While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The appraisal concluded that any impacts will be limited, site-specific and can be addressed by adhering to generally recognized performance standards, guidelines or design criteria. Therefore, this is a Category B project according to IFC’s Environmental and Social Review Procedures.

Key EHS issues related to this provisional category B project include EHS practices during construction; life and fire safety; and waste management. Performance Standards (PS) 1-4 were identified as applicable to this project. PS 5 was not identified as being applicable as no involuntary economic or physical displacement has been required; PS 6 was likewise not identified applicable as the site did not contain any valuable biodiversity or ecosystem services. PS 7 and PS 8 were not identified as applicable due to the absence of Indigenous Peoples and cultural heritage at the project site.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment and Management System: Both of the ATM project partners (YDA and INSO) have obtained certification of their management systems against the requirements of ISO 9001 (Quality Management), ISO 14001 (Environmental Management) and ISO 18001 (Occupational Health and Safety Management). Both YDA and INSO are experienced in developing/implementing similar projects, and will operate according to the requirements of these management systems during construction and operation of the Kayseri Integrated Health Campus. The project company (ATM) will establish a similar integrated environmental, health and safety and quality management system in line with ISO 9001, ISO 14001 and OHSAS 18001 as prior to the Project starting commercial operations. ATM is also required by Ministry of Health regulations to become Joint Commission International (JCI) certified.



The project was exempted from the national EIA requirement under Environmental Impact Assessment Regulation published in the Official Gazette No. 26939, dated 17 July 2008, as indicated in an official correspondence from the Ministry of Health Public-Private Partnership Directorate on August 5, 2011. However, the Company retained an independent environmental consulting firm (MGS Muhendislik Musavirlik A.S.) to prepare an ESIA in accordance with IFC requirements; the report, including an ESAP, is attached to this ESRS. Development of this health campus project includes planning and design, construction and operation stages, and each is subject to review by regulatory authorities to confirm compliance with national regulations and internationally agreed standards, particularly relating to EU regulations and norms. Construction safety, life and fire safety, wastewater discharge, handling and disposal of medical wastes all require specific permits and licenses. Radiotherapy and nuclear medicine equipment are under strict control of the Atomic Energy Institution of Turkey (TAEK).



In accordance with the Turkish environmental regulation, the Project will acquire one integrated environmental permit mainly covering project permit (construction of new facility), water use and discharge permit, waste management operation permit, hazardous substance consent permit, noise permit and air quality permit. This integrated environmental permit will be completed once the facility becomes operational.



Organization: YDA establishes an Environment, Health and Safety department for all its construction projects based on the integrated management system requirements and will apply this practice to Kayseri Health project, under the supervision of the project manager. ATM will hire an OHS lead engineer with A-class (the highest available in Turkey) OHS specialist certification, as well as several OHS engineers with C-class certification. Kayseri Integrated Health Campus Project will also appoint a full time Environmental Officer or will procure a credible environmental consulting servic
es firm authorized by the Ministry of Environment and Urbanization during both construction and operation phases as per ‘Environmental Officer and Environmental Consulting Firms Regulation’.



Training: In accordance with the company’s hiring procedure, all employees will undergo orientation and job specific training following a probation period. An extensive OHS training program will also be provided to all site employees for a one-year period which is comprised of 45 minute- sessions covering various OHS aspects. ATM will provide IFC with the log of trainings as a supplement to the Annual Monitoring Report (“AMR”).



Monitoring

Quality and EHS monitoring programs at the health campus will be established in line with the regulatory requirements and integrated management system standards. An environmental monitoring program, which focuses especially on the construction period, is included in the Environmental Management Plan for the project. During construction, air quality, surface and ground water quality, noise and soil quality will be monitored at regular intervals against relevant Turkish standards and World Bank Group guideline limits. When operations begin, monitoring will be expanded to include solid and hazardous waste disposal.



Reporting: Reporting of EHS indicators will be done internally as per the requirements of the certified management systems and externally to the national regulatory agencies requiring EHS monitoring. ATM will regularly submit to IFC an AMR on environmental, health & safety and social performance prepared in accordance with the IFC’s Performance Standards and EHS guidelines.



Emergency Preparedness: As part of the OHS Procedures Book, an Emergency Response Plan has been prepared. The plan addresses the responsibilities the emergency response coordinator and the emergency response team, and specific emergency response plans for each emergency situation (accident, earthquake, fire, storm, road accident and spill). The Company will update this Emergency Response Plan based on the final arrangement with contractors for the construction phase.

Human Resources (HR) Policy and Management: ATM expects to have 2000 employees on site at the peak of construction. Once the health campus becomes operational, approximately 410 specialized and general practitioners and 1500 assistant healthcare personnel will be employed by the Ministry of Health.



ATM has an internal HR procedure which outlines, in particular, the hiring process. As per commitments made via the ESIA process, ATM will establish a Human Resources policy and procedures to include formally structured internal grievance mechanisms for its staff and contractors as well as to ensure that all IFC Performance Standard 2 requirements are included within the policy and procedures. The company operates in accordance with The Turkish Labor Code that extensively covers workers’ conditions, worker and employer rights, retrenchment, leave, minimum wages, discipline, the relationships between workers, companies and unions, and other labor issues.



For all workers, ATM guarantees that the minimum age of employment is 18 and all workers including contractor workers are and will be registered to national social security system. There is no discrimination on the basis of personal beliefs or characteristics unrelated to inherent job requirements and company management does not prohibit or discourage freedom of association. Retrenchment is not anticipated; in fact the project has potential to create additional job opportunities in the region. Nevertheless, ATM will mitigate possible job losses of the current support staff/service providers in the existing clinics by prioritizing the procurement of these service companies and staff in the new integrated facility. The health personnel management in the closed clinics will be overseen by the Ministry of Health and the Ministry shall take all responsibility related to the staff as stipulated in the Project Agreement.



ATM adopts an open door policy and workers are free to directly communicate their concerns to supervisors and managers. If any complaint arises that cannot be solved by the immediate supervisor, the Project Manager will be available to address all concerns. This will be captured in a worker grievance mechanism.



Occupational Health and Safety (OHS): The Company published its OHS rules in July 2012. This comprehensive document contains the company’s OHS policy, description of the OHS Committee including functions and procedures, and various health and safety instructions about safety signs, personal protective equipment, trainings, emergency preparedness, labor camp safety, chemicals management, machinery, electrical work and all other construction works, noise, dust, fire safety, safety education and first aid. Accident reporting and root-cause analysis procedures and documentation are available. ATM is in the process of establishing an OHS organization comprising of an OHS Lead Engineer, OHS specialists and designated site staff for continuous monitoring and implementation of OH
S practices. The company will provide appropriate training to workers on occupational health and safety issues. Personal protective equipment will be provided to relevant workers and periodic checks of use will be conducted in accordance with the local regulations.



In order to provide health care services such as first aid and emergency treatment to the personnel working during the construction phase; an infirmary unit will be established in construction site and the company will sign an agreement with a nearby hospital for ambulance and clinical services.



Contractor safety: During project construction, the company will work with several contractors and employ approximately 2000 site personnel. With regard to the construction of the proposed project, the client contract requires contractors to comply with its OHS regulatory requirements. Evidence of good practice, such as use of appropriate personnel protective equipment and safety measures were observed during the visit to the construction site. Following IFC appraisal, the company reviewed contractor agreements in line with the OHS Rules document described above, to ensure full implementation of the occupational health and safety and environmental management system during construction.

Resource Conservation and Energy Efficiency: Groundwater resources will be utilized during the construction period and necessary permissions will be obtained from the relevant regulatory agency. Water used during the operational phase will be supplied by municipal networks. Electricity will be supplied from the city grid and natural gas will be the main source for ambient heating in the facilities. ATM have installed 40 solar panels (1.2m x 2.0m) at the construction site and will use solar energy for heating purposes during operations, saving up to 800 m3 natural gas per month. The company will utilize a natural-gas fired co-generation system at the clinics and will determine the reliable level of installed capacity needed according to the final design specifications of the buildings. ATM will review and consider local and IFC requirements for air emissions in the selection of the specific technology and will perform periodic monitoring of the emissions as required by regulatory authorities. The emission levels will comply with the maximum limits in the Turkish Industrial Air Pollution Regulation, Air Quality Regulation and World Bank Group Environmental Health & Safety Guidelines.



Kayseri Integrated Health Facility will be equipped with computer controlled building management systems and Heating, Ventilation & Air Conditioning (HVAC) to optimize energy consumption. ATM will continue to develop water and energy conservation programs, benchmark with sector best practices and report annually to IFC about relevant resource conservation initiatives.



Hazardous Materials Management: Hazardous materials such as disinfectants, laboratory chemicals, and others used in the hospitals and clinics will be supplied from reliable, certified sources and stored in locked and appropriately cooled and ventilated storage areas. The cooling systems at hospitals and clinics will utilize non ozone-depleting HFC refrigerants.



Waste management: ATM has developed an extensive waste management plan and accompanying procedures for each type of waste that includes appropriate disposal methods, waste minimization and collection of recyclable wastes wherever feasible. Non-hazardous solid waste will be segregated by type and either disposed of by the city municipality or sent to licensed companies.



Infectious and pathological waste, wastewater from radiology units and other hazardous wastes from laboratories will be segregated at source, collected at designated containers, appropriately stored on-site, then transported and disposed of by authorized contractors. Collection and disposal of the medical wastes in the project will be done in line with the Turkish Environmental Legislation (“Medical Wastes Control Regulation” published in the 22.07.2005 dated and 25883 numbered Official Journal). Once the necessary protocols are completed, medical waste disposal from both construction and operation phase will be made to Kayseri Medical Waste Treatment Sterilization C
enter in Molu region which has been authorized by Kayseri Metropolitan Municipality and operates in line with EU norms.

ATM has reported that radioactive wastes from body and organ imaging, tumor localization and similar units in the clinics will be managed in line with the regulations set by the Atomic Energy Institution of Turkey, which is a member of International Atomic Energy Agency (IAEA). ATM will submit to IFC documented radioactive waste management procedures to ensure compliance with national regulations as well as with IAEA standards and guidelines.



Effluent Management: Domestic wastewater produced in both construction and operation phases will be discharged to the Kayseri Advanced Biological Treatment Wastewater Facility and relevant sewage connection permits are obtained. Kayseri Advanced Biological Treatment Wastewater Facility is designed to treat domestic and partially industrial wastewaters with an average daily capacity of 150,000 m3/day. Radiation treatment departments will be equipped with isolated lavatories and collection tanks from which discharge is permitted after the retention period for decay of the radionuclide.



Wastewater arising from the cleaning of mixers at the concrete batch plant will be collected in sedimentation tanks and reused for washing purposes. Solid residue from the tanks will be disposed periodically according to the Solid Waste Management Plan.



Greenhouse Gas Emissions: Estimates of the CO2 equivalent emission resulting from operation of the health campus is based on energy consumption per one patient at similar facilities, or a total of 9170 tons CO2 equivalent per year. Actual data will be used to review the GHG footprint of the facility once it is operational.

There are no residential areas adjacent to the Kayseri Integrated Health Campus Project site. Currently there is a waste collection center and interurban bus station to the south, and some arable land to the north and the west. Typical risks associated with the development of this project are increased traffic of heavy machinery, noise, dust, and hazardous material handling and fire and life safety. The ESIA concludes that with the proposed mitigation measures, those risks will be minimized to comply with relevant environmental standards.



Life and Fire Safety: ATM has developed a Fire Safety Master Plan and outlined the general principles and measures in the ESIA document. For this integrated health campus project, ATM commissioned a life and fire safety consultancy with experience of international standards to work on the Fire Safety Master Plan and site-specific design and confirm that all the LFS-related aspects of design are compatible with an internationally recognized fire and life safety code (NFPA codes), as required under the life and fire safety section of the WBG EHS General Guidelines. Following construction, third party fire safety professionals will inspect the newly constructed buildings and ATM will submit to IFC certifications from these professionals that each facility is designed, constructed, and operated in full compliance with local building codes, fire department regulations, and all LFS aspects of the Fire Safety Master Plan. This commitment is captured in the attached supplementary ESAP. Any remedial measure needed to bring the buildings into compliance with IFC guidelines and one of the internationally recognized standard will be completed within a timeframe agreed by IFC.



Security Personnel: There are currently four unarmed security personnel on site but the Project will involve a private licensed company to provide general (unarmed) security to safeguard the property. The health campus will be equipped with video surveillance system which will be operated during 24 hours. The Project area is relatively safe and no major risks to the workers or community (which is located at some distance) are expected.

There are no directly affected communities associated with this project. Stakeholders include various municipal agencies, service providers, staff members from existing health centers who will be transferred to the new facility by Government and potential hospital users.

The project was publically announced in Turkey in 2011 at a large project introduction ceremony attended by the Prime Minister and involving widespread media coverage and information sharing. Thereafter project information was made available to the public via the company website, the Government and various media articles and programs. Public consultation during the ESIA included questionnaire surveys and interviews involving around 250 households in the general vicinity of the project site. As mentioned above, however, there are no residences immediately adjacent to and affected by the project site and thus the project has not been required to develop a formal Stakeholder Engagement Plan.

The final ESIA is attached with this ESRS and has been disclosed in Turkey (in 2012), as well as the websites of Governorate of Kayseri, Kayseri Provincial Health Office and the project partners. The ESIA contains a community grievance mechanism commensurate to the risks posed by this project.

Necip ATAY, PPP Projects General Coordinator
YDA İnsaat Sanayi ve Ticaret A.Ş.Vedat Dalokay Cad. No:112 Gaziosmanpasa – Cankaya 06700 Ankara, Turkiye Tel : +90 312 459 44 00Fax : +90 312 436 82 79

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Provide post-construction certification from the qualified Life and Fire Safety professional acceptable to IFC verifying based on the inspections that building’s construction adequately incorporates all elements of the engineering design laid out in the Life and Fire Safety Master Plan.	11/01/2016