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

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

This project has been classified as a Category B project as the environmental and social (E&S) risks are expected to be limited, generally site specific, and can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria.

Key environmental and social issues include; identification and mitigation of environmental, occupational health and safety (OHS) and social risks and impacts; contractor management; energy efficiency and water use; effluent monitoring and implementation of plans to align the associated performance with the World Bank Group Environmental Health and Safety Guidelines; hazardous materials management; and community health, safety and security due to transportation operations

As the production facility exists and the Project activities are occurring within the confines of the Ksani site, PS5: Land Acquisition and Involuntary Resettlement, PS6: Biodiverstiy Conservation and Sustainable Management of Living Natural Resources, PS7: Indigenous Peoples and PS8: Cultural Heritage are not considered to be applicable to the investment.

Key E&S issues and relevant mitigation measures are described in detail in the paragraphs below. In addition, Ksani will implement actions as defined in the ESAP which focus on priority mitigation measures so as to achieve compliance with IFC’s Performance Standards.

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 and Management System and Policy / Identification of Risks and Impacts and Management Program: Ksani has a documented quality management system which is certified against ISO 9001, a quality management system standard. Certification against ISO 22000 a food safety management system is ongoing and will be completed in May 2014. Prior to construction of the second furnace, Ksani conducted an environmental impact assessment in line with Georgian legislation requirements and this covered furnace construction and operation. Ksani has identified environmental, OHS impacts and risks for its operations, and developed documented instructions for safe working practices, including use of personal protective equipment.



In line with the existing projects with IFC, Sisecam is in the process of aligning its corporate level environmental, social, health and safety management system with IFC Performance Standards. Ksani is in the process of implementing the Sisecam’s corporate level environmental health and safety (EOHS) management system as being developed by the Group taking into account local needs (such as language). As defined in the ESAP Ksani will agree with IFC on a time based schedule for implementation of Sisecam’s corporate level EOHS management system in the Ksani operations. The system will include (but not be limited to) development and implementation of; (i) a documented emergency procedure including response to spills and leakages of chemicals such as machinery oil and/or gas leaks and explosions; (ii) improvement in the contractor management system to contractually define Ksani’s requirements including personal protective equipment (PPE) usage, equipment inspections including cranes, safe work instructions such as working at height, chemical handling including storage and disposal as well as waste management requirements including on site storage, transportation, segregation, recycling and proper disposal of wastes; (iii) a near miss reporting and incident investigation system; (iv) periodic (no longer than annually) EOHS impact/risk analysis related with Ksani’s operations; and (v) a procedure defining the approach to contractor’s EOHS performance monitoring including lost time injury frequency rates (LTIFR), PPE usage, working at height, etc.



Organizational Capacity and Competency: The EOHS organization consists of a full time OHS expert who reports to the General Manager. Although there is no environmental department and/or a representative dedicated to environmental management, environmental responsibilities including ongoing environmental performance and reporting to local authorities and the Group are performed by the Quality Manager who reports to the Plant Manager. The Energy Department is responsible for management of the waste water treatment plant and solid waste. Ksani’s Quality Manager and OHS expert have responsibility to perform an EOHS impact and risk assessments, provide feedback to
management on EOHS performance, supervise Ksani employees on the operations for safe working practices, and conduct EOHS training.



As there is a medical center located near the plant, Ksani does not employ its own medical staff.



There are two directorates at the Group level dealing with labor and working conditions; that is; (i) a Human Resources Directorate (HRD); and (ii) an Industrial Relations Directorate (IRD). In addition to the Group level HR organization, Ksani has its own HR Department, including a HR Manager and HR Specialists.



Emergency Preparedness and Response: Ksani has documented emergency preparedness and response plans including fire prevention and evacuation. However, Ksani has no documented procedure for accidental release of chemicals such as paints, machinery oil and / or gas leaks as well as explosion. Ṣișecam has a corporate level emergency planning unit which develops and reviews emergency plans including life and fire safety, business contingency and emergency response for disasters.



The production areas is equipped with a fire alarm system and with fire extinguishers, and with the second furnace project a sprinkler system will be installed at the production areas and high risk areas including cardboard and paints / solvents storage areas.



As a part of ESAP, Ksani will develop and provide a copy to IFC of an emergency procedure including response to spills and leakages of chemicals such as machinery oil, gas leaks and explosions.



Monitoring and Review: The Group has a system in place to monitor and review key performance indicators (KPIs), where plants provide data including air emissions results, noise levels, waste amounts, waste water quality, external grievances, fines incurred and incident rates. The data is reviewed by the recently established corporate level EOHS department.



Ksani reports OHS performance to the Group every six months. Environmental data, including information on energy efficiency, are used to generate reports and/or to provide analysis as and when needed. As a part of Sisecam’s Annual Report, EOHS performance of the group is communicated to the shareholders and interested parties.



Ksani’s environmental performance, including point source emissions, ambient air quality, waste water treatment plant effluent quality, water consumption will be reported to the Group as well as IFC through the Annual Monitoring Report (AMR)



Ksani’s OHS expert conducts daily site inspections. Findings are recorded and action plans are developed as needed. OHS performance is reviewed during monthly OHS committee meetings. Environmental performance, including interaction with local authorities, information on the submission of periodic reports to local authorities is presented to senior management annually. Implementation of Sisecam’s corporate level EOHS management system at Ksani will result in an improvement in the company EOHS performance as well.



External Communication and Gri
evance Mechanism and Ongoing Reporting to Affected People: Although not documented, Ksani has an external grievance mechanism that includes a process whereby local authorities are informed of the complaints received and reporting to interested parties and affected communities. At the corporate level, through Ṣișecam’s internet page (http://www.sisecam.com ) and as part of Annual Activity Reports, EOHS performance including information on waste recycling, energy efficiency and greenhouse gas emissions is provided. The same internet page is used for interested parties to raise and register any concerns or questions. As a part of ESAP, Ksani will develop a formal documented external grievance mechanism whereby neighboring communities and interested parties can raise and register their concerns; the approach to addressing grievances will also be documented.

Working Conditions and Management of Worker Relationship: Ksani employs approximately 280 people, of which some 25 % are females. The number of employees was around 245 before the second furnace project.



Ksani follows Group’s corporate HR policy and procedures including recruitment, training, performance evaluation, terms of employment, career development, and job descriptions. There are policies against discrimination on the basis of personal beliefs or other characteristics unrelated to a person’s ability to perform his/her duties. There is a documented formal internal grievance system, including anonymous reporting, in place where employees can raise and register their concerns.



There is no prohibition or discouragement of freedom of association and almost 160 employees are members of Georgian Metallurgy and Mining Trade Union and collective bargaining agreement included terms of employment, working conditions, benefits, vacation, grievance mechanism, etc. There is no difference in the benefits or social rights between unionized and non-unionized employees.



Although it is not anticipated, Ksani will develop retrenchment plans should any significant retrenchment become necessary in future.



Protecting the Work Force: In line with the host country laws, Ksani does not employ child or forced labor.



Occupational Health and Safety: Ksani is reviewing and translating Group’s occupational health and safety documents to Georgian. Ksani’s existing safe working practices include general site safe working rules, working near hot surfaces, and protection from glass cuts. Group’s documents include personal protective equipment (PPE) usage, information on protection from glass cuts, working at heights, chemical management, log out tag out, confined space entry, work permit system, welding and cutting, manual handling, lifting safety, electrical safety, night work, incident / near miss reporting and investigations, emergency preparedness and response plans.



Staff and prospective employees are subject to periodic health tests that are compliant with local legislation. Those tests included respiratory function, heavy metal content in blood, chromium analysis in urine and audiometry checks.



New employee induction and periodic training are mandatory for all employees. OHS training includes the topics such as general site safety rules and regulations, job specific risks and measures (such as work safety at an individual work station), incident /accident reporting, emergency procedures, waste management, chemical safety, and first aid. During the site tour, it was observed that safety shoes with non slip soles, safety glasses and ear plugs were used widely by employees. However, there were employees not using proper PPE. Contractors (working for second furnace installation/fine tuning) PPE usage rate was significantly lower than Ksani’s employee PPE usage.



As per ESAP, Ksani will develop and implement an area/department/task specific
matrix for personal protective equipment requirements for its employees, contractors and visitors and provide a copy to IFC.



The Energy Department is responsible for conducting work equipment inspections and tests, including crane inspections, fire extinguisher controls, grounding checks, etc.



Ksani’s LTIFR (number of incidents per million worked hours) has improved over the last three years, from 10.7 to 7.1. However, LTIFR is still higher than the international benchmark of 5.5. As per the ESAP, Ksani will develop and implement a near miss reporting and incident investigation system and conduct an occupational health and safety risk analysis focusing mainly on contractor management, working at heights, emergency response and provide to IFC a copy of the mitigation plan related to the identified risks.



Workers Engaged by Third Party: Ksani employs approximately 30 subcontractors for security, transportation of employees and for catering services. Temporary contractors are employed for temporary jobs such as the second furnace installation. As per the ESAP, Ksani will review its contracts for temporary contractors in order to ensure these incorporate clear requirements related to PPE use and alignment of OHS with the company’s practices and equally Ksani’s standards as applicable to environmental management e.g., that related to waste.



Ksani do not monitor contractor EOHS performance and will develop and implement a procedure defining the approach to such monitoring; this is defined in the ESAP. The company will also provide information on their performance including LTIFRs to IFC via the Annual Monitoring Report (AMR).

Resource Efficiency: Natural gas and electricity are provided via the national grid. Natural gas consumption for the existing furnace is 5.0 GJ / ton melted (based on a 70% cullet ratio and beginning of the furnace campaign) which is relatively high when compared to the industry benchmark of 3.8 GJ / ton melted (reference : eippcb.jrc.ec.europa.eu/reference/BREF/GLS_Adopted_03_2012.pdf, table 3.8). Ksani’s overall natural gas consumption, including utilities, is 6.5 GJ/tonne melted which is within the range of 4-14 GJ/ton melted from the same reference (table 3.9, with average of 6.5 GJ/ton melted). Electricity consumption is 1.8 GJ/ton melted which is also high when compared to industry benchmark of 0.6 – 1.5 GJ / ton melted (average 0.8 GJ/ton melted, from the same reference, table 3.9). These figures are expected to be 4.9GJ/ton of melted glass (for NG) and 1.1 GJ/ton of melted glass (for electricity) once the second furnace is operational. As per the ESAP, Ksani will conduct an energy efficiency audit by external specialists as performed in Sisecam’s facilities in Turkey in order to identify improvement areas and develop and implement any remedial actions as may be identified.



Green House Gases (GHG): GHG emissions in 2013 were estimated at 22,500 tonne CO2 eq/year. On completion of the second furnace expansion, GHG emissions are expected to be around 42,000 tonne CO2 eq/year.



Water consumption: Water is supplied from two wells. Ksani has significantly improved water consumption after IFC’s initial investment but is still around 2.5 m3/tonne melted glass. As such, Ksani will include water use in the planned energy efficiency audit; this is defined in the ESAP.



Pollution Prevention: Air Emissions: Ksani is not required to perform emission or ambient air quality monitoring according to Georgian legislation. Point source emissions based on raw material consumption are calculated and reported to local authorities annually. Calculated figures were in line with local\] limits. As per the ESAP, Ksani will undertake point source emission measurements and ambient air quality monitoring in line with WBG’s EHS Guideline requirements and implement measures to ensure alignment with the Guidelines if necessary.



Waste Water: Process and domestic waste water is treated through a biological treatment plant and discharged to the Ksani River. The effluent quality is not monitored and only the discharge quantity reported to Georgian authorities. As per the ESAP, Ksani will undertake effluent quality analysis for the waste water and if necessary develop and implement an action plan to bring discharge effluent quality into compliance with the WBG EHS Guidelines; this is defined in the project ESAP.



Wastes and Hazardous Materials Management: The Ksani plant has a waste segregation system in place. Cardboard, nylon, used oil are recycled by third party licensed waste companies whereas manufacturing wastes including batch house wastes, domestic w
astes including that related to the cafeteria and office are sent to the municipal landfill. Internally-generated cullet is recycled into production. Ksani will provide waste and cullet recycling figures to IFC through the Annual Monitoring Report (AMR).



There are two LPG tanks of 50 tonnes capacity each present at site for use as back up fuel. At the time of appraisal, 11 ton LPG was present. As per ESAP, Ksani will review safety measures for the LPG tanks against good international industry practices and the WBG’s EHS Guideline requirements and implement corrective actions if required. This action is included in the ESAP.



Other hazardous materials are used refractory, production coloring / decoloring agents including chromites and glass forming materials, including silica. Cleaning / maintenance chemicals are also used on-site. As per the ESAP, Ksani will review the storage, handling and disposal of hazardous materials against good international industry practices and the WBG’s EHS Guideline. Based on the findings the company will then agree with IFC on measures to be implemented to align with practices with standards defined.

Community Health and Safety: The Ksani facility is located near the town of Mina and it is not anticipated that operations will result in health and safety impacts on the neighboring communities. However as discussed above, Ksani will monitor ambient air quality and implement necessary measures if necessary to ensure alignment of the emissions with the WBG EHS Guidelines.



Truck / vehicle traffic due to transportation of raw materials and products might pose hazards to community. As per the ESAP, Ksani will develop and implement a Vehicle Operator Safety Training Procedure and Program for drivers and contractors (to the extent that it is commercially feasible for the latter) that foces on improving safety. The program will also define emergency procedures in the event of accidents.



Security personnel: Georgian local authorities provided armed security personnel to Ksani facility. Security personnel are officially trained in the use of force for defensive purposes.

At a corporate Group levela newsletter is published every two months, including information on Ksani’s performance, such as LTIFR’s. In addition, most of the employees come from the local area and communities and are generally aware of the manufacturing activities through this informal channel.

Ksani maintains good relations with local communities. Corporate social responsibility programs include cooperation with the regional green movement to plant trees at the site, support to the school and kindergarten in the local village, as well the local children’s football club, finance to support the local ambulance; and sponsorship to Georgian Juniors Team to participate in Euro championships amongst various other initiatives.

This ESRS will be lodged on Ksani and Sisecam’s website, as will be available at the Ksani facility main entrance gate.

For more information please contact:

Ümit Aydoğan (General Director)
Address:Georgia.Mtsketa.Ksani
Tel:+995 322449980
Fax:+995 322449989
e-mail:mailto:uaydogan@mina.com.ge

Mrs.Dilek Bolcan,(Corporate Environmental Manager)
Address: Is Kuleleri Kule 2 34330 4. Levent Istanbul
Tel: +(90) 212 350 3968
Fax: + (90) 212 350 4968
e-mail: mailto:mailto:dbolcan@sisecam.com
http://www.sisecam.com

Broad Community Support is not applicable for this project

The Ksani II(34591) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
1a - Ksani to agree with IFC on a time based chedule for implementation of Sisecam’s corporate level EOHS management system in Ksani operations. Schedule will cover (but not be limited with) development and implementation of ; (i) a documented emergency procedure including response to spills and leakages of chemicals such as machinery oil and/or gas leaks and explosion; (ii) improvement in contractor management system to contractually define Ksani’s requirements including personal protective equipment usage, equipment inspections including cranes, safe work instructions such as working at height, chemical handling including storage and disposal such as paint as well as waste management requirements including on site storage, transportation, segregation, recycling and proper disposal of wastes; (iii) a near miss reporting and incident investigation system (iv) periodic (not longer than annually) EOHS impact/risk anaylsis related with Ksani’s operations inclusive of a procedure defining how the findings are addressed via the system (v) a procedure defining contractor EOHS performance monitoring including Lost Time Injury Frequency Rates, Personal Protective Equipment (PPE) usage, safe working at height, etc.	30-Jun-2014	Completed	Completed	10/3/2017
1b - Ksani to develop and implement a formal documented external grievance mechanism whereby neighboring communities and interested parties can raise and register their concerns; the approach to addressing grievances will also be documented	30-Aug-2014	Completed	Completed	10/3/2017
2a - Ksani to review contracts for temporary contractors in order to incorporate clear requirements related with PPE usage, equipment inspections including cranes, safe work instructions such as working at height, chemical handling including storage and disposal such as paint as well as waste management requirements including on site storage, transportation, segregation, recycling and proper disposal of wastes. Such requirements are to align with Ksani's EOHS system.	30-Aug-2014	Completed	Completed	6/7/2016
2b - Ksani to conduct an occupational health and safety risk analysis focusing mainly on contractors management, working at height, emergency response and provide to IFC a copy of the mitigation plan related with the identified risks	31-Dec-2014	Completed	Completed	6/7/2016
2c - Ksani to develop an area/department specific matrix for personal protective equipment requirements for its employees, contractors and visitors and provide a copy to IFC	30-Aug-2014	Completed	Completed	6/7/2016
3a -Ksani to conduct an energy efficiency audit by external specialists as performed in Sisecam’s facilities in Turkey in order to identify improvement areas and develop and implement an action plan in agreement with IFC Ksani will include water use in the planned energy efficiency audit.	31-Mar-2018	Completed	Completed	05/25/2018
3b - Ksani to undertake point source emission measurements and ambient air quality monitoring in line with World Bank Group (WBG) Environmental Health and Safety (EHS) Guideline requirements and implement measures to ensure alignment with the Guidelines if necessary in accordance with a time based action plan in agreement with IFC.	30-Apr-2015	Completed	Completed	10/3/2017
3c -Ksani to conduct periodic effluent quality analysis for waste water and if necessary will develop and implement a time based action plan agreed to by IFC to bring discharge effluent quality into compliance with WBG EHS Guidelines if required.	31-Dec-2014	Completed	Completed	10/3/2017
3d - Ksani to review the storage, handling and disposal of hazardous materials against good international practices and the WBG’s EHS Guideline. Based on the findings thereon the company will then agree with IFC on measures to be implemented to align with practices with standards defined.	30-Aug-2014	Completed	Completed	10/3/2017
3e - Ksani to review safety measures for the LPG tanks against good international industry practices and WBG’s EHS Guideline requirements and implement corrective actions if required.	31-Dec-2014	Completed	Completed	6/7/2016
4 - Ksani will develop and implement a Vehicle Operator Safety Training Procedure and Program for drivers and contractors (to the extent that it is commercially feasible for the latter) focusing improving safety and this will include a procedure related to emergency response in the event of an incident.	31-Dec-2014	Completed	Completed	10/3/2017