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 Project’s potential risks and impacts include: management of environment, health and safety on site during both construction and operation, waste and wastewater management, noise and light emissions, emergency response planning, stakeholder engagement and site security. Because the reclaimed site is being created by land filling 34 hectares of the adjacent Marmara Sea bottom there is no land acquisition, nor are there sensitive habitats involved. Archeological remains of an ancient Roman and Byzantine town lie outside the project area. Given the limited scope and scale of the potential impacts, which are largely confined to the project site and can be addressed through known technology and procedures, the Project has been identified as a Category B project under IFC’s 2012 Policy Social and Environmental Sustainability.

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.

The Company will put in place an environmental and social policy consistent with the Performance Standards and Turkish laws, particularly those implementing MARPOL 73/78. The Company will also commit to good international industry practice and continuous improvement in its environment, health, safety, and social performance. The policy will be approved by senior management, who will also identify the lines of responsibility within the Company for its implementation.



The Company retained a Turkish environmental consultancy, AK-TEL Muhendislik, to prepare an environmental impact assessment (''EIA'') under Turkish law and regulations. This EIA was approved by the Provincial Directorate of Forestry and Environment in December 2006 (Decision No. 1184). Following changes in the terminal layout, the EIA was supplemented by a Project Description File report in 2007. A certificate was given in December 2007 confirming that a new EIA was not required. These permits were well in advance of the start of construction in 2011. The EIA was the subject of one local consultative meeting. The Company also commissioned studies that may be considered more technical in nature, but also relate to potential environmental impacts from the project. They include a modeling study for material transport along the coast and an earthquake risk study. The Project will prepare a study on the potential impacts from climate change.



The February 2009 Occupancy Permit places a broad requirement on the project to put in place the necessary measures to prevent environmental and marine pollution during the period that the property is being used. The Project is required to observe the relevant legislation. Additionally, where adjoining land is under the ownership of the Turkish Republic, particularly the coast and its beaches, access will be kept open to the public.



Under Turkish law, Asyaport was not required to prepare EIAs for its quarrying activities because each of their surface areas is below 25 hectares. The permits for the quarries did, however, spell out certain environment, health, and safety requirements for how they were to be operated, including a ban on blasting, appropriate disposal of solid waste and wastewater, no fuel storage on site, protection of two nearby streams from site run-off, and putting in place a rehabilitation plan once all the material had been extracted.



The Project needs systematic management and monitoring of its environmental and social aspects and impacts. A construction phase environmental, health, and safety (“EHS”) management plan will be developed that will include procedures to ensure that the project meets the commitments set out in the Turkish EIA, the Concession Agreement, Turkish law, particularly with respect to MARPOL 73/78, as well as the environment, health and safety requirements of the IFC. These will include a waste management plan, a dredging management plan, an emergency response plan, and a quarry rehabilit
ation plan. The Company will also develop an environmental monitoring plan, which will include monitoring of WBG EHS guideline parameters.



For the operation phase, TIL will implement its already-developed QDMS3 integrated management system, which has ISO 9001, ISO 14001 and OHSAS 18001 certification. Key elements of the integrated management system will be in place prior to the start of the feeder quay operations in late 2013. There will also be an operational phase monitoring program, which should include ambient air quality, noise, illumination, wastewater discharges, shoreline profile, and marine biodiversity.



The Company will appoint qualified environmental and health and safety officers. Under Turkish law, these officers must have specific education and training, followed by an examination, to be qualified for the position. The Company will make sure that the person hired has the appropriate qualifications. The Company will also develop and implement an EHS training program. The training for the construction phase will include contractors as well as Asyaport employees up to and including Senior Management. An A grade licence holder safety officer has been employed and a training programme is being implemented also covering subcontractors.

During operations, Asyaport will have approximately 700 staff working in 3 shifts 24 hours per day. Aysaport does not currently have a human resource policy, but relies on the terms and conditions in individual contracts for informing workers about their terms of employment. The Company will develop a human resources policy that will detail the conditions of employment, e.g., compensation and benefits, working hours, occupational health and safety, and ensure non-discrimination and equal opportunity in hiring and promotion. There are no labor unions representing workers at the Project, but Asyaport does not discriminate against those who wish to belong to unions. There is a workers’ representative on the management committee for the Project who was elected by the workers. As part of its human resources policy, Asyaport will identify a grievance mechanism, which will provide timely feedback to worker concerns.



Going forward, Asyaport will take reasonable measures to ensure that construction contractors and subcontractors will follow the appropriate and relevant labor and working condition requirements of Turkish labor law, which is based on the ILO core labor standards, and the IFC Performance Standards. This will include conditions in EPC contracts, as well as monitoring contractors and subcontractors to determine if they are complying. Furthermore, once established, the worker’s grievance mechanism will be open to the employees of contractors and subcontractors. The Company will put in place pre-qualification criteria based on the PS for the hiring of future contractors and subcontractors and will put provisions with respect to compliance with the PS and EHS Guidelines into their contracts.



As on-site construction continues, Asyaport will take a comprehensive approach to health and safety management by hiring a qualified H&S specialist and developing a health and safety management plan, an H&S monitoring program, risk assessments and standard operation procedures, and a training program. Management of health and safety during operation will be, as mentioned, under MSC’s QDMS3 integrated management system. The Company will also establish an H&S Committee, as required by Turkish regulations, which will be a forum for communicating H&S issues and improving worker relations.

Solid waste is currently segregated on site, with scrap metal being sold to dealers and wastepaper being given to collectors. Tires are collected by a specialized, licensed waste management company. The remaining wastes are given to the Municipality of Barbaros. Asyaport will prepare a waste management plan (“WMP”) for remaining future construction and for operation. During operation, Aysaport will continue to segregate wastes from its own operations and dispose of appropriately. It will also provide a temporary solid waste facility for the storage of solid waste coming from vessels. The WMP will describe how these vessel wastes will be handled, which will probably be through the Greater Municipality of Tekirdag.



Dredging has, to date, been minimal. However, an area of 140 m by 330 m along the feeder quay will be dredged to a depth of -13 m CD. A dredging management plan will be required for regulatory approval, particularly with respect to the disposal of dredging materials. No dredging is anticipated during operation.



The project will prepare and carry out a closure plan for the quarries. The closure plan will protect public safety, while contributing to the improvement of what was originally modified habitat.



The construction site has above-ground diesel storage tanks that need to be contained within a bund and a refueling area that is on bare ground. Other hazardous materials comprise oils and lubricants, paint, thinners and polishes used for maintenance purposes. Waste oil is removed by a specialist waste management firm. The storage areas for these materials need to be inventoried, the materials labeled, and material safety data sheets (“MSDS”) posted nearby. Staff awareness about the handling of these materials will be improved through training under the EHS training program.



During operation, Asyaport will have a Hazardous Materials Management Plan and Oil Spill Response Plan. There will be no bulk storage or transfer of hydrocarbons on site. All the same, there will be spill equipment on site, and the Company will enter into a contract with a specialist firm to provide oil spill response support.



In addition to possible spills, a risk is posed by the handling of containers loaded with dangerous materials. It is unlikely that these will include explosives and radioactive materials. The project will have a dangerous goods management plan and will implement training to go along with it. Furthermore, any dangerous cargo at the port will need to be cleared in advance with the Port Authority.



Asyaport will have both an emergency response plan and an oil spill contingency plan. The emergency response plan will include a fire fighting plan. Fire fighting equipment will be kept on site. The plans will be developed with local authorities, such as the Tekirdag Fire Department and the Port Authority.



Currently, domestic sewage is sent to a buried septic tank, which is emptied by a contractor. Storm water ru
noff during the remainder of construction will need to be controlled to avoid sediment running into the ocean.



During operation, a wastewater treatment plan will be built to handle effluent from the terminal’s facilities, but also to potentially handle ship-generated sewage. MSC cargo ships generally have onboard treatment facilities and use strategically located waste management facilities, the closest of which is in Malta. Bilge water will be run through an oil separator before being sent to a storage tank. The separated oil and water will be taken off-site for disposal. The treated discharge from the wastewater treatment plant will either be sent into the local municipal sewage network or discharged directly to the sea.



The Company will design and construct the terminal’s stormwater drainage system to reduce the risks for future impacts on water quality and improve spill control and containment. This may include oil and sediment separation from the stormwater drainage.



Non-potable water will be sourced from the municipal water system. Potable water will be sourced from bottled water.



During the land reclamation activities, trucks used Euro diesel V and a fuel additive to reduce NOx emissions. Vehicle loads were covered to prevent dust escaping. Water was used to suppress road dust. The project will develop and implement an equipment inspection and planned preventive maintenance program of both its own equipment and that of contractors. This program will include regular safety inspections of equipment such as cranes.



Most of the equipment used during operations will be electrical, with electricity supplied through the existing power grid. A 6 MW gas-fired generator will supply back-up power. The terminal is studying the possibility to feed in a next stage directly electricity to berthed vessels (“cold-ironing”), so they will not be contributing separately to air emissions. Vehicles will continue to use Euro diesel during operation. The Company will monitor, under the EHS monitoring plan, its use of diesel and other fuels, as well as the electricity taken from the grid, to determine the amount of green house gases emitted by the project.



During construction, vehicle movement has been restricted to the hours between 10 am and 5 pm for the duration of the tourist season to reduce noise impacts on the summer houses located nearby. During operation, ship movement and unloading/loading will be 24 hours per day, 7 days per week. The alignment of containers on the terminal site will reduce ship noise. There will also be a 40-45 m buffer zone on the end of the terminal closest to the nearest houses where no containers will be stored. Noise will be monitored, as is typically required for environmental permits in Turkey. Truck movements in and out of the port will follow a Traffic Management Plan (see PS4).



Lighting of the terminal area can have an impact on surrounding houses, some of which look down on the pro
ject from a nearby cliff. A certain level of lighting must be maintained for health and safety purposes. A lighting study has been carried out to help design the layout of the site. The positioning of containers will block some of the light. Each lighting pole will have directional lights that can be switched on and off, which should, with active management, reduce the amount of light being emitted. Cranes will also have their own lighting, which will reduce the need for poles. Low consumption bulbs will be used where possible, with LED lights being used in the office areas.

The beach area to the west of the terminal site has been building up as construction progressed, which was predicted by the modelling of coastal material transport. The build up is expected to stop when the beach reaches the 3 meters contour in depth. The build up of the beach is, according to Asyaport, seen as desirable by the residents whose houses face the beach.



The major trucking activity, the movement of fill from the quarries to the terminal site, has ceased. Some additional fill may be necessary once the current settlement of materials on site has taken effect and it will be possible to determine whether the amount of fill currently on site is sufficient to complete the Project. All the same, limited movement of trucks in and out of the port site during the remainder of construction is expected. As noted, the Project is primarily for the transhipment of containers rather than export into Turkey. Thus, truck traffic associated with the project is expected to be initially limited. When export is increased, the direct road linking the facility to the nearest major highway should be completed and major population areas avoided. All the same, the Company will develop a traffic management routing plan in association with local municipal authorities, to apply to all export, import, contractors and suppliers.



Asyaport currently employs its own security personnel directly rather than relying on a contractor. The Company plan to continue this practice. To ensure that security personnel use appropriate measures for guarding the site, a site security management plan will be developed and Company will ensure that the personnel are screened at the time of hiring and trained based on the plan. The security personnel are typically hired from the local area, but a port facility security officer will be hired with specific expertise to oversee the assessment, planning and installation of the terminal’s security arrangement.

A public hearing was held for the project EIA in 2006. No further meetings have been held.

To this date, local community engagement has been handled personally by the local Turkish sponsor. While the Project appears to be acceptable to the community, a more formal approach is needed. An international consultant has prepared a stakeholder engagement plan, which will be used for the remaining phases of the Project. The Company will, on at least an annual basis, inform the local communities about actions described in this ESRS, and particularly those actions that are intended to directly or indirectly address potential risks for and impacts on the local communities.

Asyaport will implement a formal grievance procedure. The Project, early on, received complaints about dust and noise, primarily related to the quarries and associated transport. These were handled in what appears to be an acceptable way, but the Company needs to ensure that process is transparent and timely. Asyaport will implement a formal grievance procedure.

Tom Van Eynde
Terminal Investment Limited S.A.
Joulehof 16c
4622 RG Bergen op Zoom
The Netherlands
Telephone: +31(0)164 274 690
Fax: +31(0)164 274 698 
Website: http://www.tilgroup.com/
E-mail: mailto:tvaneynde@tilgroup.com

Ahmet Soyuer
Asyaport
Bahar Sk. No: 2/6 Balmumcu
Beşiktaş, 34349 Istanbul
Turkey
Telephone: +90 (0)212 274 33 96
Fax: +90 (0)212 272 46 69
Website: http://www.asyaport.com

Broad Community Support is not applicable for this project

#	Action	Completion Date
PS1	· Appoint Environmental Officer	8/312013
PS2	· Establish an H&S Committee	8/31/2013
PS4	· Appoint Port Facility Security Officer	9/30/2013