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

The Etlik, Ankara project is part of the wider Turkish health PPP Program (Kayseri Health (#31029) and Adana Health (#34358) for which IFC has a mandate on financing). The project involves construction of new hospital facilities on land that is to be provided by Ministry of Health (MoH) and which does not involve physical or economic displacement. The campus once built will have total of 3,566 bed capacity.

Based on a review of available project information, key project related environmental health and safety (EHS) aspects are life and fire safety risks and adequacy of emergency preparedness and response for such large campus; other important aspects seismic risk consideration in building design, construction related EHS impacts and adequacy of the environmental and social management system; implementation of good hospital management practices; workers’ health and safety, including training and housekeeping; disinfection, sterilization, and hygiene; high fresh air requirements and good lighting, hospital solid waste and effluent treatment and disposal; hazardous materials management; opportunities for energy conservation and efficiency as well as waste minimization; community health, safety and security. The core health services will be provided by MoH and support services will be outsourced based on detailed specifications provided by MoH. Construction, maintenance and facilities management of the Campus will be undertaken by the company. Thus, the overall environmental, health, safety and social management systems to identify, assess, and manage key E&S risks and impacts during the construction and operation in compliance with IFC Performance Standards may be split between the public and private partners.

IFC’s review did not identify impacts related to:
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, due to the Project being developed in a large residential area of Ankara and involving no biodiversity impacts. PS7: Indigenous Peoples, as there are no Indigenous Peoples in the project area.PS8: Cultural Heritage, although a small tumulus is on the site, no significant impacts regarding cultural assets is anticipated for this Project.

While the risks and impacts associated with the construction and operation of medical facilities are site specific, largely reversible and readily addressed through known mitigation measures, this investment is categorized as A based upon the diversity and size of the project.

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, Management System and Policy: The partners of the company have previous experience with similar infrastructure projects, including health care facilities. Both Astaldi and Turkerler have obtained ISO 9001 (Quality Management), ISO 14001 (Environmental Management) and OHSAS 18001 (Occupational Health and Safety Management) certification. The Company (JV of Astaldi and Turkerler) will also establish a site specific environmental and social management system (ESMS) for Etlik IHC. In the scope of the management system, environmental and social policies will be put forward. At the operation stage of the project, the company and MoH will coordinate on developing and implementing an overall ESMS for both the medical and facilities operations.



The Project was exempted from the national EIA requirement. However, the company retained an independent environmental consulting firm (2U1K Muhendislik ve Danismanlik A.S.) to prepare an environmental and social impact assessment (ESIA) report. In the ESIA, the environmental and social baseline of the project area, the positive and adverse impacts, and the relevant mitigation measures of the Etlik IHC Project have been described. However, the tri-generation plant - a combined cooling, heat, and power system – to be used during operation phase and the concrete batch plant to be used during construction phase are subject to the EIA procedure in accordance with the local law. The tri-generation system will comprise six gas engines, each with an electrical installed capacity of 2.7 MWe. The total installed electrical capacity will therefore be 16.2 MWe with an efficiency of 45%. The thermal power input of the facility will thus be 36 MWth.



A Project Introduction File (PIF) has been prepared for the concrete batch plant and submitted to the local authority. For the tri-generation system a Project Introduction File (PIF) is under preparation and will be submitted to local authority. In accordance with Government regulations, an EIA necessary/unnecessary decision will be obtained for each of 2 facilities. According to the decision, a full EIA might be prepared for both of the plants. The company will deliver copies of these reports and correspondence to both the local authorities and IFC.



During site studies for the impact assessment, an ancient burial mound (a ‘tumulus’) was discovered. Although subsequent studies showed that the tumulus had been used in more recent times as a shelter or a storage area, the tumulus was not registered in the governmental records. Nevertheless, the location of key Project components were redesigned to protect the tumulus and to enable further investigation. A 75 m protection zone around the tumulus will be maintained and entrance will be forbidden to this area during the operation phase. Furthermore, a chance finds procedure will be established for the construction phase and an archeological expert will be brought in if any archeological ass
ets are discovered on the site.



In accordance with Turkish environmental regulations, the project must acquire one integrated environmental permit, which will cover the 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: The Company has recently started establishment of the project team. The project director, who has over 10 years of hospital and health care facilities construction experience, has been appointed and has started to work in August 2013. An EHS chief will be hired and necessary updates of the existing organization chart will be done before construction starts. The EHS chief will be responsible for the development and implementation of the ESMS and identification of the EHS workforce required during construction and operation phases of the project. The EHS department will also recruit additional EHS officers as are deemed necessary once the ESMS is developed.



Training: For all full time workers, an orientation and training program will be followed. In addition, a comprehensive OHS training program will be developed and provided to key project management personnel, including the site manager, EHS manager, site EHS officers, site section chiefs, and site engineers on key aspects of the OHSAS 18001 management system. OHS training also will be provided to all of the workers so that employees have the knowledge and skills to perform their work safely. The company will provide training programs and will keep a log of training courses and their contents.



Monitoring and Review: As part of the ESIA studies, an environmental and social management and monitoring plan (ESMMP) has been prepared in order to define key environmental, health and safety (EHS) and social aspects, and ensuring operation within the applicable laws and regulations of Turkey, as well as the policies of international financial organizations. The ESMS to be established will include the following management plans: contractors monitoring and management plan, hazardous material storage plan, air quality management plan, noise management plan, spill response plan, construction waste management plan, archaeological chance find procedure and traffic management plan as well as environmental, health and safety plan. Under the scope of these management plans, relevant data will be monitored. The company will retain specialists to undertake periodic monitoring/audits throughout construction and operation of the facility. The results will be evaluated and the results used to update ESMMP if required. The SPV plans to implement a third-party environmental and social management audit in accordance with WBG EHS General Guidelines and Guidelines on Health Care Facilities once every three years during the operational phase. Results of t
he audits and monitoring activities will be internally reviewed and evaluated by the project management as well as the project lenders group. The company will also submit an Annual E&S Monitoring Report (AMR) on environmental, health & safety and social performance, regularly in accordance with the IFC’s PSs and relevant World Bank Group (WBG) EHS Guidelines.



Emergency Preparedness: As mentioned above, an Emergency Preparedness and Response Plan (EPRP) will be developed and followed throughout construction and operation phases of the project. In the plan, roles and responsibilities, specific emergency response measures for spills, fire, accidents, earthquake and flood will be addressed. Contractors and sub-contractors will also be required to develop and prepare their own site-specific EPRPs in line with the overarching plan. The EPRP may be updated throughout the project lifetime when necessary.

Human Resources Policy and Management of Worker Relationship: At the time of the appraisal, no site activities had started, although both of the Company’s JV partners maintain offices on site. It is expected that a maximum of around 4000 workers will be required for the peak construction phase of the project. When the project becomes operational, approximately 10,000 workers will be employed, including both contracted workers and medical staff.



During construction phase, there will be a workers camp with a capacity of 3000 workers at the project site. The camp site will be facilitated with services and utilities in line with IFC’s Guidance on Worker’s Accommodation. These include but are not limited to daily rooms shared by 8 persons at most, bathrooms shared by 15 persons at most, air conditioning, furniture, hot water, drinking water, wastewater collection and transportation, kitchen and food in line with WHO recommendations, first aid services, leisure and communications facilities etc. With the finalization of the construction, camp facilities will be dismantled and sent to other camp sites for further use.



The Company will develop an HR Policy in line with requirements of PS2 for both construction and operation phases of the Project and will ensure that all the workers are aware of the content. For that purpose, worker induction trainings will include a summary of HR policy, which will be also displayed on selected notice boards around site. The Company has committed that the Project will comply with national labor, social security and occupational health and safety laws as well as principles and standards of the ILO core labor standards. In this respect, the HR policy will include provisions regarding age, wages, working hours, disabled employees, non-employee workers, health and safety and workers camps. The policy will explicitly prohibit child and forced labor, as well as the freedom of association and elimination of discrimination.



Although currently there is no formal workers’ grievance mechanism, one will be established for construction and operation workers before recruitment. The Company will ensure that all the workers are aware of the grievance mechanism and it is easily accessible to them.



Occupational Health and Safety: Both of the companies in the JV currently implement provisions of OHSAS 18001 in their own operations. A health and safety plan including an occupational health and safety communication and training program, which will apply during the construction phase across all contractors, will be developed. The plan will include an organization chart, safety regulations, responsibilities, accident and incident response and reporting, use of personal protective equipment (PPE), fire prevention measures, fall protection, emergency preparedness etc. Another health and safety plan composed of procedures for management of relevant occupational hazards, manual heavy lifting, electrical safety, equipment safety, ha
ndling of medical wastes, and hygiene issues will be prepared for the operational phase of the project. The company will provide appropriate training (working at height, use of PPE, working in confined spaces etc) to workers on occupational health and safety issues as explained in PS1. There will also be necessary equipment and staff for first aid and emergency transfer during construction phase. Monitoring on OHS will be followed throughout the lifetime of the project and the results will be submitted to IFC periodically.



The OHS Management Plan will be revised and updated during the operational phase. An OHS manager will be assigned and a health and safety management system established that will be applied to all staff and include training courses regarding handling hazardous material; medical waste and exposure to vector-borne diseases for workers and contractors. Furthermore, the contractor responsible for support services will ensure that the sub-contractors will adhere with OHS policies of the contractor and report incidents and accidents as well as non-compliances to the contractor.



Workers Engaged by Third Parties: During project construction, the company will engage contractors and, at the peak of construction, employ approximately 4000 personnel on site. The company will require its contractors to observe the health and safety policy of the project as well as local health and safety legislation. The contractors will also be requested to report accidents, incidents, near misses and safety non-compliances. The company will require all contractors to manage their workers in line with the established HR Policy. All the above-mentioned issues will be binding conditions in the contracts made with the Company and will be taken into consideration in the bids. The company will prepare a Contractor Management Plan (CMP) to ensure that all the contractors are aware of their commitments regarding environmental and social issues. The plan will be comprised of training, provisions regarding implementation of ESMMP to be included in the contracts, monitoring requirements etc.

Resource Conservation and Energy Efficiency: At the project site, water, natural gas and electricity will be supplied from the city grid. In the operational phase of the project, water and natural gas will also be obtained from the city network; however electricity will be produced on-site via a tri-generation plant. This plant will be composed of six gas engines, with capacity of each 2.7 MWe. The environmental impacts of the tri-generation plant will be evaluated in the PIF to be submitted to the Ministry of Environment and Urbanization. The report will also be submitted to IFC. The purpose of using a tri-generation plant is to produce almost half of the electricity requirement of the complex (approximately 220 million kWh/year) off grid. The Company will perform periodic monitoring of emissions to ensure compliance with the maximum limits in the Turkish Industrial Air Pollution Regulation, Air Quality Regulation and WBG EHS Guideline values. The relevant measurements will be reported to IFC in the AMR. The additional heat requirement will be met by 8 boilers (3 stand-by) with a total installed capacity of 80 MW. The emissions from boilers and engines will be in line with WBG’s EHS Guidelines and be monitored periodically.



Emissions due to traffic congestion are also assessed for rush hours based on the numbers of traffic modeling. According to the results, PM emissions are expected to be at negligible levels. On the other hand, NO2 emissions due to increasing number of vehicles are in compliance with WBG EHS Guidelines for long-term limit values and well below national ambient air quality standards however, the contribution of the project to the ambient air quality slightly exceeds WBG EHS Guideline recommendations in hourly periods. In this respect, the emissions will be closely monitored and reported to IFC.



In both construction and operation phases, water will be supplied from the city network. Wastewater will be mostly domestic - water consumption by workers at site - and partially industrial due to concrete batch plant to be utilized during construction. Domestic wastewater will be collected and discharged to the central sewage network of the Municipality. Sedimentation will be applied to wastewater from the concrete batch plant and the supernatant used as dust suppression water at the construction areas.



Water consumption in the operation phase is expected to be 1900 m3/day, including the hotel, forensic hospital, and rehabilitation hospital. All of the water consumed is assumed to be wastewater. There will be three main wastewater streams during operation phase. These are domestic (i) wastewater generated by patients, staff and visitors; (ii) hazardous wastewater from laboratories, medical wards and operating theatres, pharmaceutical and chemical stores and x-ray facilities etc.; and (iii) grey water from kitchens. Domestic wastewater will be directly discharged to the sewage system of the municipality where it will be treat
ed by a wastewater treatment plant (WWTP). The current wastewater treatment plant operates with nearly full capacity. The Municipality is planning to start construction of second stage of the current WWTP as a separate WWTP at a distance of 4 km to the southwest of the project area in 2015. It is expected that the construction of the WWTP will end before the Etlik IHC is fully operational and hence domestic wastewaters generated from Etlik IHC will be treated in this new WWTP.



Wastewater from laboratories and other processes will be treated in an appropriate on-site wastewater treatment plant so as to meet the discharge criteria of the sewage network defined by the Municipality. The sewer line ends up at the new WWTP mentioned above. The newly constructed WWTP will discharge treated wastewaters in line with local regulation (compliant with the EU criteria) and WBH EHS Guidelines. The treatment plant has not been designed yet; however the Company has ensured that the discharge criteria will be met. It is expected that package treatment units will be used for neutralization of such wastewaters. A grey water segregation system will be introduced to separately collect wastewater from medical hotel and that will be treated in order to use it in cistern of medical hotel of Etlik IHC. Further opportunities to save water and energy will be seek in Etlik IHC during project lifetime.



Hazardous Materials Management: For hazardous materials during construction and operation phases, hazardous materials storage procedures in line with the WBG EHS Guidelines will be developed and followed. In the operation phase, diesel, to be used as a back-up fuel for natural gas, will be stored in on site fuel tanks equipped with secondary containment. The total amount of diesel storage will be approximately 330.000 L – approximately 3-days storage. Additional cooling systems at hospitals and clinics to supplement the cooling capacity of the tri-generation system will utilize non ozone-depleting HFC refrigerants such as R134a and R410a.



Waste management: A waste management framework covering both construction and operation phases has been established in the scope of the ESIA studies. This framework consists of types of wastes, handling and disposal methods for both phases. Non-hazardous, hazardous, medical and radioactive wastes will be produced. Non-hazardous solid wastes will be segregated by type and whether they will be disposed of by the city municipality or sent to the licenses recycling companies. Hazardous wastes will be originating mostly from construction activities and maintenance in operation phase. In either case, wastes will be separately collected and labeled appropriately in a designated area on-site for further transport and disposal at the licensed companies. In the operation phase, medical wastes are anticipated to be composed of microbiological laboratory wastes, waste blood samples, and objects contaminated with blood, human tissue, used surgic
al clothes, dialysis wastes, air filters containing bacteria and viruses, injection needles, and broken glass and similar objects. It is expected that the amount of medical wastes will be close to the amounts generated in the existing hospitals that will be closed with Project implementation. Collection and disposal of the medical wastes in the project will be done in line with local regulation (i.e., Medical Wastes Control Regulation Official Gazette dated 22.07.2005, numbered 25883). All of the abovementioned wastes will be managed in accordance with the detailed and waste-specific waste management plans and procedures, which will, in turn, be in accordance with local regulations and WBG EHS Guidelines. They will be developed prior to construction and operation, as necessary and appropriate. Hazardous and non-hazardous wastes will be separately collected and stored on site. A medical waste management plan will also be established. The outline of the plan is already given in the ESIA study.



For disposal of medical wastes, off-site incineration and subsequent landfilling will be undertaken. For that purpose, construction of a medical waste incineration plant in one of the landfill facilities in Ankara is completed and has been taken into operation recently. Air pollutant emission levels have been evaluated in the EIA report prepared for the incinerator and accordingly, the emission levels of the incinerator are planned to be in line with the local regulation on incineration of wastes which is fully in line with EU standards.



Radioactive wastes from body and organ imaging, tumor localization, and similar units in the clinics will be managed in line with the guidelines from International Atomic Energy Agency (IAEA) and WBG EHS Guidelines. Furthermore, a radioactive substance management plan will be prepared before the hospital becomes fully operational.



Noise: Noise levels at the receptors in the vicinity of the project area are very close to or above the limit values set in WBG EHS Guidelines. Therefore, the allowable exceedance during the construction activities will be 3 dbA. The Company has conducted necessary modeling studies and confirmed that existing noise levels will not be exceeded by more than 3 dbA during construction. Additionally, the construction activities will be mostly concentrated at the center of the project area, which is distant to the receptors. The tri-generation plant will be a continuous noise source in the operation phase. However, the design of the tri-generation plant will include the necessary insulation in the building that houses the plant. Therefore, the noise limits will be in line with the IFC’s EHS Guidelines. The noise limits will be periodically monitored and, in case of exceeding the limit values, necessary mitigation measures will be taken.



Greenhouse Gas Emissions: CO2 emission has been calculated based on annual natural gas consumption by the tri-generation plant as well as boilers. According
ly, total GHG emissions are calculated to be 126.077 CO2 eq/yr. The client will be reporting actual natural gas consumption per annum in the AMR.



Daily water consumption is expected to be 1900 m3. The company has reported that the expected number of people to be on site is 50.000 including staff, patients and visitors. The specific water consumption is thus expected to be 38 L/person-day. According to Pollution Prevention Compliance Assistance Information for the Healthcare Industry, specific water consumption in healthcare facilities up to 500 beds is in the range of 312.5 – 1354.6 m3/bed-yr. Water consumption at Etlik IHC is expected to be much lower than that level with the value of 194.5 m3/bed-yr. Annual consumption of electricity and all fuels is expected to be around 485 million kWh, equivalent to around 453 kWh/m2. This value is below the average – 591 kWh/m2 - for health care facilities defined in U.S. Energy Information Administration.



Pesticide Use and Management: Use of pesticides in the project site will be implemented in full compliance with the provisions set in WBG EHS Guidelines.

Risks associated with the 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 (L&FS): The design of the hospital complex has been done by a very well-known design company which is experienced in health care facility design. International standards such as American Institute of Architects – AIA Guidelines for Design and Construction of Health Care Facilities, 2006, Guidelines for Design and Construction of Hospitals and Outpatient Facilities (2010) by the Facility Guidelines Institute American Disabilities Act – ADA 1994 which are referred in the WBG EHS Guidelines for Health Care Facilities were followed as well as Turkish standards for health care facilities in the architectural design of the buildings in Etlik IHC. Furthermore, NFPA standards have been taken as the basis for life and fire safety design standards. The use of NFPA standards will apply also to the forensic psychiatric hospital. Nevertheless, the client will hire an external expert for a 3rd party life and fire safety audit to ensure that the project meets the requirements of Turkish law and NFPA code. In accordance with the audit results, a L&FS corrective action plan will be prepared to ensure that L&FS related aspects of design are compatible with all Turkish and an internationally accepted (NFPA in this case) LFS code, as required under WBG EHS General Guidelines. The measures will be implemented in a reasonable time frame. The external experts will also review L&FS systems testing and commissioning upon completion of construction and certify that the system is in compliance with the accepted design.



According to the earthquake map of Ankara prepared by Earthquake Research Department of the General Directorate of Disaster Affairs, project site is in a fourth-degree (degree one being the most risky whereas degree five being with least danger) earthquake zone. The local building code addresses this level of risk, and the project buildings will be designed accordingly.



Traffic Management: The project location is in the city center and hence will result in traffic impacts during both construction and operation phases of the project. A baseline study has been undertaken to identify existing traffic load in the area. It concluded that the existing traffic load would be increased by approximately 50%. The increased traffic will be managed by making adjustments in the traffic light sequences to improve flow. In this regard, the results of the study will be shared with the Metropolitan Municipality to take necessary actions. Additionally, a framework traffic management plan, including measures to be taken and responsibilities, was presented with the ESIA. However, a detailed traffic management plan will be prepared and implemented in the context
of the traffic management study of the Metropolitan Municipality in Ankara in collaboration with Gazi University. Off-site traffic related impacts are considered to be manageable in accordance with the Metropolitan Municipality.



Security Personnel: The Ministry of Justice will be responsible for the security of the forensic hospital on site. Other than that, general security will be provided by a private company. The health campus will be equipped with peripheral fences and closed circuit TV system to be operated during 24 hours. It is committed by the client that all security personnel will be trained and will operate in accordance with the ‘International Code of Conduct for Private Security Providers’ as well as Turkish Law No. 5188 on Private Security Services.

Community engagement activities have been described within the scope of ESIA studies in a Stakeholder Engagement Plan (SEP). The engagement activities are divided into 4 stages. These are: initial engagement, impact assessment, impact assessment disclosure, and project implementation stages. The first two phases have been completed during which in-depth interviews, community level surveys, and business surveys have been conducted with residents, business owners, MoH etc in order to identify the affected communities, ascertain the potential negative and positive impacts, and to develop relevant mitigation measures. In addition, a public participation meeting was held in April 2013 in addition to previous consultation activities held with the relevant stakeholders. The outcomes of those consultation activities were taken into account in the ESIA review and necessary actions in the design of the project have been taken in order to manage public concerns. Another public consultation meeting was held in July 2013. After the ESIA was finalized it was disclosed in both English and Turkish on the website of the company as well as on the company premises. Brochures has been made publicly available informing the readers about a brief description of the project, ESIA report review places, duration of display period, and contact information for comments.

Furthermore, a public relation officer (PRO) has been hired to respond to grievances and to maintain regular communication with affected communities. A grievance mechanism has already been established and It will be advertised and announced to affected stakeholders to allow them to be informed regarding the means of functioning the mechanism and addressing the grievances. A government grievance phone-line for patient rights is accessible 24 hours a day. This mechanism can be used by the patients in case of grievances regarding the health care services they receive.

Serhat İnanç
Ankara Etlik Hastane Sağlık Hizmetleri İşletme Yatırım Anonim Şirketi
Turan Güneş Bulvarı Galip Erdem Cad. No:11
312 492 03 06
mailto:sinanc@turkerler.com
Turkey

http://www.aeh.com.tr
Varlık Mah. Akşemsettin Cad. No:14 Yenimahalle Ankara
Ilkbahar Mahallesi Galip Erdem Caddesi No:11 Çankaya Ankara

Broad Community Support is not applicable for this project

Etlik Health(33677) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Develop and implement project specific environmental and social management system (ESMS) and Environmental, Health and Safety (EHS) training program for construction phase of the project. The ESMS will be including, but not limited to the followings: contractors monitoring and management, hazardous material storage, air quality management plan, noise management plan, spill response plan, construction waste management plan, archaeological chance find procedure and traffic management plan in compliance with IFC’s PSs and WBG EHS Guidelines	31-Mar-2015	Completed	Completed	3/31/2015
Develop and implement project specific environmental and social management system (ESMS) and Environmental, Health and Safety (EHS) training program for operational phase of the project. The ESMS will be including, but not limited to the followings: contractors monitoring and management, hazardous material storage, air quality management plan, noise management plan, spill response plan, construction waste management plan and traffic management plan in compliance with IFC’s PSs and WBG EHS Guidelines	30-Aug-2018	Completed	Completed	5/30/2022
Develop EHS management capacity with EHS manager and officers	30-Nov-2015	Completed	Completed	11/30/2015
Develop EHS management capacity with EHS manager and officers	31-Mar-2015	Completed	Completed	3/31/2015
Develop and implement an orientation and training program including OHS training for all hired workers	31-Mar-2015	Completed	Completed	3/31/2015
Prepare and submit Project Introduction Files (PIF) for tri-generation and concrete batch plants to the Ministry of Environment and Urbanization for EIA necessary or not decision	31-Jan-2015	Completed	Completed	1/31/2015
Prepare and submit Project Introduction Files (PIF) for tri-generation and concrete batch plants to the Ministry of Environment and Urbanization for EIA necessary or not decision	31-Mar-2015	Completed	Completed	3/31/2015
Develop and implement an HR Policy in line with IFC’s PS2 for construction phase and ensure that all the workers are aware of the content	31-Mar-2015	Completed	Completed	3/31/2015
Develop and implement an HR Policy in line with IFC’s PS2 for operation phase and ensure that all the workers are aware of the content	30-Aug-2018	Completed	Completed	5/30/2022
Develop and implement a formal workers’ grievance mechanism in compliance with IFC’s PS2 requirements	31-Mar-2015	Completed	Completed	3/31/2015
Amend the workers’ grievance mechanism for operational period	30-Aug-2018	Completed	Completed	5/30/2022
Develop and implement an Occupational Health and Safety (OHS) Plan based on the risk analysis for the construction phase	31-Mar-2015	Completed	Completed	3/31/2015
Revision of the OHS Plan for the operational period activities	30-Aug-2018	Completed	Completed	5/30/2022
Develop and implement monitoring of contractor compliance in terms of health and safety policy as well as HR Policy of the Company in compliance with PS2 requirements for construction period	31-Mar-2015	Completed	Completed	3/31/2015
Ensure contractor compliance with the requirements of PS2 in contracts requiring compliance with Project HR Policy, ESMP, ESAP, EHS and other Plans linked to ESMP	30-Jun-2018	Completed	Completed	5/30/2022
Provide third party certification by a quailed professional acceptable to IFC that the design of life and fire safety systems for each new facility complies with the Life and Fire Safety requirements of the IFC General EHS Guideline, that the design is fully responsive to NFPA (or other international life safety code) and the host country safety code. Upon completion of construction provide certification by a qualified professional acceptable to IFC affirming that facilities construction faithfully incorporates all element of the engineering design/	31-Mar-2015	Completed	Completed	3/31/2015
Provide training to the security personnel and ensure operation in accordance with “International Code of Conduct for Private Security Providers”	31-Mar-2015	Completed	Completed	3/31/2015