While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The Adana IHC is part of the wider national health PPP program in Turkey. 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 1,550 bed capacity.

Based on a review of available project information, key project related environmental health and safety (EHS) aspects were identified as life and fire safety risk and adequacy of emergency preparedness and response for the campus; 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; hospital solid waste and effluent treatment and disposal; hazardous materials management; opportunities for energy conservation and efficiency as well as waste minimization and 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 Adana IHC will be undertaken by the project 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:
PS5: Land Acquisition and Involuntary Resettlement, as the land which will be provided by MoH is government owned land, and physical and economical resettlement will not occur. The land, which was previously used by 6th Regional Directorate of State Hydraulic Works as warehouse and vehicle maintenance, currently belongs to Treasury and has already been allocated to the Ministry of Health (MoH).
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, due to the project being developed in an urban area of Adana and the land having no obvious biodiversity or ecosystem service value.
PS7: Indigenous Peoples, as there are none in the project area.
PS8: Cultural Heritage, since the area where the project located is not a protected area and is not an area of historical value.

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 B.

Environmental Health & Safety Guidelines that are expected to be relevant to this investment include applicable parts of:
General EHS; and
Health Care Facilities.

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.

Policy

As a recently established entity, ADN PPP does not have an environmental and social policy. One of the major shareholders of the project company - Ronesans Saglik A.S., a subsidiary of Ronesans Holding, operates under the EHS policy of Ronesans Holding A.S., which is publicly available on its website. As per the ESAP item 1 and 12, the project company, after conducting a thorough gap analysis, will develop an overarching E&S policy defining environmental health and safety (EHS) objectives that provides a framework to the company’s management during the construction and operational phases of the project. The policy will include a commitment to implement IFC’s PSs in its all operations (or more stringent national standards if they exist).



Assessment

Under current national EIA legislation, since the tendering process of the project was completed prior to publication of latest EIA regulation (October 03, 2013), the project was exempted from the national EIA requirement. However, the Company retained an independent environmental consulting firm (ELC Group which is a company of Royal Haskoning) to undertake the environmental and social works and prepare an environmental and social impact assessment (ESIA) report in line with IFC and other multilateral finance requirements.



In accordance with the local regulations the project will require i) construction permit from the municipality, ii) environmental permit from the Ministry of Environment and Urbanization (MoEU), which results from the assessment and approval of environmental report prepared in accordance with applicable environmental regulation iv) helipad license form General Directorate of Civil Aviation; and v) occupancy permit from the municipality for the operation period. The project company will provide all necessary permits and licenses required by national legislations for the construction and operational phases of the project.



Management

The partners of the Company have previous experience with similar infrastructure projects, including health care facilities. Ronesans Saglik A.S. has obtained ISO 9001 Quality Management, ISO 14001 Environmental Management and ISO 18001 Occupational Health and Safety Management certifications. An ESMP has been developed as part of the ESIA study, which includes description of the mitigation measures during the construction and operation phases, responsible parties for the implementation of the mitigation measures, the timing, monitoring and audit requirements. The ESMP focuses on the avoidance of impacts, and where this is not possible, presents technically and financially feasible and cost-effective mitigation measures to minimize or reduce possible impacts to acceptable levels. The company and IFC have agreed in the ESAP item 2 and 13 that ESMS consistent with PS1 requirements will be developed and implemented at project level. The ESMS required by PS1 is based on a continuous improvement process, similar to accepted international
frameworks for quality and environmental management systems, like ISO 14001. While IFC is not requiring a formal ISO 14001 ESMS, its elements may be expanded to meet broader scale of PS1 management system: adequate capacity to oversight of OHS matters and more extensive stakeholder engagement process.



Organizational Capacity

The project company was established in June 2013 and started establishment of the project team. The project manager, who has over 10 years of construction experience, started in post in January 2014. As per the ESAP items 3 and 14, the Company will establish an EHS department and appoint a Director with responsibility and authority for all EHS matters. The corporate EHS department will be provided with sufficient authority and resources to achieve effective and continuous E&S performance. This may include in-house staff, as well as external consultants.



Training

For all hired employees including third party employees an orientation and training program will be conducted during construction and operational phases of the project (ESAP items 2 and 13). In addition, a comprehensive OHS training program will also be developed and provided to key project management personnel, including the site manager, the EHS manager, the site EHS officers, the site section chiefs, and the site engineers on key aspects of OHSAS 18001 management system. The OHS training will be provided to all 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 Evaluation

As part of ESMS, the company will develop monitoring plans to address, at a minimum, air quality; water quality; noise; waste; life and fire safety; and occupational health and safety monitoring activities. It will identify the specific environmental monitoring measures to be implemented as covered in ESAP items 2 and 13 - the parameters to be measured, sampling and analytical methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and the definition of thresholds that signal the need for corrective actions. Monitoring thresholds will be consistent with those referenced in the applicable IFC EHS Guidelines. These plans will include formal internal and external auditing, monitoring and evaluation processes. The company will retain specialists within its EHS team and independent parties to undertake these periodic monitoring/audits throughout construction and operation of the facility.



The results of the audits and monitoring activities will be internally reviewed and evaluated by the project management as well as lenders of the project. The Company will also submit an annual monitoring report (AMR) on environmental, health & safety and social performance to IFC, regularly in accordance with the IFC’s PSs and relevant World Bank Group (WBG) EHS Guidelines.



Emergency Preparedness


An Emergency Preparedness and Response Plan (EPRP) will be developed and followed throughout construction and operation phases of the project as included in ESAP items 2 and 13. 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.

At the time of the appraisal, no site activities had started and the company did not have office at site. At the peak of the construction phase, it is expected that 1,800 workers will be on site. Workforce will be recruited locally as much as possible including local subcontractors. The workforce requirement during the operation phase is anticipated to be approximately 4,500 in total, with 2,500 health service personnel to be employed by the MoH, and 2,000 service employees to be provided through the third party service providers of the project company.



Human Resources Policies and Procedures

As per the ESAP items 4 and 15, the Company will develop an HR Policy in line with requirements of PS2 and will ensure that all the workers are aware of the content. For that purpose, the induction training will include 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. Furthermore, child and forced labor elimination as well as the freedom of association and the elimination of discrimination will be addressed in the policy.



Grievance Mechanism

The project company will establish a formal grievance mechanism for the direct and contracted employees and ensure that all staff is aware of the mechanism and it is easily accessible to them (ESAP items 7 and 18).



Health and Safety

Ronesans Saglik A.S. currently implements provisions of OHSAS 18001 in its own operations. The ESMS which will be developed by the project company will get OHSAS 18001 certificate for the management of health and safety issues. The management system will ensure that all applicable health and safety legislation and IFC standards on PS2 are met. The OHS Management Plan of construction phase will include an occupational health and safety, communication and training program and will apply across all contractors (ESAP item 6). The plan will include provisions of organization chart, safety regulations, responsibilities, accident and incident response and reporting, use of personal protective equipment (PPE), fire prevention measures, fall protection and emergency preparedness.



A standalone Occupational Health and Safety (OHS) Management Plan composed of procedures for management of relevant occupational hazards, manual heavy lifting, electrical safety, equipment safety, handling of medical wastes, and hygiene issues will be prepared for the operational phase of the project (ESAP item 17). The Company will provide appropriate training (e.g. working at height, use of PPE, working in confined spaces) to workers on occupational health and safety issues as detailed in PS1. There wil
l 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 monitored, revised and updated during operational phase (ESAP item 13). An OHS manager will be assigned for managing OHS issues. The health and safety management system established as a subset of the management system 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.



Although the large majority of the workforce will be sourced locally, there will be on-site worker accommodations. The camp site will be facilitated with services and utilities in line with IFC’s Guidance on Worker’s Accommodation. Those will include but 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, life and fire safety provisions, kitchen and food in line with WHO recommendations, first aid services, leisure and communications facilities.



Workers Engaged by Third Parties

The project company will work with contractors during the construction phase and with service providers during the operational phase. The Company will require its contractors and service providers to observe the health and safety policy of the project as well as local health and safety legislation. The contractors and service providers will also be requested to report accidents, incidents, and safety non-compliances. The project company will require that the contractors and service providers manage their employees in line with the established HR Policy. All the above-mentioned issues will be binding conditions in the contracts made with the contractors and service providers and will be taken into consideration in the bids. As per the ESAP item 2 and 13, the project company will develop a Contractor Management Plan (CMP) in order to ensure that all the contractors and service providers are aware of their commitments regarding environmental and social (including labor/PS2) issues. The plan will be comprised of training, provisions regarding implementation of ESMP to be included in the contracts and monitoring requirements (ESAP items 2, 13, 5 and 16).



Supply Chain

The project company, as per the ESAP items 8 and 19, will integrate in its OHS management plan procedures and mitigation measures to ensure that primary suppliers within the supply chain are taking steps to prevent or to correct life-threatening situations related to supply chain workers
, and where remedy is not possible, the project company will shift the primary supply chain over time to suppliers that can demonstrate that they are complying with IFC’s performance standard.

The project company will manage environmental impacts during construction and operation phases of the project as per its new established environment, health and safety and security management system. The system will include procedures and standards that meet IFC’s PS3 provisions and applicable general and sector specific EHS guidelines.



Resource Conservation

At the project site, water, natural gas and electricity will be supplied from the city grid during the construction phase. 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 compose two gas engines, with capacity of each 4.3 MW. The purpose of using a tri-generation plant is to secure the electricity required by IHC. The estimated energy requirement of the IHC is approximately 73 million kWh/year. The additional heat requirement will be met by a boiler with a total installed capacity of 40 MW. In order to reduce stack emissions from the tri-generation system, a catalytic converter system will be used. The design of tri-generation plant and boiler will ensure the emissions from boiler and engines will be in line with WBG’s EHS Guidelines and be monitored periodically.



Energy Efficiency

The electricity, heating and cooling needs of the facility will be from the trigeneration and boilers systems that will be installed inside the IHC during operation. Annual consumption of electricity is expected to be around 73 million kWh, equivalent to around 250 kWh/m2. This value is below the average (591 kWh/m2) for health care facilities defined in U.S. Energy Information Administration. The tri-generation system and boiler will use natural gas. Due to the fact that the energy and natural gas requirements will be high for the IHC operation, efficiency opportunities and associated tasks to achieve energy savings will need to be considered in the design and operation of the IHC project.



Water Consumption

It has been reported by the client that the expected number of people to be on site is about 35,000 including staff, patients and visitors. In this respect, the specific water consumption is expected to be approximately between 50 – 70 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 Adana IHC is expected to be much lower than that level with the value between 412 – 584 m3/bed-yr.



Waste Management and Disposal

A waste management plan covering both construction and operation phases for Adana IHC has been developed in the scope of the ESIA studies. Within the scope of the waste management plan all types of wastes were described and classified with the international codes. Waste specific treatment and disposal options, anticipated amount of waste, transp
ortation and disposal methods are provided. Non-hazardous, hazardous, medical and radioactive wastes will be produced during construction and operational phases of the project.



It is anticipated that approximately 600,000 m3 of excavated material will be generated that will require off-site disposal. Non-contaminated excavated soils will be stockpiled on the ground within construction site and will immediately be transported to the disposal area licensed and approved by the municipality in compliance with the related local regulation (Regulation on Control of Excavated Soil, Construction and Demolition Wastes-Official Gazette Date/No: 18.03.20104/25406). Other non-hazardous solid wastes which will be generated during construction phase will be segregated by type and will be disposed by the municipality.



In the operation phase, non-hazardous solid wastes will be segregated by type and will be disposed by the municipality. Medical wastes are anticipated to be composed of microbiological laboratory wastes, waste blood samples, and objects contaminated with blood, human tissue, used surgical clothes, dialysis wastes, air filters containing bacteria and viruses, injection needles, and broken glass and similar objects. Medical wastes will be disposed to Adana Sofulu Integrated Solid Waste Disposal Facility which has Medical Waste Sterilization Unit with 8-10 tons per day capacity. Collection and disposal of the medical wastes in the project will be done in line with local regulation (Regulation on Medical Wastes Control-Official Gazette Date/No: 22.07.2005/25883).



The daily wastewater discharge generated during the construction phase is expected to be 445 m3 which will be discharged into the nearby municipal wastewater collection line and treated by biological treatment plant of the municipality.



During the operational phase, daily water consumption is expected to be between 1,750 and 2,480 m3 which will also be discharged into the nearby municipal wastewater collection line. The current municipal wastewater treatment plant operates with 67% capacity. Project wastewater load will represent less than 3% maximum increase in the existing flow rate indicating that this will still be within the treatment capacity of the plant.



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. As specified in ESAP item 1, a health care waste management system will also be established and implemented during the operational phase.



Hazardous Materials Management

Hazardous wastes generated during the construction and operational phases of the project will be separately collected and labeled appropriately in a designated area and disposed in licensed facilities. 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 (ESAP item 14).



Hazardous Wastewater Management

During the operational phase, domestic wastewater generated in health care facilities contains a variety of pathogens, organic pollutants, nitrogen, phosphorus and suspended solids due to its sewage content. There will be no separate wastewater treatment plant within the IHC for this contaminated water from the health units. As reported by the Company, wastewater from departments within the IHC will be collected via different piping systems and discharged directly into the sewer system, except for the wastewater that is contaminated with radioactive substances (i.e. from nuclear medicine department) which will be collected separately and/or subject to neutralization prior to being discharged into the sewer system. It is important to note that several conditions are set for liquid wastes contaminated with radioactive substances in the Regulation on Wastes Generated upon Usage of Radioactive Substances (Official Gazette Date/No02.09.2004/25571) related to discharging this type of wastewater into the sewer system. As per the related IFC guidelines for health care facilities, the Company will ensure that wastewater characteristics are in compliance with all applicable permits and that the municipal facility is capable of handling the type of effluent discharged. In addition as per the above mentioned regulation, the Company will provide necessary approval for the discharge of liquid wastes containing radioactivity and provide necessary evidences that the municipality’s wastewater treatment facility is capable of handling hazardous wastewater treatment as defined in ESAP item 20.



Air Emissions

The primary sources of air pollution during construction include dust from earthworks and main construction activities, emissions from construction vehicles. Within the scope of ESIA, a baseline survey of air quality for SO2, PM10, CO, NO, NO2, NOx and O3 was undertaken and a baseline measurement of air quality for PM10 and PM deposition was performed. Air dispersion modeling study (for PM10 and PM dispersion) was undertaken to estimate the air quality impacts associated with the construction. In accordance with the result of the modeling studies, daily and monthly ground level concentration (GLC) values of PM10 to be generated during the construction phase in controlled working conditions are 37.06 μg/m3 and 23.93 μg/m3, respectively for earthworks and 4.94 μg/m3 and 4.93 μg/m3, respectively for main construction. These values are significantly below the associated limit values stipulated in World Health Organization (WHO) Guidelines (except for the slight exceedance of WHO limit value during earthworks) which
are 50 μg/m3 and 20 μg/m3 respectively. On the other hand, when the long-term total pollution value is considered, it is seen that the above mentioned limit values are exceeded. However, this is related with the high ambient background air quality values and not directly associated with the emissions from the project.



The primary sources of air pollution during operation phase of the project will be emissions from the tri-generation plant and boiler system and the secondary sources of air pollution are anticipated from increased local traffic. In order to identify the impacts from the tri-generation and boiler systems, air dispersion modeling study was undertaken for the NO2 parameter. Hourly and annual GLC values of NO2 estimated from the tri-generation system and boilers are 44.00 μg/m3 and 2.06 μg/m3, respectively. These GLC values are significantly below the associated limit values defined in the WHO guidelines which are 200 μg/m3 and 40 μg/m3, respectively.



Greenhouse Gas Emissions

Generation of greenhouse gas emissions during the operation of the tri-generation and boiler systems is calculated as 87,968 tons CO2/year. As per the IFC Performance Standard 3, the project company will be reporting the annual direct and indirect emissions in the annual monitoring report (AMR).



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 which are 55 dBA and 45 dBA for residential areas during daytime and nighttime respectively. However, according to the result of baseline environmental noise measurement presented in the ESIA the daytime results are between 53.04 and 66.22 dBA while the nighttime measurement results are between 47.72 and 60.13 dBA. As per the mentioned guidelines, noise impacts should not exceed the aforementioned levels or result in a maximum increase in background levels of 3 dB at the nearest receptor location off site. In this respect, the necessary modeling studies have been conducted and ensured by the Company that the existing noise levels will not be exceeded 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.



Tri-generation plant, vehicle traffic and helipad will be a continuous noise source during the operation phase of the project. However, noise impact assessment for the operational phase of the project is not complete. Therefore, cumulative noise levels should be assessed in order to conclude whether the project will have significant impact on local residents. Furthermore, as per the ESAP, the Company will periodically monitor the noise limits and in case of exceeding the limit values, will take necessary mitigation measures in line with the IFC’s environment, health and safety (EHS) guidelines. The noise management plan as specified in ESAP item 2 and 14 will cover relevant monitoring proced
ures.

Typical risks associated with the construction of this project are safety risks, increased traffic of heavy machinery, noise, dust, hazardous material handling, and fire and life safety.



The Company will implement construction area safety measures to protect the citizens, including barricading, control of the access, traffic safety, control of the construction vehicles, clear demarcation of areas and provision of safety information to visitors (ESAP item 11).



Life and Fire Safety (L&FS)

As reported by the project company, the overall design, construction and operation of Adana IHC will be based on Turkish Regulation on the Fire Protection of the Buildings, and Turkish and European (EN) standards. However, when local standards are not sufficiently detailed and are incomplete, internationally accepted life and fire standards (National Fire Protection Association-NFPA standards, International Building Code-IBC and European-EN standards) will be applied. For this reason, in addition to mapping of Turkish requirements for life and fire safety will be conducted in order to identify the insufficient areas and incorporate them into the design based on the international standards, the company will develop a Life and Fire Safety Master Plan for the project and it will be reviewed by professional acceptable to IFC to comply with IFC’s life and fire safety requirements. The company shall also obtain the design and post-construction life and fire safety certifications as defined in ESAP item 9 and 21.



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



Traffic Management

The project location is in a residential area and hence will result in traffic impacts during both construction and operation phases of the project. During the construction phase, traffic increase in the local environment is anticipated to be the one of the major impacts of the project due to the construction vehicles and trucks carrying constructional materials. Approximately 500 trucks would be travelling to and from the construction site for a period of six months during the excavation phase and approximately 300 trucks would be travelling to and from the construction site during the main construction period. In the operation phase, there will be significant increase in traffic load due to transportation of employees, patients and visitors. According to the preliminary traffic assessment conducted by the project company, it is estimated that 14,000 vehicles will visit the facility daily with the peak traffic being between 8:00 – 14:00 with an estimated average vehicle load of 8,000. The project company committed to perform the traffic assessment and develop for const
ruction and operation phases of the project, a traffic management plan considering vehicular traffic, emergency conditions, pedestrian traffic entering, exiting and internal traffic and the pedestrian traffic generated from the metro line which will be constructed by the municipality (ESAP items 2 and 13).



Security Personnel

Security arrangements to be performed during the construction phase have not been established yet. The health campus will be equipped with peripheral fences and closed circuit TV system to be operated during 24 hours. General security of the campus will be provided by a private company. There are different security measures in the high security forensic psychiatric hospital including fences, walls, remote control steel doors, iron railings, closed circuit camera systems, security buildings and security staff. The Ministry of Justice will be responsible for the security of the forensic hospital on site. The company will develop security plan for construction and operational phases of the project as per the ESAP items 2 and 13. This plan will be consistent with the national requirements. In addition, the Company will ensure that all security personnel are trained on human rights and voluntary principles; internal and external grievance mechanism is established; and process code violations from security personnel against members of the community and employees is identified and disclosed as defined in ESAP 10 and 22.

Stakeholder Engagement Analysis and Planning
The Company, through its consultant, started stakeholder engagement activities during scoping stage and continued during the preparation of the ESIA report. A public consultation meeting was held on November 8, 2013 in Yuregir district and attended by 50 people. The meeting was announced via advertisements in one national and two local newspapers thirteen days in advance on October 26, 2013 and the advertisement was repeated at the same newspapers on November 1, 2013. 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. In addition to public meetings with the local community, face to face meetings were held with the governmental authorities and relevant NGOs in order to identify the affected communities, ascertain the potential negative and positive impacts, and to develop relevant mitigation measures.

The project company has already developed a standalone Stakeholder Engagement Plan for the construction and operational phases of the project including patients, their visitors and families as stakeholders in addition to institutional stakeholders and nearby communities.

Grievance mechanism and public disclosure
The stakeholder engagement plan determines procedures for consultation, disclosure of information and a solid and locally acceptable grievance mechanism. The grievance management system will ensure that all comments, suggestions and objections received from the project stakeholders, especially from local communities, are properly addressed. Related stakeholders and local communities will be informed about the grievance management system during the consultation and disclosure activities. All grievances will be recorded, responded and resolved in a defined timeframe. A government grievance phone-line for patient rights is accessible 24 hours a day. This mechanism can also be used by the patients in case of grievances regarding the health care services they receive.

The website of the Adana IHC Project has already been created both in English and Turkish for the disclosure of the project-related documentation. The ESIA was disclosed on the website of the Company on June 20th, 2014.

The project company will make the project related documents (Environmental Impact Assessment-EIA, Environmental and Social Review Summary-ESRS, Environmental and Social Action Plan-ESAP, Non-Technical Summary-NTS covering a summary of EIA and Stakeholder Engagement Plan-SEP) publicly available in local language at the project site and in its website http://www.pppadanahastanesi.com . After disclosure of the ESRS and ESAP, the project company will initiate communications with the local community as planned in related stakeholder engagement plan for addressing any critical concerns regarding project operations.

The company will make available project related documentation in the local office upon its establishment. In the meantime the project documentation will be available at the addresses given below:

Korkut Ersozoglu
General Manager
Adana PPP A.S.
Refik Belendir Sokak No: 110/2
Yukari Ayranci – ANKARA - TURKEY
E-mail: mailto:korkut.ersozoglu@ronesans.com
http://www.pppadanahastanesi.com/

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
1. Develop an overarching policy defining EHS objectives that provides a framework for the management and operations of the company and commitment to implement IFC’s PSs in its operations (or more stringent national standards if they exist)	10/30/2014
2. Establish and implement an environmental and social management system (ESMS) and associated plans and procedures for project construction phase consistent with IFC’s performance standards and World Bank Group provisions and relevant general and sector guidelines. The management system is to be developed based on a detailed risk assessment and include:	10/30/2014
2a) Environmental and social management plan, incorporating key operational and monitoring procedures: occupational health and safety, air quality control, noise control, emergency preparedness and response, construction camp management, contractor management, traffic management, liquid and solid waste management, hazardous materials management, community health and safety management, security as well as archaeological chance finds and community grievance management.	10/30/2014
2b) Induction and EHS training programs for the staff and contractors for construction phase based on a risk assessment study.	10/30/2014
3. Develop EHS management capacity by establishing an EHS management department for construction phase of the project.	10/30/2014
4. Develop a HR Policy in line with IFC PS2 requirements for construction phase and ensure all employees are aware of its content.	10/30/2014
5. Prepare template third party contracts (construction and services) to ensure proper coverage of OHS requirements and employee access to a grievance mechanism.	10/30/2014
6. OHS management system to be developed and maintained during construction period.	10/30/2014
7. Develop a formal grievance mechanism for the employees consistent with the requirements of PS2 to raise concerns and suggestions and ensure that it is accessible to the third party (contracted) employees.	10/30/2014
8. Integrate in OHS management plan procedures and mitigation measures to ensure that primary suppliers within the supply chain are taking steps to prevent or to correct life-threatening situations related to supply chain workers, and where remedy is not possible, the Project Company will shift the primary supply chain over time to suppliers that can demonstrate that they are complying with IFC’s performance standard.	10/30/2014
9. Develop a Life and Fire Safety Master Plan for the project and it will be reviewed and design certification will be provided by a professional acceptable to IFC to comply with IFC’s life and fire safety requirements.	10/30/2014
10. Develop a security force usage policy and procedures including relevant training programs based on a risk assessment. Ensure that security personnel are screened before employment and that security personnel are trained on human rights and Voluntary Principles.	10/30/2014
11. Develop a procedure to implement construction area safety measures to protect the citizens, including barricading, control of the access, traffic safety, control of the construction vehicles, clear demarcation of areas and provision of safety information to visitors.	10/30/2014
12. Revise the policy defining EHS objectives that provides a framework for the management and operations and commitment to implement IFC’s PSs in its operations (or more stringent national standards if they exist)	11/30/2017
13. Establish and implement an environmental and social management system (ESMS) and associated plans and procedures for operational phase consistent with IFC’s performance standards and World Bank Group provisions and relevant general and sector guidelines. The management system is to be developed based on a detailed risk assessment and include:	11/30/2017
13a) Environmental and social management plan, incorporating key operational and monitoring procedures: occupational health and safety, air quality control, noise control, emergency preparedness and response, construction camp management, contractor management, traffic management, liquid and solid waste management, hazardous materials management, community health and safety management, exposure control for blood-borne pathogens, radiation exposure control, radioactive substance, security as well as community grievance management.	11/30/2017
13b) Induction and EHS training programs for the staff and third party service providers for operation phase based on a risk assessment study.	11/30/2017
14.  Develop EHS management capacity by establishing an EHS management department for operation phase of the project.	11/30/2017
15. Revise HR Policy in line with IFC PS2 requirements for operation phase and ensure all employees are aware of its content.	11/30/2017
16. Prepare template third party contracts (third party service providers) to ensure proper coverage of OHS requirements and employee access to a grievance mechanism.	11/30/2017
17. OHS management system to be developed and maintained during operation period.	11/30/2017
18. Develop a formal grievance mechanism for the employees consistent with the requirements of PS2 to raise concerns and suggestions and ensure that it is accessible to the third party (contracted) employees.	11/30/2017
19. Integrate in OHS management plan procedures and mitigation measures to ensure that primary suppliers within the supply chain are taking steps to prevent or to correct life-threatening situations related to supply chain workers, and where remedy is not possible, the Project Company will shift the primary supply chain over time to suppliers that can demonstrate that they are complying with IFC’s performance standard.	11/30/2017
20. Provide necessary evidences that the municipality’s wastewater treatment facility is capable of handling hazardous wastewater treatment and necessary approval for the discharge of liquid wastes contain radioactivity.	11/30/2017
21. Obtain post construction life and fire safety certification provided by a professional acceptable to IFC to comply with IFC’s life and fire safety requirements.	11/30/2017
22. Develop a security force usage policy and procedures including relevant training programs based on a risk assessment. Ensure that security personnel are screened before employment and that security personnel are trained on human rights and Voluntary Principles.	11/30/2017