PS1: Social and Environmental Assessment and Management Systems;
Tiryaki Agro’s operations is mostly concentrated in Gaziantep, including the sourcing, processing, storage and trading of grains, pulses, oil seed and nuts with the capacities of 240 mt/day pulses, 400 mt/day bulgur, 480 mt/day lentils, 250 mt/day packaging for retail and 1200 mt/day for bulk products, 25 mt/day pistachio and 92,000 mt storage
In addition, Tiryaki Agro initiated the construction of a storage and processing facility in coastal city of Mersin Free Zone in 2011. The facility with a storage capacity of 141,000 mt covers a total area of 51,000 m2.
Environmental and Social Assessment:
Submission of an Environmental Impact Assessment (EIA) study for the proposed Project is not required by the local authorities in Turkey (EIA Legislation, dated July, 17, 2008, No: 26939). Nevertheless, Tiryaki will have a third party Environmental and Occupational Health and Safety audit for both Gaziantep and Mersin facilities against the applicable local and national requirements and IFC’s Environmental and Social Standards and WBG’s relevant EHS guidelines as per ESAP and Tiryaki will complete audit gaps in a timely manner. Tiryaki has received an Industrial License from the local authorities for the Gaziantep facility and reported compliance with country’s relevant legislations.
Management Systems and Organization:
Tiryaki Gaziantep plant obtained the ISO9001:2008 certification and the ISO 22001:2005 (Food Safety Management) certification, both of which have been certified until 2013. Kosher certification, organic certification and compliance certification with Bio-Suisse standards are also available.
Organization:
Quality and environment issues at the Tiryaki Gaziantep facility are overseen by the Quality Manager and his assistant, whereas OHS issues are under the responsibility of the HR and Administration Manager. An OHS consultant was hired to follow-up with relevant legal requirements. In addition, Tiryaki will assign a Corporate Environment, Health and Safety (EHS) Manager/Coordinator who will oversee the environment, health and safety (EHS) issues associated with its operations at both plants and will be responsible for the integration of EHS system into the existing quality management system. Establishing a corporate level EHS function will ensure a consistent approach to EHS issues across all of Tiryaki’s operations. The Company will have a more systematic Environmental and Social Management system in line with internationally recognized standards. Supply chain management system procedures will be also integrated into the corporate Environmental and Social Management System. The schedule for developing and implementing these changes is included in the attached ESAP.
Training:
A training program is established to ensure that staff competency levels are maintained and address competency gaps, if necessary. The HR manager updates the program as needed during the year to include new training needs identified during the normal course of operations. OHS and fire trainings are given to all employees on a yearly basis. Staff engaged in food operations that come directly or indirectly into contact with food are trained, and/or instructed in food hygiene principles and practices to a level appropriate to the operations they perform. All employees are made aware of their roles and responsibilities in preventing food from contamination and deterioration.
Monitoring:
Solid wastes, energy consumption, lost time accidents and customer complaints are among the monitored parameters for the various operations at Tiryaki Agro plants, in compliance with relevant regulatory requirements. Going forward, and as set forth in the ESAP, effluent discharges and air emission parameters will also be monitored. Reporting of quality indicators is done internally at weekly department meetings and annual management review process as per the requirements of the certified management system. The management review topics include, but are not limited to, the following: follow-up actions from previous management reviews; analysis of results of verification activities; changing circumstances that can affect food safety; product recalls/withdrawals; review of system updating activities; internal audits results; review of communication activities, including customer feedback and target setting for the following year.
PS2: Labor and Working Conditions
Human Resources Policy and Management:
Tiryaki currently employs 726 peoples, including 279 managerial and 446 operational staffs. Among these, female workers constitute approximately 23 percent of the total workforce. No contractors are employed in the Tiryaki Gaziantep operations except for construction workers.
Human resources (HR) management system of Tiryaki is presently under a review process by a HR Consultant Company. General guidelines on Tiryaki policies and procedures for employees cover key aspects, including recruitment, employment categories, and training, working conditions, workplace rules, performance management, social benefits, disciplinary actions and dismissal. Hours of employment comply with local regulations in Turkey and with PS2 requirements. The Company’s employees are entitled to sick leave, maternity leave, compassionate leave, traditional holiday leaves, vacation days and marriage leave for certain days depending on their seniority and contract type. Tiryaki’s wage scales meet or exceed the minimum wage in Turkey. All employees are provided with proper meal and transportation services.
There is no issue related to forced labor and child labor and the minimum age of employment is 18 years old at all plants.
Workers’ Organization:
There is presently no active trade union at the Gaziantep facility, although Tiryaki has indicated that it does not prohibit the establishment of workers’ associations at any of its facilities. The Company will modify its HR policies to include a clear statement supporting the right to freedom of association.
Non-Discrimination and Equal Opportunity:
Company complies with the national labor law requirements for non-discrimination and has a documented hiring procedure. It will be explicitly stated in the HR hiring procedure that the Company is an equal opportunity employer, and does not make employment decisions on the basis of personal characteristics unrelated to inherent job requirements.
Grievance Mechanism:
The Company adopts an open door policy and an informal employees’ grievance mechanism exists. Tiryaki is currently working to establish employee satisfaction surveys and questionnaires.
Retrenchment:
There are no current plans for retrenchment; in fact, the Company plans for an increase in production capacities that will require recruitment of additional labor from the local market. In the event that retrenchment becomes unavoidable, the Company will develop and implement a retrenchment plan in accordance with PS2 and the Turkish labor law.
Occupational Health and Safety:
Tiryaki has adopted OHS procedures and instructions for its operations, and has developed an OHS training program to cover regulatory requirements, duties and responsibilities, and job-specific risks of employees in line with the local legislation requirements. Monthly OHS meeting are held with the participation of occupational physician and nurse, representatives from HR department and technical staff, OHS consultant to identify risks and to continuously improve workplace OHS conditions. Outcomes of the workplace incident evaluation forms are also discussed during these meetings which result in a time bound action plans.
A workplace physician works several days a week in the factory in line with the national Occupational Health and Safety legislation (No: 25311, dated December 9, 2003). Construction workers also can benefit from same services with direct employees. A medical examination is required for all workers upon their recruitment. Staff also undergoes medical examination annually, including lung and throat screenings and audiometric tests.
First aid kits are available for easy access, where needed. The HR Manager is responsible for the overall first aid program and the Company ensures that at least 10% of its employees received first aid training.
Number of lost time accidents for last 12 months was 11 with 102 lost days. In accordance with the timeframe outlined in the ESAP, the Company will implement a work permission system including hot works, electricity, work at height and confined spaces. The Maintenance Department is responsible for proper operations of plant equipment using an established preventive maintenance program.
Tiryaki will perform comprehensive risk assessments for all its production lines and workplaces to further reduce the risk of accidents as set forth in the ESAP. Housekeeping, dust aspiration systems, machine guarding for packaging equipments and electrical installations will be improved and be free of dust, thermo-graphic analyses of electrical installations will be done.
Personal Protective Equipment (PPE) usage is generally adequate at the facilities. As part of its efforts to enhance its overall OHS program, the Company will undertake workplace monitoring at the facilities, including noise, dust, and temperature and light measurements for all workplace and outside areas of the plants.
All new machinery acquired for the Mersin plant will be installed and approved according to EU Machine Directive. Construction workers safety rules will be strictly implemented during Mersin plant construction.
Fire Safety:
At the Gaziantep facility, key fire prevention equipments, including fire extinguishers and fire hydrants, as well as evacuation signs are in place. The Mersin facility will be constructed, and operated in full compliance with local building codes, local fire department regulations, local legal/insurance requirements, and in accordance with an internationally accepted Life and Fire Safety (L&FS) standard.
Supply Chain:
Tiryaki’s primary products are pulses (lentils, rice, chickpeas, peas, bulgur and beans - 49% total), grains (barley, wheat and corn – 35% total), nuts (pistachio, almond, walnut, and peanut – 9% total) and other products (oil seeds, organic cotton and animal feeds – 7% total). More than 60% of overall sourcing is international whereas the remaining 40% is domestic. Domestic sourcing is done through brokers. International sourcing is done from contracted farmers for organic products and from organized markets for conventional products. The supply chain departments maintain written specifications for ingredients of products. The purchasing information requests the following documents to be shipped with every lot of incoming materials: Health certificate; GMO certificate with the shipment lot number; Data sheet including pesticide residues and heavy metals analysis; Product specifications; Aflatoxin certificate; Fumigations certificate; Allergen information. Incoming lots are sampled and tested against certificates of analysis. Test results are maintained by Quality Control department. Whenever new commodities are purchased from new suppliers, Tiryaki evaluates and analyzes the ingredient. Going forward, Tiryaki Agro will continue and expand the scope of its supply chain’s assessment of suppliers in terms of labor (child and forced labor) and biodiversity-related risks associated with the conversion of natural and critical habitats, in addition to the existing quality assessment system. In case of a supplying country or a region having a high risk of harmful child labor, forced labor and/or deforestation, the Company will search for new suppliers to avoid the above mentioned risks. Supply chain risk assessment and management will be enhanced as outlined in the ESAP. For instance, cotton supplied from Kirgizstan and Turkey and soy bean from Brazil may carry harmful child labor risks and deforestation risks respectively. Tiryaki will use best commercial efforts to mitigate these issues in their supply chain and report specific data in the supply chain management system reporting procedures.
PS3: Pollution Prevention and Abatement
Air Emissions:
The Gaziantep facility operates natural gas fire steam boilers which essentially limit particulate matter and sulphur oxides emissions. The facility obtains the natural gas from the distribution grid. Emission permit from relevant government authorities is available. With the changing needs and economical concerns, Tiryaki’s technical department have installed coal fired fluidized bed boilers for the Gaziantep facility. The new system will be commissioned in 2012. The emission measurements will be in line with the WBG’s Air Emissions Guidelines and new permit will be submitted before operation starts.
Water and Waste Water Management:
Periodical measurements for the discharge waters are not available. The waste water is discharged to a central industrial waste water treatment plant (WWTP) in the Gaziantep Industrial Zone. The discharge parameters of this central WWTP are in line with both local and WGB effluents guidelines.
Solid and Hazardous Waste Management:
Solid non-hazardous waste and hazardous waste management are well established, involving waste segregation and reduction. Packaging waste is recycled in collaboration with CEVKO (Environmental Protection and Packaging Waste Recovery and Recycling Trust).
Cooling agents:
The organic products storage use approximately 70 kg of R22 as a refrigerant in their cooling systems. The Company will have a phase-out plan for all ozone-depleting agents used at its plants.
PS4: Community Health, Safety and Security
The Tiryaki’s Gaziantep facilities are located in the Gaziantep Industrial Zone and the new facilities are located in Mersin Free Zone, so there are no immediate households or neighbors in the vicinity of the facilities. Tiryaki employs unarmed private security personnel and they are regularly trained and certified as per the local regulatory requirements (Law No:518).
Raw materials and finished products are delivered in bulk via trucks. As set forth in the ESAP, the Company will ensure that adequate internal controls are in place to ensure that vehicles and trucks entering and leaving Company facilities are well tracked and in good condition. The Company will ensure that traffic rules and vehicle maintenance periods are strictly followed by its outsourced distribution fleet.
Tiryaki Agro has an active grievance mechanism for the customer complaints and regularly monitors the number and root cause of complaints and under the scope of Good Manufacturing Practices (GMP) and food safety system. Traceability practices and product recall procedures are available, in case of any need.
PS5: Land Acquisition and Involuntary Resettlement
For the time being, the Company does not need to undertake land acquisition. In the eventuality of future expansion projects involving land acquisition, the Company will address potential impacts in accordance with Turkish requirements and PS5.
PS6: Biodiversity Conservation, Sustainable Natural Resources Management
Potential issues associated with the conversion of natural and critical habitats, including deforestation risks, are not currently assessed by the Company. In parallel with the requirements in PS2, those supply chain risks will also be assessed and managed as part of the proposed Company’s supply chain management system procedures.
Genetically-modified organisms (GMOs) are considered alien species. Any new introduction of such organisms through supply chain should be assessed in a manner consistent with the existing host country regulations and in compliance with the Cartagena Protocol for Biosafety.
