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
PS 5 – Land Acquisition and Involuntary Resettlement
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources and PS 8: Cultural Heritage are not considered applicable to the project, because SEDAS transmission lines are generally co-located along highway, road, and other rights-of way to minimize costs and disturbance to ecological, socio-economic, and cultural resources. Also, where sensitive areas or artefacts are identified, slight route modifications or specific mitigation solutions are generally available to avoid impacts on such areas or artefacts. As noted under PS 1 below, procedures for dealing with potential impacts on forest areas and chance finds of cultural heritage will be incorporated into SEDAS’ management systems. PS7: Indigenous Peoples is not considered applicable as there are no indigenous people in Turkey.

Key E&S issues related to this project encompass the following:
Environmental and social management system, procedures and technical capacity for its effective implementation and continuous monitoring/reporting
Hazardous and non-hazardous waste management, air emissions, greenhouse gas (GHG) emissions
Wastewater and storm water management
Occupational Health and Safety (OHS)  as well as labor and working conditions of employees, including contractor employees
Community Health and Safety
Stakeholder engagement

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Policy, Management Systems and Organizational Capacity and Competency



As electricity distribution lines and relevant facilities are not covered by Turkey’s Environmental Impact Assessment (EIA) Regulation, SEDAS operations are not required to undertake EIAs. In certain cases, forest areas are used as right-of-ways for electrical distribution lines to supply electricity to rural areas within the SEDAS region. The construction of these lines does not fall within the Turkish EIA regulations since they are typically 34.5 kV or <1 kV which is below 154kV (the lower limit for EIA studies). In order to properly identify and manage potential risks to biodiversity in future, SEDAS will undertake a high level assessment of ecological risks and impacts in any forest areas to be used as rights-of-way, and will develop any necessary mitigation measures recommended. The company will also develop and implement a standard procedure for construction works in forest areas that identifies contractor EHS requirements, as per ESAP action #3

In addition, construction activities may accidentally lead to the uncovering of cultural heritage. A chance find procedure will be developed and implemented by SEDAS and its construction contractors as per ESAP action # 3.





SEDAS has a Quality Management System (QMS) that covers some procedures, instructions and other relevant documents related to EHS issues. The QMS and related documentation were prepared based on ISO 9000, ISO 14001 and OHSAS18001 management system standards Nevertheless, environmental and Occupational Health and Safety (OHS) policies and operational procedures are not formalized or well documented.



Therefore, the company will develop/adapt and implement an E&S Management System (ESMS) that covers its existing operations and future expansions in line with IFC Performance Standard 1 as per ESAP action #1. The ESMS will cover all key elements of PS 1, namely EHS Policy/ies, a process to systematically identify EHS risks and impacts, a set of management procedures and/or program aimed at mitigating key EHS risks, well defined organizational capacity to manage EHS issues, emergency preparedness and response procedures, stakeholder engagement arrangements (including a grievance mechanism) and EHS monitoring and review procedures.



The Quality Management (QM) department is responsible for environmental issues which are managed by the Quality Supervisor who is an environmental engineer and supported by a quality specialist. OHS Issues are managed by three full-time OHS experts (B Level certified as required by Turkish OHS Legislation) and two OHS support staff, who are in charge of OHS issues within the Sakarya, Bolu/Düzce, and Gebze/Kocaeli regions respectively. The company will restructure the QM department to develop and implement an integrated EHS and QM management system with documented job descriptions and increased capacity as per ESAP action #1. This capacity increase will allow the upper
management of SEDAS/SEPAS to better manage the EHS aspects of their business associated with operations and maintenance.





Emergency Preparedness and Response.

The company has started to prepare a corporate emergency response plan, which is a legal requirement. A set of procedures to assist employees and emergency response teams during an emergency is included in the company’s ''Internal Regulation on Occupational Health and Safety''. SEDAS needs to prepare emergency plans covering accidents, fires, natural disasters and oil spills as set forth in ESAP action 5 Fire and evacuation drills have been conducted at operation buildings in Kocaeli and Gebze in 2014 and SEDAS receives external consulting support from a fire safety services company.. Distribution and transformer stations have smoke and motion detectors against unauthorized entry and transformer units are locked and repair and maintenance units and warehouses are equipped with fire extinguishers, smoke detectors and alarms connected to security guard house.

Monitoring and Review. Energy consumption, near miss and lost time accidents are among regularly monitored parameters. Thermal camera measurements are performed regularly for electrical installations. For occupational health and safety, lost-time accidents have to be reported on-line. There is evidence of a safety key performance indicator (KPI) monitoring and improvement system in place, including tracking of near miss incidents and use of ''Corrective Preventive Action Forms''.

There is no established monitoring program and review of environmental and social performance besides monthly audits at temporary waste storage areas located in Kocaeli and Bolu Main Warehouses and Adapazarı Operational Warehouse. SEDAS’ contractor management requirements will need to be enhanced to include regular inspections and periodic reporting in relation to contactors’ EHS performance and compliance with required laws and regulations, as per ESAP action # 4.



Training

According to the relevant legislation, workplaces conducting ‘very dangerous works’ are required to ensure that the employees who are engaged in these tasks receive necessary vocational trainings, as well as standard 16-hour OHS training every two years. Induction and periodic OHS trainings are provided to the SEDAS employees within the relevant regulatory framework. Yearly training programs are prepared by the Quality Manager. In 2014, SEDAS established a new training center in its Sakarya office. Training programs include operational and safety training on simulator equipment including old and new transformer models, old and new electrical panels, and different type of electrical poles (wooden, metal and concrete) for grounding and work at height. Trainings are provided to operational staff by OHS experts, electrical engineers and technicians. Additionally 20-minute training videos have been recorded by the company on various technical topics to aid these trainings. All SEDAS el
ectrical technicians hold valid EKAT certificates (i.e. vocational certification required as per the Regulation on Electrical High Current Facilities) and attend refreshment courses offered by TEDAS every 5 years, as legally required. SEDAS will include environmental awareness trainings in periodical training program for all sites and employees as per ESAP action#1

Working Conditions and Management of Worker Relationship



Human Resources Policies and Procedures

The total number of employees working or AKCEZ, SEPAS and SEDAS is 1,852. There are a total of 208 women employed in the three companies representing 11.2% of the total workforce.. AKCEZ manages labor and working conditions according to written procedures and policies through its Human Resources (HR) Department, which oversees all labor related matters in SEPAS and SEDAS. AKCEZ has a written HR policy and HR management system, including ‘Personnel Regulations’ and HR procedures and instructions These procedures and regulations cover rules for recruitment, preparation of job descriptions, delegation of works, disciplinary actions, internship, annual leave policy, promotions, training instructions, a grievance mechanism for employees, dismissal, leave of employment, personnel attendance control and workplace safety rules.

The salary policies of AKCEZ, SEPAS and SEDAS are well defined and communicated to employees. Blue collar employees are paid daily wages and white collar employees are paid monthly salaries. This wage system is in line with national regulatory requirements. Daily transportation services are provided for employees. Alternatively, for employees residing in out of route locations, transportation ticket costs are reimbursed. The disabled personnel employment of AKCEZ, SEPAS and SEDAS is compliant with the 3% rule of the law. All three companies aim to employ principles of fair treatment at the workplace and equal opportunity in relation to recruitment and career advancement. No discrimination by ethnicity, sex or religion is allowed according to company requirements. It is indicated in the HR policy of AKCEZ that “the company thrives to create an atmosphere in which the employees are provided equal opportunities to improve themselves”. It was reported that the employees have the opportunity to voice their comments and grievances through the established grievance mechanism.

Workers’ Organizations

There is collective bargaining between the trade union members and SEDAS, with agreements renewed every 2 years. Most SEDAS employees and all blue collar employees are members of the trade union of energy, water and gas workers of Turkey (TES-IS) which is based in Ankara. There have been significant gaps in terms of wages and benefits between workers that became members of TES-IS before privatization on 31 December 2009 (first group) and those after privatization (second group), stemming from the fact that the first group still benefit from privileges gained while SEDAS was a state-owned company. Included in the second group are a total of 954 former sub-contractor employees working in repair and maintenance, meter reading and power connection/disconnection for customers, who were recruited by SEDAS as of July 2013 following negotiations with TES-IS. Although the latest collective agreement renewal has reportedly included studies for equa
lization of benefit payments (i.e. overtime fees, shift benefits, hazardous duty payment rates and bonus payment day numbers) between the first and second groups; these benefits have not been completely aligned yet. The company will continue to address these discrepancies in benefits with the labor union during the process of negotiating collective agreements in 2017 and beyond, in accordance with PS 2 objectives.

Retrenchment

AKCEZ, SEDAS and SEPAS do not anticipate a reduction in the current workforce; in fact the project will create new employment opportunities thus will increase the overall employment figure. However, if becomes necessary in future, AKCEZ, SEDAS and SEPAS will prepare a retrenchment plan based on consultations with the affected workers, the workers’ labor unions and in accordance with local Labor Codes and IFC PS2 requirements.

Grievance Mechanism

SEDAS has a written grievance mechanism for its employees to raise workplace concerns. The employees are informed about the grievance mechanism at the time of hiring. According to the ‘Grievance and Recourse Instructions’ of the HR Department, the grievance must be in written form and verbal grievances are put on record by writing the grievance down in a report signed by the employee and the officer receiving the complaint. The HR Director is informed at all stages of the grievance assessment. Complaint/ recommendation boxes are available. The instruction document does not address anonymous complaints which is not in line with PS2 The company will improve the grievance mechanism so as to manage anonymous grievances and cover contractor employees as well.



Protecting the Work Force

AKCEZ, SEDAS, SEPAS do not engage in child or forced labor. There are no employees under the age of 18. The youngest employee is 20 years old and works in the call center. SEDAS maintains copies of ‘statement of employment’ for contractor employees (such as cleaning, security, etc.) and ensures by reviewing these records that the contractors also apply the same conditions on child and forced labor.



Occupational Health and Safety

Although the company has procedures in place to manage OHS and labor issues, it has not yet developed a systematic OHS management system. Health and safety management has improved in recent years, including improvements in PPE usage, safety measures, OHS training, documentation, risk assessments and emergency planning. The company has also taken steps to increase the level of safety awareness of employees. SEDAS implements a corporate ''Internal Regulation on Occupational Health and Safety'' which defines the OHS policy and covers health and safety rules and instructions for site works.

SEDAS has established OHS Committees at regional facilities where a minimum of fifty employees are employed as legally required and in accordance with an internal ‘OHS Committee Instruction’.

There is an Internal Audit Department that monitors compliance of local operations and pro
cedures with OHS requirements. Corrective actions items are developed from audit findings and notified to the related departments.

Accident and Near Miss Recording A total of 37 reportable accidents occurred in 2014, with 27 lost time injuries including one serious injury due to a fall from height (an employee fell from an electrical pole during maintenance activity). A total of 24 reportable accidents occurred during the first five months of 2015, with 14 lost time injuries including one serious injury due to a traffic accident. The last fatality occurred in January 2013, where a contractor employee lost his life due to electrocution.

SEDAS launched a near-miss system and organized a poster competition among its employees in April 2015 to raise awareness of the issue. ‘Near Miss and Hazard Reporting Forms’ have been developed and near miss boxes installed at 40 locations across SEDAS facilities where site employees can easily access.

SEDAS will monitor LTIFR (Lost Time Injury Frequency Rate) and compare it to the sector average. This will be reported to IFC in the AMR (Annual Monitoring Report) as per ESAP action #2

Risk Assessment According to the local legislation, workplaces conducting ‘very dangerous works’ are required to perform health and safety risk assessments and conduct reviews/ revisions every two years. A health and safety risk assessment process was initiated at SEDAS in 2010 and was carried out by an external company (Bureau Veritas). The company is currently in the process of revising its risk assessment by a team of supervisors, OHS experts and operations staff and planning to complete it within 2015. Draft risk assessment documentation dated April 2015 were available for review during the site visit, which cover small/big customers, meter reading and non-technical loss operations. Risk assessment documentation covering repair and maintenance works were not yet available.



Personal Protective Equipment (PPE) During the site visits, proper use of personal protective equipment (PPEs) was noted by SEDAS and contractor employees. PPE provided to repair and maintenance staff includes (but is not limited to) the following: hard hats, eye protectors, Low Voltage gloves, High Voltage gloves, mechanical work gloves, insulating shoes, harnesses, torches, safety vests, arc flash protection clothing (for summer & winter), LV/HV detectors and V-watch personal voltage detectors. Trainings are provided to employees about PPE usage in accordance with the ‘PPE Instruction’ of SEDAS. Telescopic platforms and ladders are frequently used during network maintenance operations. It was reported that work at heights training was provided to all relevant personnel.

Workplace Exposure SEDAS has conducted noise, illumination and electromagnetic field measurements at its facilities. The electromagnetic field measurement study was undertaken in 2010 in the SEDAS headquarters buildings and its vicinity by the Electrical and Electronics Engine
ering Department of Technical University of Istanbul. The measurements were made between 50 Hz and 1,000 Hz frequencies. Investigation of the report revealed that the electric and magnetic field measurements were found to be significantly lower than the national and international limits.

A workplace doctor and nurse from an authorized Joint Health and Safety Unit are employed at each operational region of SEDAS in line with labor regulations. Health and safety monitoring program includes periodical health examinations of SEDAS employees by the workplace doctor.

Electrical and Mechanical Safety SEDAS has repair and maintenance teams operating in five regions (Gebze, Kocaeli, Sakarya, Düzce and Bolu) operating under the Network Operation and Maintenance Department in Izmit and managed by 17 electrical engineers as regional chiefs.

All maintenance operations are implemented through the Preventive Maintenance Module of the SAP system where automated work orders are generated and forwarded the maintenance teams. After the completion of tasks, necessary information is entered into the SAP system and work orders are closed. The recently established SCADA system is used to provide remote control of equipment shut down and transfer of electricity from one unit to another in case of repair and maintenance.

It should be noted that the Quality Department has issued instruction documents detailing health and safety measures to be taken during for each repair and maintenance operation, applicable to both employees and contractors.

Workers Engaged by Third Parties

SEDAS engages with several contractors on a regular basis including construction works (both above and below ground), cleaning services, security services and tree trimming services. Additionally, removal of end-of-life meters and transfer of electrical meters located indoors to outside of premises has been subcontracted to third parties. Reportedly, on average 300 contractor employees per month work in SEDAS operations.

Currently, 58 unarmed security personnel (from Tepe Savunma ve Guvenlik Sistemleri Inc.) and 93 cleaning personnel from various contractor companies work full time in SEDAS premises. Contract conditions of these indirect payroll employees comply with legal requirements.

The contractors are liable to take all necessary health and safety measures as per national health and safety legislation and ensure that its personnel uses personal protective equipment (PPE) during work. According to the requirements of the contract agreement, SEDAS reserves the right to inspect the activities of the contractor on-site and may fine the contractor in case of non-compliance with health and safety requirements. In addition, SEDAS’s ‘Internal Regulation on Environment, Health and Safety’ is provided to the contractor as part of the contract. . Apart from general occupational health and safety requirements, the internal regulation provides instructions related to environmental management. It’s
strictly implemented that power in the energy lines will be cut-off only by SEDAS personnel prior to the start of construction works. Furthermore SEDAS will include in the contracts the requirement to prepare and implement a Construction Environmental and Social Management Plan (CESMP) which will include the mitigation measures as per ESAP action #1

The company will ensure that contracted workers have access to a grievance mechanism. In cases where the third party is not able to provide a grievance mechanism the client‘s grievance mechanism will cover the contracted workers as per ESAP action #4.

Resource Efficiency

Technical energy loss in the distribution is 6.76% (including theft) and there are ongoing efforts to decrease the technical losses in each province.



Water

Water is supplied from city network and mainly used for domestic purposes in the SEDAS facilities. SEDAS/SEPAS operations are not under the scope of Environmental Permit and License Regulation and there is no direct discharge of wastewater into receiving bodies that would require control under an environmental permit. Industrial wastewater is not generated in the facilities. Domestic wastewater generated from the office buildings and other facilities is discharged to municipality sewer lines. Stormwater runoff is generated at the facilities acting as storage and warehouses, such as Kocaeli and Bolu Main Warehouses and Adapazarı Operational Warehouse that have large open areas. The company’s main warehouses were rebuilt in 2012 and are equipped with drainage systems that collect surface water runoff and convey it to oil/water separators. Nevertheless, the 2015 audit has recommended that a detailed surface water management program will be implemented, as set forth in ESAP action #6, including periodic testing of the runoff in transformer storage areas with potentially contaminated runoff.



Hazardous Wastes



Waste Oil

An inventory of transformers containing PCBs has not been prepared to date and waste oils are disposed of based on a one-time analysis of a composite of different oils. In order to comply with the regulations, PCB content in transformer oils will be analyzed and waste oils will not be mixed and will be analyzed prior to disposal. The waste oils will be disposed of in line with the PCB content of the oil. Presently they are all being sent for oil regeneration as Category I waste oil. The company will develop an inventory of transformers containing PCBs, analyze the PCB content in transformer oils and develop a relevant phase-out plan for such transformers as per ESAP action #6



Wood Preservatives:



SEDAS uses wooden poles particularly in rural areas. Wood preservative chemicals were not observed at the storage facilities during site visits. Based on the Regulatory Compliance and EHS Audit Report of AECOM (2009), wood preservative chemicals were used in the past. The current practice is use of impregnated wooden poles.



Air Emissions

SEDAS/SEPAS operations are not under the scope of Environmental Permit and License Regulation and there are no industrial emissions of concern that would require control under the ‘Environmental Permit’.



Greenhouse Gases. The company will calculate greenhouse gases emissions annually and submit the results to IFC in AMR.

SEDAS monitors and analyzes accidents and fatalities involving members of the public associated with the company’s operations. There is no specific system established for monitoring of such incidents, other than following media reports. Facilities installed in residential/commercial areas or at open public space have safety warning signage to remind the public of potential hazards associated with these facilities. However, a third party fatality occurred last year where a child lost his life entering a construction area. The accident indicates that additional measures need to be taken at facilities for prevention of unauthorized access and necessary safety precautions should be taken during construction activities to ensure public safety (e.g., safety cones, warning signs). In this regard, risks to third parties and associated actions that need to be taken are being identified by SEDAS within the scope of the ongoing risk assessment process and some trainings have been provided to the public.





SEDAS uses a large number of operational vehicles. In the last two years (2014/2015), SEDAS has experienced six traffic accidents that resulted in employee injuries (no third party injuries reported), mostly by the teams working in city and village roads and highways. SEDAS does not implement a driving safety policy and procedures and needs to provide its own drivers internal training on defensive driving. It was reported that defensive driving training is planned in 2015, which will initially include 200 driver employees. The ultimate goal is to extend the training to all operation drivers (including rental company drivers). Measures will be taken to minimize risks associated with traffic, including management of contractor vehicles as per ESAP action #5.



SEDAS employs unarmed private security personnel from Tepe Security Management and they are regularly trained and certified as per the local regulatory requirements.

The company had a Stakeholder Engagement Plan (SEP) which was not active use during site visit. That plan was revised by consultant company (ELC) in October, 2015 and SEDAS has started to implement it.
According to the SEP, priority stakeholders for SEDAS/SEPAS are considered as employees, sub-contractors (construction, cleaning, security, etc), customers (reportedly about 1.5 million consumers), local authorities and communities located in four provinces within its operation area (i.e. Sakarya, Kocaeli, Düzce and Bolu).
SEDAS/SEPAS serve a total population of nearly 3.3 million consumers spread out in four provinces.
AKCEZ has a Customer Care Department, which manages customer relations of SEDAS/SEPAS. Communication with customers is carried out through the ‘Contact Form’ available in AKCEZ, SEDAS and SEPAS corporate websites and the call center (i.e. ‘ALO 186’). Customers may also directly contact the Customer Care Department and submit comments and grievances. The majority of grievances are related to meter reading issues (30.7 %), fixture/lamp requests (19.5 %) and pole replacements (15.7 %). Other common grievance topics included invoice objections, low voltage, damaged equipment and distribution line re-routings.
There is a Corporate Communications Department, in charge of managing community and press relations of SEDAS/SEPAS. Relevant corporate communication plans are prepared annually. ‘SEDAS Communication Strategy’ document prepared for the year 2015 indicated that improving the reputation of company is a priority for SEDAS. It was reported that in 2014, 1830 positive, 757 neutral and 404 negative media coverages were recorded, indicating a decline in negative publicity compared to previous years. In this regard, crisis management training has been provided to company management and consultancy services are received from external public relations companies.
Briefings and awareness studies are conducted through corporate websites and public meetings. Regular meetings are held with the participation of local authorities and muhtars (i.e. ‘village headmen’ or, in urban settings the neighborhood representative of the government). Reportedly, SEDAS aims to understand and assess the demands, grievances and suggestions of the community through contacts with muhtars. Local administrators (such as municipal and governorship representatives) also attend these meetings and express their demands and expectations from the company. Meetings are generally held in district governorship buildings with participation of representatives of Corporate Communications and Customer Care Departments as well as engineers in charge for the province and district. In addition to verbal communication, the participants are asked to deliver their demands, grievances and suggestions in writing through the distributed forms during the meetings. The comments are then evaluated and taken into the investment plans if deemed necessary.
SEDAS reportedly prepares and distributes informative brochures and posters prior to construction activities in settlement areas. Local administrations (muhtars) are also informed directly in advance. Excavation permits are obtained by SEDAS from local municipalities prior to underground infrastructure works.
Other public engagement activities undertaken include the following:
Press conferences are held every 6 months and regular press releases are issued.
Chamber of Electrical Engineers and SEDAS are together arranging an Energy Efficiency Conference that will be held in 2015.
A painting competition on ‘Energy Savings’ was organized in 2013 for primary school students for the purpose of increasing awareness among children. 20 students were awarded gifts.

This ESRS and the attached ESAP (2015) will be disclosed at SEDAS’s webpage (http://www.sedas.com) and available at the following locations in Turkish.

Name of the Place: SEDAŞ Genel Müdürlüğü
Address: Orhangazi Caddesi PK 160 54100 Sakarya/Turkey

Contact Name: Zülal KARAGÖZ BAŞOĞLU
Title: Quality Supervisor
Email: mailto:zulal.basoglu@sedas.com
Telephone: +90 (264) 295 85 00 ext.60240

Name of the Place: AKCEZ Enerji Yatırımları San. ve Tic. A.Ş.Address: Maltepe Mah. Orhangazi Cad. Trafo Tesisleri No:72
54100 Sakarya / TÜRKİYE
Contact Name: Fırat SOĞANCIK Title: Budget&Controlling Manager
E-mail : mailto:firat.sogancik@akcez.com.tr   
Telephone : +90 (264) 295 85 00 – 530 962 30 96

Broad Community Support is not applicable for this project

AkCez II(36711) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Develop and implement a systematic Environmental and Social Management System (ESMS) which includes quality, environment, health and safety (Q-EHS). (i) Prepare necessary environmental and social (ES) management plans within the scope of the ESMS to be developed.	31-Dec-2016	Completed	Completed	12/31/2016
(ii) Hire or assign an individual E&S Manager to better coordinate E&S management across different regions	31-Mar-2016	Completed	Completed	3/31/2016
(iii) Restructure the Quality Management (QM) department to develop and implement an ESMS with defined roles and responsibilities and increased capacity (the job description will describe specific E&S responsibilities)	31-Mar-2016	Completed	Completed	3/31/2016
(iv) Include in the contracts the requirement to prepare and implement a Construction Environmental and Social Management Plan (CESMP) which will include the mitigation measures.	31-Jan-2016	Completed	Completed	1/31/2016
(v) Organize environmental awareness trainings for all employees periodically	31-Jan-2016	Completed	Completed	1/31/2016
Develop a comprehensive EHS monitoring and training program covering the EHS performance and training of the contractors as well. EHS monitoring to include: (i) Repeat noise measurements at selected facilities where former measurements indicated noise levels above the guidelines.	30-Jun-2016	Completed	Completed	6/30/2016
(ii) Conduct testing of the run off in areas after environmental risk assessment results	30-Jun-2016	Completed	Completed	6/30/2016
(iii) Start to monitor LTIFR for accidents and benchmark with sector average	30-Jun-2016	Completed	Completed	6/30/2016
I. BIODIVERSITY Conduct a high level assessment on a site-by-site basis to evaluate the ecological potential of the areas where the distribution lines will pass. Ensure that the environmental scoping assessment started by SEDAS includes ecological potential assessment Develop a general procedure for construction works in forest areas in order to identify the requirements for the contractor in terms of EHS with particular emphasis on biodiversity.	30-Jun-2016	Completed	Completed	6/30/2016
II. CULTURAL HERITAGE Develop a chance find procedure to be implemented by SEDAS and the construction contractors.	30-Jun-2016	Completed	Completed	6/30/2016
III. SEP Implement the agreed Stakeholder Engagement Plan (SEP) in order to ensure effective communication of the investment plans, potential impacts and mitigation measures for construction and operation (i.e. maintenance activities) to communities through public meetings, publications and corporate websites.	30-Jun-2016	Completed	Completed	6/30/2016
The company will continue to address these discrepancies in benefits with the labor union during the process of negotiating collective agreements in 2017 and beyond, in accordance with PS 2 objectives	31-Dec-2017	Completed	Completed	12/31/2017
Communicate the existing grievance mechanism to employees effectively. Enhance the grievance mechanism so as to manage anonymous grievances and cover contractor employees as well.	30-Jun-2016	Completed	Completed	6/30/2016
Establish policy and procedures for oversight of contractor labor conditions and EHS performance related to construction works to include (at a minimum): • Increase of regular inspections • Verification of proper accident reporting • Review and approval of contractors health and safety plans to meet Project standards • Verification of training and professional credentials for contractor EHS staff • Verification of proper labor conditions (social security, minimum wage, working hours, no child/forced labor etc.)	30-Jun-2016	Completed	Completed	6/30/2016
Include public safety issues in the risk assessment process.	31-Dec-2016	Completed	Completed	12/31/2016
Ensure that necessary safety precautions are taken during construction activities to ensure public safety (e.g., safety cones, warning signs, and community safety awareness trainings).	30-Jun-2016	Completed	Completed	6/30/2016
Develop road safety policy, practices and procedures to include a defensive, off road and antiskid driving training program for own drivers and sub-contractors’ drivers	30-Jun-2016	Completed	Completed	6/30/2016
Develop a corporate emergency response plan and define notification channels .Emergency plans need to cover accidents, fires, natural disasters and oil spills. Conduct emergency drills at all offices and sites in line with relevant legislation	31-Dec-2016	Completed	Completed	12/31/2016
Implement a storm water management program covering the operational warehouses with potential contaminated runoff.	31-Dec-2016	Completed	Completed	12/31/2016
Develop inventory of transformers containing PCBs, analyze the PCB content in transformer oils and develop a relevant phase out plan for transformers. Do not mix waste oils and analyze prior to disposal. Ensure proper waste oil classification for appropriate disposal activity.	31-Dec-2017	Completed	Completed	12/31/2017
LAND ACQUSITION (i) Develop a comprehensive Corporate Land Acquisition and Resettlement Framework (LARF) that sets out same approach, principles, procedures and institutional responsibilities that will be applied in preparation of Land Acquisition Plans for individual project developments. The LARF will include the requirements for avoidance or minimization of displacement; meaningful consultations; socio-economic assessment; compensation process; grievance mechanism for the affected populations	31-Mar-2016	Completed	Completed	3/31/2016
(ii) Publish a community pamphlet (summary LARF) locally and make available in each affected community in Turkish to allow for meaningful consultations	31-Mar-2016	Completed	Completed	3/31/2016
(iii) Disclose information on the restrictions for third party crossing projects along the distribution lines and raise awareness on H&S risks and potential legal/financial implications in case of violations of restrictions by third parties. Conduct internal monitoring activities on land acquisition and compensation processes for all projects.	31-Mar-2016	Completed	Completed	3/31/2016