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 project doesn’t include any new land acquisition and the energy efficiency projects will be implemented in the existing plants which are located away from known cultural and/or historical area in Organized Industrial Zones in Turkey and far from sensitive and/or urban areas in Bulgaria. Thus, PS 5 Land Acquisition and Involuntary Resettlement, PS6: Biodiversity Conservation and Sustainability and PS8: Cultural Heritage are not considered applicable to the project. There are no indigenous people in the host countries that may be affected by the project, thus PS7: Indigenous Peoples is not applicable.

This project has been classified as a Category B project as the environmental and social risks (E&S) and its potential 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. The project is expected to have positive environmental impacts including reduction in greenhouse gas emissions and energy consumption.

The key E&S issues include: the occupational health and safety during construction and the operations, disposal of hazardous materials arising from furnace cold repair and/or during equipment installations.

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: Sisecam has a corporate level environmental and energy policy and occupational health and safety policy, which are applicable to all of its activities. As a part of the existing projects with Sisecam, the Group has a commitment to IFC that all of its plants will implement EHSS management systems which will be certified according to international standards of ISO 14001 Environmental Management system and OHSAS 18001 Occupational Health and Safety Management system by 2015.



Trakya Cam has an existing EHSS management system in place in Bulgaria and Turkey in line with ISO 14001 and OHSAS 18001 including procedures for identification and mitigation of impacts and risks, operational procedures and safe working practices. According to the existing management system, environmental impacts and occupational health and safety risks were identified per each facility and plant level mitigation plans were prepared. In addition, Trakya Cam plants in Turkey and Bulgaria has certified ISO 50001 based Energy Management System in place.



Organizational Capacity and Competency: Sisecam has corporate level environmental coordinator and occupational health and safety (OHS) coordinator. Besides, Trakya has an Environmental Manager at Group level. Each of Trakya’s plants has a dedicated environmental officer and an OHS specialist. The environmental officers report to the Technical Manager who reports to the Plant Managers. OHS specialists report to Human Resources (HR). Environmental officers and OHS specialists at the plant level have a dotted reporting link to the corporate level coordinators.



In addition, the EHSS organization includes doctors, nurses and health technicians at plant level. The EHSS organization is responsible from permit applications, EHSS performance reporting to local authorities and to the Group, management of wastes, waste water treatment plant operations, conducting impact assessments and risk analysis, supervising the staff on EHSS topics, conducting EHSS trainings.



At the corporate level Sisecam established an energy efficiency department and designated an Energy Efficiency Manager. At the plant level, energy efficiency improvement opportunities are identified through energy audits and/or benchmarking. At the plant level Technical Managers are responsible for the implementation of energy efficiency projects.



There are two directorates at corporate level dealing with labor and working conditions; (i) Human Resources Directorate (HRD); and (ii) Industrial Relations Directorate (IRD). In addition to the Group level HR organization, Trakya plants have their own plant level HR Departments, including HR Manager and HR Specialists.



Emergency Preparedness and Response: Ṣișecam has emergency plans including life and fire safety, business contingency and emergency response for disasters. In addition, as
a part of the existing EHSS Management System, Trakya plants have documented emergency preparedness and response plans including firefighting, first aid, traffic accidents, floats, evacuation, chemical spills, and search and rescue.



The production areas are equipped with fire alarm systems and with fire extinguishers. Sprinkler systems are installed at high risk areas including the warehouses. There is secondary containments to limit the accidental release of chemicals around the storage areas. Gas/smoke detectors are installed in the offices and in the production areas where required by the local legislations.



Foam typed fire suppression systems and secondary containments are incorporated to waste heat recovery (WHR) projects in Mersin and Bulgaria and flue gas treatment (FGT) project in Bulgaria, where flammable chemicals will be used.



Monitoring and Review: Trakya Plant’s EHSS performance, including energy consumption, point source emissions, ambient air quality, waste water treatment plant effluent quality, water consumption, noise levels, waste amounts, external grievances, fines incurred and incident rates are reported to the Group as well as IFC through Annual Monitoring Report (AMR). This data, including information on energy efficiency, is used to generate internal reports and/or to provide analysis as and when needed. As a part of recently issued Sustainability Report, EHSS performance is communicated to the shareholders and interested parties. As a part of ESAP, Sisecam will agree with IFC on an updated AMR template where plant benchmark data and the JV’s EHSS performance will be reported.



As a part of EHSS management system, 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.



External Communication and Grievance Mechanism and Ongoing reporting to Affected People: At the corporate level, EHSS performance including information on waste recycling, energy efficiency and greenhouse gas emissions is provided through Ṣișecam’s internet page (http://www.sisecam.com ) and as part of Sisecam’s Annual Activity Reports as well as Sustainability Report covering the Turkish Plants. The same internet page is used for interested parties to raise and register any concerns or questions. As per ESAP, Sisecam will develop and provide a copy to IFC of a corporate level documented external grievance mechanism which facilitates the registration of concerns by interested parties and the approach to addressing these by the company.

Human Resources Policies and Procedure: Sisecam Group employs approximately 20,500 people, of which approximately 2,500 are employed at Trakya Cam Plants. The energy efficiency projects are not expected to change the number and/or the composition of the labor force. Trakya Cam plants follow Group’s corporate HR policy and procedures including recruitment, training, performance evaluation, terms of employment, career development, and job descriptions. All the HR policies and procedure are distributed to employees by use of “pocket employee books” and employees are able to access to the policies and procedures through Sisecam’s intranet. As a part of on boarding and orientation training, all employees are provided recorded trainings, including implementation of HR policies and procedures as well as employee’s right.



Working Conditions and Terms of Employment: White color employees have an “individual labor agreement” which includes working conditions, term of employment, benefits, vacation, wages, working hours, annual leave, and employee rights. Blue collar employees have “collective bargaining agreements (CBA)” in which working conditions and terms of employment at a minimum comply with national labor codes. There are areas in the CBA such as length of paid annual leave, marriage allowance, meal allowance, marriage leave, etc. where the benefits are beyond the requirements of the law. There is no difference in the benefits or social rights between white collar (mostly non-unionized) and blue collar (mostly unionized) employees.



Workers’ Organizations: There is no prohibition or discouragement of freedom of association and all blue collar employees are members of Trade Unions (Kristal Is in Turkey and Podkrepa in Bulgaria). There are employee representatives where the employees can raise their concerns when they would like to discuss with the management and there is provision for anonymous reporting. .



Non Discrimination and Equal Opportunity: Sisecam has policies against discrimination on the basis of personal beliefs or other characteristics that are unrelated to a person’s ability to perform his/her duties, which are also implemented in Trakya Cam Plants.



Retrenchment: Although it is not anticipated, the possibility of a retrenchment given the market conditions cannot totally be excluded. The existing CBA requires negotiation with the trade union prior to retrenchment. Previous practices in Sisecam included voluntary retirement, transfers between enterprises of the Sisecam Group and payments of extra compensation beyond that is required by law. If a retrenchment occurs, Sisecam will share a retrenchment plan acceptable to IFC, which will be developed in line with IFC’s Good Practice Note on Managing Retrenchment.



Grievance Mechanism: There is a documented formal internal grievance system in place where employees can raise and register their concerns, including through anonymous reporting. The system included use of “complaints a
nd suggestion boxes” which were distributed throughout the Trakya Cam’s Plants and/or direct communication with the supervisors/managers. The grievance mechanism is included in the Human Resources procedures and in the CBA. In addition to the internal grievance mechanism, the employees have right to ask for legal judicial and/or administrative remedies.



Protecting the Work Force: In line with the host country laws, the minimum age for employment is 18 in both Sisecam, and in Trakya Cam plants. Both Turkish and Bulgarian laws are in place, restricting child and forced labor in line with ILO standards.



Occupational Health and Safety: Trakya Cam plants’ existing EHSS management system, which was established and certified according to OHSAS 18001 Occupational Health and Safety Management System Standard, includes documented procedures and instructions for site safe working practices, personal protective equipment (PPE) usage, working near hot surfaces, protection from glass cuts, work permit system, working at heights, chemical management, manual handling, electrical safety, night work, incident / near miss reporting and investigations, emergency preparedness and response plans.



Onboarding and orientation programs for new employees and periodical refreshment training includes EHSS topics such as job specific risks and measures, safe working practices, incident / accident reporting, emergency procedures, waste management, chemical safety, and first aid.



During the site visit, it was observed that, different sites require different PPEs for the same process lines. As a part of the ESAP, Trakya Cam Plants will benchmark their site specific PPE Matrix, update them if necessary and provide IFC a copy (or progress report on the action item).



Staff and new employees are subject to periodic health tests including respiratory function, heavy metal content in blood and in urine, and audiometry checks.



Trakya Cam’s LTIFR (lost time injury frequency rate, number of incidents per million worked hours) has improved from 20.5 (in 2011) to 10.3 (in 2012) and to 11.2 (in 2013). In parallel, LTISR (lost time injury severity rate, number of lost days per million worked hour) also improved from 314 (in 2011) to 285 (in 2012) and to 280 (in 2013). However, LTIFR is still higher than the international benchmark of 5.5 (reference: http://www.bls.gov). LTIFR of Trakya Cam plants range from 3 to 16 in 2013. As per the ESAP, Trakya Cam will develop and implement an occupational health and safety improvement program, including behavioral safety discussion and share a copy of the plan with IFC. The plan will also include a documented method, as an action item, to allow Trakya Cam plants to identify and replicate best practices between plants.



Workers Engaged by Third Party: Trakya Cam plants employs almost 500 contract employees for security, catering services and employee transportation. During energy efficiency project installation / construction al
most 100 contractors will be hired for mechanical, electrical and civil works. The Technical Manager will be responsible for contractor selection and OHS experts are responsible for monitoring of the contractor’s OHS performance. As a part of the existing EHSS management system, contractors are required, as per contract requirements, to follow host country (Turkey’s and Bulgaria’s) E&S and OHS legislative requirements, including risk assessments, nomination of OHS experts and EHSS training to employees. Contractors are also required, to follow Trakya Cam’s EHSS system requirements, including safe working instruction for contractors, incident reporting, emergency response, PPE requirements, machinery and equipment inspections, safe working instructions for working at heights, working with cranes and pressurized equipment and that related to hot works, as per contract requirements. No accommodation will be needed for contracted workers.



Supply Chain: The majority of the raw materials are supplied by Sisecam enterprises or their subsidiaries, which mostly have environmental, health and safety management systems in place.

Resource Efficiency: Trakya Cam uses natural-gas fuelled regenerative cross-fired furnaces. Natural gas consumption for float glass production within the typical range seen in the industry.



Specific electricity consumption is monitored together with other productions and utilities and data shows wide variation between plants. This project includes an energy monitoring system installation which will allow Trakya Cam plants to monitor more closely and therefore drive improved performance.



Green House Gases (GHG): The main source of GHG emissions is the natural gas, electricity consumption and carbonated raw materials. Carbon dioxide (CO2) equivalent emission is estimated to be around 1.1 million tpa.



The Project is expected to improve efficiency while resulting in lower energy consumption and reduce GHG emissions. Expected annual savings from the Project is estimated at around 63.000tpa CO2 equivalent.



Water consumption: Water is provided from the municipal network. Water consumption ranges from 1.3 to 3 m3/ton glass. Trakya Cam plant made improvements in water consumptions after previous IFC investments. In addition, as a part of their existing EHSS management system each plant has specific targets for water and energy consumptions.



Point Source Emissions: The main source of point source emissions is natural gas fired glass furnaces. For Trakya Cam plants in Turkey, particulate matter (PM), hydrogen chloride and hydrogen fluoride emissions are below WBG Guideline values (respectively 100 mg/Nm3, 30 mg/Nm3 and 5 mg/Nm3) and local requirements. Nitrogen oxide (NOx) emissions range from 1,200 mg/Nm3 to 2,500 mg/Nm3, which are in line with local requirements but exceeds WBG Guideline values of 1,000 mg/Nm3. Sisecam plans to implement a reduction plan for air emissions including installation of Secondary Systems for Emission Control, where it is required by local authorities. For the Trakya Cam Bulgaria, as the local requirements are 20 mg/Nm3 and 500 mg/Nm3 for PM and NOx respectively, a flue gas treatment system, including selective catalytic reduction of NOx was installed for the operational float furnace. As a result, Trakya Cam Bulgaria’s float glass furnace PM emission is 8 mg/Nm3 and NOx emission is 350 mg/Nm3. As a part of the project, for the second furnace of Trakya Bulgaria, which is under construction, a flue gas treatment system will be installed.



Ambient Air Quality: Monitoring data for Bulgaria showed that air quality remained well within WBG Guideline values for NOx (10 µg/m3 versus limit of 200 µg/m3), PM10 (4 µg/m3 versus limit of 50 µg/m3) and sulphur dioxide (SO2, 3 µg/m3 versus limit of 20 µg/m3) and local requirements. For Turkish Trakya Cam plants, in line with Turkish legislation requirements, only NOx is monitored which remains well with in WBG Guideline values (measurements range from 11 to 20 µg/m3)



Effluents: Main waste water sources are cooling water, glass and mirror process waste water and sanita
ry (domestic) wastewater. Storm water is collected separately in all Trakya Cam plants.



In Trakya Cam Bulgaria, all domestic waste water is collected separately and discharged to municipal network, which ends with a chemical - biological treatment plant operated by the local authorities. Trakya Cam Bulgaria’s domestic effluent waste water quality is in line with the local authorities’ acceptance criteria. Process waste water is treated on site first to fulfill WBG Guideline values and local acceptance criteria and discharged municipal network as well.



In Trakya Cam Turkey, there are waste water treatment plants for process and domestic waste water before discharge to natural receiving bodies. The effluent quality is in line with local requirement but there some plants where WBG Guideline values are exceed for total suspended solid and chemical oxygen demand requirements.



Waste: Trakya Cam plants has waste segregation systems in place as a part of the existing EHSS management system. Recyclable wastes, including plastic, metal, cardboard, waste oil, electronic equipment, used batteries and accumulators are recycled by third party licensed waste companies. Internally generated cullet and dust collected from bag filters are recycled into production. Domestic wastes including wastes from the cafeteria are landfilled in municipal waste areas. Hazardous wastes including containers of oil and other chemicals, mainly used for mirror process are disposed by certified third party hazardous waste contractors.



Wastes that will be generated from furnace cold repair and/or during equipment installation will be recycled/disposed in line with the existing waste management practices.



Hazardous Materials Management: Hazardous materials include chemicals/solvents used for mirror and auto glass processes, cutting liquids, fuel used by the generators, hazardous gases including hydrogen used in auxiliary processes, ammonium used for flue gas treatment unit for the first glass furnace in Bulgaria and paint/solvent/cleaning chemicals for maintenance operations. There are material safety data sheets (MSDS), available for the hazardous materials in used. The hazardous materials are stored in separate and well ventilated areas where secondary containers are in use and absorbent materials are provided.



As a part of the new energy efficiency projects, flammable chemicals will be used for waste heat recovery system as heat transfer fluids in Mersin and Bulgaria and ammonium will be in use for flue gas treatment for second glass furnace in Bulgaria. Trakya Cam incorporated required secondary containment, online monitoring, fire suppression, fire detection and alarm system to its design in line with local legislation and good industrial practices.

Community Health and Safety: The construction and installations will be within the existing plant boundaries. Trakya Cam implemented construction safety measures to protect the community, including clear demarcation of construction site; restricted access to construction site; proper illumination of area; documented procedures for traffic safety to ensure safe movement of construction vehicles. For the operational phase, heat transfer fluids and ammonia will be transported in line with the existing measures defined in Trakya Cam’s EHSS management system, including, transportation by special vehicles where absorbent materials, emergency kits and MSDS will be provided.



Security Personal: Security personnel are unarmed and trained in the use of force for defensive purposes.

Sisecam has a Group level social responsibility framework, which is built on partnership with educational institutions. Engagement activities under the social responsibility framework include seminars in the universities, symposiums and conferences are organized for the students and sector professionals, focusing on energy efficiency where Trakya Cam also contributed. Sisecam is leading public awareness programs for glass recycling, especially in Turkey.

As a part of its social responsibility framework, Sisecam Group provided technical support to public institutions in order to provide project based solutions for energy efficient buildings and participated in the “renovation of public buildings to energy efficient buildings project”. The first case study was the renovation of Trabzon Ahi Hospital together with Ministry of Health and Ministry of Environmental and Urbanism. The project will serve as a model for public hospitals and going forward, all the public buildings will be renovated with energy efficient glasses.

Sisecam, publishes a newsletter every two months, including information on Trakya Cam’s performance. The Group’s Annual Sustainability report was issued first time in 2014 which also include information on Flat Glass plants in Turkey.

This ESRS will be available at the Trakya Cam’s Turkish Plants and Trakya Cam Bulgaria facilities main entrance gate.

For more information please contact:

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

Trakya Cam VIII(35338) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Sisecam will agree with IFC on an updated AMR template where plant’s benchmark data and JV’s EHSS performance will be reported.	31-Mar-2015	Completed	Completed	3/16/2015
Sisecam will develop and provide a copy to IFC of a corporate level documented external grievance mechanism which facilitates the registration of concerns by interested parties and the approach to addressing these by the company.	30-Jun-2015	Completed	Completed	5/31/2016
Trakya Cam Plants will benchmark their site specific PPE Matrix, update them if necessary and provide IFC a copy (or progress report on the action item)	31-Aug-2015	Completed	Completed	5/31/2016
Trakya Cam will develop and implement an occupational health and safety improvement program, including behavioral safety discussion and share a copy of the plan with IFC. The plan will also include a documented method, as an action item, to allow Trakya Cam plants to identify and replicate best practices between plants.	30-Apr-2015	Completed	Completed	2/12/2018