and government regulation — none of which lend themselves to quick fixes
The Limits Of Certification In Managing Biodiversity Risk
At the heart of the dispute is the credibility of voluntary certification schemes. Coles and Woolworths rely on Best Aquaculture Practices (BAP), ASC and GLOBALG.A.P. to validate their salmon sourcing. Farms in Macquarie Harbour lost Aquaculture Stewardship Council (ASC) certification in 2018 after failing to meet environmental standards, but they continue to be certified under other schemes.
“These applications are used as a green shield,” Roebuck told me in an interview and Rountree added, “An endangered species that’s only found in one small place on the planet could be completely missed. That’s why due diligence frameworks are so important.”
Independent reviews reinforce the concern. A WWF-commissioned study found that both ASC and BAP had failed to prevent environmental impacts in Macquarie Harbour. Complaints lodged with certification bodies were dismissed with “nothing to see here” responses, according to campaigners
Sophie Ryan, chief executive of the Global Salmon Initiative, acknowledged that biodiversity risks are “unique to each region” and that responses must be tailored. “Our members are working closely with local universities and industry stakeholders to ensure minimal impact at every site… This is an evolving area, and we remain committed to staying at the forefront of science and technology to ensure our members are farming to the highest environmental standards,” she said.
For investors, those assurances underscore the gap between industry narratives and international expectations. The OECD Guidelines, revised in 2023, make clear that certification and voluntary standards cannot substitute for company due diligence. That gap is now at the heart of the conflict.
Why Investors Are Paying Attention To Biodiversity Risk
For investors, the issue is no longer just reputational. Salmon farming faces a wide range of operational and financial risks: mass mortality events, disease outbreaks, harmful algal blooms, and reliance on wild-caught fish for feed. These risks can drive volatility in supply, raise costs, and threaten profitability. When compounded by the potential extinction of an endangered species, the governance implications are stark.
Ryan argues that shareholder resolutions “play an important role in providing direction and raising awareness,” but that real impact requires “complete supply chain transformation – from ingredient sourcing and farming practices, to processing and transport, and even consumer education.” For investors, that position reflects both the scale of the challenge and the frustration that progress remains slow.
Australian regulators are already scrutinizing greenwashing. A Senate inquiry has examined the use of responsibly sourced labels on salmon products, raising the prospect of enforcement action. Globally, initiatives such as Nature Action 100 (of which Woolworths is a member) are demanding that companies disclose biodiversity risk and set concrete targets.
The OECD complaint signals that voluntary measures are no longer enough. Companies are expected to act on the best available science, even in the absence of government intervention. For investors, the concern is simple: if boards fail to address such visible biodiversity risks, what confidence can there be that they are managing other, less visible risks across their supply chains?
A Global Precedent For Biodiversity Risk Governance
What happens next will matter far beyond Tasmania. If the OECD complaint against Woolworths proceeds, it will test how international grievance mechanisms apply to biodiversity. If investors succeed in winning majority support at Coles, it will mark the first time shareholders have forced a retailer to change sourcing practices to protect an endangered species.
Either outcome would set a precedent for how biodiversity risks are handled by companies worldwide. From palm oil in Indonesia to soy in Brazil and mining in Africa, supply chains intersect with fragile ecosystems and threatened species. The “Save the Skate” campaign may prove to be just the beginning of a broader reckoning.
The Unanswered Biodiversity Risk Questions
There are still gaps in the public record. Neither Coles nor Woolworths has disclosed the volume of salmon sourced from Macquarie Harbour, making it difficult for investors to assess exposure. Neither has published site-specific biodiversity risk assessments, despite referencing the Taskforce on Nature-Related Financial Disclosures in sustainability reports.
Without greater transparency, investors are left to rely on NGO research and shareholder resolutions to push for accountability. “It’s astonishing that Coles is willing to gamble being associated with a potential extinction,” Roebuck said, “instead of listening to their customers, shareholders, and investors’ funds, representing millions of members, who are simply asking for Coles to be a responsible business leader and remove a small amount of their salmon supply.”
A Flashpoint For Corporate Accountability
Biodiversity loss is accelerating worldwide. The Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services warns that more than one million species are at risk of extinction. For companies, the question is whether they treat this as a marginal CSR issue or as a material governance and financial risk.
Coles and Woolworths are about to provide an answer. The Woolworths case illustrates why biodiversity has become such a difficult governance challenge: companies are caught between certification schemes, shifting science, shareholder activism, and international guidelines, with no easy answers. Yet the pressure is only going to build, and boards that fail to act decisively on visible biodiversity risk may find themselves facing not only reputational fallout but escalating activism, litigation, and regulatory intervention.
The Save the Skate campaign is more than a fight for one species. It is a test of whether boards can adapt to the age of biodiversity risk, or whether — as with climate — it will take years of activism, litigation, and financial loss to force their hand.
