PS1: Social and Environmental Assessment and Management Systems;
PS2: Labor and Working Conditions;
PS3: Pollution Prevention and Abatement;
PS4: Community Health, Safety and Security;

While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment may have impacts which must be managed in a manner consistent with the following Performance Standards:

PS1: Social and Environmental Assessment and Management Systems;
PS2: Labor and Working Conditions;
PS3: Pollution Prevention and Abatement;
PS4: Community Health, Safety and Security;

No issue related to PS5 Land Acquisition and Involuntary Resettlement has been identified in relation with current expansion projects as MNT provides services at existing buildings/areas provided by the hospitals. Clinics owned by MNT are developed either as greenfield projects or at existing buildings rented or purchased based on willing buyer/willing seller basis.
MNT facilities are located within urban areas, therefore, there is no issue in relation to PS6 and PS7 namely biodiversity conservation, sustainable natural resource management and indigenous people. No adverse impact has been identified on cultural heritage with regard to PS8.
MNT will incorporate all IFC Performance Standards on Social and Environmental Sustainability into its management system and will accordingly evaluate future expansion projects to ensure operation in full compliance with IFC requirements.

The key environmental and social issues related to this project include regulatory compliance; structural design and safety; radiation safety; life and fire safety; hazardous materials and waste management; human resources policy and practices; engagement with communities. 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 Procedure.

Environmental and social risk mitigation measures will be as described in the following paragraphs.

PS1: Social and Environmental Assessment and Management System

Management Systems and Assessment: MNT operates under robust assessment and management systems established in accordance with the international standards. Nuclear medicine and radiotherapy operations in Turkey are strictly controlled and certificated by the Atomic Energy Institution of Turkey (TAEK - Turkiye Atom Enerjisi Kurumu), which is a member of International Atomic Energy Agency (IAEA). Some of MNT’s healthcare facilities within Turkey are accredited by the European Association of Nuclear Medicine (EANM). All MNT facilities in Turkey and other countries (currently including Moldova and Romania) are actually established in line with the European norms and the Company aims to gradually extend the accreditation to the entire facilities.

The Company has established a quality management system in accordance with ISO 9001:2008 and is in the process of extending certification to all its operational centers and clinics within a defined action plan. The Company targets to achieve integrated management systems certification in accordance with the ISO 14001 and OHSAS 18001 standards as well. Workplace risk assessments and monitoring, hazardous materials and waste management procedures as well as emergency preparedness and management procedures are readily established and being implemented at all operational centers and clinics.

Health care services provided by MNT are controlled also by the Ministry of Health in the countries where MNT operates. In Turkey, the inspections cover a broad range of topics similar to the Joint Commission International Accreditation standards recognized by the World Health Organization. In accordance with those standards; health care organizations must develop policies, systems and procedures addressing the following areas: access to care and continuity of care, patient and family rights, assessment and care of patients, medication management and use, quality improvement and patient safety, prevention and control of infections, staff qualification and education, management of communication and information, governance, leadership and direction, facility management and safety including but not limited to medical equipment management, preventive maintenance of equipment and utilities, hazardous materials and waste management, emergency management.

MNT will formally incorporate all IFC Performance Standards on Social and Environmental Sustainability into its management system and will accordingly evaluate future expansion projects to ensure operation in full compliance with IFC requirements and internationally agreed standards.

Organization: Establishment and coordination of overall quality and environmental management systems is the responsibility of the Bozlu Group Quality Department under supervision of Group Medical Director. The establishment of procedures and control of implementation at the operational sites are under strict control and supervision by the Group Medical Director of Nuclear Medicine and the Group Medical Physics Director of Radiation Oncology. Key responsibilities of the management, medical, technical and administrative staff are documented in accordance with the ISO 9000:2008 standards and other regulatory norms that the Company is adhered to. MNT will review its organization and management systems documentation and ensure that IFC Performance Standards are formally incorporated and assignments made to monitor performance at each center which is operational or under developmental phase as well as at the corporate level. Additional resources will be provided as necessary.

Training: Trainings for staff are organized and ensured by the Group Medical Directorate. All staff members and contractor employees receive induction training at hire and regular refresher trainings. Training includes, but is not limited to; management systems, service excellence, risk assessment and control with particular focus to radiation safety, emergency preparedness and response, and infection control mechanisms.

Monitoring: Quality and EHS (Environment, Health and Safety) monitoring programs at hospitals and clinics are set in line with the internationally agreed regulatory requirements on operation of health care facilities, radiation safety, other OHS (Occupational Health and Safety) regulations and ISO 9000:2008 standards. Beside, MNT will regularly submit to IFC an Annual Monitoring Report on Environmental and Social Performance prepared in accordance with the IFC’s Performance Standards and guidelines.

PS2: Labor and Working Conditions
Labor Relations: MNT has an internal human resources procedure which describes in particular, hiring and contract making processes, promotions and general working conditions in line with the local regulations. The minimum age of employment at MNT is 18. There is no discrimination on the basis of personal beliefs or characteristics and company management reports no prohibition or discouragement of freedom of association. Actually, there is no union activity or collective agreement in the operational units, employees are working through individual contracts. Retrenchment is not anticipated in the near future; in fact, MNT is currently in a growth phase. Employees are free to communicate grievances directly to the management. MNT is in the process of updating its human resources procedures and practices in line with the latest regulations in Turkey and making necessary arrangements for the control of overtime working and provision of extended leave period to be 30 days/year and. MNT will also review its internal Human Resources procedures to include formally a structured internal grievance redress mechanisms for its staff and contractors as well as to ensure that all IFC Performance Standard 2 (PS2) requirements are formalized within the Company policy and procedures. MNT will ensure that corporate human resources policy and procedures and OHS practices are consistently implemented at all countries of operations in addition to local regulatory compliance.

Occupational Health and Safety: MNT has in place several programs to ensure occupational health and safety for the employees in its centers and clinics. All staff members receive training and are qualified to deal with specific risks of their workplaces, particularly about radiation safety. The personnel working in the radiotherapy and nuclear medicine areas are equipped with dosimeters and the exposure of relevant staff members to radioactivity is regularly controlled by TAEK (Atomic Energy Institution of Turkey). The radiation levels at the workplaces are also continuously or regularly monitored according to risk level. The dose limits of occupational exposure according to the Directive 96/29/ Euratom – Ionizing Radiation, laying down basic safety standards for the protection of the health care employees.

MNT will develop occupational health and safety control mechanisms also for the contractor and sub-contractor work, at project development, construction and reconstruction phases. GLOBUS is the main contractor company undertaking design, construction or reconstruction tasks for the development of MNT departments and clinics. Occupational health and safety rules and other working conditions in accordance with the IFC PS2 requirements will be included in the contractor and sub-contractor agreements. MNT and GLOBUS will establish regular inspection mechanisms to ensure compliance to the contract requirements.

PS3: Pollution Prevention and Abatement
Hazardous Materials and Waste Management: Radiopharmaceutical products, nuclear therapy, imaging, and radiotherapy equipment are supplied from reliable, certified sources, transported by licensed contractors in line with the international regulations and standards, appropriately stored and utilized at operational MNT units. Radioactive wastes are managed in line with the regulations set by the Atomic Energy Institution of Turkey which is a member of International Atomic Energy Agency (IAEA). Radioactive wastes are stored at isolated on-site storage facilities with controlled access until the radiation levels becomes acceptable for disposal. All hazardous waste is transported by authorized organizations and disposed of at government approved facilities.

Other Wastes and Effluents Management: Treatment rooms where patients are treated by radioiodine I-131 are equipped with isolated lavatories and collection tanks from which discharge is permitted after the retention period for decay of the radionuclide. Non-hazardous domestic wastewater is discharged to the municipal sewer system without any specific requirement. Non-hazardous waste is collected and disposed of by the municipality. MNT will develop its waste management program towards waste minimization, collecting recyclable wastes separately, where feasible.

Resource Conservation and Energy Efficiency: MNT sites use infrastructure and utilities provided by the hospitals where they are located. For the development of outpatient centers owned by MNT, the Company will take into consideration energy and resource efficiency at design phase and implement building management systems where applicable.

PS4: Community Health, Safety and Security

Community Health and Safety / Hazardous Materials Supply: MNT has strong supply chain control mechanisms both for equipment and radiopharmaceuticals in line with the international regulations. MNT centers and clinics are equipped with new generation medical equipment strictly controlled in accordance through certified quality management systems as well as by regulatory authorities particularly to ensure radiation safety for the patients and outdoor communities both for routine operations and at emergency cases. The medical equipment and areas as well as radiation monitoring apparatus are subject to robust regular maintenance and calibration programs. Areas at risk are isolated through lead shielding and leakage tests are conducted by the regulatory authorities prior to licensing and regularly during operational phase. MNT will further review its risk assessment and monitoring programs and make benchmarking between operational sites to ensure consistent protective measures are implemented at all operational sites.

Building structure and seismic risks are reviewed by the civil engineers and architects of GLOBUS, prior to the establishment of MNT units in operational hospitals or conversion of existing buildings into nuclear medicine units, in order to prevent any potential damage by the heavy structure of lead shielding required to ensure radiation safety at nuclear treatment and radiotherapy areas. MNT will ensure that formal risk assessments conducted at each operational unit include evaluation of life and fire safety provisions and means of evacuations.

MNT will establish an effective communication with the management of the hospitals where it operates and will formalize a framework for systematic sharing of internal and third party verification documents on life and fire safety and building structural safety. Inspection records, risk assessment documents and implementation of planned mitigation measures will be tracked in a documented manner to ensure compliance with the regulations and internationally agreed standards. MNT will develop formal review and screening mechanisms on life and fire safety and building structural safety for its prospective accommodation to ensure safe operations prior to start-up.

In addition to the licenses regarding radiation safety, MNT will provide IFC with the master plans prepared by qualified professionals and documents related to the verification by third party experts on life and fire safety and building structural safety of its own outpatient centers which are operational or under construction and relevant measures to be in compliance with national and internationally agreed standards. All new buildings shall be designed and operated in full compliance with local building codes, local fire department regulations and in accordance with internationally agreed life and fire safety standards. All life and fire safety requirements apply to existing buildings programmed for renovation. Suitably qualified professionals will conduct a complete life and fire safety and building structural safety review of existing buildings slated for renovation. Improvement actions will be implemented in accordance with the findings and recommendations of the review.

Security: MNT employs unarmed security personnel in accordance with the IFC’s PS4 requirements in its headquarters, outpatient centers and other buildings.

PS5: Land Acquisition and Involuntary Resettlement
No issue related to PS5 Land Acquisition and Involuntary Resettlement has been identified in relation with current expansion projects as MNT provides services at existing buildings/areas provided by the hospitals. Clinics owned by MNT are developed either as greenfield projects or at existing buildings rented or purchased based on willing buyer/willing seller basis.

MNT has Quality Management and Marketing & Communications Department to establish strong mechanisms to receive and address client and community concerns and provide information about its operations under close supervision of Group Medical Director for Nuclear Therapy and Group Medical Physics Director of Radiotherapy operations.

MNT is working in line with the agreements set with Social Security Institutions and is committed to comply with all regulatory requirements associated. Hence, its health care services are maintained easily accessible to large communities from all income levels.

MNT has been actively involved in strong cooperation with academic institutions in order to contribute research and development in nuclear therapy and radiotherapy.

MNT will continue to perform and extend community engagement activities in a structured manner.

Contact Name: İsmail Dernek
Address: Dr. Sevket Bey Sokak. No:5 19 Mayis Mahallesi Sisli/Istanbul
Tel: 00 90 212 231 03 03
E-Mail: mailto:ismail.dernek@bozlu.com