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 risks (E&S) and impacts 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.

In Soda, key E&S issues include identification and mitigation of environmental, occupational health and safety (EOHS) and social risks and impacts; air emissions including implications of any proposed change in the fuel mix from natural gas to coal, wastewater and solid waste generation from both the soda ash and chromium (sulphate) production lines, worker health and safety issues and energy efficiency in Trakya and Anadolu Cam’s sites where the funds will be used.

As the production facilities are existing and operational and the proceeds will not be used for major expansion plans; PS5: Land Acquisition and Involuntary Resettlement, PS6: Biodiversity Conservation and Sustainability, PS7: Indigenous Peoples and PS8: Cultural Heritage are not considered applicable.


Key environmental and social (E&S) issues and relevant mitigation measures are described in detail in the paragraphs below. In addition, Soda Sanayii, Trakya and Anadolu Cam will implement an Environmental and Social Action Plan (ESAP). The ESAP is focused on priority mitigation measures to achieve compliance with IFC’s Performance Standards (PSs).

 IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s 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 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: Soda facilities
have quality, environmental, health and safety, energy and food safety policies
and management systems in place and most of their plants are certified against
ISO 9001, a Quality Management System, ISO 14001, an Environment Management
System, OHSAS 18001 an Occupational Health and Safety Management System, ISO
50001, an Energy Management System, ISO 22000, a Food Safety Management System
and FSSC 22000, a Global Food Safety Management System Standard. Mersin has
implemented the environment, health and work safety management systems under
the “Three-Way Responsibility Commitment”, a voluntary practice specific for
the global chemical industry. According to the existing management system, main
environmental impacts and occupational health and safety risks are identified
per each facility with the identified impacts and risks being mitigated through
a plant level action plan.

Organizational Capacity and Competency: Sisecam has a corporate level
Environmental Occupational Health and Safety (EOHS) organizational structure.
There are plant level EOHS groups that will also have dotted line reporting to
the corporate EOHS level.

The number of staff in EOHS groups at the respective Soda facilities varies and
includes EOHS Managers, EOHS engineers, an OHS expert, occupational doctor and
nurse. EOHS managers and engineers report to the plant director/manager,
whereas OHS experts, doctors and nurses report to human resources.

There are two directorates at the Group level dealing with labor and working
conditions; (i) the Human Resources Directorate (HRD); and (ii) the Industrial
Relations Directorate (IRD). The HRD handles recruitment, performance
evaluation, salary, career planning, organizational capability, personnel
development and training, whereas the IRD is responsible for collective
bargaining, relations with employee organizations and OHS. In addition to the
Group level HR organization, Soda also has its own HR Director responsible for
both HR and Industrial Relations, to whom the plant level HR manager reports.

The EOHS groups at the individual plants perform the EOHS impact and risk
assessments, provide feedback to management on EOHS performance and supervise
the Soda employees and operations. The groups also conduct EOHS training to
staff as a part of the orientation program, and there is periodic awareness
training.

Emergency Preparedness and Response: As a part of existing management system
and risk assessments Soda has documented emergency preparedness and response
plans including fire prevention, first aid, and response to spills. Fire
exercises and evacuation drills are conducted periodically on each site. In
addition, Ṣișecam has a corporate level emergency planning unit which develops
and reviews emergency plans including life and fire safety, business
contingency, emergency response for disasters and accidental release of
chemicals.

Monitoring and Review: Sișecam 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 and fines incurred. The data is reviewed by the recently established
corporate level Sustainability Department. Soda facilities report on OHS
performance (including incident rates) to the Group every six months.
Environmental data is used to generate reports and/or to provide analysis as
and when needed. Although it is not specific to the chemical business, as a
part of Sisecam’s Annual Report, EOHS performance of the Group is communicated
to shareholders and interested parties.

EOHS teams conduct daily and monthly site inspections at every facility.
Findings are recorded and action plans are developed as needed. EOHS
performance is reviewed during monthly OHS committee meetings. As a part of the
existing management system, annual management reviews are conducted.

External Communication and Grievance Mechanism and Ongoing Reporting to
Affected People: As a part of the existing management systems, facilities
developed documented procedures for recording and managing external grievances.
At the time of the appraisal, there were no complaints raised by interested
parties and/or neighboring communities. At the corporate level, EOHS
performance including information on waste recycling, energy efficiency and
greenhouse gas emissions are shared through Ṣișecam’s internet homepage
(http://www.sisecam.com ) as a part of Annual Activity Reports. This same site
may be used for interested parties to raise and register any concerns or
questions.

Working Conditions and Management of Worker Relationship: Soda employs
approximately 1500 people of which some 10% are females.

Ṣișecam has developed a corporate HR policy and procedures related to
recruitment, training, performance evaluation, terms of employment, career
development, job descriptions. This includes 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 and
external grievance system in place at the corporate level which allows for
anonymous reporting.

There is no prohibition or discouragement of freedom of association and the
individual plants have collective bargaining agreements which define 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. There was a strike in the Turkish operations in 2012
which ended when the parties reached a negotiated agreement on all issues
related to working conditions.

Lay-offs, dismissals or job cuts are not anticipated in Soda based on
projections till 2020. Even so, should any retrenchment occur, all requirements
will be fulfilled in line with the national labor law, company legislations and
collective agreements, and in accordance with IFC’s requirements related to
retrenchment.

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

Based on the appraisal findings, Soda’s HR policy and procedures are in line
with PS2 requirements.

Occupational Health and Safety: All Soda plans have occupational health and
safety management (OHS) systems in line with host country legal requirements,
and these include periodic risk analysis and OHS training. Soda Mersin and SSL
are also accredited against OHSAS 18001, an OHS management system.

Existing systems include documented procedures for lock out tag out, confined
space entry, chemical management, work permit system, welding and cutting,
manual handling, lifting safety, electrical safety, night work, incident
reporting and investigations and emergency preparedness and response plans.

Health tests are done periodically for the staff and include respiratory and
skeletons system control, chemicals in blood and audiometry checks.

New employee induction and periodic training are mandatory for all employees.
EOHS training includes topics such as management system requirements, general
site safety rules and regulations, incident / accident / near-miss reporting,
emergency procedures, waste management, chemical safety, confined space entry,
permits to work, material handling, fire prevention, working at heights / fall
protection and first aid.

Ṣișecam has Group level incident frequency rate targets and OHS management is
promoted by periodic benchmarking and recognition of best practice at plants
within the Group. Ṣișecam’s overall incident frequency rate has improved in the
last three years from 19 to 15. Lost time injury frequency rates (LTIFR; number
of lost time injuries per million hours worked (LTI/mmhrs) is 11 for Mersin
Soda, 15 for Mersin Chromium, 0 for Cromital and 7 for SSL for 2013. Except
for Cromital these figures exceed the global benchmark for the chemicals sector
of 3.5 LTI/mmhrs; .

As per the ESAP, Soda will develop and provide to IFC EOHS action plans per
plants which will include a schedule for the implementation of Sisecam’s
corporate level EOHS management system. So as to improve OHS with the objective
of reducing LTI rates further, Soda will also develop and implement plant
specific action plans to improve the use of personal protective equipment,
ensure effective equipment guarding and minimize uneven surfaces.

Workers Engaged by Third Party: Soda employs approximately 500 subcontractors
for security, catering services, cleaning jobs, warehouse operations. In
addition, Soda’s brine and limestone quarries are operated by contractors to
supply raw material to Soda. Subcontractors are required, as per contract
requirements, to follow Soda’s EOHS management system requirements, including
conducting risk assessments, attending OHS committee meetings and periodical
EOHS inspections, provide EOHS trainings to its employees, and they have access
to Soda’s grievance mechanism. Soda is monitoring its subcontractors EOHs
performance, including LTIFR.

Resource Efficiency: Soda’s production processes are energy intensive. In
Mersin, the Company meets its own energy requirements through its energy
generation station, as well as registering an electricity sales volume of
around 2,000 GWh every year.

IFC’s has supported Sisecam’s investment in production capacity expansion and
enhanced energy efficiency at its SSL plant since acquisition in 2007. Recent
investments have included steam system rationalization, expansion of
electricity generation in the cogeneration utility system and replacement of
the coal boiler with a larger unit with enhanced efficiency and pollution
controls is currently in the late stages of planning.

Energy efficiency audits by external experts were conducted in the Mersin and
SSL plants in 2013, and areas of improvement were identified. Site specific
plans have been developed to implement energy efficiency related actions
including waste heat recovery, installation of high efficiency motors,
variables speed drives etc. It is planned to extend energy efficiency
management audits to plants in other countries in 2014, with implementation
investments to follow. As per ESAP, Soda will provide IFC the schedule for
energy efficiency audits and agree with IFC on time-based improvement plans per
plants when the audits are complete.

In 2012, Soda acquired a 250MW electricity and steam combined cycle gas turbine
cogeneration plant (cogen plant) at Mersin. The steam generated is entirely for
captive consumption in the Mersin soda plant, while the electricity generated
(in 2012, around 1.7 GWh, almost 67 % of Mersin city’s needs) is sold to the
national grid.

As part of cost reduction program in the Mersin plant, installation of a coal
boiler is planned in order to produce steam for the production process, while
shutting down one of the cogeneration plant’s two gas turbines thereby reducing
Soda’s electricity sales to the grid. The company plans to employ Best
Available Technology similar to the one being currently utilized by its joint
venture with Solvay (Soda Sodi) in Bulgaria where a Foster Wheeler designed
boiler based on circulating fluidized bed (CFB) technology was implemented. The
gaseous emissions from the CFB plants will meet the requirements of the new
European Union Large Combustion Plant Directive (LCP) and WBG’s requirements
(e.g. sulphur dioxide (SO2) and nitrogen oxides (NOx) emissions to be less
than 200 mg/Nm3 and PM to be less than 30 mg/Nm3). Mersin Soda natural gas
consumption (excluding lime kilns) is around 700 million m3/year which is
expected to be reduced to 320 million m3 / year with an additional use of
320.000 tpa coal after the fuel conversion project. No change is expected for
the chromium process natural gas consumption which is around 29 million
m3/year. The coal conversion project is expected to increase the carbon dioxide
(CO2) equivalent emissions by 5 tpa which is around 0.5 % increase in Mersin
plant’s GHG emissions. The within-the-fence effect (new coal use vs reduced gas
use) of the coal conversion project is small, but the GHG impact of the project
comes from the (outside-the-fence) need to replace electricity previously
generated by Soda. The net effect of the project is an increase in GHG
emissions of around 440,000 tpa CO2 eq. This will be partially offset by Trakya
and Anadolu’s energy efficiency projects as discussed by the paragraph below

Green House Gases (GHG): The main resource consumption will be related to
production energy demand and cooling needs. The CO2 equivalent emissions are
calculated as 1,813,000 tpa for Mersin, 634,000 tpa for SSL, and 3,440 tpa for
Cromital. Soda will provide energy consumption figures and GHG emissions to IFC
through Annual Monitoring Reports (AMR). The energy efficiency projects at
Trakya Cam and Anadolu Cam include waste heat recovery projects to produce
electricity (total 48 million kWh/year) and hot water for process and domestic
usage, installation of variable speed drives, installation of motion triggered
lightening, design improvements and capacity increase for the furnace to reduce
fuel consumption, installation improvements, etc. which is expected to result
in a reduction of 16.6 million m3/year natural gas and 123,2 million kWh
electricity consumption, which will save 90,000 tpa CO2 equivalent emissions.
As per the ESAP, Trakya and Anadolu Cam will provide a progress report on the
implementation of resource efficiency projects with actual improvements in
energy consumption.


Water consumption: Water is supplied from the national grid as well as from
wells. Soda Sanayii will provide water consumption figures to IFC through
Annual Monitoring Report (AMR).

Pollution Prevention :
Air Emissions: The most significant air emissions are related to manufacturing
process emissions, boiler emissions and dust associated with raw material
(e.g., limestone, coal, etc) handling. For Mersin soda ash, the chromium plant,
and the Cromital chromium plant, point source particulate matter, NOx, CO, SO2,
chromium (Cr) and hexavalent chromium (Cr6+) emissions meet host country legal
requirements and the WBG EHS Guideline limits. At the time of the appraisal,
there was no ambient air quality monitoring for Mersin Plant. Soda will provide
information on ambient air quality for the Mersin Plant via the AMR. In
addition, as per ESAP, Soda will provide ambient air quality dispersion model
study to demonstrate the effect of coal conversion project.

For SSL, as mentioned in the ESRS of IFC’s 2013 project, the majority of point
source emissions meet local requirements and the WBG EHS Guidelines, however
boiler emissions exceed relevant WBG Thermal Power EHS Guideline values. The
new boiler that SSL plans to install will be equipped with fluidized bed
combustion and lime injection for flue gas desulphurization and has been
specified to meet national regulations which are equivalent to the WBG EHS
Guideline values for a degraded air shed. One existing boiler will continue to
operate. SSL will investigate options to address SO2 emissions from this
boiler and by the end of 2015 will present to IFC a time-based plan for further
SO2 reductions. . Options to be considered include end-of pipe treatment for
Boiler 6, possibly integrated with emissions neutralization, or even boiler
replacement. SSL will overhaul the main boilers’ (#6 and #7) electrostatic
precipitators and will add particulate control to the smaller boiler (#2).

Emissions of the cogen plant in the Mersin plant are in line with local
requirements as well as WBG’s EHS Guideline for Thermal Power.

Waste Water:
SSL’s process waste water is discharged from the factory to the “white sea”
settling ponds, and from there overflows without treatment to the Spreca River.
This is not compliant with local requirements of WBG EHS Guidelines as this
effluent is highly alkaline, with a pH of around 11.5. Neutralization of these
process effluents is required. SSL is in discussion with equipment suppliers
and in accordance with SSL’s environmental permit and water permit this work
must be completed by the end of 2015.

There are two waste water treatment plants at the Mersin plant, one for the
soda production process and the other for the chromium production process.
Treatment plants consist of settling ponds (lagoons) where particles settle
before discharge to the sea. Settling ponds are abandoned and replanted for
daily usage when filled with solid particles. Based on periodic monthly
analysis, both plants effluent quality meet host county requirements.

Process waste water and domestic waste water of Cromital is discharged to the
Organized Trade Zone’s network which has a waste water treatment plant. Soda
will provide waste water amounts and analysis to IFC via the AMR.

Wastes and Hazardous Materials Management: In line with the existing EOHS
management system implementation, Soda plants have an effective waste
segregation system in place. Chemical packages, treatment sludge, domestic
wastes, nonhazardous packaging materials, scrap metals are transported,
recycled and / or disposed by third party licensed waste companies. Soda will
provide waste figures to IFC via the Annual Monitoring Report.

Some chromium chemicals such as chromic acid are toxic due to the presence of
the hexavalent chromium constituent. Handling instruction including that
related to occupational, health and safety as well as environmental measures is
defined for hazardous chemicals, including hexavalent chromium.

In the production of sodium dichromate, the company employs a mature
calcium-free (no-lime) roasting technology to achieve clean production. This
technology is in contrast to oxidative roasting of chromate with lime which
resulted in hexavalent chromium laden solid waste, a legacy which the chromium
production facilities have to remediate to avoid soil and underground water
pollution.

In the past, Soda used to produce sodium monochromate via the oxidative
roasting of chromite with limestone (calcium containing) and soda ash. This
process resulted in large amounts of solid waste contaminated with hexavalent
chromium. This waste is at Mersin site and the company has developed a
proprietary process that is currently being used to remediate the waste. The
remediation process enables the reduction of the toxic hexavalent to a
non-toxic trivalent chromium state. The company continues to monitor the
groundwater for any hexavalent chromium contamination and will provide IFC
annual reports through the AMR. At the time of the appraisal, hexavalent
chromium content was in line with Turkish legislation’s requirements.

The most significant waste disposal issues relate to disposal of tailings (the
white sea) and boiler ash at SSL and this is currently disposed of to the
“black sea ” tailings area. SSL would like to sell ash to the adjacent cement
works, but has been unable to do so because its unburnt carbon content at
around 5% does not meet the cement company’s specification. It is expected that
the new boiler will enable more complete combustion of coal, which will permit
disposal of ash to the cement company. The white sea area was developed in
stages with different areas used for disposal over time. One area now has very
low calcium chloride content in the residues, does support vegetation and
appears suitable for use as a soil improver, to reduce the acidity of the
locally-found acidic soil. There is a new storage area constructed to
facilitate effluent neutralization and chloride levels in the existing ponds
will gradually reduce, enabling such uses in the future.

Community Health and Safety: At SSL the Faculty of Mining, Geology and Civil
Engineering of Tuzla conducted a study in January 2008 on tailing dams/ponds
stability and concluded that the risk of the tailing dams collapse is minimal.
The study concluded that an addition of 17 meters on top of the existing dam is
possible enabling disposal for the next 120 year without jeopardizing
community’s safety.

Soda has developed emergency plans including mitigations measures for community
health and safety including accidental release, plant evacuation, etc. As a
part of the existing management system, there is a formal external grievance
mechanism, where neighboring communities can raise and register their concerns.

Security personnel: Unarmed security personnel are employed through private
security contractors. Security personnel are trained in the use of force for
defensive purposes.

Soda maintains good relations with local communities and Sisecam publishes a newsletter every two months, including information on Soda’s performance. Most of the employees come from the local area and communities are generally aware of the manufacturing activities through this informal channel.

Soda organizes cultural and educational activities and as well as sporting events including a painting competition among the primary school students,

Open days for local primary school students, kite festivals especially for disabled children, tree planting festivals where more than 15.000 trees planted in 3 years in Mersin are also convended. Soda is the main and sole sponsor of Mersin University’s program for “Preservation of Sea Turtle Population in Kazanli/Mersin” since 2008 and is also the main sponsor of Mersin International Music Festival.

The Ṣișecam Group provides theoretical and practical internships in its companies to high school and university students each year.

As part of its environmental, health and safety management systems, all Şişecam plants have established communication procedures to openly share information with third parties and to address community concerns about the possible adverse impacts of their operations and control measures in place.

ESRS will be shared on Soda Sanayii’s website as well as at all sites.

For more information please contact:

Name : Mrs.Dilek Bolcan,(Corporate Environmental and Sustainability 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

Soda Sanayii(34669) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Soda Mersin, Cromital and SSL will agree with IFC on time-based improvement plans per plants related with the energy efficiency audits findings	31-Aug-2015	Completed	Completed	10/6/2017
Trakya and Anadolu Cam will provide a progress report on the implementation of resource efficiency projects with actual improvements in energy consumption	30-Apr-2015	Completed	Completed	1/15/2016
Soda Mersin will provide a copy of the air quality dispersion modelling study to IFC with a time-based plan to reduce emissions of airborne pollutants agreed with IFC, so as not to damage human health or the environment (if the the level of air emissions arising from the Project affects the air quality negatively).	31-Dec-2014	Completed	Completed	1/26/2016