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

This proposed investment is classified as a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects as the environmental and social impacts of the project are limited, site-specific and can be minimized, avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria.

The key environmental and social aspects of the project relate to Elif Egypt and Elif Plastik’s ability to manage environmental, occupational health and safety, human resources and food safety (related with the manufacturing of primary packaging for food products) issues as well as regulatory compliance, labor and working conditions during construction and operational phases, contractors management, control of emissions to air of volatile organic compounds (VOCs) and the possible need for incineration of such compounds, energy efficiency in film forming and printing and ink drying operations, and treatment and disposal of sanitary waste water and process effluents arising from cleaning of printing machinery and possibly washing of recycled Plastik. Elif Egypt will implement environmental and occupational health and safety systems similar to the existing operations in Elif Plastik Turkey; effective implementation of these allied to the actions defined in the project Environmental and Social Action Plan (ESAP) will ensure environmental and social (E&S) risks and impacts are effectively mitigated.

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.

Elif Plastik has presented information on how its existing environmental and social management system addresses the identified impacts and how it will ensure that the proposed project will upon implementation of the specific agreed measures; comply with the environmental and social requirements, which include the Egyptian and Turkish laws and regulations and IFC’s Performance Standards (dated January 01, 2012). The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow. Additional actions are summarized in the attached ESAP.



Environmental and Social Assessment and Management System, Policy and Identification of Risk and Impacts and Management Programs:



Elif Plastik in Turkey has a documented management system consisting of a policy and procedures for identification and management of environmental, social, occupational health and safety (ESOHS) risks and impacts; emergency preparedness; and monitoring and reviewing ESOHS performance. Elif Plastik established and certified its ESOHS system in accordance with ISO 14001and OHSAS 18001, environmental and occupational health and safety systems respectively. In addition, Elif Plastik certified operations according to BRC-IoP, a global food safety standard for packaging materials, ISO 22000 Food Safety Standard and ISO 9001, a quality management system. The company is also a member of Sedex (Supplier Ethical Data Exchange). Elif Egypt will also develop and implement a documented ESOHS system, including that related to food safety, identical to that associated with Elif Plastik and in line with the PS requirements.



Elif Egypt has not performed an environmental and social impact assessment as yet though this is required in accordance with national law; the latter is also a requirement defined in the ESAP. Impacts such as noise, air pollution, waste management and the like during the construction phase of Elif Egypt will be managed via an Environmental Management Plan to be developed and implemented for this phase; this is defined as a requirement in the project ESAP.



Elif Plastik’s current environmental and occupational health and safety management system includes an approach to identify environmental impacts and occupational health and safety risk analysis.



A construction permit for activities up to 15 meters had been obtained for Elif Egypt at the time of the appraisal; however, a 22 meter height allowance may be required for Elif Egypt’s process. Although there are neighboring facilities within 6th of October Industrial zone with structures of up to 30 meters in height, Elif Egypt will be required to either obtain a construction permit allowing 22 meters height, or review its design to limit the height of activities to within 15 meters.



Elif Plastik has environmental permits in line with national laws.



Organizational Capacity and Competency: Elif Egypt has a project management team consisting of managers repor
ting to the Board, including a Managing Director, Marketing Director, Project Manager, and Technical Manager. The Project Manager and his department are responsible for the overall project management and supervision of the project development. The Technical Manager and his department are responsible for project design, and for assessing the E&S risks in line with the PSs and, if necessary, for ensuring mitigation measures are implemented during the design and/or construction phases. The management team is responsible for the organization of tenders for the selection of contractors. Design has been completed by the Shaker Consultancy Group and Albonian Consulting Engineers. Both companies have international references and good track records in Egypt.



During the construction phase there will be 3 main contractors for: i) civil and steel works; ii) electro mechanical works; and iii) equipment installation. The contractors will have dedicated E&S staff and the civil and steel works contractor will be responsible for overall contractor E&S coordination.



Elif Egypt’s project management team will have weekly meetings with the contractor and E&S issues will be reviewed during the weekly meetings. Project oversight and quality control will be provided by the Elif Egypt management team.



Elif Egypt has commissioned a local legal firm to obtain the relevant permits, approvals and licenses from authorities. Elif Egypt will be required to provide semiannual progress reports related to the situation of the permits/approvals/licenses to IFC.



Elif Plastik has an environmental, occupational health and safety team, consisting of 2 engineers and 3 technicians reporting to Elif Plastik’s CEO. Elif Plastik’s E&S department will provide support to Elif Egypt as well.



Emergency Preparedness and Response: Elif Egypt will develop a documented emergency preparedness and response plan applicable to both construction and operational phases which will cover emergencies such as fire, earthquake, dust storm and wind, personal injuries and first aid, terrorism and civil disturbance, suspicious devices, bombs and received mail. Elif Plastik’s existing life and fire safety as well as spill prevention and control measurements (such as flame detectors, smoke detectors, water and foam based sprinkler systems, emergency showers, absorbents) which are in line with internationally accepted criteria’s are incorporated to Elif Egypt’s design criteria.



Monitoring and Reviewing: Elif Plastik has a system in place to monitor and review key E&S performance indicators (KPIs), including injuries, near misses, spills / leakages, waste management issues on a yearly basis. For the construction period, Elif Egypt’s contractors will have designated E&S staff in order to ensure that E&S mitigations measures will be in place and the E&S system will be effectively implemented. The Project Manager and Technical Manager will be in contact with the contractor’s E&S responsible staff
to monitor E&S performance. Elif Egypt will develop a monitoring and review process for both construction and operational phases in line with Elif Plastik’s existing system and IFC’s PSs and WBG’s related EHS Guidelines requirements. Elif Egypt will submit to IFC an Annual Monitoring Report on Environmental and Social Performance, including KPIs, prepared in accordance with the IFC’s Performance Standards and WBG’s General EHS Guideline and EHS Guidelines for Metal, Plastik and Rubber Products Manufacturing requirements.



External Communications and Grievance Mechanism and Ongoing Reporting to Affected Communities: Elif Egypt is located in an industrial zone and no communities are located in proximity. Elif Plastik is in Esenyurt, Istanbul, in an industrial zone as well. Both companies will though be required to develop an external communication and grievance mechanism where interested parties can raise and register their concerns.

Working Conditions and Management of Worker Relationship: Elif Egypt is expected to create 300 direct employment positions at the production facility and additional 200-300 indirect jobs in Egypt. Several hundred temporary jobs will also be created during the construction phase.



Elif Plastik has employs approximately 780 employees.



During the construction phase, depending on the work load and plan, one or two shifts will be employed in Elif Egypt.



Both Elif Egypt and Elif Plastik will be working in 3 shifts, 6 days a week during the operational phase.



Elif Plastik has a documented Human Resources (HR) Policy and Procedures defining key responsibilities, procedures covering recruitment, company rules, ethics, performance evaluation, legal requirements, employment agreements and employment conditions, code of conduct, disciplinary actions and grievance and compensation. There is no discrimination on the basis of personal beliefs, sex or characteristics, and there is no prohibition or discouragement of freedom of association. Elif Plastik is not anticipating retrenchment. There is a grievance mechanism where all employees can raise and register their concerns. Elif Egypt will adopt the existing Elif Plastik’s HR Policy and Procedures which are considered aligned with this Performance Standard.



Elif Egypt will include in the contractual clauses with the construction companies the requirement to comply with this PS, IFC’s requirements for worker’s accommodation and the EMP for the construction phase. Prior to construction the agreed HR documentation will be submitted to IFC. The EMP will also define Elif’s Egypt’s approach to monitoring the contractors to ensure compliance with their HR documentation.



Elif Egypt will ensure that adequate facilities and amenities are provided in the construction phase including adequate accommodation if needed; fire safety; potable water that meets national standards; toilets, washing and cleaning facilities and; locker/storage facilities.



Protecting the Work Force: In compliance with local labor laws and Company’s policy, Elif Egypt and Elif Plastik will not use child or forced labor. Contractors are also required to hire only employees older than 18 years of age as a requirement in the contracts; there will be ongoing inspections at the site to confirm compliance. Workers Engaged by Third Parties: Elif Egypt has verified that companies/personnel contracted to do the construction work are legal entities with a Certificate of Registration and a labor license issued by the statutory authorities. Elif Egypt has included in the contracts explicit clauses regarding labor and occupational health and safety.



Elif Egypt will employ contractors for the security and catering services during the operational phase and the employment conditions of these staff will comply with this PS. All other works will be performed by Elif Egpyt’s staff.



Elif Plastik employed 40 workers for the security and
catering services; E&S requirements are successfully defined in the existing contracts.



Occupational Health and Safety: Elif Plastik has a well documented and implemented system for occupational health, safety and environment. Topics include process waste segregation, key responsibilities, medical examination, chemical management, training, ESOHS policy, risk assessment, environmental impact assessment, periodical inspections, management review, incidents, workplace safety, safety signs, personal protective equipments, emergency preparedness and plans, housekeeping, and access roads. Lessons learned related to workspace air quality and noise levels have been incorporated to Elif Egpyt’s design. Elif Egypt will adopt the existing ESOHS system of Elif Plastik for its operations to both the construction and operational phases, including the key elements such as a permit to work system, lock out tag out procedures, chemical management to ensure prevention of accidental release and use/installation of secondary containments, monitoring of exposure to vibration.



All construction site workers at Elif Egypt will be required to undergo initial safety training prior to starting work. Shaker Consultancy Group and Albonian Consultant Engineers will also perform regular audits and inspections in order to monitor mitigation measures such as use of personnel protective equipment, work equipment improvement, training, etc. related with the workplace risks will be implemented. Occupational health and safety rules and other working conditions, in accordance with the IFC PS2 requirements, will be included in contractor agreements. In addition, Elif Egypt will establish regular inspection mechanisms to ensure compliance of contractors with the contractual requirements.

Resource Efficiency: Elif Plastik has implemented various resource efficiency projects including heat recovery for workspace and water heating, and waste water recycling from the plastic recycling department. Similar projects have been incorporated into the design of the Elif Egypt facility.



Both for Elif Plastik and Elif Egypt, water is being supplied from the municipal networks and electricity from the city grid. Natural gas (NG) is the main energy source for heating.



Both water and energy (electricity and fuel) consumption will be monitored and reported internally and Elif Egypt and Elif Plastik will provide the figures to IFC through the Annual Monitoring Report.



Resource efficiency measures have also been considered in the design of the development such as variable speed drivers for all equipments, thermal insulation for the roof and windows and use of flexible ducks for cooling/heating of the workspace for Elif Egypt. Such measures are have also been implemented in Elif Plastik.



Greenhouse Gases (GHG): The main source for GHG during the construction phase in Egypt will be the fuel consumed by construction vehicles and electricity usage during construction. GHG emission is estimated to be 313,000 tone CO2 equivalents/year during the operational phase in Egypt, and is calculated as 1,500,000 tone CO2 equivalents/year for Elif Plastik. As noted though, GHG reduction projects, including heat recovery from compressors will be implemented in Egypt.



Waste Water: Elif Egypt’s waste water will be discharged to the industrial zone’s waste water collection system which discharges to the municipal waste water treatment plant. Elif Plastik’s waste water is treated by existing waste water treatment plant and discharged to the municipality’s collection network. Elif Plastik’s waste water quality is in line with the acceptance limits of 6th of October Industrial Zone as well as Turkish environmental laws and WBG EHS Guideline requirements. Elif Egypt and Elif Plastik will provide waste water amount and effluent quality data to IFC via the Annual Monitoring Report to ensure compliance with national law and the WBG EHS Guidelines.



Waste Management: Elif Plastik has an effective waste segregation system in place. All the wastes, except plastic production wastes are recycled and / or disposed by the authorized third party contractors. The plastic production wastes are recycled and used by Elif Plastik in the plastic bag manufacturing process. Elif Egypt’s excavation wastes, hazardous chemical packages, domestic wastes, non hazardous packaging materials, scrap metals will be sent to Municipality Landfill Area and/or to a licensed waste company / recycler. Elif Egypt will recycle all film / plastic wastes within its production facility as per the approach at Elif Plastik. Elif will develop a waste management program as part of the environmental management system and report on associated figures to IFC via the Annual Monitoring Report.



Hazardous Materials Management: Elif’s hazardous materials include printing ink, solvents, adhesive and hardeners as well as the chemicals that are used for maintenance and cleaning purposes. Solvent usage is estimated to be over 240 ton/ year in Elif Egypt and it was 1,480 ton/year in Elif Plastik in 2012. Elif Plastik has an efficient solvent recovery process in place. Elif Egypt will implement a similar process and will be required to have specific control measures, including secondary containment, spill kits, and fire safety controls where hazardous materials, such as ink, solvents, adhesive and hardeners will be stored and/or used.



Emissions: Elif Plastik’s emissions are in line with Turkish and Egyptian laws as well as emission limits set for 6th of October Industrial zone. However, VOC emissions are above that defined in the sector specific EHS Guidelines for Metal, Plastik and Rubber Products Manufacturing. Thus Elif Egypt will review the design to ensure that mitigation measures such as incineration are in place to ensure that VOC emissions will be less than 75 mg/Nm3 i.e., in accordance with the requirements of the EHS Guideline. Elif Plastik will also implement mitigation measures (such as incineration) to ensure that VOCs emitted comply with the standards defined in the EHS Guidelines for Metal, Plastic and Rubber Products Manufacturing.



Historical Contamination: 6th of October Industrial Zone is relatively a new industrial area and the land acquired by Elif Egypt was not used by any residential and/or industrial purposes. However, there is a neighboring battery production company using lead and chloride. In order to define a baseline for potential land contamination, Elif Egypt will be required to perform a soil analysis and provide the results to IFC.

Community Health and Safety: Elif Egypt engaged the professional services of a qualified Life and Fire Safety professional to ensure that the design incorporates necessary fire exits, fire detection/alarm system throughout the entire facility building in line with an internationally recognized NFPA’s Life and Fire Safety Code (including NFPA 1, 10, 12, 13, 14, 72, 101). The design implementation will also be monitored by the same life and fire safety professional who will perform a close out audit at the end of construction to confirm compliance with the Code. During the design, structural safety was also reviewed by external professionals as well. There are foam and gas type sprinkler systems in place as well as fire retarding doors, walls, alarm and detection systems in place in Elif Plastik facility in line with Turkish laws requirements which includes international standards requirements.

Elif Egypt will be required to implement construction area safety measures to protect the contractor employees and neighboring facilities including clear demarcation of construction areas; restricted access to construction sites; proper illumination of areas; and provision of safety information to visitors and people residing in the project while construction is being completed.



Security: Elif Egypt will employ unarmed security forces at the gate of the project site. Elif Plastik has unarmed security forces as well.

Elif Egypt and Elif Plastik will develop a formal external grievance mechanism where all interested parties can raise and register their concerns. The information related to the respective operations Elif’s grievance mechanism will be shared through its internet site and at the project site.

This Environmental and Social Review Summary document and relevant action plan will be available at Elif Plastik’s Head Office, Elif Egypt’s internet site and at proposed project site gate.

For more information please contact:

Name : Ayhan Ilgaz (QA Manager)

Address: Elif Plastik Ambalaj San. Tic A.S.
Tel: +902126220622
Fax: +902126220653
e-mail: mailto:AYHANILGAZ@elifplastik.com.tr

http://www.elifplastik.com.tr

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
1a) Elif Egypt to complete an environmental and social impact assessment (ESIA) compliant with Egyptian laws and IFC Performance Standards	09/30/2013 12:00:00 AM	Completed	Completed	02/05/2014 12:00:00 AM
1b) Elif Egypt to develop and implement an Environmental Management Plan for the construction phase that will include but not be limited to:, · A waste management program (type of waste, disposer/recycler, amount) for construction debris, domestic and hazardous solid waste, and sewage · A chance find protocol for cultural artefacts, · Safety measures for the community including that related to traffic safety so as to ensure safe movement of construction vehicles within the site and out of the site · An external communication and grievance mechanism where all interested parties can raise and register their concerns · Measures to be implemented by Elif Eqypt to ensure contractors comply with the requirements of PS2: Labor and Workidng Conditions	09/30/2013 12:00:00 AM	Completed	Completed	03/05/2014 12:00:00 AM
1c) For the operational phase, Elif Egypt to develop and implement a documented Environmental, Social, Occupational Health and Safety System (ESOHS) system, similar to Elif Plastic and in line with PSs requirements, including (not limited with) the following elements; · Food safety · A documented emergency preparedness and response plan · A monitoring program for liquid and solid waste and emissions aligned with IFC’s PSs and World Bank Group’s related EHS Guidelines requirements. · Pre-employment and periodical employee’s health and safety monitoring system including workplace monitoring of exposure to vibration, chemicals and noise, · A waste management program (type of waste, disposer/recycler, amount) for hazardous and non-hazardous wastes · A monitoring procedure for water and energy (electricity and fuel) · A communication and grievance mechanism where all interested parties can raise and register their concerns	06/30/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
1d) Elif Egypt to obtain all relevant permits /approvals/licenses prior to construction and operations and submit copies to IFC	06/30/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
2a) Elif Egypt to Develop and implement a documented HR Policy and Procedures aligned with Elif Plastik’s existing system, national requirements and IFC’s PS2 requirements	09/30/2013 12:00:00 AM	Completed	Completed	03/05/2014 12:00:00 AM
2b) Elif Egypt to include the requirements for contractors associated with the operational and construction phases to be aligned with the requirement of PS 2, including occupational health and safety. this is to include requirements related to worker’s accommodation and training requirements	07/30/2013 12:00:00 AM	Completed	Completed	03/05/2014 12:00:00 AM
2c) Elif Egypt to develop and implement a procedure for monitoring compliance of contractors with PS 2 requirements.	09/30/2013 12:00:00 AM	Completed	Completed	03/05/2014 12:00:00 AM
3a) Elif Egypt to develop and implement control measures, including secondary containment, spill kits, and fire safety requirements where hazardous materials, such as ink, solvents, adhasive and hardeners that will be stored and/or used.	06/30/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
3b) Elif Egypt to amend the project design such that VOCs emitted comply with the standards defined in the EHS Guidelines for Metal, Plastic and Rubber Products Manufacturing.	09/30/2013 12:00:00 AM	Completed	Completed	03/05/2014 12:00:00 AM
3c) Elif Plastik to implement mitigation measures such as incineration to ensure that VOCs emitted comply with the standards defined in the EHS Guidelines for Metal, Plastic and Rubber Products Manufacturing.	03/31/2014 12:00:00 AM	Completed	Completed	04/08/2014 12:00:00 AM
3d) Elif Egypt to perform a soil analysis and provide the results to IFC. Thereafter If necessary, agree with IFC on an action plan to address contamination.	09/30/2013 12:00:00 AM	Completed	Completed	03/05/2014 12:00:00 AM
4) Elif Egypt to provide IFC a copy of the close out audit report of Life and Fire Safety professional at the end of the construction and agree on implementation of a corrective action plan if necessary.	06/30/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client