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 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

Identified applicable performance standards

Environmental and social categorization and rationale
This corporate-level investment is a Category B project according to IFC’s Policy on Environmental and Social Sustainability.

Key E&S risks for this Project include; (i) quality, environmental, occupational health and safety (OHS) management systems, food safety and bio-security programs; (ii) OHS risks for direct employees and contractors/third parties; (iii) energy use efficiency; (iv) air emissions and dust; (v) domestic wastewater treatment; (vi) life, fire and traffic safety; (vii) labor transparency; (viii) completion of remaining ESAP (Environmental and Social Action Plan) items from the former “Tiryaki” (#28467) project; and strict implementation of GMO (Genetically Modified Organisms) procedures and policies and compliance with local law.


Since both operations are already run on the Industrial Organized Zones and there is no other land requirement that will trigger involuntary resettlement and/or economic displacement will be of concern, PS5 is not applicable. PS7 and PS8 do not apply as there are no indigenous peoples or cultural heritage sites in the area of influence 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.

Identification of Risks and Impacts: Submission of an Environmental Impact Assessment (EIA) study for the proposed Project is not required by the local authorities in Turkey (EIA Legislation, dated July, 17, 2008, No: 26939). Tiryaki has made a commitment in the scope of the existing project to have a third party Environmental and Occupational Health and Safety audit for both Gaziantep and Mersin facilities against the applicable local and national requirements and IFC’s Environmental and Social Standards and WBG’s relevant EHS guidelines as outlined in the ESAP of the existing project (#28467) Submission of the audit results are expected in January 2014. Tiryaki has already received an Industrial License from the local authorities for the Gaziantep facility and reported compliance with country’s relevant legislations. Operational permit, business license (GSM) and allowance report of Fire Department after inspection are obtained for Mersin Plant.



Management Programs. Tiryaki Gaziantep plant has obtained the ISO9001:2008 Quality Management System and the ISO 22000:2005&FSSC Food Safety Management certifications, as well as kosher certification, organic certification and compliance certification with Bio-Suisse standards. As a part of its commitment under the existing IFC investment, Tiryaki implemented an EHS Management System in compliance with IFCs Performance Standard 1 and has obtained ISO14001 and OHSAS 18001 certifications (Certification body- TUV NORD Turkiye, dated July, 2012). After the operation starts at the Mersin facility, the Company will extend the EHS Management system already established in Gaziantep facility to Mersin facility within a timeframe agreed in the ESAP of the existing investment. For Mersin plant, risk assessment studies have been conducted for the construction activites and accident reports are also recorded which have been reviewed by IFC specialist during the course of latest supervision visit.



Organization. Quality and environment issues at the Tiryaki Gaziantep facility are overseen by the Quality Manager, whereas OHS management is under the responsibility of the HR and Administration Manager at the corporate level. An OHS consultant was hired to undertake site inspections and follow-up with relevant legal requirements. A local Environmental consultancy firm named T-Ofis was contracted to follow up environmental legislation compliance. As per the ESAP of the existing Tiryaki project, Tiryaki has assigned a Corporate EHS Coordinator who oversees the environment and OHS issues associated with its operations at both plants to ensure a consistent approach to EHS issues across all of Tiryaki’s operations.



Training. Tiryaki has a training program established to ensure that staff competency levels are maintained and competency gaps are addressed, if necessary. The program is updated as needed throughout the year to include new training needs identified during the normal course of operations. OHS and fire
trainings are given to all employees on a yearly basis. Staff engaged in food operations that come directly or indirectly into contact with food are trained, and/or instructed in food hygiene principles and practices to a level appropriate to the operations they perform. All employees are made aware of their roles and responsibilities in preventing food from contamination and deterioration.



Monitoring and Reporting. Solid and hazardous wastes, energy consumption, air emissions, lost time accidents and customer complaints are among the key parameters monitored at Tiryaki Agro processing plants, in compliance with relevant regulatory requirements. Reporting of key performance indicators (KPIs) is done internally at monthly department meetings and annual management review process as per the requirements of the certified management system. The management review topics include, but are not limited to, the following: follow-up actions from previous management reviews; analysis of results of verification activities; changing circumstances that can affect food safety; product recalls/withdrawals; review of system updating activities; internal audits results; review of communication activities, including customer feedback and target setting for the following year. The above mentioned environmental data is yearly reported to Gaziantep Province Environmental Directorate and lost time accidents are reported to Social Security Directorate. As soon as the operations fully starts at Mersin facility, Tiryaki will develop a monitoring system for wastewater and air emissions for verification of compliance with WBG EHS Guidelines and also perform noise, dust and light measurements at work places and outside the area of the plant. The results will be shared with IFC in the Annual Monitoring Report (AMR). There is no need for stakeholder engagement plan according to the local legislation since the environmental and social impacts of project are not significant and there is no immediate affected community.

Human Resource Policy and Management. Within the context of the existing Tiryaki project, the Company has agreed to revise its Human Resources (HR) Policy to ensure consistency in rights of blue and white collar workers and include a section on workers’ right to form/join professional trade unions and the right for collective bargaining. The new HR Policy which was finalized and submitted to IFC in July 2012 includes information regarding employment terms, service terms, duties, rights, responsibilities, trainings, promotions, performance assessment, and awards as well as disciplinary actions and conditions on termination of contract. HR Policy also mentions freedom of association and non-discrimination requirements of IFC’s PS2. Additionally, a handbook including the information on working conditions and health and safety issues is provided to the new employees. Tiryaki currently employs 612 peoples, including 228 managerial and 384 operational staffs. Among these, female workers constitute approximately 23 percent of the total workforce. Currently there are 27 white collar and 71 blue collar employees working in Mersin Plant. The employment figure is expected to increase when the plant is fully operational. HR activities for Mersin Plant, including recruitment, waging policy etc. are organized from Gaziantep office. In waging system, blue collar employees work for minimum wage in addition to overtime payments (270 hours/annum at most). Scale system is applied for waging system of white collar employees. In determination of wages for white collar personnel life standards at the cities where plants are located are taken into account. Vouchers are given to every employee for religious holidays.



Retrenchment: The number of employees has decreased about 10% since the last two years mainly due to moving of administrative personnel to Istanbul for white collars and restructuring the production process for blue collars. This retrenchment process was carried out in line with Turkish Labor Law, indemnities and all rights were paid and no related court case was reported. No collective redundancy is determined to be of concern. Should collective dismissals become necessary, Tiryaki is committed to prepare a retrenchment plan based on consultations with the affected workers, and in accordance with local Labor Codes and IFC’s PS2 requirements.



Workers Organization and Grievance Mechanism: There is presently no active trade union at the Tiryaki facilities, although Tiryaki has indicated that it does not prohibit the establishment of workers’ associations at any of its facilities. Worker representatives for nuts and pulses departments have already been selected as part of client’s committment to introduce election for worker representatives as an alternative mean to workers’ organizations for its employees to express their concerns and grievances as outlined in the ESAP of the existing project ( #28467). The documentation regarding elections has been
provided to IFC. The Company has placed a number of suggestion boxes at locations throughout the facilities to allow employees to submit suggestions or complaints and selected suggestions are awarded. As well as these internal grievance mechanisms, external worker protection mechanisms are ensured by the national labor laws and union activities, where relevant.



Occupational Health and Safety (OHS). Tiryaki Gaziantep plant operates in accordance with an OHSAS 18001 certified occupational health and safety management system and this includes risk assessment studies, accident root cause analysis and reporting. The Company is also obliged to comply with national OHS legislation which establishes the general principles relating to the prevention of occupational risks, protection of workers at the workplace, elimination of risk factors and occupational accidents, training of workers and their representatives, and general guidelines for the enforcement of these principles. Tiryaki has developed an OHS training program to cover regulatory requirements, duties and responsibilities, and job-specific risks of employees in line with the local legislation requirements. Bimonthly OHS meeting are held with the participation of occupational physician and nurse, representatives from HR department, technical staff and Safety Officer to identify risks and to continuously improve workplace OHS conditions. Safety officer working in Gaziantep facility visits Mersin facility 2-3 times per month and reports his findings with top management regularly. A medical room and a doctor was available on site. EHS issues have been included in the contracts and contractors that do not adhere to health and safety rules were issued verbal and written notice or a certain amount of fine depending on the continuation of the violation. No lost time accident was reported during the construction period.

A workplace physician works several days a week in the factory in line with the national Occupational Health and Safety legislation (No: 25311, dated December 9, 2003). Construction workers also can benefit from same services than the direct employees. A medical examination is required for all workers upon their recruitment. Staff also undergoes medical examination annually, including lung and throat screenings and audiometric tests. First aid kits are available for easy access, where needed. The Company ensures that at least 10% of its employees received first aid training. The Maintenance Department is responsible for proper operations of plant equipment using an established preventive maintenance program.



Gaziantep facility’s lost time injury frequency rates (LTIFR) are 14.5 and 30 and average work days lost 21 and 4.4 in 2012 and 2013 respectively. LTIFR is higher than sector average of 7 (Reference Frequency Rates By Sector (LTIFR) Injuries per million hours worked - based on 2010 USA data) . No lost time workplace accidents have been recorded at Mersin facility. The Compa
ny will have continuous efforts to reduce number of accidents. In accordance with the timeframe outlined in the ESAP of the existing project (#28467), the Company will implement a work permission system and procedures including hot works, electricity, work at height and confined spaces. The work permit system has been introduced in Mersin for construction works. Tiryaki has performed its fourth risk assessment at Gaziantep facility and its first risk assessment at Mersin facility to further reduce the risk of accidents as set forth in the ESAP of the existing project (#28467). In Mersin facility, the construction of 45 silos has been completed and some of them are currently in use. The process lines for red lentils and rice are completed and are in the testing phase. Beans and chickpeas process lines will be installed after testing of the existing lines is completed. During the site visit of the IFC specialist, it was observed at the Mersin facility that the bags stored in the warehouses were piled too high that goes beyond the requirement of maximum 3 m height outlined in the Turkish OHS regulation. The Company will make sure stack heights of the bags in the warehouses do not exceed the required limit value. Housekeeping practices were observed to be mostly in good conditions however, it was not clear if the dust evacuator were working properly since considerable amount of dust existed particularly at pit and tower location. Based on this observation, IFC requested the Company to perform a test for measuring performance of the evacuator and take corrective actions, including enforcement and monitoring of cleaning routine by the management and upgrading or replacement of the equipment. It was also noticed that noise levels at the processing plants were quite high. To address this issue, there is an action item in the ESAP of the existing project (#28467) for measurement of dust, noise, light and temperature at Mersin facility and the results of the measurements will be shared with IFC in the AMR. The Company also completed thermo-graphic analyses as outlined in the existing ESAP ( #28467) and is in the process of deriving outcomes and relevant action plan. Personal Protective Equipment (PPE) usage is generally adequate at the facilities. However, it was observed during the site visit that some contractors did not use safety shoes and other PPE for safety at work. The client was advised to effectively manage contractors’ compliance to health and safety issues as outlined in the contracts.



Fire Safety: At the Gaziantep facility, key fire prevention equipment, including fire extinguishers and fire hydrants, as well as evacuation signs are in place. The Mersin facility has been constructed, and will be operated in full compliance with local building codes, local fire department regulations, local legal/insurance requirements, and in accordance with an internationally accepted Life and Fire Safety (L&FS) standard.



Supply Chain: Tiryaki’s primar
y products are pulses (lentils, rice, chickpeas, peas, bulgur and beans - 49% total), grains (barley, wheat and corn – 35% total), nuts (pistachio, almond, walnut, and peanut – 9% total) and other products (oil seeds, organic cotton and animal feeds – 7% total). More than 60% of overall sourcing is international whereas the remaining 40% is domestic. Domestic sourcing is done through brokers. International sourcing is done from contracted farmers for organic products and from organized markets for conventional products. The supply chain departments maintain written specifications for ingredients of products. The purchasing information requests the following documents to be shipped with every lot of incoming materials: Health certificate; GMO certificate with the shipment lot number; Data sheet including pesticide residues and heavy metals analysis; Product specifications; Aflatoxin certificate; Fumigations certificate; Allergen information. Incoming lots are sampled and tested against certificates of analysis. Test results are maintained by Quality Control department. Some of the commodities such as paddy, soy bean, hazelnut and cotton purchased by Tiryaki are of concern due to supply chain issues. Child labor, migrant labor and biodiversity issues are the major concerns for supply chain of these commodities and in order mitigate these issues and expand the scope of its supply chain’s assessment of suppliers in terms of these risks, the Company started the mapping of its commodities sourcing. A draft study including an initial assessment of IFC has been prepared and updated by the client and IFC’s E&S specialist using IFC’s GMAP tool. Based on this study, there are 24 commodities purchased from 35 different countries. The Company met with ECOM which is an existing IFC Client to have guidance on supply chain risk assessment and management and drafted a management system’s supply chain procedure. Going forward, the Company will complete the remaining actions on supply chain management outlined in the ESAP of the existing Tiryaki project (#28467), including the development and implementation of written procedures to identify harmful child labor, forced labor, and biodiversity issues and the revision of supplier agreements to include provisions to ensure child or forced labor and issues related to biodiversity due to conversion of natural/critical habitats are avoided.

Hazelnut was started to be traded by the Company in 2012 and 250 tones/year is supplied from two trader companies in Turkey to be sold in internal market. In the meantime, Fair Labor Association (FLA) reported that the presence of illegal foreign workers mainly from Georgia, child labor, lack of employment records, compensation discrimination, harassment (http://www.fairlabor.org/sites/default/files/documents/reports/nestle_hazelnut_report.pdf). The Company will prepare a Supplier Code of Conduct for hazelnut and will make its best efforts to supply hazelnut from fair trade suppliers
, as per the attached ESAP.

Energy use and greenhouse gas emissions. Energy sources utilized in Gaziantep facility are natural gas, coal and electricity. Annual natural gas consumption of Gaziantep facility is recorded to be 4.03 m3/ton while coal and electricity consumptions are respectively 20.264 tones/year and 121 kWh/ton for 2012. The average annual water consumption for the same period is calculated as 199.480 m3.



Air emissions The Gaziantep facility operates natural gas fire steam boilers which essentially limit particulate matter and sulfur oxides emissions. The facility obtains the natural gas from the distribution grid. With the changing needs and economical concerns, Tiryaki’s technical department have installed a coal fired fluidized bed boilers for the Gaziantep facility. The new system was commissioned in 2012. Within the scope of environmental permit activities held by Tiryaki, emission measurements have been conducted and, emission measurement report has been submitted. Data indicates compliance with national law and the emission parameters detailed in the WBG General EHS Guidelines.



Wastewater Treatment. The wastewater is discharged to a central industrial waste water treatment plant (WWTP) of Gaziantep Industrial Zone. A copy of discharge permit prepared by the management of the industrial zone in July 2012 has been reviewed during the appraisal.

Data indicates compliance with national law and the effluents discharge parameters of WBG General EHS Guidelines.



Management of solid and hazardous wastes. Solid non-hazardous waste and hazardous waste management are well established, involving waste segregation and reduction. Packaging waste is recycled in collaboration with CEVKO (Environmental Protection and Packaging Waste Recovery and Recycling Trust). Hazardous wastes are separately collected and disposed by licensed companies approved by the Provincial Directorate of Ministry of Environment and Urbanization.



Cooling agents: The organic products storage use approximately 70 kg of R22 as a refrigerant in their cooling systems. The Company has prepared a R22 phase-out plan in line with local legislation and will make sure non-ozone depleting refrigeration agents are purchased going forward.

The Tiryaki’s Gaziantep facilities are located in the Gaziantep Industrial Zone and the new facilities are located in Mersin Industrial Zone, so there are no immediate households or neighbors in the vicinity of the facilities. Tiryaki employs unarmed private security personnel and they are regularly trained and certified as per the local regulatory requirements (Law No:518).



Raw materials and finished products are delivered in bulk via trucks. As required in the ESAP of the existing project ( #28467), the Company ensured that contracted logistic company drivers received OHS trainings and traffic rules and vehicle maintenance periods are strictly followed by its outsourced distribution fleet. Traffic measures at Mersin facility are expected to be completed by the end of 2013. Tiryaki Agro has an active grievance mechanism for the customer complaints and regularly monitors the number and root cause of complaints and under the scope of Good Manufacturing Practices (GMP) and food safety system. Traceability practices and product recall procedures are available, in case of any need.

Potential issues associated with the conversion of natural and critical habitats, including deforestation risks from its commodities sourcing activities are not currently assessed by the Company. In parallel with the requirements in PS2, those supply chain risks will also be assessed and managed as part of the proposed Company’s supply chain management system procedures.

Genetically-modified organisms (GMOs) are considered alien species. Any new introduction of such organisms through supply chain should be assessed in a manner consistent with the existing host country regulations and in compliance with the Cartagena Protocol for Biosafety. The Company does not have a separate policy for prevention of GMO since exported goods are tested by the government officials of Provincial Directorate of Agriculture before the product is allowed into the local market. Nevertheless, the Company will have an internal procedure against possible GMO contamination risks as per attached ESAP.

Given the limited potential for adverse social and environmental impacts arising from the Project, community engagement is not required by the Turkish authorities for a facility like Tiryaki. The information about the Project will be shared with the community through publishing this Environmental and Social Review Summary. The technical content of the ESRS and ESAP will be translated into Turkish and utilized to convey assessment details and proposed remedial measures to the local community as part of Tiryaki’s stakeholder engagement program.

Tiryaki engages in ad-hoc and informal community engagement through various social responsibility projects, such as supporting orphanages, providing Iftar dinner during Ramadan holidays, supporting municipality activities. Tiryaki is involved in a corporate social responsibility (CSR) project with Anadolu Cagdas Egitim Vakfi (ANACEV) and pays scholarship for students (150 TL/month). Furthermore, Tiryaki supports education activities by paying tutiton fees of open learning for its employees. The company also plans to provide support for education of personnel’s children.

Gaziantep and Mersin Addresses:
Contact Person: Elif Gul
Tel: +90 342 211 97 00



Fax:+90 342 337 97 09
Tiryaki Agro Gida San. Ve Tic. A.S
3 Organize Sanayi Bolgesi , Mehmet Batalli Bulvari
13 No’lu Cadde No:8, Baspinar
TR27070, Gaziantep, TURKEY
Mersin Tarsus Organize Sanayi Bölgesi Gelişme Alanı Kadri Şaman Bulvarı No:5 Akdeniz - Mersin – Türkiye

Istanbul Office Adress:
Abdullah Aga Mah. Semsi Efendi Sok.Yagcılar Kosku No:16 34676 Beylerbeyi / Istanbul /TURKEY
Contact Person:
Mr. Ertan Akbulut
Chief Financial Officer
Abdullah Aga Mah. Semsi Efendi Sok.
Yagcilar Kosku No:16 34676 Beylerbeyi/Istanbul
Turkey
Phone: +90 216 333 20 00 ; Fax: +90 216 333 20 20

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
- Ensure stack heights of the bags in the warehouses do not exceed the required limit value. Write an instruction for daily use	12/31/2013 12:00:00 AM	Completed	Completed	12/20/2013 12:00:00 AM
Ensure that dust evacuator in Mersin Plant work properly , test the equipment and upgrade equipment if necessary and improve cleaning routine	03/31/2014 12:00:00 AM	In Progress	Under discussion with IFC client
As part of the supply chain component of its corporate Environmental and Social Management System, Tiryaki will develop a Supplier Code of Conduct for its suppliers in Turkey to ensure sustainable purchasing practices for hazelnut. As per the IFC’s related supply chain requirements, this code of conduct will specifically prohibit purchase of hazelnut known to be produced breaching national environmental and social legislation and/or violation of IFC Performance Standards, namely produced through harmful child /forced labor, illegal labor practices. Tiryaki will provide IFC a copy of the Supplier Code of Conduct for review and will include the Tiryaki’s Supplier Code of Conduct in all contractual agreements with hazelnut suppliers.	03/31/2014 12:00:00 AM	In Progress	Under discussion with IFC client
As part of the supply chain component of its corporate Environmental and Social Management System, Tiryaki will develop a Supplier Code of Conduct for its suppliers in Turkey to ensure sustainable purchasing practices for hazelnut. As per the IFC’s related supply chain requirements, this code of conduct will specifically prohibit purchase of hazelnut known to be produced breaching national environmental and social legislation and/or violation of IFC Performance Standards, namely produced through harmful child /forced labor, illegal labor practices. Tiryaki will provide IFC a copy of the Supplier Code of Conduct for review and will include the Tiryaki’s Supplier Code of Conduct in all contractual agreements with hazelnut suppliers. Tiryaki will submit the replacements of hazelnut suppliers to Fair Trade ones by volume where the Company’s leverage is possible	06/30/2014 12:00:00 AM	In Progress	Under discussion with IFC client
(i) Carry out a risk assessment for GMO contamination which is above permitted levels (ii) Prepare a documented procedure for risk elimination/ minimization and implement the procedure	06/30/2014 12:00:00 AM	In Progress	Under discussion with IFC client