PS1: Environmental and Social Management systems
Tamek has three plants located in Karacabey Bursa , Kiziksa Balikesir and Salihli Manisa: Karacabey Plant produces fruit juices, tomato/pepper paste, canned foods, jams/marmalades, fruit juice concentrates and frozen food; Kiziksa Plant produces fruit juices, fruit juice concentrates, ketchup, mayonnaise, and tomato puree; and, Salihli Plant produces tomato/pepper paste, canned foods, canned “ ready to eat” meals.
Environmental and Social Assessment:
The development of an Environmental Impact Assessment (EIA) study for the proposed project is not required by the local authorities. Nevertheless, the Company, in cooperation with the Ministry of Environment and Forestry, has applied to the EIA Directorate for re-assessment of the plants in light of new capacity increase and upgrade activities. The Company was stated to imply no significant risks to the environment with its current production specifications.
Management Systems and Organization:
All Tamek plants are certified ISO 9001 by the Turkish Standards Institution (TSE) and the International Certification Network (IQNet) in June 2010 and the certification is valid until June 2013. A food safety management system consistent with ISO 22000 and HACCP (Hazard Analysis and Critical Control Point) is up and running, though room for improvement remains. All plants are currently in the process of assessing hazards and preparing HACCP plans to be certified in 2011. R&D Manager and Production Managers are responsible for the execution of the system.
Each plant has its own part-time safety officer and quality engineer who oversee occupational health and safety (OHS) and environmental responsibilities respectively. The company has contracted an OHS Consultant who is certified by the Ministry of Labor as A-Class OHS Specialist as per local legislation requirement. The OHS consultant visits each of the three plants twice a month and carries out the risk assessments, accident root cause analyses, organization of trainings and inspections in coordination with the plant management team and OHS officers (Engineers of Technical Departments) at each plant. Risk assessment studies have not been completed yet in Karacabey and Kiziksa plants; the delay in the process is related to the incomplete deployment of the equipments. Once the installation is completed, risk assessment process will resume.
Tamek has agreements with two environmental consulting companies; Cevretek and Ekoced whose representatives work in cooperation with the quality engineers of each plant. Cevretek is a design and construction company that provides consultancy on wastewater treatment plant operations. On the other hand, Ekoced provides guidance on environmental requirements and monitoring of legal compliances.
The Company will hire a Corporate Environment, Health and Safety (EHS) Manager/Coordinator who will oversee the environment, health and safety issues associated with its operations at all plants and will be responsible for the integration of EHS system in to the existing quality management system.
Tamek will have a more systematic Environmental and Occupational Health and Safety Management system in line with internationally recognized standards, (e.g. ISO14001 and OHSAS18001 respectively) as per the attached Environmental and Social Action Plan (ESAP).
Training:
Tamek has an established training program to provide necessary induction and periodic trainings for all of its direct and contractor employees on EHS aspects related to its operations, including but not limited to PPE (Personal Protective Equipment) usage, specific job trainings, environmental awareness, etc. The Company records and reports all training activities and trainees.
Monitoring: Effluent discharges, air emissions, solid wastes, energy and water consumptions and lost time accidents, customer complaints, suppliers’ performances are among the regularly monitored parameters for the various operations at all plants, in compliance with Turkish regulatory requirements.
Reporting:
Reporting of EHS indicators is done internally as per the requirements of the certified management system and externally to the national regulatory agencies requiring EHS monitoring.
PS2: Labor and Working Conditions
Human Resources Policy and Management:
Tamek currently employs around 370 people temporarily, and the number of employees reaches 1200 during peak production season including the seasonal workers. During the seasonal peak, approximately 580 people are employed at Karacabey, 210 at Kiziksa, 240 at Salihli plants, and 170 is employed in its head office in Istanbul. The contractor employees are approximately 110. As of end October 2010, women employees constituted 35% of the total workforce. Tamek utilizes contracted workforce particularly for cleaning, packaging, security and warehouse operations and has in place mechanisms to control contractor operations to be in line with the Turkish Labor Act 4857. In addition to its regular and contracted staff, the company employs seasonal workers during harvesting and planting seasons due to the increasing production capacity.
Tamek has a well established human resources management system with various internal regulations and procedures that cover all aspects in detail, including recruitment, training, working conditions, performance evaluation, social benefits, disciplinary actions and dismissal.
HR department in the head office oversees general employment policies and procedures under the guidance of HR Manager. Besides, each plant has its own HR unit that reports to the head office. Tamek staff is provided with comprehensive handbooks related to working principles, safe driving, human resources policy and procedures, rules and conditions of collective agreement, emergency preparedness, fire safety and occupational health and safety.
Tamek employees at all plants work 6 days a week in 7.5 hours-shifts with two 15-minute breaks. Number of the shifts is adjusted according to the required production capacity.
For all workers Tamek guarantees minimum wages above the sector average. The annual payment package includes monthly gross salary and a total of 4-months wages bonus except for temporary workers who are paid a 1-month bonus per year. Also family and child allowances, annual leave, religious holiday and fuel allowances are provided to union member employees in the amounts agreed in collective agreement. Overtime is paid in accordance with the Working Conditions regulation and the collective agreement.
There is no issue related to forced labor and child labor and the minimum age of employment is 18 at all plants. Part-time trainee students are employed in cooperation with their vocational high schools and working conditions are applied as per relevant regulations.
Workers’ Organization:
Tamek management has stated that each employee is free to join a worker organization and confirmed the existence of the union at its three plants. Each plant has two union representatives; one male and one female. All blue collar workers (including the seasonal workers) which represent around 65% of the total workforce, are member of Tek Gida - Is Trade Union; a subordination of Turk-Is Worker Confederation. The collective bargaining agreement is renewed every two years. (
http://www.tekgida.org.tr)
Non-Discrimination and Equal Opportunity:
The company has a documented HR policy that precisely indicates company values and working principles with all stakeholders. It is clearly stated in the policy 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. Tamek also complies with the national labor law requirements for non-discrimination.
Grievance Mechanism:
The Company adopts an open door policy and a formal employees’ grievance mechanism exists. Tamek is currently working with Promethus HR consulting company to establish functional re-organization and any employee satisfaction surveys. The consultants are currently meeting with white collar employees and will start the consultations with blue collar employees afterwards. Aside from internal grievance mechanism, external worker protection mechanisms are ensured by the national labor laws and union activities.
Retrenchment:
There are no current plans for retrenchment, however if it becomes unavoidable, the company will implement retrenchment plan in accordance with PS2 and in consultation with the Tek Gida Is Union.
Occupational Health and Safety:
Monthly OHS meeting are held with the participation of occupational physician and nurse, representatives from HR department and technical staff, OHS consultant, and union representatives to identify risks and to continuously improve workplace health and safety 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 for several days of the week in each factory in line with the national Occupational Health and Safety legislation (No: 25311, dated December 9, 2003). A nurse is also employed full time for Karacabey Factory. Contractors and seasonal workers can benefit from same services with direct employees. A medical examination is required for all workers upon the employment. Staff also undergoes medical examination annually, including lung and throat screenings and audiometric tests.
Each plant employs approximately 30 trained first aiders which are above the minimum regulatory requirement of 10% of workforce.
Contractor agreements include clear terms of working conditions, wages and occupational health and safety. Frequent audits are undertaken by Tamek representatives to monitor the compliance of the above requirements.
All employees are provided with free meal and transportation services. A reputable catering company serves meals at all plants in line with hygiene standards. Nevertheless, the capacity of the canteen and social areas in Karacabey factory will be increased to meet with the changing seasonal needs.
Work permission system for hot works, work at height is available in all factories, additionally stand alone worker, electrical works and confined space work permissions will be prepared. Implementation of a work permission system is still ongoing although documents have already been prepared.
All plants and warehouses have detailed maintenance programs for lines and equipment, such as forklifts, pressurized vessels, compressors, boilers, etc. Machine guarding and safety equipment will be improved for all facilities and lock out/tag out procedures for cleaning and maintenance works will be implemented at all sites. Noise measurements will be performed at all workplaces accounting for changing production types (e.g. bottling or canning). There are ongoing studies on improvement of workplace ergonomics such as installation of rotating chairs at the manual working phase of food production. Ergonomic studies will be continuously strengthened in all factories with the contribution of plant physicians.
During the demolishing of old buildings and construction of new buildings, the contractor safety will closely monitored work at height and potential asbestos handling issues, and necessary precautions will be taken.
Fire Safety:
Fire extinguishers and fire hoses are available in all sites and fire drills are conducted every six months. Nevertheless, fire detection and alarm system needs to be installed in each site including warehouses and visitors’ dormitories and be audited by independent fire safety experts. Also, water storage and pump capacities should be evaluated and appropriate extinguishing systems for specific risk areas as well as emergency signage, evacuation routes and emergency lighting should be installed.
Detailed fire safety reports have been prepared by the Turkish Foundation for Fire Protection (TUYAK) for Karacabey (August 2010) and Kiziksa plants (September 2010) and necessary actions have been proposed to the company management.
Supply Chain:
The fruits and vegetables are supplied from the villages in the vicinity of the plants; Torbali, Salihli, Golmarmara, Yenisehir, Karacabey, Kemalpasa, Manyas and Suleymaniye villages. Purchasing methods of fruit and vegetables are done in two ways; contractual purchase from growers and direct purchase from free market. Vegetables like tomatoes and peas which are purchased in bulk amounts are supplied from contracted growers to secure the supply, reduce the risk and ensure the quality. Fruits are supplied from the free market which is a common country practice for fruit juice industry. Annual operation plan is prepared every year in November. Tamek Agriculture department gives continuous support to the contracted growers through its agricultural engineers, technicians and supplies. Tamek has continuously supported the contracted growers during the transmission period from conventional irrigation to drip irrigation and has given trainings to avoid underground over fertilization. In 2009, Turkey started to experience Tuta Absoluta damages in Turkish farms and greenhouses caused by this well-known serious pest of tomato crops in Europe and South America. Tamek has organized trainings to avoid Tuta Absoluta by biological methods and other pests for the contracted growers. Moreover, the company supplies fertilizers and approved pesticides as well as drip irrigation pipes to its contracted growers. Quality specifications for raw materials and Supplier Evaluation forms are used during the purchasing process. The Company will extend its supply chain management system and procedures in terms of environmental and social aspects as per the attached ESAP.
For pesticide management, please refer to “Pesticide Use and Management” section under PS 3, and for GMO (Genetically Modified Organisms) please refer to last paragraph under PS 6.
PS3: Pollution Prevention and Abatement
Resource Conservation and Energy Efficiency:
Total water consumption for the first 10 months of 2010 was around 2.65 million cubic meters (m3) and the approximate water consumption per production figures for each plant are: 12 m3/ton for Karacabey plant, 19 m3/ton for Kiziksa plant and 29 m3/ton for Salihli plant which are considerably higher than the industry benchmark range of 6-6.5 m3/ton. The company will undertake a water audit and study and identify measures to improve water usage efficiency. Tamek will also invest in the recycling system for cooling waters and the re-design of water pipelines at its Kiziksa plant.
The company consumes approximately 67kWh/ton electricity for its operations at all plants. There is an energy management program in place and several projects are being implemented accordingly, such as installation of oxygen meter to stacks for combustion efficiency, heat control application for compressors, and installation of frequency convertors to engines. The Company has also planned to invest in the insulation of steam valves and pipe lines, and installation of speed controllers to the compressors at its Salihli plant. Also, each plant has an energy leader who received the necessary trainings tailored to the requirements of the Energy Efficiency Law of 2007 and the Regulation on Increasing Efficiency in the Use of Energy Sources and Energy of 2008.
Air Emissions:
Tamek operates natural gas fire steam boilers at all plants which essentially limit particulate matter and sulphur oxides emissions. Karacabey and Kiziksa plants obtain the natural gas from the distribution grid, however in Salihli plant, natural gas is provided from two above-ground LNG tanks which are safely sustained in line with regulatory requirements. The maximum measured NOx emission from existing boilers is around 230 mg/Nm3 which is below the IFC Guideline limit of 320 m g/Nm3. The capacities of boilers are a total of 60tonnes/hr for Karacabey and a total of 30 tonnes/hr for each of Kiziksa and Salihli plants. All plants have obtained emission permissions from relevant government authorities and emission measurements are performed by accredited laboratories. Review of the available data indicates compliance with the local regulations as well as with the WBG’s EHS Guideline for Food and Beverage Processing.
Water and Waste Water Management:
Wastewater generated at Karacabey, Kiziksa and Salihli plants range between approximately 500- 4500 m3/day, 100-1700 m3/day and 500-5000 m3/day respectively, depending on seasonal variations in production capacity, thus the amount of process water utilized. In Kiziksa and Salihli plants, domestic wastewater and process wastewaters are treated in biological treatment plants and discharged into Karadere and Gediz Rivers respectively.
Periodical measurements of the discharge waters are conducted including COD, TSS and pH parameters and the results satisfy both the local discharge limits (100 mg/L, 100 mg/L and 6-9 for COD, TSS and pH respectively) and WBG’s EHS Guideline for Food and Beverage Processing. Currently Karacabey plant wastewater is discharged to Susurluk River via irrigation channels, however the relevant permission for connection to the municipal sewage system was obtained in December 2010 and accordingly the construction of a wastewater treatment plant (with the capacity of 5000 m3/day) and a 7.5 km long discharge pipeline has just started.
The Company will extend the wastewater monitoring program in all plants to cover all parameters within the applicable WBG’s EHS guidelines in addition to local requirements. This will ensure that good treatment practices are consistently implemented at all sites where treated effluent is discharged to the surface water.
Solid and Hazardous Waste Management:
Solid non-hazardous waste and hazardous waste management at all plants visited 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). The product packages have a green dot and recycling code as required by relevant legislation.
Hazardous waste generated at all plants mainly includes fluorescent lamps, print cartridges, contaminated packages, edible oil and waste hydraulic oil. The company has planned the construction of a hazardous waste collection area for its Karacabey plant.
Waste oil is collected by a licensed company for processing and re-use. Process waste sourced from mayonnaise production is collected and sent to the licensed company ALBIO1 for biodiesel production.
Cooling agents:
The warehouses use 7.5 tons of ammonia (NH3) as a refrigerant in their cooling systems. Tamek will ensure that its handling and storage practices are in line with the best industry practice and the ammonia unit is periodically maintained by experts and equipped with safety features required to comply with national regulations for working with ammonia. The relevant emergency action plan as well as PPE usage will be improved. The Company will also have a phase-out plan for all ozone-depleting agents used at its plants.
Pesticide Use and Management:
Tamek is committed to develop a formal Pesticide Management Plan for its supply chain which will cover the areas of pesticide selection and handling, application and storage, staff training, safety requirements, and disposal, consistent with national laws and regulations, IFC policies and guidelines and World Health Organization (WHO) guidance. The Company will immediately suspend the use of all pesticides that fall in WHO classification as Class 1a and 1b, and will properly dispose of any remaining stocks.
PS4: Community Health, Safety and Security
There are no immediate households or neighbors in the vicinity of Karacabey and Salihli plants. Tamek employs unarmed private security personnel from ABS Security Management and they are regularly trained and certified as per the local regulatory requirements. All plants are monitored via CCTV (Closed Circuit Television) systems.
Raw materials and finished products are delivered in bulk via trucks. 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.
Tamek 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 and food safety system. Traceability practices and product recall procedures are available in case of any need.
PS6: Biodiversity Conservation, Sustainable Natural Resources Management
Water used at Tamek plants for production purposes and other operations is sourced from artesian wells and is treated with filtration and reverse osmosis. Water samples are sent to an accredited lab every three months for assessment. Tamek has obtained the operating licenses for all of the seven wells used at Salihli plant. The licenses for five of nine active wells in Karacabey and five of eight active wells in Kiziksa will be obtained in 2011. The Company will also commission a hydrogeological evaluation of the existing wells to ensure that the reserves of ground water allow for the current and future extractions while maintaining sustainability, quality and taste.
Tamek Kiziksa Plant is located 25 km south of Lake Manyas which is a listed RAMSAR (Convention on Wetlands of International Importance) Wetland site and national park (Manyas Bird Paradise) important for bird breeding but no impact on this site has been encountered or anticipated.