The company has presented extensive information on its current practices and policies that seek to address these risks and impacts to ensure that the proposed Project currently complies with or will upon implementation of specific additional agreed measures, comply with host country laws and regulations and the IFC Performance Standards on Social and Environment Sustainability and environmental, health and safety guidelines. Information about how these potential impacts are or will be addressed by the sponsor/project is summarized in the paragraphs that follow. Additional actions are summarized in the attached Environmental and Social Action Plan (ESAP).
Integrated Management Systems
- Environmental and Social Management System:
Atateks has implemented an ISO 9001:2000 certified Quality Management System for their four operations in Turkey (Corlu, Kirac, Uzak and Istanbul). The company has developed and implemented a Code of Conduct which specifies the environmental and social policies for all their operations. These include pollution prevention, reduction of resource consumption, respect for human rights, terms of employment and working conditions. Sewing and finishing operations in Turkey and Jordan are WRAP (Worldwide Responsible Apparel Production) certified. The operation in Jordan has also obtained Golden List Certification from the Jordanian government and is subject to frequent labor audits from its US and European customers. Atateks has also obtained certification of its dyeing operations to Oeko-Tex Standard 100, which is a global testing and certification system for textile raw materials, and intermediate and end products at all stages of production. The certification ensures that chemicals used and end products do not contain substances that are prohibited or regulated by law, or chemicals which are known to be harmful to health.
Although Atateks has a well established quality management system, environmental, health and safety and social management aspects are less well integrated into the system. The organizational structure is decentralized and plant managers have ultimate decision making power with regards to environmental and social issues. Monitoring and reporting of EHS and HR issues needs to be reinforced and information needs to be more systematically employed by senior management in order to further improve performance and help ensure consistent implementation of industry good or best practices. Training programs are reviewed on a yearly basis in order to ensure training needs are captured and delivered. A responsible person for human resources issues at a corporate level has been appointed since 2006. At present, this corporate-level position determines company wide policies and procedures to be implemented at the factory level, with responsibility for implementation left to the individual plant personnel and plant managers. There is a need to strengthen the current senior-level management capacity/structure in place at the corporate level to ensure consistent application, accountability and oversight of Atateks’ human resource, environmental, and health and safety policies and procedures on a consistent basis.
The company can enhance its corporate level capacity to manage EHS and HR issues by recruiting or designating two or more senior-level professionals with clear responsibilities and decision making power. These two positions will have a general oversight and better understanding on actions to improve EHS and HR performance at all operations and be responsible further building out and enhancing the existing management system framework to create a more fully integrated management system to ensure consistency and improve EHS and HR performance at the operational level. This integrated management system shall achieve ISO14001, OHSAS 18001 and SA8000 certification at all existing operations in Turkey and Jordan within two years following IFC signing.
- Environmental and Social Assessment:
All facilities have all legal operational permits provided by the Turkish authorities which confirm that all operations are in compliance with national laws and regulations. Atateks undertakes assessments which includes environmental and social requirements and are in compliance with local laws. Assessment of buildings in terms of life and fire safety, wastewater treatment, access to energy and water is not performed as consistently as it can be. Atateks will include environmental, health & safety, human resources and social aspects consistent with IFC’s Performance Standards as part of their due diligence process for new acquisitions. For their Greenfield project in Egypt, Atateks will produce an ESIA in accordance with IFC guidelines and send to IFC for review and comment. Corrective measures will be implemented to ensure compliance with local and IFC requirements if and as necessary.
Labor and Working Conditions
- Human Resources Policy:
Atateks has a well-conceived and acceptable Human Resources (HR) policy and procedures which include aspects of recruitment, working hours and overtime, holidays, sick and annual leave, wages and benefits, employees’ and employers’ responsibilities, disciplinary practices, promotion and a grievance mechanism. The HR policy and procedures are based on Atateks’ Code of Conduct and are readily accessible to employees. Policy and procedures are communicated to all employees on notice boards near the cafeteria, through a one day induction training at all facilities, and through each employment contract. Contracts clearly state terms of employment and working conditions as per national regulations. Turkish authorities undertake labor and OHS inspections on a yearly basis and clients, including major European and American Brands, conduct labor audits of the company’s garment manufacturing operations in Turkey and Jordan. Following review of internal and externally sourced documentation and interviews with management and external parties, as well as on-site inspection, there are currently no significant non-compliances against clients’ Codes of Conduct, although some practices can be further improved to ensure consistency of good or best industry practice.
The total number of employees at Atateks is 1,785. Normal working hours are 48 per week based on a 6 days working schedule, worked in some facilities on a 3 shift basis. Overtime is up to 2 hours per day and it represents 2-3% of total hours worked in Turkey and 8% in Jordan. Overtime is compensated at a premium of 25% on normal days and 50% on holidays. Minimum wage in Atateks is 585 YTL/month gross in Turkey and 110JD/month gross in Jordan. All payments are done on time and through bank transfers. Wage compensation offered by Atateks is average compared to the textile industry in the area. In the case of Jordan where the majority of the workforce consists of resident guest workers, satisfactory dormitory facilities and provision of three meals a day in addition to salary. Benefits include paid national holidays and annual leave in accordance with Turkish and Jordanian law, health insurance, pension, transport and food. Average turnover rate is 2-3%, and absenteeism is below 1%. Atateks is planning on expanding its operations to Egypt in the medium term and at this stage there are no plans to reduce the labor force.
- Workers Organization:
Atateks does not have an officially-recognized trade union representing workers in any of its facilities at present and does not enter collective negotiations with any worker organizations. However, the workers in the Kirac, Istanbul and migrant guest workers in the Amman plants have elected workers’ representatives who serve as liaisons with management. In the case of the Corlu facility the workers’ representative is a qualified professional hired and appointed by management. Workers at the Corlu facility shall elect a workers’ representative for each separate production plant within the facility who can liaise with the management-hired workers’ representative on a regular basis. At the Amman facility, IFC has advised the company that Jordanian workers also need to elect their workers’ representative. In order to further improve worker-management communication, ensure any grievances rise quickly to management attention and to help ensure transparency in workers’-management relationship, Atateks will ensure that all workers’ representatives are freely chosen by the workers through a voting system. Atateks in consultation with IFC will establish clear responsibilities and describe the main function of a workers’ representative in order for workers to better understand the scope of the function. Training will be provided accordingly.
- Non discrimination and equal opportunity:
The HR Policy is based on Atateks values and procedures include non-discrimination on recruitment, disciplinary practices, issues that are grounds for dismissal, performance rewards and grievance procedures. Approximately 35% of the staff is women which are both at the plant level (stitching and quality assurance) and in middle management. Freedom of expression and religion is enforced at all facilities and time/area for prayers are provided.
- Protecting the Work force:
Atateks’ contracts require a minimum age of 18 years and literacy for all workers. Date of birth and identity cards are checked as part of the hiring process. No apprentice program is used at the facilities in Turkey and Jordan. Migrant guest workers are contracted in Jordan where the selection and hiring process incorporates several steps as determined by Jordanian legislation. The process of hiring migrant workers is done through certified agents (list is provided by the migrant workers country of origin in Jordan) and Atateks has all records to ensure compliance with national law. Roundtrip airfare is paid by the company and is not deducted from the employee’s salary. Current practice is the agreement on a 3 year contract and residence status is reviewed by Jordanian authorities every year through a medical exam. Working hours, overtime and salary structure is the same as for Atateks’ Turkish operations. In addition they are offered accommodations in dormitories, three meals per day and medical care, without any payroll deduction. In case of hospitalization and need of medicines, Atateks covers 100% of the cost. Dormitories are adequate and in an area outside of the industrial zone. Through inspection, review of records and workers interviews it was determined that labor and working conditions are adequate in compliance with national legislation and IFC guidelines. In order to further ensure adherence with best practice in the sector, Atateks shall seek participation in the pending “Better Works Jordan” Program, a new initiative co-sponsored by the Jordanian Government, ILO, IFC, USAID and others, should this program be implemented.
- Grievance mechanism:
Employees can express grievances through three channels:
- providing written comments via suggestion boxes located in every plant; in Jordan the suggestion box is locked and keys held by the ministry of labor who checks content on a monthly basis
- by engaging an immediate supervisor or human resources manager, and
- requesting that issues or concerns be communicated to management via workers’ representatives who are also part of the disciplinary committee.
In addition, management has an “open door” policy, and in some cases grievances are addressed by the CEO directly. The relevant personnel manager at the plant level is responsible for ensuring that a response addressing issues of concern is provided and the human resources department generally takes the lead in addressing complaints. The grievance process is documented; however, to further improve transparency, Atateks will clearly define the associated management review process.
- Outsourcing operations:
Atateks outsources its dying, printing and finishing operations for 100% of their yarn production at the plant in Istanbul. At present there are no environmental or social provisions in the contract with companies providing these services. Atateks will develop a screening mechanism in order to ensure that these companies comply with national regulation regarding environmental, health and safety, human resources and social aspects. Atateks will also ensure that EHS and terms of employment provisions are included in contracts with these companies, and that these companies implement these provisions to address these issues consistent with PS2.
- Occupational Health and Safety:
In general the client provides workers with a relatively safe and healthy work environment. The factories are not overcrowded, the temperatures are acceptable and sufficient breaks are allowed during the day (for Turkey: 1h30min lunch break and two 15 min breaks and for Jordan: 1h lunch break and two 15 min breaks); the shifts vary based on operation and plant.
Lost time due to accidents are monitored and reported in a systematic manner in Corlu, and show a decrease in relation to the two previous years. Atateks will ensure that accidents statistics are recorded and monitored at all their operations following the model used at Corlu. Atateks does maintain MSDSs for all chemicals used, though chemical storage and handling needs to be strengthened. Workspace air quality has been monitored for temperature and noise parameters. Most of the results are within WBG/IFC guidelines, however not all parameters are monitored. Atateks will begin monitoring of fumes and VOCs and compare them with WBG/IFC guidelines. Following such monitoring any necessary corrective actions will be implemented in order to ensure reduction or elimination of any avoidable health risks that may be identified and can impact the workforce. There is a permanent doctor at the plants in Corlu, Amman and Uzak. The doctor at the Istanbul facilities and HQ is shared during the working days. The company doctors stated not having identified any occupational illness among employees.
OHS risk assessment can be further systematized, in part to clearly identify some areas which could pose health risk to the workers and which have not been clearly identified. Personal Protective Equipment (PPE) is provided and required to be used but on-site observation indicated there is a lack of consistent enforcement in some facilities or production lines. General housekeeping in some of the production facilities could also be improved.
- Life and Fire Safety:
Life and Fire Safety aspects are managed in an appropriate manner, however Atateks will assess their fire risk at all warehouses and report on any corrective actions for improvements consistent with best practice. Atateks will implement corrective actions should the report show this to be necessary to meet local or IFC requirements. Fire exits and signs are clearly visible at almost all facilities. Some improvement is necessary at the yarn manufacturing plant in Istanbul, to ensure easy evacuation for workers and visitors. Portable extinguishers and fire fighting equipment are available at all facilities. Fire drills are undertaken at least on an annual basis and trained fire wardens are appointed in each plant. In Corlu, fire drills are undertaken annually. In Jordan, fire drills are undertaken every 6 months.
Pollution Prevention and Abatement
- Effluent management:
Effluents generated at the garment and yarn manufacturing operations in Amman and Istanbul are mainly domestic and stormwater. These effluents go to the municipal wastewater system. At the integrated plant in Corlu wastewater includes: wastewater from dying and washing, domestic wastewater, and stormwater. Corlu has a well operated wastewater treatment plant with a total capacity of 1,500 m3 per day, which include domestic and process wastewater. Stormwater is not treated. Primary treatment system includes aeration and sedimentation ponds. Sludge is collected daily in tanks and disposed in an approved landfill. Daily monitoring of treated effluent at the discharge point is done and parameters measured pH, BOD5, and COD are within local and IFC minimum requirements. Parameters such as Total Suspended Solids (TSS), oil and grease, heavy metals and color are not monitored. Atateks will monitor and report all as per IFC guidelines, for industrial wastewater at their operations and it is recommended that independent third party analysis should be undertaken to define a verifiable baseline. Atateks will upgrade the waste water treatment system should monitoring show this to be necessary to meet local or IFC requirements.
- Air emissions:
Emissions to air are products of combustion arising from boilers, three gas-fired engines at the cogeneration plant in Corlu, and emissions from drying, printing, washing and finishing processes. Electricity used at Corlu is generated by three gas fired 3 MW engines in a cogeneration system, as well as electricity bought from the grid during 24 hour periods when prices per kWh are lowest. Monitoring data of particulate matter, NOx and SOx are within local and IFC requirements. Atateks will measure VOC emissions to air from its dying and printing operations, and will report these measurements to IFC. If results exceed IFC guidelines, Atateks will implement corrective actions according to an implementation plan to be presented to IFC. Atateks uses 2 boilers, with heat input capacity of 4MWth and 6MWth. They operate at approximately 60% capacity and between 400 and 520 hours per year. Due to their capacity, no emission monitoring is required by national law or IFC guidelines.
- Energy efficiency:
The team at Corlu has the technical capacity to undertake energy audits and a number of effective energy efficiency measures have been implemented in the past year, generating a reduction in consumption and cost savings. Other energy efficiency opportunities remain and Atateks will undertake an energy audit at all operations, analyze feasibility of recommendations and implement improvement measures identified on an agreed timeline.
- Water use and consumption:
Water consumption is not significant at most of the plants. At Corlu three deep wells provide water for the plant, no monitoring of water supply is done at the moment. The lease for extracting water from the wells is for 30 years and license is provided by the local authority.
- Hazardous materials:
Atateks has Oekotex certification for all the chemicals used at their dying operations. Hazardous materials are adequately managed at most of the operations; however storage and handling of chemicals in some of the plants needs to be improved. No adequate containment for sulfuric acid at the Corlu plant was observed. Atateks has MSDSs for all chemicals used. Atateks will assess its hazardous material management and present and implement recommendations for improvements according to best practice and begin a control and monitoring program.
- Solid Waste Management:
Solid waste generated is mainly comprised of yarn scraps, paper waste, fabric, plastic containers and cartons. All are collected separately and sold for recycling. Atateks will assess its solid waste management and present recommendations for improvements according to best practice and begin a control and monitoring program.
- Community Health, Safety & Security:
Impacts and risks to nearby communities are limited and no documented complaint has been presented since beginning of operations. At Corlu the company is managing and operating a deep well which provides water to the nearby community. Liability with respect to this issue shall be assessed. Security guards are used at all operations and are not armed.
