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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
As Istanbul One is located within the IMES Dudullu Organized Industrial Zone (OIZ) in Istanbul and the potential Ankara facility is likely to be located in an OIZ or in an urban area which will be purchased on a willer buyer/ willer seller basis, PS 4 Community Health, Safety & Security; 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 country, 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 key E&S issues include: implementation of an EHSS system consistent with IFC’s Performance Standards including adequate assessment and management of risks and impacts; establishment of an external communication system, establishment and implementation of a human resources management system and management of wastes.

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: Zenium has an existing EHSS management system (ESMS) in place including operational procedures and safe working practices. Zenium will adapt its EHSS system to operations in Turkey. Zenium will update its ESMS to reflect Turkish and IFC requirements.



The ESMS referenced above will be applicable for all future operations and activities in Turkey and Zenium will keep IFC informed of any potential new activities.



No Environmental Impact Assessment was required for these data center projects under Turkish regulations. In line with Turkish Occupational Health and Safety (OHS) legislation, risk assessments including excavation, working at height, crane operations were used during the construction of Istanbul One. Risk assessments included environmental impacts such as waste, waste water, spills, emissions and ambient dust. These assessments were conducted by Kent Development’s OHS experts and Zenium’s project management team. As per the ESAP, Zenium will provide IFC with the EHSS the risk assessments and associated mitigation measures for; (i) Istanbul One’s operational phase; and (ii) Ankara DC’s construction and operational phases, in line with both Turkish OHS legislation and IFC’s PS requirements.



At the time of the appraisal, a construction permit was already received for Istanbul One. The process for submission and obtaining other permits/licenses was ongoing.



Organizational Capacity and Competency: There was one “B” certified and one “C” certified occupational health and safety (OHS) expert at the construction site in Istanbul who were responsible for conducting risk analyses, developing and monitoring mitigations plans, reporting on OHS performance to management on daily, weekly and monthly basis, and to supervise construction employees. The OHS experts also conducted OHS trainings as a part of the on boarding program and periodical training plan. A similar approach would be put in place for the potential construction of the Ankara DC construction. As per the ESAP Zenium will nominate EHSS officers acceptable to IFC for Istanbul and potential Ankara DC’s for the operational phases.



Emergency Preparedness and Response: Both Ankara and Istanbul cities are on known earthquake zones and Zenium facilities were design by expert static engineers. Zenium incorporated Turkish seismic, life and fire safety legislation requirements into its design. An argon gas based fire suppression system will be installed. There will be smoke / gas detection and alarm system for the operational phases. For the construction of Istanbul One, a documented emergency preparedness and response plan that included a focus on earthquakes, firefighting, first aid, traffic accidents, floats, evacuation, chemical spills, and search and rescue was developed. On the Istanbul One construction site, the emergency response team consiste
d of more than 25 employees in addition to 15 first aiders. Zenium would develop similar emergency plans and teams for the potential Ankara DC’s construction. Zenium’s EHSS system will cover emergency plans for the operational phases.



Community Health and Safety: Zenium 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 within the site and out of the site; and provision of safety information to visitors while construction is being completed. As a part of Zenium’s EHSS, these same construction safety measures would be implemented at the potential Ankara DC’s construction. Unarmed security personnel will be employed through private security contractors.



Monitoring and Review: Zenium has a system in place to monitor and review key E&S performance indicators (KPIs) during construction including waste management, energy consumption, fuel consumption and incident rates. The KPIs were reported and reviewed daily and weekly by the construction management team and monthly by Zenium’s senior management. Corrective / preventive actions were planned if needed.



Once the data center is operational, the Data Center Manager will have monthly meetings with each client and report on energy usage, water usage, and waste generation. A “Client Monthly Report”, which was developed by Zenium, has been incorporated into the existing ESMS.

Working Conditions and Management of Worker Relationship: At the time of the appraisal, Zenium employed 170 contractors for the construction works in Istanbul. When the sites become operational, the number of employees will be around 20 in Istanbul and 10 for the potential site in Ankara. There will be no temporary workers and / or seasonal changes in the work force.



Zenium has a documented HR policy and procedures which will be adapted to operations in Turkey. As per the ESAP, Zenium will update and implement an HR policy and procedures for operations in Turkey, in line with both Turkish labor legislation and IFC’s PS 2 requirements including term of employment, working conditions, training, non-discrimination and equal opportunity and freedom of association



Although not documented, Zenium has an internal grievance system in place during the construction of Istanbul One, where contractor employees could raise their concerns in the EHSS committee’s monthly meetings. However, employees were not able to raise anonymous reports in the existing system. The updated HR procedures mentioned above will incorporate an internal (worker) grievance mechanism which will allow anonymous grievance reporting amongst both staff and construction contractors, as noted in the ESAP.



Protecting the Work Force: In line with the national laws, Zenium and its construction contractors do not employ child or forced labor.



Occupational Health and Safety: For the construction phase, Zenium and its contractors’ OHS capacity has been described above under PS1. Kent Development, Zenium’s main contractor, implemented an EHSS plan in place in line with Turkish legal requirements, including periodic risk analysis, training, documented instructions, periodical inspections of the equipment and work place monitoring.



This construction EHSS system included an incident reporting and investigation system that covers both actual incidents as well as near misses. During the construction of Istanbul One, there was one injury reported related to a fall from an elevated location and the lost time injury frequency rate (LTIFR, number of injuries per million work hours) was less than 1, which is satisfactory when compared to international benchmark of 6.5 (reference: http://www.bls.gov)



At the time of the appraisal personal protective equipment (PPE), including safety shoes, high visibility jackets, goggles, masks, work clothes, hard hats, ear plugs, gloves etc., were provided to contractors. There were various warning signs displayed throughout the construction site including signs related to the use of PPE and prohibiting smoking. Machinery risks and hazardous places were clearly marked, fenced and with physical barriers installed.



Pre-employment and periodical health tests for the construction contractors included respiratory system control and audiometry checks. There were one doctor and one health technician employed to provide health services to contractors.




There are on boarding EHSS training programs in place and periodic EHSS training was mandatory for all visitors and construction’s contractor employees. EHSS training included topics such as waste management, working with cranes, working with hand tools, risk mitigation measures, first aid and emergencies.



Workers Engaged by Third Party: During the operational phase, Zenium will employ subcontractors for security, catering services and transportation of the employees. For the potential construction of the Ankara DC, contractors would be hired for mechanical, electrical and civil works. As in Istanbul One’s construction, contractors will be required to have defined EHSS organizational responsibilities, including an OHS expert. Zenium’s project management team and the Turkey Country Manager will be responsible for contractor selection and monitoring of the contractor’s OHS performance. Almost 200 contractors would be employed during the construction phase of the potential Ankara DC.



For the construction of Istanbul One, contractors were required, as per contract requirements, to follow Turkish E&S and OHS legislative requirements, including conducting risk assessments, nominating OHS experts and providing EHSS training to employees. Subcontractors were also required as per contract requirements, to follow Zenium’s construction EHSS system, 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 pressurized equipment and that related to hot works. The EHSS performances of contractors, including near misses, injuries, traffic accidents, number of medical consultations were reported weekly to project management team. Accommodation near the construction site was provided for almost 90 construction employees during construction of Istanbul One. Heating and hot water were supplied by electrical heaters. Food and drinking water were provided by external companies. Zenium will require the same EHSS requirements for its contractors for Ankara project and similar accommodation will be provided during the construction period. Zenium will ensure that construction worker accommodation fulfills the basic requirements referred to in Turkish law and the IFC/EBRD good practice note on worker accommodation processes and standards (2009, referenced in PS 2).

Resource Efficiency: Electricity will be provided from the national grid for all facilities. It is expected that Istanbul DC will consume 5 million kWh per year, and the potential Ankara DC would consume around 1.5 million kWh per year. Office heating will be provided by A/C units with R304 refrigeration gases. For hot water supply, electrical heaters will be installed.



Water for own usage will be provided by the municipal network.



Zenium will monitor energy and water consumptions and will provide monthly reports to its clients.



Emissions: The main source of emissions will be the generators which will be used in case of power failures. There will be more than 30 standby generators which are expected to be operational around 3 hours per year for testing and maintenance. There will be no boilers at the facilities.



Green House Gases (GHG): The main source of GHG emissions will be from fuel used by generators and electricity consumption. Carbon dioxide (CO2) equivalent emission is calculated to be around 120.000 tpa for Istanbul DC. Based on its surface size, GHG emissions is estimated to be around 30.000 tpa for the potential Ankara DC. The cooling agent will be chilled water connected to the free cooling type roof top chillers.



Effluents: Storm water and domestic wastewater will be collected separately and domestic wastewater will be discharged to OIZ’s collection network.



Waste: Construction phase wastes include excavated soil which will be used by Zenium for landscaping, paint/cement/adhesive containers and packages, metal scraps, used oil, small amounts of medical wastes and organic waste from the cafeteria and labor camp. There was a waste segregation system in place where waste was separated at the source and recycled/disposed by licensed third party companies. Operational phase wastes will include electronic cards, packaging waste, paper, plastic from the office works, waste oil, waste lamps, batteries, solvent/paint wastes from maintenance operations and cafeteria wastes. Zenium’s EHSS plan will include a waste management matrix that will ensure that all kind of waste will be recycled/reused/disposed in line with Turkish E&S legislation requirements. As per the ESAP, Zenium will agree with IFC on a time-based plan for Istanbul and Ankara to construct a new waste storage area to ensure that all waste is properly stored in a well-ventilated area, away from direct exposure to sunlight and away from the maintenance process, where secondary containment is installed and the basement is impermeable.





Hazardous chemicals: Hazardous chemicals include fuel used by the generators and paint/solvent/cleaning chemicals for maintenance operations. Secondary containers were incorporated into the design of the fuel tanks. Zenium’s EHSS will include procedures for selection, handling, storage and disposal of hazardous chemicals.

External Communications and Grievance Mechanisms : As the facilities are located within industrial zones far from communities there are no directly affected communities. As such, no stakeholder engagement plan is required. The company has a mechanism to register customer complaints and comments. Zenium maintains good relations with local neighboring companies and OIZ management. Zenium will develop a formal external grievance communication procedure where all external parties such as other companies and the OIZ management can raise their concerns and have them responded to in a timely manner. The information related with Zenium’s grievance mechanism will be shared at the gates of the project sites during construction, and on the company website during operations

The Environmental and Social Review Summary will be shared on Zenium’s website, at the gate of Istanbul DC’s and the potential Ankara DC’s construction sites as well as site gates when they are operational.

For more information please contact:

For more information please contact:
Aslıhan Güreşcier
Country Manager
Data Merkezi Bir Üretim İnşaat Sanayi Ve Ticaret Limited Şirketi
Yukarı Dudullu Organize Sanayi Bölgesi
3. Cadde No:4 Ümraniye
34775 Istanbul
M: +90 (0)533 064 0803
E: mailto:aslihan@zeniumtechnology.com

or

Suzie BallGlobal Marketing DirectorZenium Technology Partners Limited6th Floor
65 Grosvenor Street
London W1K 3JH
United KingdomT: +44 (0)20 3667 8440M: +44 (0)7774 264347E: mailto:suzie@zeniumtechnology.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Zenium will provide IFC with the EHSS risk assessments and associated mitigation measures for; (i) Istanbul One’s operational phase; and (ii) Ankara DC’s construction and operational phases in line with both Turkish OHS legislation and IFC’s PS requirements.	03/31/2015
Zenium will nominate EHSS officers acceptable to IFC for Istanbul and Ankara DC’s for the operational phases.	01/31/2015
Zenium will develop and implement an External Communications Procedure for Istanbul and Ankara DCs, such as OIZ management, other companies in the OIZ, can raise and register their concerns	03/31/2015
Zenium will update and implement its HR policies and procedures in line with both Turkish labor legislation and IFCPS 2 requirements including terms of employment, working conditions, training, non-discrimination and equal opportunity and freedom of association Zenium will develop an internal grievance mechanism which will allow anonymous reporting and redress if worker and contractor grievances.	03/31/2015
Zenium will agree with IFC on a time-based plan for Istanbul and Ankara to construct a new waste storage area to ensure that all wastes, are properly stored in a well-ventilated area, away from direct exposure to sunlight and away from the maintenance process, where secondary containment is installed and the basement is impermeable.	03/31/2015