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
There are no indigenous people that may be affected by the project, thus PS7: Indigenous Peoples is not applicable.
According to EIAs, there are no significant protected natural and historical landmarks in or around the project areas.
According to available project presentation files, existing and future projects are located away from known cultural and/or historical area, thus PS8: Cultural Heritage is not applicable. As per ESAP item# 1, Akfen shall develop and implement a ‘chance find’ procedure to be used during all construction activity, to aid in managing archaeological finds.

This project consists of an equity participation in Akfen Energy, a new company that groups Akfen Holding A.S.’ energy assets, to support its expansion plans including construction of small to medium capacity hydroelectric power plants, solar power plants and wind power plants in Turkey and potentially in other countries. The project has been classified as Category B in accordance with IFC’s Policy of Environmental and Social Sustainability as the potential environmental and social risks and impacts are expected to be limited, generally site specific, and can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria.
The key E&S issues include the company’s capacity to manage environmental, social and occupational safety aspects both at the corporate level and across multiple existing and greenfield assets; contractor management; land acquisition and resettlement; stakeholder engagement; biodiversity impacts such as bird/bat impacts (WPPs) and environmental flows (HEPPs); and labor and working conditions, in particular construction worker health and safety.

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.

E&S Assessment and Management system and Policy / Identification of Risks and Impacts and Management Program: Akfen Energy does not currently operate under a certified Environmental and Social Management System (“ESMS” and/or “EHS”). Management of E&S issues adopted by Akfen Energy is based on risk assessment and inspection processes to inform specific safety controls to be implemented at their operational sites. A number of centralized procedures (or standards) have been established for consistent management of key safety risk areas. To date, no E&S management plans/programs have been developed for Akfen Energy projects as part of the Environmental Impact Assessment (“EIA”) process (this is not a Turkish requirement).

As outlined in the ESAP item #2, Akfen shall develop and implement an EHS at the corporate and site level. The ESMS will include but not limited to; (i) a policy; (ii) management programs/plans to mitigate risks and impacts; (iii) organizational capacity and competency; (iv) emergency preparedness and response; (v) stakeholder engagement; and (vi) monitoring and review. The ESMS will be applicable for all future operations and will be extended to every construction contractor retained by the company.

The EIA process in Turkey is defined as a legal requirement and the EIA Regulation sets out the principles related to this process. Hydro-electric projects are currently at various stages of development. The Cicekli, Kavakcali, and Calikobasi HEPPs required EIAs, which have been completed for the first two sites. There has been no decision on Catak as the status of the protected area designation is currently under discussion as outlined in the PS6 section below. There are four sites (Dogancay, Doruk, Otluca and Camlica III) that under current EIA Turkish regulations (2014) would have been required to submit an EIA. However, since the application process pre-dated the enactment of the new regulations, only the submission of a Project Presentation File (screening type assessment) was required.

Solar projects: For the unlicensed projects (less than 1 MW) there is no requirement for an EIA as confirmed by official letters from the Environmental Regulator received by Akfen Energy. If the project is between 1 and 10 MW a request has to be submitted to the regulator requesting an opinion on whether an EIA is needed, while for projects over 10MW an EIA is required. Four of Akfen’s SPP projects will require an EIA whilst Yaysun-1 is exempted from the EIA process because of its capacity.

Wind projects: EIA development for the pipeline of WPP projects will come after the pre-licensing application from the energy regulator is approved. The company has completed screening studies to assess initial site constraints (e.g. wind yield, general environmental and biodiversity issues, including birds, land status and cultural heritage risks) and grid connection options. These preliminary assessments did not identify any significant environmental or so
cial issues. Discussions with relevant regional local authorities to get an initial opinion on the project was also part of the initial assessments.

As per ESAP item#3 Akfen shall develop a procedure of independent impact assessment on environment, biodiversity and local communities as well as cultural heritage for all new investments. Any new project that would fall under the European Union EIA Directive will include a screening assessment which will be conducted by Akfen and its advisors (unless a project falls into a category no approval is required) to define the scope of the due diligence. All projects will follow national legislation and the final EIA may consist of a local EIA plus supplementary information as defined by the screening assessment on environmental and social issues.

There are two potential transboundary watercourses associated with the project, details of which are attached as Annex 2. The 7 MW Cicekli HEPP is under construction on a sub-tributary of the Coruh River Basin; the Coruh flows through Turkey before entering Georgia for a short distance before flowing into the Black Sea. The HEPP will have no storage capacity and affected flow represents a negligible proportion (0.1 %) of the overall flow of the Coruh River; in addition, Coruh River flows are controlled by two larger downstream HEPPs, namely Borcka (300 MW) and Muratli (115 MW), located close to the border. Finally, there are no significant agricultural or industrial uses of Coruh River on Georgia side. The operational 7 MW Gelinkaya HEPP is located on a sub-tributary of the Euphrates River basin; the Euphrates flows through Turkey into Iraq and Syria before entering the Persian Gulf. Again, the affected flow volume is an insignificant proportion of the flow of the Euphrates and this large river’s flow is furthermore controlled by Turkey’s largest dams, including Keban Dam (1.330 MW), Karakaya Dam (1.800 MW), Atatürk Dam (2.400 MW) and Birecik Dam (672 MW). Therefore ongoing operation of Gelinkaya HEPP is considered to have no measurable impact on water availability or use in downstream countries.

Organizational Capacity and Competency: Akfen Energy has an E&S management structure including an occupational health and safety (“OHS”) expert (responsible for reviewing work-related risks and conducts periodic site visits) and an environmental engineer, (works across Akfen Energy operations, providing technical assistance). Furthermore, each of the HEPP and SPP portfolios has a dedicated head who is responsible for all permits, licenses and overall E&S management. Plant managers and their deputies are responsible for OHS issues at sites. There is an ongoing program in place for defining Akfen Energy’s reporting structures and responsibilities between individual sites and senior management levels. As outlined in the ESAP item#4, Akfen shall nominate and maintain an OHS manager at corporate level. The person should be a main point of contact for every stakeholder, no
n-governmental organizations (”NGOs”), local communities and grievances from third parties, as well as review all new EIA’s for new projects and maintain an internal audit system. In addition,, per ESAP item#5, Akfen shall create an ”environmental council” consisting of environmental, H&S and social specialists from the plants to improve information exchange and strategic planning.Emergency Preparedness and Response: Each operational Akfen HEPP has emergency plans, in line with Turkish legal requirements, covering life and fire safety, firefighting, first aid, evacuation, floods, and search and rescue. Plans include details such as response approaches and reporting, are locally tailored and include nominated and trained teams to handle specific emergency situations. Fire alarm systems and fire extinguishers are present at all plants. According to the identified risks, sites are provided with smoke (and some heat) detectors while others have sprinkler systems installed. Gas/smoke detectors are present in the offices and in areas where required by the local legislations. New projects will be designed to have similar systems. As per ESAP item#5, as part of its OHS management plan, Akfen Energy, shall prepare and emergency response plan, inclusive of an early warning procedures in case of flood threatening the public (typically for floods with a return period of five years or more).

Monitoring and Review: As required by Turkish legislation, there is a system in place whereby monthly inspections at each project location are undertaken by Akfen Energy’s environmental and OHS staff and/or by external experts/consultants. In addition, there are scheduled formal annual internal audits and spot audits conducted by Akfen Energy personnel. These audits cover technical, environmental, health and safety issues. Akfen’s management receives audit results and there is a formal process of reviewing, responding and closing the report’s findings through a corrective action system. As a part of this system, several improvements, including cranes and safety signs are implemented throughout the all existing HEPPs. E&S performance of the existing plants, including energy consumption and incident rates are reported to and Akfen Energy’s senior management.

Social Impact Assessment and Stakeholder Engagement: Social impact assessment is not a legal requirement in Turkey; therefore, EIAs do not include social assessments. Excluding a number of community projects implemented under Akfen Holding’s its Corporate Social Responsibility (CSR) program over the last couple of years, Akfen formal stakeholder engagement arrangements are limited to holding one public participation meeting per project during the EIA preparation process as required by local regulations (company’s current stakeholder engagement arrangements are detailed in the related section of this ESRS). Per ESAP item# 6, 7 and 8 Akfen shall (i) develop and implement a corporate communication plan and implement suc
h plans at the companies’ level and develop separate stakeholder engagement plans (“SEP”) for each project (at least for each major investment). This should include the development and implementation of a grievance mechanism. The SEP (s) should address potential issues that may be raised by NGOs in Turkey. As part of SEP and EHS, Akfen shall prepare a register of risks for the public and develop and implement and monitor mitigation measures. The register should be prepared by a specialist used with the implementation of international Industry good practices on hydropower schemes; (ii) monitor implementation of the SEP and grievance mechanism to ensure a continuous and systematic stakeholder engagement programme throughout the projects life cycle. The SEP should be reviewed and if necessary updated annual or when material changes occur in the Project; (iii) As a part of the development, planning, design and construction and commissioning of each project, Akfen will develop a non-technical summary (“NTS”) as appropriate and community leaflet for each new project in construction or to be developed in the future providing a project description, the EIA process, the environmental and social benefits/impacts, mitigation and management measures and the contact details for communications with a link to the SEP. Akfen shall develop a corporate internet site, with inclusive of a sustainability page and disclose as appropriate NTS and community information brochures for new projects on this web site. In addition, Akfen will appoint a community liaison officer (“CLO”) with appropriate skills and experience to effectively manage the implementation of the SEP at each site.

Human Resources (“HR”) Policies and Procedure / Working Conditions and Terms of Employment: An “Ethics Code” is published by Akfen Holding setting out a clear commitment on employees’ behavior. At corporate level, Akfen Holding has also developed HR policies and procedures in line with Turkish legal requirements. Holding level HR policies and procedures are implemented in all group companies, including Akfen Energy. Main gaps between Turkish legal requirements and PS2 are defined in the following sections. As per ESAP item#9 Akfen Energy shall develop and adopt HR policy and management system covering all employees, on a best effort basis for contractors as well as sub-contractors, to include (but not be limited to); (i) approach to managing its workforce; (ii) management of worker relationships; (iii) access to worker’s organisations; (iv) working conditions and terms of employment; (v) child labour and forced labour policies; (vi) equal opportunities and non-discrimination; and (vi) oversight provided of contractor policies/procedures.

Akfen Holding Group employs approximately 10.000 people, of which about 170 are employed at Akfen Energy plants. Akfen Energy’s workforce will increase when the next three HEPPs become operational, with each plant adding nearly 10 employees as staff. The existing Konya SPP has four employees working as security guards. It is expected that new HEPPs, SPPs, and WPPs will create approximately 150 new jobs.

Labor management and labor practices are managed by the head office HR department at Akfen Holding level. All issues related to conditions of employment (e.g., wages, working hours and overtime work, sick and annual leave, employee rights, benefits etc.) are regulated by individual employment contracts, signed by the employee and the employer in accordance with Turkish Labour Law. The national maximum working hours cap is 45 hours per week. Shift patterns at each of the hydropower stations indicates that, at most, staff undertake six 8 hour shifts per week with a 30 minute lunch break. While staffing levels are minimal at each of the HEPPs, the plants includes two day-shift workers that can also cover for colleagues’ holidays or sick leave. Akfen Holding Groups’ labor practices, which are in line with IFC’s PS requirements, are implemented in all group investments, including Akfen Energy’s potential portfolio facilities.

Workers’ Organizations: As stated by Akfen’s management, all employees are free to join a union if they so choose. However, Akfen Energy does not currently have any staff who are members of unions and/or workers organizations. As per ESAP item#9, HR policy shall include access to worker’s organisations.

Non Discrimination and Equal Opportunity: Although Akfen Holding has no documented policies against discrimination on the basis of personal beliefs or other characteristics that are unrelated to a person’s ability to perform his/her duties, senior management at Akfen encourages nondiscriminati
on. There are no barriers for women to work at Akfen Energy sites. However, culturally women at some locations do not typically apply for jobs on HEPPs. As per ESAP item#9, Akfen Energy shall adopt HR policy and management system to include equal opportunities and non-discrimination.

Retrenchment: No retrenchment has occurred and none is foreseen by Akfen Energy. Should there be any retrenchment in the future, Akfen shall follow the Turkish legal requirements including selection, transparency, and notice and employee assistance and implement the relevant PS provisions.

Grievance Mechanism: At present, there is no central grievance management process or documented grievance mechanism. There is an “open” door policy and employees are encouraged to approach their line manager and senior management to discuss any complaints, comments or incidents. All employees are reported to be able to set up appointments to discuss their grievances with their managers and/to the HR team. Each employee gets a copy of the company employee handbook listing a number of HR staffs contacts and details who are available 24/7. Prior to construction, Akfen will set up and maintain a formal grievance mechanism for employees and contractors and disseminate information about its uses to the workforce. To ensure this, as per ESAP item#10, Akfen shall develop formalized human resources management system and procedures with special regard to grievance procedures.

Protecting the Work Force / forced labor / child labor: The minimum working age in Akfen is 18 years old. A statement in contracts with sub-contractors provides that they must comply with national law that indicates a general working age of 18 (but a minimum age of 16 but with requirements of special controls). There is no forced labor and no restrictions are imposed on staff wishing to cease employment other than statutory notice periods. As per ESAP item # 10, Akfen shall develop formalized human resources management system and procedures that should include welfare arrangements for construction workers prior to construction activities commencing. At the time of construction activities commencing, Akfen will ensure that arrangements to be in place for construction workers so that they should have access to welfare facilities such as drinking water, toilets and dining facilities; and during construction and operations, conduct regular employee standards audits to the best effort for contractor and sub-contractor employees to ensure compliance with the Labor Law and International Labor Organization (“ILO”) Principles which Turkey is a party.

Occupational Health and Safety (OHS): Akfen Energy doesn’t have a certified E&S system. Health and safety approaches at existing sites are based on risk assessment and inspection processes to inform specific safety controls to be implemented at sites. A number of centralized procedures (or standards) have been established for consistent management of key safety risk areas. Risk
assessments are undertaken by a committee comprising of a health and safety expert, a doctor, an employee representative and a relevant technical representative from the site. Assessments are documented and stored electronically using an on-line system.

A number of deficiencies in health and safety arrangements were noted during appraisal site visits. As per ESAP item # 11, Akfen shall review and align the OHS plans in line with the PS2 requirements. Plans should guide all Project-related activities during construction and operation. PS2 requirements include (but not be limited to); (i) job- and task-specific hazard and risk analysis and controls for activities; (ii) provision of PPE, requirements for use of PPE, and enforcement of PPE use; (iii) safety training for all personnel, covering hazards for their jobs.(i.e. undertake driver safety training and code of conduct training for the drivers of the transfer trucks as well as drivers of employee service buses.); (iv) develop an accident investigation program. Record incident statistics, including total work hours, serious injuries, lost time, etc.; (v) develop a medical monitoring program for employees; (vi) ensure implementation of a work permit system covering both workforce and contractors for dangerous tasks such as confined space; (vii) establish and implement a “Lock Out Tag Out” system; (viii) implement workplace hazard monitoring; and (ix) place safety signage where necessary. Safety signage should address fire safety, emergency response, noise, PPE, no smoking, traffic control, etc.

There have been no reported accidents relating to portfolio asset staff in the past 3 years. Akfen does not include in their reporting accidents related to construction contractors as this, according to Turkish legislation, is the service provider (in this case construction contractor’s) own responsibility. Akfen Energy’s OHS plan, referred from ESAP item # 11, shall cover contractors as well. A fatal accident occurred in 2012 at the Doruk HEPP site during construction. Three employees of Akfen Construction, the on-site contractor, and the son of an employee aged 17 were hit by a landslide while working. This accident has been subject to a legal investigation of Akfen Construction by regulatory agencies. Following Turkish law, legal cases were brought against the subcontractor and there is no ongoing case against Akfen Energy.

Workers Engaged by Third Parties: Akfen uses contractors for a number of tasks. Akfen Energy requires all contractors and sub-contractors to comply with the requirements outlined in the procurement document. This includes provisions for compliance with national law on labor and working conditions and stipulates health and safety performance requirements to be provided prior to awarding work. Before commencement of work, all sub-contractors must submit a risk assessment for review by Akfen Energy. Akfen conducts checks on contractors to ensure that their activities are aligned w
ith the legal requirements and that they manage risks properly. Should any non-conformances be observed, Akfen Energy reserve the right to stop any work and notify the contractor, impose penalties as defined by the contractual agreement, or cancel the contract.

Akfen Energy does not provide worker accommodation for their operational sites.

Resource Efficiency: Akfen Energy’s renewable energy projects will not consume natural gas and / or other fuels. Consumption of water will be limited at these projects too, with only minor usage during construction, and minor usage during operation of solar projects (for annual panel cleaning).

None of the projects is expected to generate Green House Gases (GHGs) during operations; in practice, these projects will displace GHG emissions relative to the Turkish grid average.

Effluents: Water discharges from hydropower projects during the construction phase and during the operational phase (e.g., domestic wastewater, dewatering of tunnels, and wastewater from batching plant) will be collected in cesspool tanks or lined pits and transferred to a wastewater treatment plant and/or a sewerage collection network in line with local authorities’ requirements and IFC provisions.

Hazardous Materials and Waste Management: There is no significant use of hazardous materials at Akfen Energy operational and construction sites. Where applicable, risk assessments have been completed and control measures have been established to minimize risk of exposure and impact on sensitive receptors.

Existing plants have waste segregations systems in place whereby recyclables are reused/recycled by third party licensed waste companies and domestic waste is either collected by municipalities directly and/or transported by licensed third party to municipal landfills. Hazardous wastes, including containers of oil and other chemicals mainly used for maintenance and/or cleaning, are disposed by certified third party hazardous waste contractors.

The main liquid wastes generated at existing HEPPs are sewage effluent, which is stored within underground storage tanks for periodic collection, and waste oil from equipment. Waste oil is generated from regular maintenance operations of equipment or from transformers leaks, which drain to an underground oil tank. The volumes generated from each of these waste streams at each of the HEPPs is not be significant.

Akfen Energy has been subject to a number of environmental penalties and fines related to unauthorized dumping of construction wastes and/or wastewater discharge. The root causes included failure in the implementation of the documented waste management plan and contractor management. Effective implementation of Akfen Energy’s new EHS, as developed per ESAP item#2, shall prevent similar unauthorized dumping and discharges to occur in the future.

Historical pollution / Soil Contamination: The land for all the HEPP and SPP sites visited by the teams were greenfield, predominantly forested areas, prior to construction and would have no historical contamination. No PCBs is present in any of the transformer used at the existing and pipeline projects.

Infrastructure, building and equipment design and safety: Akfen Energy does incorporate health and safety considerations into the design, construction and operations of its projects. A few deficiencies were noted during the site visits (e.g.no formalized system for inspection and maintenance as part of the Dam Safety Program.

At the time of appraisal, only the Camlica HEPP qualifies as a large dam under the International Commission on Large Dams definition (greater than 15 metres in height or with a reservoir volume of more than 3 million m3), as it is 30 m high. In line with Turkish requirements, hydropower plants with dams are manned on a 24 hour basis. Camlica is the only dam holding back a specific dedicated reservoir, and it is fitted with an alarm system in case of dam failure. According to third party experts, Akfen Energy dams are designed to safely withstand Maximum Probable Flooding events and have spillways sized accordingly. In the event of emergencies, communication procedures are triggered; with initial notification being to the Municipal Authority, and action plans are in place in coordination with local Emergency Services.

Although Akfen HEPPs are newly constructed and observed to be in good condition and well-maintained, the company currently does not have a formalized approach to ensuring that the highest levels of dam safety are maintained. As per ESAP item #12, Akfen shall review and update the current emergency response plans in consultation with responsible authorities and communities to cover at least fire, flood response, spills, severe injuries or fatalities, or other events that could reasonably be expected to occur within the lifetime of the projects in line with the IFC’s requirements. Trainings and drilling exercises should be conducted on regular basis.

Akfen E&S management system will include a comprehensive inspection and maintenance plan for all sites. In addition, as outlined in the ESAP item#5, Akfen shall develop a procedure for an inspection and maintenance programme with regards to dam safety against ICOLD standards and implement the inspection programme once the procedure is developed.

Natural Hazards: Landslide mitigation measures, as part of the project design, have been implemented at a number of HEPP sites; however, installed concrete/ mesh protections are not subject to a formal inspection/ maintenance regime. The company’s ESMS shall contain provisions and plans to ensure control of concrete and mesh used for landslip protection and continue soil stabilization programs, with replanting schemes when needed, are included in the inspection and maintenance regime program at all sites.

Emergency Preparedness and Response: As per ESAP item#12, Akfen shall review and update the current emergency response plans in consultation with responsible authorities and communities.

Site Security: Security personnel are unarmed and trained in the use of force for defensive purposes. All security personnel are Ak
fen Energy’s staff and no third party service provider is used. The recruitment process is in line with Turkish legal requirements related with “special security forces” legislation, including pre-employment and periodical psychological tests. All sites visited had security fencing in place with a security guard on duty in order to limit any unauthorized access to the facilities. There is extensive use of Closed Circuit Television (“CCTV”) surveillance at sites both at manned areas as well as at the weirs. According to Akfen, whilst solar projects do not need to be manned, there are security guards at sites. The guards monitor the site through a series of CCTV cameras and, if any problems are identified, the police is notified in case of a security issue or the EPC contractor is called in case of equipment failure or malfunction.

Assessment of Biodiversity and Living Natural Resources: To date, biodiversity screening and assessment studies have been conducted in accordance with national norms. In the future, these studies will be expanded to meet IFC PS 6 requirements, including for example more consistent assessment of ecological flows for hydroelectric projects, and comprehensive bird and bat studies for new wind power projects.

No projects have been identified that affect protected areas and sensitive or Critical Habitat; however, one pipeline hydropower prospect (Catak) is on hold due to a dispute between Akfen and a NGO as to whether it falls into a national park. Akfen will not develop any new project that is located within an existing or potentially protected areas based on the screening areas. If a site is located in a potentially sensitive areas, as defined in the screening assessment such as National Parks, the scope of the EIA will be agreed with IFC.

As per indicated under PS1 above, in line with the ESAP item#3 Akfen shall develop a procedure of independent impact assessment (EIA) on environment, biodiversity and local communities as well as cultural heritage for all new investments. Any new project that would fall under the European Union EIA Directive will include a screening assessment which will be conducted by Akfen and its advisors (unless a project falls into a category no approval is required) to define the scope of the due diligence. All projects will follow national legislation and the final EIA may consist of a local EIA plus supplementary information as defined by the screening assessment on environmental and social issues.

For wind projects (which are at a relatively early stage of assessment), third party consultants have carried out desk-based bird sensitivity screening and identified that project locations at Ucurtma and Kuba are close to mitigation routes and to known bird areas. As a part of its enhanced EHS refered from ESAP item#2 Akfen Energy will ensure that for any wind farm located in a bird sensitive area as defined in screening assessment by an ornithological or their advisers will undertake an appropriate bird and bat monitoring to assess environmental impacts. This procedure will be implemented in case the tenders are awarded.

Protection and conservation of biodiversity. For the hydropower plants, where studies are available, there is a wide range of species present across the project portfolio but none are listed as critical or endangered with the exception of 2 fauna species, Alburnus orontis (Orontes spotted bleak, a species of ray-finned fish in the Cyprinidae family) and Oxynoemacheilus seyhanensis (a species of ray-finned fish in the Nemacheilidae family). These two species are categorized as endangered and are only found at the operational Camlica HEPP site. Çamlıca uses the water from the reservoir supplied from Zamanti River and Gedin creek and gives it to the power house which is located on Zamanti River. The len
gth of the dewatered section from dam structure until power house is 3.8 km through the creek/river. The EIA does not give information on whether or not the existing size of grid mesh is fully appropriate as it is dependent on the location specific features and species such as types and presence of breeding ground. Other EIA requirements are in line mostly with PS6 critical habitat requirements. As per ESAP item #15, Akfen shall undertake, an environmental monitoring assessment at each current and future HEPP location, to verify the biological effectiveness of the ecoflows. This should consider factors such as (i) aecoflows to be able to maintain water quality (temperature, dissolved oxygen, etc.); (ii) ecoflows to support the maintenance of fish populations, particularly the more vulnerable species; and (iii) ecoflows to give the streams the capacity to support spawning, incubation, rearing, and passage of fish and it shall confirm that the presence and sizing of fish protection grids on the water intakes are appropriate. Where necessary, Akfen will maintain a minimal water flow on all hydro project to ensure that not net biodiversity loss and no negative impact on downstream water users.

Management of Ecosystem Services: Significant volumes of water from nearby rivers are used at HEPPs to drive the turbines to generate power; the water is then returned to the river to maintain ecological flow. The cumulative impacts of water abstraction for the HEPPs is monitored and assessed, and mitigation measures have been implemented. The calculated ecological flows at the HEPPs represent in all cases at least 10% of the mean annual flow and may vary monthly. However, the methodology to calculate ecological flows is not consistent throughout the HEPPs. For example, at the Demirciler HEPP, the ecological flow is based on the result of the wet environmental method while at the Yagmur HEPP it is based on the average of Tennant and wet environment methods and at the Cicekli HEPP is based on the flow duration indicator. The details of ecological flow requirements and the length of the river that is subject to reduced flow is provided in the Annex for each of HEPPs.

For three of the HEPPs (Sekikaya, Sirma and Gelinkaya) the water reservoir is regulated / controlled by Turkish State Hydraulic Works (local authority), and Akfen use the water that is provided. For these sites Akfen do not manage the ecological flows and therefore there are no calculations held by Akfen for these plants.

Turkish State Hydraulic Works requires Akfen to record the measured ecological flow data. No concerns and/or complains have been raised by downstream users / affected communities and ecological flows that are provided during the appraisal appear to be sufficient to maintain the needs of affected communities and ecological values.

The company does not have a corporate-level stakeholder engagement framework or project-specific stakeholder engagement plans, nor does it have an external grievance mechanism at corporate and project levels. The company’s stakeholder engagement activities in Turkey are limited to public participation meetings held during EIA preparation as per local legal requirements. Minutes of these meetings are recorded and maintained as required by relevant EIA regulation. Akfen did not receive any specific claims and/or concerns raised by the communities during these meetings.
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. Project specific brochures were prepared and distributed to stakeholders including communities in close vicinity of corresponding projects. However, the format of these brochures is standard for all projects and the content covers technical and legal details, emphasizes renewable character of the project and the preservation of nature. No action plan document has been prepared and disclosed to the communities.
Although the company responds to community concerns, especially when a significant issue is raised, there is no formal grievance mechanism in place for local communities and interested parties. The village headmen and Mayor’s offices are provided with Akfen’s contact details should they require to communicate with the company. However, there is no registered monitoring system to log grievances or concerns raised by the people via these channels.
At the moment, all stakeholder engagement related activities are centrally processed by Akfen executives and managers at headquarters. Individual site managers are also involved in public relations activities for operational projects.
In addition to the standard stakeholder engagement arrangements summarized above, one-on-one communication and consultation with relevant stakeholders should be maintained if privately owned lands are to be acquired. Currently, these land acquisition related engagement activities are performed by the topographical engineer who is also assistant general manager, responsible for the land expropriation management at the headquarters.
Per ESAP item# 6, 7 and 8 Akfen shall (i) develop and implement a corporate communication plan and implement such plans at the companies’ level and develop separate stakeholder engagement plans (“SEP”) for each project (at least for each major investment). This should include the development and implementation of a grievance mechanism. The SEP (s) should address potential issues that may be raised by NGOs in Turkey. As part of SEP and EHS, Akfen shall prepare a register of risks for the public and develop and implement and monitor mitigation measures. The register should be prepared by a specialist used with the implementation of international Industry good practices on hydropower schemes; (ii) monitor implementation of the SEP and grievance mechanism to ensure a continuous and systematic stakeholder engagement programme throughout the projects life cycle. The SEP should be reviewed and if necessary updated annual or when material changes occur in the Project; (iii) As a part of the development, planning, design and construction and commissioning of each project, Akfen will develop a non-technical summary (“NTS”) as appropriate and community leaflet for each new project in construction or to be developed in the future providing a project description, the EIA process, the environmental and social benefits/impacts, mitigation and management measures and the contact details for communications with a link to the SEP. Akfen shall develop a corporate internet site, with inclusive of a sustainability page and disclose as appropriate NTS and community information brochures for new projects on this web site. In addition, Akfen will appoint a community liaison officer (“CLO”) with appropriate skills and experience to effectively manage the implementation of the SEP at each site.

This ESRS will be available at the Akfen Energy’s Plants’ main entrance gate.

Contact Person: Songül Eyidemir
Company Name: Akfen Yenilenebilir Enerji A.Ş.
Address: Koza Sok. No.22 Gaziosmanpaşa, Çankaya, Ankara
Email: mailto:seyidemir@akfen.com.tr
Phone: +90 312 408 1000
Facsimile: +90 312 441 6814

Broad Community Support is not applicable for this project

Akfen Energy(36772) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
1. The EIA process for each new project to consider the range of cultural heritage considerations Develop and implement a ‘chance find’ procedure to be used during all construction activity, to aid in managing archaeological finds.	31-Dec-2016	Completed	Completed	8/1/2016
2. Develop and implement an environmental, health and safety management system at the corporate and site level. Ensure appropriate reporting lines to be implemented through Akfen Holding and through Akfen Energy. Attain certification to ISO 14001, OHSAS 18001and ISO 50001.	31-Dec-2018	Completed	Completed	1/25/2017
3. Develop a procedure of independent impact assessment (EIA) on environment, biodiversity and local communities as well as cultural heritage for all new investments. This will include appropriate biodiversity assessments for birds and bats - and aquatic surveys (fish etc). Design mitigation measure for each Project. Any new project that would fall under the EU EIA Directive will include a screening assessment which will be conducted by Akfen and its advisors(unless a project falls into a category no approval is required) to define the scope of the due diligence . all projects will follow National legislation, - The final EIA may consist of a local EIA plus supplementary information as defined by the screening assessment on environmental and social issues.For all projects where an EIA is required - publish a Non Technical Summary (NTS) at the time of the zoning plan Stakeholder Engagement Plan (SEP) on internet and disclose as appropriate EBRD and IFC to approve any A category Project.	31-Dec-2016	Completed	Completed	8/1/2016
4. As part of EHS management system, nominate and maintain an EHS manager at corporate level. The person should be a main point of contact for every stakeholder, NGOs, local communities and grievances from third parties, as well as review all new EIA’s for new projects and maintain an internal audit system.	31-Dec-2016	Completed	Completed	8/1/2016
5. Create an ”environmental council” consisting of environmental, H&S and social specialists from the plants to improve information exchange and strategic planning. As part of the EHS team and ‘environmental council’ Develop a procedure for an inspection and maintenance programme with regards to dam safety against ICOLD standards.Implement the inspection programme once the procedure is developed. As part of EHS management plan prepare and emergency response plan, (and implement when necessary) inclusive of an early warning procedures in case of flood threatening the public (typically for floods with a return period of five years or more).	31-Dec-2016	Completed	Completed	8/1/2016
6. Develop and implement a corporate Communication Plan and implement such plans at the companies’ level. Develop separate Stakeholder Engagement Plans (SEP) for each project (at least for each major investment). This should include the development and implementation of a Grievance Mechanism. The SEP should be reviewed and if necessary updated annual or when changes occur in the Projects. The SEP (s) should address potential issues that may be raised by NGOs in Turkey. If necessary, or request arrange for meetings as appropriate.As part of SEP and EHS management prepare a register of risks for the public and develop and implement and monitor mitigation measures. The register should be prepared by a specialist used with the implementation of international Industry good practices on hydropower schemes	31-Dec-2016	Completed	Completed	8/1/2016
7. Monitor implementation of the SEP and grievance mechanism to ensure a continuous and systematic stakeholder engagement programme throughout the projects life cycle. Documentation of all stakeholder activities and logging of grievances to inform the annual monitoring report. The SEP should be reviewed and if necessary updated annual or when material changes occur in the Project	31-Dec-2016	Completed	Completed	8/1/2016
8. Develop a Corporate internet site, with inclusive of a sustainability page and disclose as appropriate NTS and community information brochures for new Projects on this web site	31-Dec-2016	Completed	Completed	10/1/2016
9. Develop and adopt Human Resource Policy and management system covering all employees, on a best effort basis for contractors as well as sub-contractors, to include (but not be limited to) (i) Approach to managing its workforce, (ii) Management of worker relationships; (iii) Access to worker’s organisations; (iv) Working conditions and terms of employment; (v) Child labour and forced labour policies; (vi) Equal opportunities and non-discrimination; (vii) Oversight provided of contractor policies/procedures	31-Dec-2017	Completed	Completed	1/1/2017
10. Develop formalised human resources management system and procedures with special regard to grievance procedures. This should include welfare arrangements for construction workers prior to construction activities commencing	31-Dec-2017	Completed	Completed	1/25/2017
11. Akfen to review and align the H&S Plans in line with the EBRD PR4 / IFC PS2 and PS4 requirements. Plans should guide all Project-related activities during construction and operation. Requirements to include (but not be limited to): (i) Job- and task-specific hazard and risk analysis and controls for activities; (ii) Provision of PPE, requirements for use of PPE, and enforcement of PPE use; (iii) Safety training for all personnel, covering hazards for their jobs.(i.e. Undertake driver safety training and code of conduct training for the drivers of the transfer trucks as well as drivers of employee service buses); (iv) Develop an accident investigation program. Record incident statistics, including total work hours, serious injuries, lost time, etc.; (v) Develop a medical monitoring program for employees; (vi) Ensure implementation of a work permit system covering both workforce and contractors for dangerous tasks such as confined space; (vii) Establish and implement a “Lock Out Tag Out” system; (viii) Implement workplace hazard monitoring; (ix) Place safety signage where necessary. Safety signage should address fire safety, emergency response, noise, PPE, no smoking, traffic control, etc.	31-Dec-2016	Completed	Completed	8/16/2016
12. Review and update the current emergency response plans in consultation with responsible authorities and communities to cover at least fire, flood response, spills, severe injuries or fatalities, or other events that could reasonably be expected to occur within the lifetime of the projects in line with the EBRD and IFC requirements. Trainings and drilling exercises should be conducted on regular basis.	31-Dec-2016	Completed	Completed	8/16/2016
13. Develop a land acquisition and compensation framework for the purchase of land for new projects the framework where possible and to the extend when possible will include associated infrastructure such as powerlines. For each project undertake risk assessment associated infrastructure even if not develop by Akfen. The objectives of the framework should describe how to: (i) avoid or minimise resettlement, economic displacement; (ii) consider feasible alternative project designs; (iii) mitigate adverse social and economic impacts from land acquisition; (iv) provide compensation for loss of assets at replacement cost; and (v) improve or, at a minimum, restore the livelihood and standards of living	31-Dec-2016	Completed	Completed	10/1/2016
14. Adopt a formal grievance mechanism, enact the Stakeholder Engagement Plan and develop a land acquisition and compensation framework.	31-Dec-2017	Completed	Completed	10/1/2016
15. Undertake an environmental monitoring assessment at each current and future HEPP location, to verify the biological effectiveness of the ecoflows. This should consider factors such as: (i) are ecoflows able to maintain water quality (temperature, dissolved oxygen, etc.); (ii) can ecoflows support the maintenance of fish populations, particularly the more vulnerable species; and; (iii) do ecoflows give the streams the capacity to support spawning, incubation, rearing, and passage of fish? Confirm that the presence and sizing of fish protection grids on the water intakes are appropriate.	31-Dec-2018	Completed	Completed	10/1/2016