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
PS 5 – Land Acquisition and Involuntary Resettlement
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 risks of the project are; capacity of the ASTRA’s corporate environmental, social, occupational health and safety (ESOHS) management system to effectively manage ESOHS performance; permits and regulatory compliance; environment, health and safety practices during construction and operational phases; waste management particularly including construction waste; hazardous materials management; occupational health and safety including employee training and monitoring programs; contractors management; adequacy of human resources policy and practices; structural and life and fire safety;. ASTRA will implement ESOHS system; and effective implementation of this 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.

As the existing and planned project sites are located in urban areas within the city center and/or within university campus areas and no indigenous people are known to be in the area or affected by the project, no issues have been identified in relation to PS6 andPS7. The Company will develop a formal chance finds protocol providing appropriate protection in the event of unexpected discovery of items of cultural heritage.

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.

ASTRA has presented information on how its current practices and policies address the identified impacts and how it will ensure that the proposed projects, upon implementation of the specific agreed measures, comply with the ESOHS requirements, which include the 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 Environmental and Social Action Plan (ESAP).



Environmental and Social Assessment and Management System, Policy and Identification of Risk and Impacts and Management Programs: Astra does not currently have a corporate sustainability policy, nor a documented ESOHS management system ASTRA has not undertaken a formal environmental and social impact assessment of its projects as this is not required by national law.



ASTRA will develop a corporate policy describing environmental and social principles to be applied to its construction and dormitory operation activities, in a manner compliant with relevant local regulation and the Performance Standards.



As defined in the ESAP, Astra will undertake an assessment of environmental, social and occupational health and safety risks that could arise in the construction and operational phases of the project, and as also defined in the ESAP, will develop an ESOHS Management Plan for the construction phase and a ESOHS management system for dormitory operations as defined in the attached ESAP.



Organizational Capacity and Competency: ASTRA has a management team consisting of Millstones Fund Manager and the founders of the company. The board is responsible for overall project management and supervision of the project development as well as establishing and developing relationships with contractors/construction, nominating subcontractors, and obtaining permits, approvals and licenses from authorities.



During Uniyurt construction in Afyon, the Business Development Manager, who reports to the board, was responsible for E&S supervision and reporting performance to the board of the main construction contractor. He is located in Afyon and is responsible for supervising the OHS performance of the existing dormitory. Both the contractor’s ESOHS responsible officer and ASTRA’s Business Development Manager conducted daily, weekly and monthly inspections and reporting performance to the board. A similar organization will be established for the proposed project.



ASTRA has an architect who works as project manager for the construction projects. For legal issues and in order to follow up permit/licenses of the projects, external lawyers are contracted.



Orhun Holding, which is owned by one of the local entrepreneurs, has design (Hun Yapi) and construction (Bati) companies. Hun Yapi has been nominated for the design of the new dorms and has completed the designs of Sakarya and Izmir do
rmitories. Zonguldak dorm’s design is in progress. Afyon dorm’s expansion project design was completed as a part of the original plan of 2011. Bati is expected to construct the Sakarya dormitory, while contractors have not been appointed for the other projects.



For Sakarya dorm, as a part of the E&S requirements, ASTRA will contract two OHS experts to monitor and supervise the OHS issues on construction site. Contractors will be required to establish an ESOHS organization with nominated responsible officer performing daily inspections.



ASTRA will develop a corporate level ESOHS organization structure, advise this to IFC and nominate ESOHS officers for both construction and operational phases of each dormitory. ESOHS awareness training (including risks and impacts identified during the ESOHS impact assessment and risk analysis process and related mitigation measurements) will be provided both for ASTRA and for the contractor’s employees. For the proposed projects, training will be conducted before the construction works will be started. ASTRA will provide IFC a training program to ensure contractors and dorm staff will be trained.



Emergency Preparedness and Response: ASTRA has a documented emergency preparedness and response plan for its existing dorm, Uniyurt in Afyon. This plan will be reviewed and as necessary strenqthened, in the context of the ESOHS management system.



Monitoring and Reviewing: ASTRA management team meets once a month to discuss the performance of Uniyurt Afyon and the project status. For the construction phase, it is planned that construction site managers will provide daily, weekly and monthly reports to the management on ESOHS performance. ASTRA will develop the template of the daily, weekly and monthly construction ESOHS performance report to ensure that key performance indicators (KPIs), including injuries, near misses, spills / leakages, waste management issues, community complaints will be covered during the management review. ASTRA will regularly submit to IFC an Annual Monitoring Report on Environmental and Social Performance, including KPIs, prepared in accordance with the IFC’s Performance Standards and guidelines.



External Communications and Grievance Mechanism: ASTRA has no system to record / reply concerns and complaints from the interested parties. ASTRA will develop an external communication and grievance mechanism where all interested parties can raise and register their concerns.



Ongoing Reporting to Affected Communities: ASTRA will be required to share information related with the progress of the projects on its website through annual performance reports.

Human Resources (HR) Policies and Procedures: There is no designated HR officer in ASTRA. The existing HR documents include roles and responsibilities, and a detailed and well implemented performance evaluation system. ASTRA will develop an HR policy and procedures aligned with national laws and IFC’s PS2 requirements, and disseminate and explain this policy to all employees.



Working Conditions and Terms of Employment: Uniyurt, Afyon dormitory currently has an operational team of 35 staff. Dormitory operations are expected to employ approximately 175 staff at total and during the construction phase, 250 - 400 employees will be hired by contractors.



All ASTRA staff will have documented employment agreements where employment conditions, term of employment as well as benefits will be defined in line with Turkish labor laws.



ASTRA will ensure that adequate facilities and amenities are provided during the construction phase including: adequate living/sleeping facilities (if needed) and space per person; fire safety; potable water that meets national standards; toilets, and facilities for management and disposal of garbage, sewage and other waste by incorporating requirements to the contractor contracts.



Workers’ Organization and Non-Discrimination and Equal Opportunity: There is no discrimination on the basis of personal beliefs, or characteristics unrelated to inherent job requirements, and there is no prohibition or discouragement of freedom of association. Although there is no trades union within ASTRA, employees have the right to form an employee organization,



Retrenchment and Grievance Mechanism: ASTRA is not anticipating retrenchment since the Company is expanding. There is no formal grievance mechanism that enables employees to raise and register their concerns. ASTRA will develop a formal internal grievance mechanism and provide information on the grievances to IFC through an Annual Monitoring Report.



Protecting the Work Force: In compliance with local labor laws and the Company’s policy, ASTRA does not use child or forced labor. Contractors will also be required to hire only employees older than 18 year of age, which is confirmed through verification of documents and controls during the daily inspections and at construction site gates.



Workers Engaged by Third Parties: ASTRA will verify that companies contracted to do the construction work are legal entities with a Certificate of Registration and a labor license issued by the statutory authorities. ASTRA included in the contracts of Sakarya Dorm construction project with construction companies explicit clauses regarding labor and occupational health and safety. The company will review these clauses to incorporate any missing additional conditions derived from the implementation of the ESOHS MS.



At Afyon dormitory, catering and security services were outsourced. The catering company has a certified food safety, environmental and occupational health and safety mana
gement system.



Occupational Health and Safety: ASTRA has no documented OHS system in place. Awareness trainings to Uniyurt’s technical / maintenance team were provided. Mitigation measures such as use of personnel protective equipment, good housekeeping, fencing/guarding of equipments possessing hazard were implemented in Uniyurt. ASTRA will establish and implement an OHS system for the dorm operations All construction workers will be required to have initial safety training prior to starting work.



Occupational health and safety rules and other working conditions, in accordance with the IFC PS2 requirements, will be included in contractor agreements. In addition, ASTRA will establish regular inspection mechanisms to ensure compliance of contractors with the contractual requirements.

Resource Efficiency: Resource efficiency measures have been considered in the design of the developments such as double glazing for windows and the roof insulation. For the heating of the dorms and for catering services, either natural gas or LNG will be used. Water will be supplied either by wells and / or from the municipal networks and electricity from the city grids. Both water and energy (electricity and fuel) consumption will be monitored and reported internally and ASTRA will provide the figures to IFC through Annual Monitoring Report. Uniyurt’s electricity consumption figure is 52 kWh/m2 and water consumption figure, including all activities on dorm such as water used in the rooms, catering, laundry and irrigation is 0.125 m3/person/day which are satisfactory.



Resource efficiency measures such as condensing boilers and high standards of thermal insulation are in use in Uniyurt. ASTRA will develop a resource efficiency program to be incorporated to the new dorm designs to improve its consumption figures.



Greenhouse Gases (GHG): The main source of GHG will be the fuel consumed for heating and electricity usage for lighting. GHG emission is calculated as 1,090 tonne CO2 equivalent/year for Uniyurt and .is estimated to be 3,275 tonne CO2 equivalent/year for the proposed project (with Uniyurt) ASTRA will provide the consumption figures as well as GHG figures to IFC through Annual Monitoring Report.



Waste Management: At Uniyurt, ASTRA has a waste segregation system in place for domestic wastes, used batteries and recyclable wastes such as paper, metal and plastic. Corporate level ESOHS management system will ensure that all future dormitories will have similar waste management systems in place and ASTRA will provide waste figures and method of disposal/recycling both from the dorms and from construction activities (such as excavation wastes) to IFC through Annual Monitoring Report.



Waste water and Emissions to Air: In Uniyurt, domestic wastewater is discharged to municipality’s network. Waste water will be discharged to municipality’s network in other dorms as well and necessary connection permits will be obtained.. No emission measurements were performed on the boiler and generator exhaust, though these are not of the scale requiring regular emissions monitoring. ASTRA will provide waste water analysis to IFC through an Annual Monitoring Report.



Hazardous Materials Management and Pesticides Control: Hazardous materials in use included cleaning detergents and substances as well as maintenance / operational chemicals for the boilers, grease, etc. ASTRA will be required to have specific control measures, including secondary containment, spill kits, and fire safety controls where hazardous materials, such as oil, grease, cleaning agents will be stored and/or used. Material safety data sheets will be provided for the chemicals in use.



Uniyurt pest control method includes periodical treatment three times a year. Uniyurt does no
t use internationally prohibited and/or restricted pesticide(such as the products that fall in WHO Recommended Classification of Pesticides by Hazard Class Ia (extremely hazardous); or Ib (highly hazardous) and/or Class II (moderately hazardous)) in use.

Community Health and Safety: Dorm building construction and operational license are subject to approval by local fire / emergency authorities in Turkey. As a part of the construction permit approval process, sprinkler system, alarm, emergency lightening, fire escapes are required to be incorporated in the design. Local authorities also conduct inspections before the issue of the operational permit



Turkish legislation related to dormitory operations includes fire safety requirements which are in line with internationally accepted good practices. Smoke detectors and sprinklers in the rooms, emergency lighting, and alarm system were installed in Uniyurt Dorm. Every building has two fire escape stairs. There were two fire pumps, one electrical and one diesel, to pump water from a fire-fighting storage tank to fire hydrants as well as to the sprinklers, installed within and outside the dormitory buildings. There were also portable fire extinguishers located within the dorm buildings.



ASTRA incorporated Turkish life and fire (L&F) as well as seismic code requirements into its design. ASTRA will provide IFC LFS master plans for new dormitories and a representation from a competent professional acceptable to IFC that these master plans meet all Turkish and internationally accepted code (like NFPA). A similar representation, supported by documentation, will be provided for the existing dorminory.



In addition, ASTRA will provide IFC with the copies of seismic risk studies of dorms, conducted by agreed professionals and relevant consolidation activities along with the verification reports.



If the competent professionals are unable to provide the representations referred to above, then corrective actions to bring about compliance will be agreed between ASTRA and IFC and implemented according to a mutually agreed time scale.



ASTRA will be required to implement construction area safety measures to protect the community, 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 projects while construction is being completed.



As part of the implementation, ASTRA will develop and implement procedures for traffic safety to ensure safe movement of construction vehicles within the site and out of the site.



Security: ASTRA employs unarmed security forces at the gate of Uniyurt. The company will employ unarmed security forces at other project sites as well.

ASTRA maintains good relations with local communities. ASTRA will develop a formal external grievance mechanism where neighboring communities can raise and register their concerns. The information related with ASTRA’s grievance mechanism will be shared at the gates of the dorms as well as on its web page.

ASTRA will be required to establish a community engagement program as requested by PSs and Turkish Legislation on Environmental Impact Assessment and held consultation meetings (at least 3 meetings per dorm). ASTRA will provide a copy of the minutes to IFC.

This Environmental Review Summary and relevant action plan will be available at ASTRA’s Head Office, ASTRA’s internet site, Uniyurt’s gate and at construction site as well as dorm gates when they are completed.

For more information please contact:

Name : MR.KEREM MAVITUNCALILAR

Address: : ASTRA YAPI ISLETMECILIGI A.S., ARIF AGA, # 25, YENIBOSNA/ISTANBUL/TURKEY
e-mail: keremm@mailto:milestone@com.tr

http://www.uni-yurt.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Develop a corporate level ESOHS policy	10/31/2013 12:00:00 AM	Completed	Completed	10/21/2013 12:00:00 AM
Provide IFC both operational and construction phase environmental and social impact assessment and occupational health and safety (OHS) risk analysis compliant with Turkish laws and IFC Performance Standards as well as mitigation plans to manage the impacts and the risks.	10/31/2013 12:00:00 AM	Completed	Completed	01/07/2014 12:00:00 AM
Develop and implement an Environmental Management Plan for the construction phase.	10/31/2013 12:00:00 AM	Completed	Completed	01/07/2014 12:00:00 AM
For the operational phase, develop and implement a documented Environmental, Social, Occupational Health and Safety System (ESOHS) system, in line with PSs requirements	01/31/2014 12:00:00 AM	Completed	Completed	01/07/2014 12:00:00 AM
ASTRA to develop; · a corporate level ESOHS organization structure, · nominate an ESOHS responsible officer for both construction and operational phases. · a training program to ensure contractors and dorm staff will be trained prior to starting work and periodically.	10/31/2013 12:00:00 AM	Completed	Completed	01/07/2014 12:00:00 AM
Develop and implement a documented HR Policy and Procedures aligned with national laws and IFC’s PS2 requirements, and disseminate and explain the policy to employees	10/31/2013 12:00:00 AM	Completed	Completed	01/07/2014 12:00:00 AM
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 such as requirements and training requirements.	10/31/2013 12:00:00 AM	Completed	Completed	10/21/2013 12:00:00 AM
Develop and implement a procedure for monitoring compliance of contractors with PS 2 and contractual requirements.	10/31/2013 12:00:00 AM	Completed	Completed	03/07/2014 12:00:00 AM
Develop a resource efficiency program to be incorporated to the new dorm designs to improve its energy and water consumption figures	10/31/2013 12:00:00 AM	Completed	Completed	10/21/2013 12:00:00 AM
Provide IFC a representation from a competent professional acceptable to IFC that the life and fire safety master plans of its existing and future dorms meet all Turkish and internationally accepted code (like NFPA).	09/30/2013 12:00:00 AM	Completed	Completed	02/03/2014 12:00:00 AM
Provide IFC with the copies of seismic risk studies of dorms, conducted by agreed professionals and relevant consolidation activities along with the verification reports.	09/30/2013 12:00:00 AM	Completed	Completed	08/12/2013 12:00:00 AM
If needed, develop time-bound action plans to enhance LFS or seismic design to levels compatible with internationally accepted codes.	09/30/2013 12:00:00 AM	Completed	Completed	02/03/2014 12:00:00 AM