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
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
PS7: Indigenous Peoples does not apply because there are no distinct social groups identified as Indigenous Peoples in the project locations.

Based on the environmental impact assessments reviewed during appraisal, there is no known cultural or historical heritage on the existing or proposed project locations, therefore PS8: Cultural Heritage is not considered to be triggered at this time. As per ESAP item#1, RHOL shall enhance its existing corporate level environmental, health and safety (E&S) management system to meet the requirements of PS1. The E&S management system shall include a chance find protocol for construction related projects. All future projects will be screened against all IFC Performance Standards for applicability, and impacts and risks will be mitigated to achieve outcomes consistent with PSs.

The project is category A, due to the nature of assets in Ronesans Energy’s operations, including the Kanyon Enerji project that IFC previously categorized A.

Key environmental, health and safety and social (E&S) issues are as follows: (i) the capacity, maturity, and reliability of the Group’s corporate E&S management system to effectively manage E&S performance, including its ability to enable current and future project compliance with IFC’s PSs; ii) identification and management of environmental and social impacts from the construction and operation of energy assets; (iii) contractor management; (iv) labor and working conditions management including the accommodations provided during construction; (v) community health and safety, including during construction operations; (vi) structural safety and life and fire safety in project design; and (vii) land acquisition and compensation.

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 Management System and Policy: RHOL has adopted a corporate level E&S policy signed by the Chairman of Board in 2015. The policy sets up RHOL commitments to effectively manage E&S in all activities by providing safe and health working conditions, preventing occupational incidents, injuries, illnesses and harm to people and the environment. RHOL is committed to ensure implementation of its projects and operations in compliance with the host country requirements, allocate resources, provide staff training, set E&S targets and objectives and monitor the results.

To implement policy commitments, RHOL is in the process of developing a corporate level E&S management system that will include documented E&S procedures and instructions based on internationally recognized standards such as ISO 14001 and OHSAS 18001 by the end of 2016. In order to ensure this, a third party consultancy has been hired to evaluate the gaps and develop an action plan per each group company. A number of the group companies, including Ronesans construction and real estate businesses, have developed and implemented their own E&S management systems (certified in accordance with the international standards listed above) and applied these at the project level, including at construction sites. Other group companies have developed E&S procedures to identify and manage E&S impacts and risks. Management systems in place are largely consistent with IFC PS requirements in conducting an environmental and social impact and risk assessment, monitoring and reviewing of E&S performance and staff training.

RHOL’s commitment to update its corporate E&S policy and E&S management systems to reflect IFC Performance Standards requirements, as captured in ESAP item#1.

Identification of Risks and Impacts and Management Programs: Legally required environmental and social impacts assessment (ESIA) for RHOL’s health, energy and real estate businesses are conducted by third party consultants in line with the existing legislation. However, unless required by lenders ESIAs do not include screening against IFC’s PS requirements, and key issues such as evaluation of social impacts and development of environmental and social management and monitoring plans might be missing. RHOL’s corporate level E&S management system shall ensure that the pipeline projects will be screened against IFC PSs as a part of ESIA process and management programs will be developed and implemented to mitigate the risks.

No ESIA has been conducted for the transmission lines of REN’s operating projects, as this was not required by Turkish legislation. RHOL shall commission ESIAs and associated E&S Management Plans for all new energy projects, including transmission lines, and provide for public disclosure purposes.

E&S impact and risk registers, including job safety analysis are prepared prior to start of construction works in Ronesans. Implementation of risk reduction and mitigation measures is a mandat
ory condition for the daily construction work and is ensured through several levels of supervision activities as described further below under PS2.

For the operational real estate and energy assets, based on site visit observations, E&S impact and risk analysis are conducted by RHOL’s staff and/or by external consultants. Management programs, including training, periodical inspections and monitoring are developed. There are site level E&S impact and risk analysis procedures in place defining the process and the responsibilities.

Ronesans’ healthcare company RSY doesn’t yet have an operational asset, thus no impact assessment and/or risk analysis has been conducted.

Organizational Capacity and Competency: RHOL has established a corporate project management office (“E&S Department” or “E&S team”) of 8 experts at its head office, reporting to a corporate level Director (“E&S Head)”. Each group company in every country of operations has its own E&S department (“E&S Coordinators” or “E&S Subcommittees”). Subcommittees are reporting to the executive board of the group companies. Project managers (for construction phase) and site/facility managers (for operational phase) are responsible for E&S performance at project/asset level. There are more than 260 E&S technicians/supervisors at site level (both for construction sites and at operational assets), responsible for day to day implementation of E&S management systems, reporting to project managers and site/facility managers. E&S experts will be assigned for health care facilities when they are operational. Energy assets have E&S technicians / supervisors for the existing operations and an E&S expert position.

The corporate E&S team is responsible for coordination and improvement of the corporate level management system, benchmarking and monitoring of E&S performance on the corporate level and introduction of best E&S practices into operations. E&S coordinators of the group companies are responsible for incorporation of the corporate requirements and standards into E&S operational procedures, target setting and supervision of E&S performance within area of their responsibility. The progress on incorporation of the requirements at business level is reported monthly to the corporate E&S team, which reports to RHOL’s senior management.

At the construction site level, prior to commencing any construction work activities, the project manager assigns a project E&S team, which consists of a manager, engineers, technicians, officers and workers. When needed, local E&S experts with experience on the host country’s E&S legislation are also employed. The project E&S team is responsible for staff training, E&S hazards and risk assessment, routine site inspections and controls and supervision of RHOL’s and subcontractors’ employees, coordination of accident investigation, preparation of E&S performance reports.

RHOL provides regular training to all staff, including contractors on E&S to enhance personnel skill
s and qualifications in accordance with operational needs. RHOL has a corporate level E&S Training Program with the matrix of mandatory trainings required for staff depending on the type of performed work. The training program includes an E&S orientation program and mandatory topics for performing of a specific operation. E&S training plans based on the corporate requirements are specified at the group company. Typically E&S trainings on the project / asset level include induction, periodical awareness trainings as well as daily toolbox talks on E&S. Mandatory trainings cover electrical safety, work at height, hand tools, excavation and trenches, heavy machinery, equipment and site traffic, lifting operations, behavioral safety, leadership, hazardous substances and materials, confined spaces, personal protective equipment, lock out-tag out, emergency preparedness and other. In 2015, around 11 hours E&S training per staff is provided. In 2016 RHOL plans to engage external consultants to conduct E&S Leadership and Management Commitment Training for its group companies, aimed to improve the corporate safety culture.

Emergency Preparedness and Response (EPR): According to the documents reviewed during the site visits, the group companies have developed EPR procedures, for firefighting, evacuation, first aid, and response to spills. Procedures included communication plans with the local authorities and neighboring communities and as well as responsibilities related with fire suppression system controls. Fire and first aid exercises, evacuation drills are conducted on at least once in every three months at each project / asset, where almost 130 drills are recorded in 2015.

Monitoring and Review: In 2015 RHOL launched a corporate E&S web-portal, where each construction project and operational asset can provide information on its E&S key performance indicators such as injuries, environmental incidents, near misses, waste amounts, energy and water consumptions, training hours, toolbox hours. This portal serves most of the group companies, except operational assets of the energy and Heitkamp, Per ESAP item #1, all RHOL companies’ E&S performance shall implement corporate reporting procedure to ensure periodic senior management review of E&S performance, consistent with good industry practices.

Construction E&S teams conduct daily site inspections and have the authority to stop any unsafe activity on site until appropriate action is taken. In 2015, according to the reports provided during the site visit, E&S teams stopped construction more than 700 times for unsafe behavior, failure to use personal protective equipment and not complying with documented safety working instructions. Documented warnings are recorded and further training is provided in each case. Daily inspection findings are discussed during project daily meetings and/or reported directly to asset managers. E&S performance is reported to E&S coordinators and E&S head on a weekly and month
ly basis. As a part of E&S management system, senior management of the group companies review E&S performance on bi annual base.

Human Resources (HR) Policies and Procedures: RHOL employs around 32.000 employees in 17 countries. There is a corporate HR policy and associated procedures for handling internal (employee) grievances, recruitment, training, performance evaluation, terms of employment, career development and job descriptions and these are in line with IFC Performance Standard 2 requirements. These are available to all employees either through the company’s intranet or as employee handbook or both. As per ESAP item#2, RHOL shall update its HR policy and procedures to ensure coverage of all PS2 requirements, as described in the paragraphs bellows.

Working Conditions and Terms of Employment: At construction sites, employees are generally working 8 hour shifts, 6 days a week At operational assets and head offices, employees who have administration related jobs generally work 5 days a week. At other operational assets such as REN’s HEPPs and/or RGY’s and Desna’s assets, teams generally work on 2 or 3 shifts (each shift is 8 hours), thus maximum 48 hours is not exceeded in any case.

All employees have written contracts which include the working conditions, terms of employment, wages and benefits provided, probation period, working hours, overtime, annual leave. For migrant workers employed for construction projects, RHOL ensures obtaining of work permits and other documents required from the state migration authorities in compliance with host country regulations. According to RHOL management, migrant workers are engaged on equivalent terms and conditions to non-migrant workers carrying out similar work (including wage level, benefits and overtime compensation). Subcontractors are required to provide equivalent terms and conditions to non-migrant workers in line with RHOL requirements per contractual covenants.

RHOL provides accommodation to its staff and to contractors’ workforce if needed at construction camps. Living conditions at construction camp observed by IFC during the appraisal site visit were in line with IFC’s requirements in terms of minimum space, adequate sanitary and washing facilities, cooking and lighting. Taking into account that RHOL operates in multiple countries with different requirements for workers accommodation, as per ESAP item#2, RHOL shall develop corporate level standards for management of workers engaged by third parties (i.e. contractors) including workers’ accommodation to ensure consistency with IFC Performance Standard 2.

Workers’ Organizations: Although there is no labor unions or collective bargaining agreements in place in group companies, according to RHOL management employees have the right of freedom of association by the host country laws and have the opportunity to collectively represent to the management any issues that they may have. However, as RHOL with its subsidiaries is operational in 17 countries where there might be different requirements related with freedom of organization, as per ESAP item#2, RHOL shall revie
w its HR policy and procedures to include clear commitments to ensure employees’ rights related with freedom of association.

Non-discrimination and Equal Opportunity: RHOL’s corporate level code of ethics, which is disclosed at Ronesans web page and shared with all employees as a part of their orientation program, outlines the standards for all employees and covers aspects on equal opportunities and non-discrimination on race, ethnical origin, nationality, religion, age, gender and/or physical disability.

Retrenchment: RHOL is not anticipating retrenchment in its operational assets as the business is growing but the possibility of a retrenchment given the market conditions in construction business cannot totally be excluded As per ESAP#2, if a retrenchment occurs, RHOL shall share a retrenchment plan acceptable to IFC, which will be developed in line with IFC’s Good Practice Note on Managing Retrenchment and PS2 requirements. At construction projects, instead of dismissal, most of the staff is transferred to other project locations, generally within the same country. Construction business’ turnover target is a maximum of 9.9 %, which is low when compared to sectoral benchmark figure of 50 %, according to RHOL management. As per ESAP#5, RHOL shall review and document its policy and procedures related with transfer of the employees to other locations and ensure that they are in line with PS2 provisions.

Grievance Mechanism: There is a corporate employee grievance mechanism, where employees can raise their concerns through several channels, including direct contact with an HR committee and /or with discipline committee, by use of ethics hotline and /or by use of a mailbox system-called “sesini duyur/raise your voice”, which allows anonymous reporting. Contractors have access to internal grievance mechanism as well. In 2015, more than 11.000 unsafe conditions, unsafe behaviors and/or work place / relation related concerns were raised through the system, which shows the system is widely in use. No grievances, related to discrimination, unfair treatment and/or bullying have been raised, however, in the last 2 years. Private health insurance, smoking areas and relaxing areas have been improved in line with the grievances raised through the system.

Protecting the Work Force: RHOL ensures that child labor and/or forced labor are not employed by the group companies and by its contractors by verification of relevant documents. This requirement is checked at construction sites during the daily site tours, conducted by project E&S teams.

Occupational Health and Safety: A corporate level E&S management system establishment is in progress since 2015, and although not certified according to international standards, the group companies have their own E&S management systems. The systems in place include: (i) identification of potential E&S hazards and risks; (ii) provision of preventive and protective measures; (iii) training of workers; and (iv) recording
and reporting of occupational accidents, incidents and near misses. E&S safety instructions cover confined space entry, work permit system for high-risk tasks such as hot works and working at height, welding and cutting, vehicle safety, manual handling, lifting safety, electrical safety, night work, incident reporting and investigations, emergency preparedness and response plans. Working clothes and personal protective equipment are provided to employees in accordance with the type of performed works (special clothes, masks, goggles, gloves, ear plugs and etc.). All workers are subject to medical examinations, including respiratory system, skeleton system and audiogram upon admission and periodically thereafter.

Based on the site visit observations, RHOL implements required safety measures at construction areas by fencing and organizing of restricted access to construction sites; clear demarcation of hazardous areas or unsafe conditions, placing of safety signs and adequate warning and proper illumination of areas.

RHOL staff and contractors’ equipment used at construction sites (cranes, trucks, and excavators) undergo regular maintenance and inspections and is operated by experience trained employees. This is a documented requirement of existing E&S system in place, which is checked during E&S team’s daily site tours.

There is a near miss reporting and incident investigation system in place. As the data collection at corporate level started in 2015, there is no reliable data available for prior years. For construction businesses, in 2015, around 1.200 near misses were reported which shows that the system is widely in use. For construction businesses, lost time injury frequency rate (LTIFR – number of injuries per 1.000.000 man hour and includes cases where the injured person cannot return to the job on the next day) is around1.16 for 2015. LTIFR is improved when compared to previous year, from2.03 for 2014, and it is highly satisfactory when compared with U.S. Benchmark of 7.5 in the construction industry (reference: http://www.bls.gov). However, the group’s LTIFR statistics doesn’t include the lost days from the fatalities. In 2015 there were two fatalities among contractor employees, both in Russia. Five fatalities were recorded in 2014 and two in 2013. There were no injuries and/or fatalities in 2015 in operational assets of real estate and energy businesses. Based on the investigation of each incident/accident, E&S Corporate Department issues E&S Alerts with lessons learned and distributes it among the group companies through web portal. As an outcome of incident investigations, especially the ones related with fatalities, RHOL updated its operational procedures, implement job hazard analysis before the start of specific tasks, developed checklist focusing on the lessons learned and initiate a training program to boost corporate level safety culture.

Workers Engaged by Third Parties: RHOL construction group companies significantly re
ly on contractors for electrical installations, civil works and steel works. There are around 12 000 contractors working for almost 100 subcontractor companies in RHOL. By legal agreements, contractors are required to adhere to RHOL’s E&S Policy, comply with national and RHOL’s E&S requirements (covering risk assessments, trainings, mitigation measures such as PPE, health screening), develop E&S management plans prior to start of work and have a designated E&S engineer. RHOL construction group companies have developed a contractors’ E&S supervision system based on daily inspections, audits and regular reporting requirements. Accident statistics for contractors are included in overall RHOL’s safety performance recording. At operational assets, contractors are generally employed in cleaning, security and/or catering services. Although all the group companies have contractor management systems, however, as the all fatalities occurred in contractor related activities, differ from each other and as per ESAP item#1, RHOL shall review its contractor management plan, the E&S requirements and the monitoring process per the incident investigations, with the objective of enhancing supervision of contractors and update as necessary to ensure it is in line with World Bank Group’s Environmental, Health and Safety Guidelines and good international industrial practices.

Resource Efficiency / Water / Energy and Material Efficiency Projects: in most RHOL sites, including the ones where it provides EPC services, natural gas, electricity and water is supplied from national grid and/or municipal network. In the construction sites, where there is no natural gas and/or electricity, fuel oil might be in use for generators as well as electricity is used for heat and hot water supply. Similarly, for the operational energy business’ assets, electricity is produced in house and electrical heaters are used for heating/hot water.

RHOL’s E&S web portal is used for monitoring of energy and water consumption at each project site. Fuel oil usage by vehicles and standby generators is recorded through the same system. However, the energy usage of the operational assets of energy business and/or in construction projects of Desna as well as Heitkamp are not monitored through the corporate level web portal. As required under PS1, all the group companies’ E&S performance shall be monitored and reported to senior management on a periodic basis.

Based on the clients’ requirements in construction sector and/or in line with its real estate business strategy to provide most efficient facilities to their clients, RHOL incorporates energy efficient measures into their projects during designing, constructing and operating stages. Thus RHOL utilizes advanced Building Management Systems in its investment projects to ensure that heating, air conditioning and ventilation systems installed in the structures use optimum level of energy and water. RHOL has in house know-how within its engineering team to implement the international LEED (Leadership in Energy and Environmental Design) standards in its projects and some of RHOL’s projects are certified by the United States Green Building Council (USGBC) to LEED standards. Good international industry practices (GIIP) including insulation of roof surfaces and external walls; use of variable refrigerant volume (VRV) cooling system; air conditioning with air and water cooled chillers; use of variable speed drives for pumps; use of energy saving lamps; lightening controls for corridors, occupancy sensors and low flow showerheads and faucets in the bathrooms, dual flush for water closets and water efficient urinals in the bathrooms.

For instance, per the design specifications of the health care facilities, electricity consumption is expected to be around 250 kWh/m2 and water consumption to be around 500 m3/bed annually. Those values are below than the average consumptions referred from WBG’s EHS Guideline for Healthcare Facilities, defined in U.S Energy Information Administration (591 kWh/m2) and Pollution Prevention Compliance Assistance Information for the Health Care Industry (around 300 to 1350 m3/bed).

Green House Gases (GHG): Current GHG emissions from the RHOL’s real estate properties are estimated at 150,000 tonnes of carbon dioxide (CO2) equivalent ton per annum (tpa). According to RHOL, esti
mated GHG reductions from its energy assets are around 120.00 tpa. As a part of E&S management system enhancement referred in ESAP item #1, the group shall quantify direct emissions from the owned real estate and operational healthcare facilities, as well as indirect emissions associated with the off-site production of energy used by the project. RHOL will implement technically and financially feasible and cost-effective options to reduce project-related GHG emissions during design and operation of properties. Individual properties shall report to headquarters on energy and water consumption, and performance of similar types of occupancies shall be compared. Adverse monitoring results shall be investigated and corrective actions shall be developed. Based on the on-going monitoring of resource consumption, additional cleaner production measures might be integrated into design and operational processes of future properties.

Air Emissions and Ambient Air Quality: Air emissions from RHOL operations are mainly related to fuel and energy consumption by vehicles and equipment for transportation, and/or heat, hot water and electricity production. Ambient air quality during construction and /or operational phases is not monitored unless it is required by ESIA and/or by local authorities. RHOL’s corporate level E&S management system shall ensure that the relevant ESIA process will include air emission/ambient air quality modelling for the projects that produce significant air emissions, e.g. potential future CCGT project currently in the pipeline.

Waste and Hazardous Materials Management: Hazardous materials consumption for construction sites mainly includes fuel and machinery oil used by construction vehicles and equipment, cement additives (used as hardeners or for fluid loses or for corrosion control), isolation materials and paints. For operation assets, hazardous materials are limited with cleaning chemicals (like detergents), fuel and machinery oil used by the pumps and generators, and maintenance wastes including waste fluorescent lamps and paint. For RSY, when they are operational, there will be medical wastes and used laboratory chemicals.

Based on the site visit observations, the group has an effective system for chemical and hazardous substances labeling including material safety data sheets and trainings for hazardous materials safety is provided. Secondary containment and spill response kits are in use. There is an effective waste segregation system in place at the group companies. Excavation wastes, chemical packages, domestic wastes, nonhazardous packaging materials, scrap metals are transported, recycled and / or disposed by third party licensed waste companies.

Wastewater: Domestic wastewaters are discharged to the closest existing sewage system in line with host country legislative requirements, either directly and/or in case when there is no network within vicinity of the site, by use of septic tanks and transported by third party l
icensed trucks.

Infrastructure and Equipment Design and Safety: In line with client requirements and/or good international industrial practices, design documentation developed by RHOL design team is based on international accepted standards such as EUROCODE (European structural design codes), IBC (International Building Code), ASHRAE (American Society of Heating, Refrigeration, and Air-Conditioning Engineers), BS (British Standards), EN (European Norms), DIN (German Standards), NFPA (U.S. National Fire Protection Agency), ANSI American National Standards Institute), ASME (American Society of Mechanical Engineers), SMACNA (Sheet Metal and Air Conditioning Contractors National Association), CIBSE (Chartered Institution of Building Services Engineers), IEC (International Electrotechnical Commission) as well as on national standards of different countries including aspects on seismic stability, life and fire safety, environmental protection and energy efficiency.

As an EPC contractor RHOL creates the joint venture with reputable and experienced technology providers in different industrial sectors (such as Mitsubishi Heavy Industries, Kawasaki, Mitsui) to guarantee the safety of installed equipment and technologies. RHOL contracts specialized logistic companies for transportation of equipment and construction materials, satisfactory to RHOL corporate requirements in terms of permits and licenses, safety, route selections, staff training.

All kinds of construction work implemented for EPC projects, including: underground works, concrete, structural steel, piping, equipment erection, general erections works, coating and painting, electrical and other utilities, insulation are subject for daily quality control implemented as a part of corporate quality management system. The quality of completed construction works is checked and accepted by a project management team, technical representatives of a client and design company (design supervision) and project’s compliance to the applicable standards is confirmed by a group of third party technical experts at commissioning stage. The same verification by external third party experts is used in RGY, RSY, Desna and REN, where RHOL acts as designer and constructor of its own projects.

At the time of appraisal, none of the existing HEPPs would fall under the International Commission on Large Dams (ICOLD) definition of large dam (greater than 15 meters in height or with a reservoir volume of more than 3 million m3). All diversion weirs are less than 12.5 meter in height (ranging from 10.4 m to 12.5 m, where Sena is the highest) and largest reservoir is 1.7 million m3. In line with Turkish legal requirements, the hydro power plants are manned on a 24 hour basis. There is an alarm system in all HEPPs used in case of start of operations and/or water release. According to RHOL and third party experts ESIA, the HEPPs are designed to be able to pass safely the Maximum Probable Flooding levels (in line with Turkish legislation requir
ement for small hydropower plants which include 100 years modelling) and have spillways sized accordingly. In the event of emergencies, communication procedures are triggered; with initial notification being to the Village Authority, and action plans are in place in coordination with local Emergency Services. Depending on group companies, generally project manager and/or plant manager and/or shift supervisor and/or E&S engineer is responsible from this communication. There is an ongoing improvement plan to install public announcement systems and surveillance cameras downstream of the HEPPs and use specialized monitoring to detect movement in the weir body, in line with a recent regulatory requirements. Staff is trained in the ERP covering earthquakes, landslides and other emergency situations. There is an inspection plan in place, where the HEPPs, diversion weirs, transportation galleries and channels are inspected annually.

Community Health and Safety: Risks of accidents for the general public during construction are mitigated through measures such as: access control, barricading, signage, proper securing of material while moving them from one place to another, planning material movement to cause minimum disruption, speed controls. Other impacts to the community such as noise, air pollution and other nuisances during construction are assessed, mitigated and managed on a project level if required by local authorities. At RENs, reservoirs, transportation channels and plants are fenced, warning signs are installed, and security and E&S site tours include checking of the community safety measures referred above.

Ecosystem Services: Some ecosystem services appear to be impacted by HEPPs. Loss of priority ecosystem services and related action requirements are discussed under PS5.

Community Exposure to Disease: As a part of existing legislation in Turkey, RSY shall develop a plan to prevent community exposure to disease and provide the approval from the local authorities for obtaining the operational license. As none of the RSY assets are operational, this plan will be prepared and submitted to local authorities during operational license application process.

Security Personnel: Except at Sena hydropower project, security personnel at all RHOL facilities are unarmed. Security services are provided by RHOL’s clients, where RHOL works within their facilities. RHOL uses both private security providers (such as in Sena HEPP and most of the operational real estate assets) and/or use its own staff for security (in operational energy assets and several construction sites). There is no public security personal in RHOL project sites and/or in operational assets. There was an armed raid by a group of people in Sena in 2014 that resulted in additional security measures being taken by the company, including deployment of armed (private security personnel. As per ESAP item#3, RHOL shall commission a review of its security arrangements in all countries against
PS4 requirements and develop a corrective action plan if necessary in order to bridge any identified gaps.

Biodiversity impacts are mainly related to REN’s ongoing hydropower operations. As these assets are operational, the impacts have generally already occurred. Specific impacts on biodiversity may include (i) changes in the river flows that may impact migrant birds; (ii) changes to river flows leading to reduced fish diversity and numbers; (iii) the blocking of in-stream fish migration by weirs; and (iv) disruption to the life cycles of reptiles and plants present within the vicinity of the HEPPs.

All of REN’s HEPPs are located in Turkey, on mix of natural and modified habitat, as the surrounding land cover on these sites usually consists of forest and/or grassland, while adjoining land has similar land cover; tree harvesting, crops and bee-keeping are also conducted near all HEPP locations.

None of the REN’s project locations are within a national protected area, although all overlap with bird migration flyways such as the Black Sea/Mediterranean and/or with East Asia/East Africa flyways. . However, impacts on migrant birds are considered to be of low significance as these are run-of-river HEPPs that do not significantly block water flow or create significant reservoirs that might otherwise have impacts on migrant birds. Transmission lines are relatively short (1 to 14 km) for existing HEPPs.

Ozluce HEPP overlaps with the Eastern Black Sea Mountains (including Pontic and Kackar Mountains) Key Biodiversity Area (KBA). Literature studies identified that 7 critically endangered plant species are expected to occur in Ozluce project area whereas 1 bird, 3 plants and 2 reptile species were identified in the Sena HEPP area. Please refer to Annex 1 for details of the species potentially present at project locations. Based on ESIA findings for these HEPPs, the impacts of the HEPPs on biodiversity are considered to be of low significance. Per ESIAs no specific action item was suggested.

As per ESAP item#5a, 5b and 5c, RHOL shall engage with qualified third party PS6 biodiversity specialist(s), acceptable to IFC, to review and align current company practices with PS6 requirements. With support from the qualified PS6 expert, RHOL shall develop a company procedure for commissioning fit-for-purpose, PS 6-compliant baseline and impact assessment studies for all relevant future hydropower investments, including relevant field studies and environmental/minimum flow provision. RHOL, with support from the qualified PS6 expert, shall carry out a review of biodiversity impacts at existing energy facilities in line with PS6 requirements and develop needed action plans to address any gaps.

Environmental flows: Each HEPP is required to release a minimum environmental flow, ranging from a seasonally variable minimum release from Sena and Dogan HEPPs, to a long-term average minimum release from others. The minimum ecoflow requirements are generally 10-12 % of average monthly flow. For further details and dewatered section lengths, please refer to Annex 1. Downstr
eam water usage, including irrigation as well as flow needed for aquatic life is taken account in the permitting conditions. No endangered fish species were identified through ESIA and literature studies.

The company does not have a corporate-level stakeholder engagement policy or project-specific stakeholder engagement plans, nor does it have an external grievance mechanism at corporate and project levels.
For the HEPP projects implemented in Turkey by REN, there have been some attempts at stakeholder engagement supported at the corporate level, though these activities were not based on any formal stakeholder mapping. Regular meetings with affected communities and villages were held from the initial stages of each project. These meetings were however not run in a systemic manner and the concerns and claims expressed by the attendees were not always recorded. In general such encounters were designed with a view to establishing positive relations with affected communities and also helped employ staff from the area and allowed the company to engage in certain community investment and support activities.
A former mayor from the region is employed as community relations consultant for the projects in Yesilirmak River Basin (Kale and Osmancik). The community relations role does not exist at the other HEPPs and corresponding site managers are the main point of contact for the community. There is nosystematized ongoing reporting to affected communities.
EIAs are publicly disclosed and announced during the Government approval process as per national regulations, but were not disclosed on the company’s website or at project sites.
RHOL companies provide contact information at the gates of each construction project area for public concerns. Procedures and management commitment on how grievances would be treated are to be further developed and communicated at the relevant sites. Based on the discussion at the visited project site during the appraisal, there were no concerns raised previously for the completed and ongoing projects of RCI and RHI. The interested parties are invited to share their concerns with the local authorities where the local authorities will follow up and provide feedback. At the corporate level contact details for any queries is provided at RHOL website.
As per ESAP item#1, the company shall prepare a corporate stakeholder engagement framework, in line with PS 1 provisions, for identifying and mapping key internal and external stakeholders, disclosing relevant project information in a timely manner and consulting with key stakeholders (including affected communities) on an ongoing and iterative basis. The stakeholder engagement framework shall include a requirement to develop and implement appropriately scaled and locally applicable community grievance mechanisms for those projects which the company develops on its own. The company shall also ensure that suitably experienced community liaison staff are deployed during the construction and early operations phases of all greenfield power developments.

RHOL shall disclose this ESRS, ESAP, annex 1 and annex 2 on http://www.ronesans.com

Contact Person: Onur Behzat Tokdemir
Company Name: Rönesans Holding
Address: Portakal Çiçeği Sokak No:33 Y. Ayrancı 06540 Çankaya / Ankara
Email: mailto:onur.tokdemir@ronesans.com
Phone: +90 216 430 6000
Facsimile: +90 216 430 6902

Broad Community Support is not applicable for this project

RHOL Equity(36747) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
ESAP 1 - RHOL’s shall enhance its existing corporate level E&S policy and E&S management system to meet the requirements of PS1, to include ( (but not limited to); a) A chance find protocol for construction related management procedures; b) A corporate reporting procedure covering all RHOL companies to ensure periodic senior management review of E&S performance; c) A corporate stakeholder engagement framework, in line with PS 1 provisions, for identifying and mapping key internal and external stakeholders, disclosing relevant project information in a timely manner and consulting with key stakeholders (including affected communities) on an ongoing and iterative basis. The stakeholder engagement framework shall include a requirement to develop and implement appropriately scaled and locally applicable community grievance mechanisms for those projects which the company develops on its own; d) A review of its contractor management plan, the E&S requirements and the monitoring process per the incident investigations, with the objective of enhancing supervision of contractors and update as necessary to ensure it is in line with World Bank Group’s Environmental, Health and Safety Guidelines and good international industrial practices;	30-Dec-2016	Completed	Completed	12/30/2016
ESAP 2 - RHOL shall review and update its HR policy and procedures to ensure coverage of all PS2 requirements are incorporated. This shall include (but not limited to); a) Development of corporate level standards for management of workers engaged by third parties (i.e. contractors) including workers’ accommodation to ensure consistency with IFC Performance Standard 2; b) Clear commitments to be incorporated to policy and procedures to ensure employees’ rights related with freedom of association; c) A procedure to be followed in case of a retrenchment occurs, where RHOL shall share a retrenchment plan acceptable to IFC, which will be developed in line with IFC’s Good Practice Note on Managing Retrenchment and PS2 requirements; d) Development and implementation of a documented policy and procedure related with transfer of the employees to other locations in line with PS2 provisions.	30-Dec-2016	Completed	Completed	12/30/2016
ESAP 3 - RHOL shall commission a review of its security arrangements in all countries against PS4 requirements and develop a corrective action plan if necessary in order to bridge any identified gaps.	30-Sep-2017	Completed	Completed	4/20/2018
ESAP 4a - RHOL shall engage with a qualified third party PS5 expert (s), acceptable to IFC, to align company practices with IFC’s PS 5 requirements.	30-Jun-2016	Completed	Completed	6/28/2016
ESAP 4b - RHOL, with support from the qualified third party PS5 expert, shall develop a Land Acquisition and Involuntary Resettlement Framework consistent with PS5 requirements. This will include community engagement processes based on a livelihood impact assessment and a grievance procedure	30-Oct-2016	Completed	Completed	10/30/2016
ESAP 4c - RHOL, with support from the qualified third party PS5 expert, shall commission an audit of land acquisition previously undertaken or ongoing at representative RHOL sites (including but not limited to REN project sites, OHTLs and natural gas pipelines and other project sites if expropriation took place) to ensure consistency with the new Land Acquisition and Involuntary Resettlement Procedure referred to above. Based on this information, RHOL shall develop and agree with IFC on a time-bound plan to mitigate any major residual or ongoing social impacts caused by the land acquisition process, prioritizing the most vulnerable households and those who have yet to receive compensation including users of pasture and grazing lands.	28-Feb-2017	Completed	Completed	2/28/2017
ESAP 5a - RHOL shall engage with a qualified third party PS6 biodiversity specialist(s), acceptable to IFC, to review and align current Company practices with PS6 requirements.	30-Jun-2016	Completed	Completed	6/28/2016
ESAP 5b - RHOL, with support from the qualified PS6 expert, shall develop a company procedure for commissioning fit-for-purpose, PS 6-compliant baseline and impact assessment studies for all relevant future hydropower investments, including relevant field studies and environmental/minimum flow provision.	30-Oct-2016	Completed	Completed	10/30/2016
ESAP 5c - RHOL, with support from the qualified PS6 expert, shall carry out a review of biodiversity impacts at existing energy facilities in line with PS6 requirements and develop needed action plans to address any gaps	30-Jun-2017	Completed	Completed	4/20/2018