While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
Since the project location is within the urban areas of Istanbul city, PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable. There are no Indigenous Peoples affected by the project, thus PS7: Indigenous Peoples is not applicable. Although the construction sites are within the city center of Istanbul, which is an ancient city with plentiful cultural heritage, the construction of the tunnels is expected to pose a low risk to cultural heritage since they will be built below the depth of feasible archeological resource locations. The City Conservation Council requires MMI to perform all tunneling and construction works in Besiktas area under the supervision of the Archaeological Museum Directorate and, according to MMI requirements, in the event of a chance find during earthworks, construction work will be stopped by Alarko and the Ministry of Culture and Tourism will be notifiedon how to proceed with the activity to ensure protection and rescue of the object if necessary. As no cultural heritage is known to be affected by the project and the risks of impacts are considered low, no mitigation measures other than the PS 1 chance find procedure (as referred from ESAP action # 1) are required and PS 8 is not deemed to be applicable.

The project has been classified as Category B as it involves business activities with potential limited adverse environmental or social risks and/or impacts that are few in number, generally site specific, largely reversible, and readily addressed through mitigation measures.

The key E&S issue associated with the proposed project is stakeholder engagement and the capacity of MMI, its metro line operating subsidiary Istanbul Ulasim and construction contractor Alarko to manage Environmental, Health & Safety and Social (EHSS) matters associated with tunneling and station construction. Additional issues include labor and working conditions, especially occupational health and safety and contractor management; emergency preparedness and response; and community 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.

Environmental and Social Assessment and Management system and Policy / Identification of Risks and Impacts and Management Program: Both construction company Alarko and municipal operating company IU have ISO 14001- and OHSAS 18001- based EHSS management systems. Both Alarko’s and UI’s system, which is in line with IFC PS 1 requirements, includes documented EHSS policies and safe working instructions and procedures including excavation works, confined spaces, speed policy, work permit system, electrical safety, explosion safety, personal protective equipment usage, traffic safety and working with heavy construction vehicles.



In line with Turkish environmental permitting requirements, a Project Presentation File (PPF, which is disclosed in the “Client’s Documentation Tab” as a part of this ESRS) was completed in 2007 by MİMKO Mühendislik, İmalat, Müşavirlik, Koordinasyon ve Tic. A.Ş , under contract by MMI. The PPF contains an evaluation of potential environmental impacts and descriptions of mitigation measures for construction and operations including resource consumption, waste management, noise, vibration, impacts on flora and fauna, land acquisition, management of effluents and incident management. It also includes a review of geological formations and hydrology. Based on the review of PPF, the Istanbul Directorate of Ministry of Environment and Forestry decided that no further Environmental Impact Assessment was required for the project (with certification date of July 07 2009 and number 2009/04-51/2191).



Construction contractor Alarko has also conducted an environmental impact and occupational health and safety risk analysis for the construction phase and developed a construction phase management plan including specific mitigation measures for inspections, near misses and incident reporting.



IU conducts environmental impact and occupational health and safety risk analysis in line with its existing EHSS management system. As per Environmental & Social Action Plan (ESAP) action #1, MMI will ensure that IU reviews and extends the scope of its EHSS management system to include MMI Metro Line’s Kabatas-Mecidiyekoy operations.



As per ESAP action #2, MMI will ensure that IU develops an environmental impact assessment and occupational health and safety risk analysis, with a special focus on occupational health and safety risk analysis for the operational phase of Kabatas Mecidiyekoy line.



Organizational Capacity and Competency: MMI’s European Side Rail System Directorate has overall responsibility for the construction of the rail systemand their responsibility includes management of contractors and EHSS issues. MMI has an EHSS team, consisting of 50 staff, and one of their experts is assigned to the project as EHSS coordinator, in order to conduct site tours, monitor contractors’ performance and to ensure the activities are performed in line with the requirements defined under the construction contract. As part of the default contrac
t templates, contractor companies are required to employ EHSS staff. In addition, for the construction phase of the project, MMI has assigned EHSS management responsibilities to consulting engineering company EMAY, which has in turn appointed an EHSS responsible to monitor the EHSS performance of construction company Alarko. As per ESAP action #3, IU will nominate an EHSS officer responsible for the overall supervision of EHSS aspects during operations.



Alarko has eight EHSS staff specific to the project and an additional two geological / geotechnical engineers supporting this team. There are an additional four Alarko EHSS employees at corporate level to supervise and support the project site team. Alarko’s EHSS project staff will report to the project manager and their roles and responsibilities include conducting risk assessments, providing training and reporting EHSS performance to senior management. All EHSS staff are certified in line with Turkish legal requirements and/or have previous academic training or work experience in EHSS-related fields. Alarko’s sub-contractors are required to have dedicated EHSS teams as well. The majority of the employees working at EMAY, IU and Alarko have a technical background and management has a good understanding of environmental impacts and energy efficiency.



During the operational phase, IU’s dedicated EHSS management team will supervise the EHSS aspects of the project. The team is currently staffed by 39 specialists whose responsibilities include the implementation of IU’s EHSS related commitments with respect to community safety, operational safety and reporting EHSS performance.



Emergency Preparedness and Response: Alarko has an emergency preparedness and response plan for construction including evacuation, earthquake, floods, and injuries for the construction works. The plan includes communication with the local authorities. At the construction sites visited, first aid kits and fire extinguishers were provided. There is an ongoing training program to ensure that there will be at least one first aider per ten employee and necessary number of emergency response team members.



IU has an existing emergency preparedness and response plan for operations including evacuation procedures, earthquakes, power failures, floods, fires, and injuries. In addition, there are plans related with sabotage and terrorist attacks. Evacuation routes and emergency equipment are clearly marked and there are alarm and announcement systems in the existing stations and in the railcars (including emergency team and equipment) operated by IU.



Monitoring and Review: For the construction phase, Alarko EHSS and project staff will conduct daily toolbox talks with the employees. Alarko’s EHSS team has developed a checklist to conduct weekly site tours focusing on dust, noise, safety of the access roads, water on site/tunnel, fencing, chemicals safety, stairs, electrical safety, spills, wastes, grounding, illumination
, excavation, heavy work vehicles and impacts on affected communities. The EHSS team also uses hand terminals to record unsafe behaviours and conditions during their daily site tours. Performance indicators have been developed including waste amounts, energy (fuel and energy) and water consumption, incident and near misses rates, and training hours. EHSS performance will be reported monthly to EMAY and to Alarko’s senior management. Alarko’s corporate EHSS team also conducts monthly site tours to review EHSS performance and provide feedback to senior management.



IU has a monitoring and reporting system for its existing operations. This includes incident rates (both employees and passengers), energy and water consumptions. EHSS performance is reported to MMI and IU senior management monthly as well. In addition, both Alarko and IU will hold monthly occupational health and safety meetings, where employees can raise their concerns and minutes are recorded for local authorities’ inspections.



Stakeholder engagement for this project is discussed under the ‘Stakeholder Engagement’ tab.

Human Resources Policies and Procedure / Working Conditions and Terms of Employment; There are almost 14,000 employees within MMI and 2,400 employees within IU. Once operational, it is expected that the project will create an additional employment for 60 people, mainly related with maintenance and station operations as the railcars are planned to be operated in driverless mode. For MMI and IU, terms of employment and benefits are defined and provided according to Turkish “Public Employees Personnel Regulations”.



EMAY has 81 employees which will increase to 110 during the peak construction period. Alarko has employed [47] workers (83 % male) for the MMI project, plus an additional 57 sub-contractors. During the peak construction period, Alarko will employ around 150 employees whereas the number of sub-contractors will increase dramatically to around 1,200 at the peak period. It is expected that 6,500 sub-contractors will be employed during the project’s entire construction period. Alarko will work 24/7 and will arrange the working hours to be in line with Turkish legal requirements in which International Labour Organizations (ILO) conventions are adapted. IU will operate the line from 6 am to 12 am while maintenance works will be completed from 12 am to 6 am.



Both IU’s and Alarko’s Human Resources (HR) policies and procedures are in line with Turkish regulations whereas improvement opportunities with respect to IFC PS2 are defined in the following sections.



Workers’ Organizations / Non Discrimination and Equal Opportunity / Retrenchment: For IU and Alarko, there is no discrimination allowed on the basis of ethnics, personal characteristics or gender. “Demiryol-Is” union represents 1,700employees in IU. Although there is no union in Alarko, as Turkey has ratified the core ILO Conventions on freedom of association, Alarko management stated that all employees and sub-contractors are free to join a union and/or workers organizations. As per ESAP action #6, MMI will ensure that Alarko updates its HR Policy and procedures to confirm employees’ rights to freedom of association.



No retrenchment is expected as a result of this project, as new jobs are being created. At the moment, there are no firm plans by MMI to restructure the bus services operating along the metro alignment. Should this happen in future, the affected bus services are likely to be redeployed as feeder routes for the proposed metro line. Thus no retrenchment is anticipated at the bus company as a result of this project.



Grievance Mechanism: MMI has a worker grievance mechanism where all employees, including contractors, can raise and register their concerns. This mechanism includes reporting to an official Inspection Committee, to supervisors, to labor unions and/or anonymous reporting through phone call/emails.



For Alarko, at present, there is a documented grievance mechanism. However, this mechanism is not allowed to be used anonymously and/or by sub-contractors.
There is also an “open” door policy and employees are encouraged to approach their supervisors, manager and senior management or HR 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 staff contacts and details who are available 24/7. As per ESAP action #6, MMI will ensure that Alarko revises its internal grievance mechanism to allow anonymous reporting and redress of worker and sub-contractor grievances. For IU, an internal grievance mechanism is defined under collective bargaining and by Turkish labor laws, where all employees have right to raise and register their concerns.



Protecting the Work Force / forced labor / child labor: Both for IU and Alarko, the minimum working age is 18 years. For Alarko, a statement in contracts with sub-contractors provides that they must comply with national law that indicates a general working age of 18. There is no forced labor and no restrictions are imposed on staff wishing to cease employment other than statutory notice periods.



Occupational Health and Safety: Both Alarko and IU have documented and certified management system to ensure occupational health and safety for the employees.



Alarko’s system includes documented safe working procedures and instructions for personnel protective equipment usage, training, safety in excavation and tunneling works, lifting, working in confined spaces, safe working with electrical equipment, waste management, and chemical safety. For NATM, explosives will be used for controlled blasting, however, they will be provided by an authorized/certified third party company and explosives will not be stored at site. Transportation of explosives will be performed by the authorized third party company in line with the Turkish legislations in force. Charge of the explosives will be performed under the supervision of mining engineers and another authorized third party company, which is hired by Alarko, will make the geological analysis and do the necessary calculations to decide on the amount of the explosive to be used. An EHSS onboarding training, of at least 16 hours, is provided to all new employees, including the sub-contractors. There is one doctor and health technician on site to provide health services and conduct on site health risk assessments. Pre-employment and annual health controls included blood analysis, respiratory system control, eye control, audiometry, screening for HIV/tetanus/hepatitis, skeleton system controls. No accommodation will be needed as the construction site will be within the city center. Food will be provided from contracted third party companies, and every construction site will have cafeterias on the ground where employees can have their food and drinks. Drinking water analysis will be performed periodically in line with the existin
g EHSS management system, Alarko’s lost time injury frequency rate (LTIFR, number of lost time work cases per million work hour) in its other similar metro construction works is 0.6, which is significantly lower than the industrial benchmark of 7.5 (http://www.bls.gov, for all construction works), showing that its EHSS system is being effectively implemented. As well as incident reporting and investigation, Alarko’s system includes near miss and unsafe condition reporting, which is widely used by the employees by use of hand terminals and/or suggestion/near miss reporting boxes.



IU has an effective EHSS management system including speed policy, safety at maintenance works, electrical safety, machine safety, moving equipment safety, and industrial hygiene issues such as noise and air quality. LTIFR is around 3.26 , which is satisfactory when compared to industrial benchmark of 6.5 (http://www. bls.gov, rail transportation). IU is providing EHSS training to its staff as a part of on boarding and periodical training program. The staff to be employed is subject to medical testing and analysis specific to the job where he/she will be employed. The health tests are done annually according to legislation in force. As per ESAP action #1, IU will extent the scope of its EHSS management system to cover MMI Metro Line operations. This will include planning of the manual railcar operations in case of emergencies as the new railcars will be operated automatically, without a driver.



Workers Engaged by Third Parties: For the construction phase, MMI’s requirement includes EHSS staff nomination, risk assessments, an EHSS plan to mitigate the risks to be developed and EHSS performance to be reported to MMI. As discussed above, Alarko already completed those requirements and provided the documents/implementation proof to MMI. Alarko incorporated similar EHSS requirements into its contract templates for sub-contractors. MMI will monitor the compliance to contractual requirements by use of EMAY through its daily site tours, weekly project meetings and monthly reporting and Alarko will monitor the compliance by use of its own EHSS staff, through similar control mechanisms. Both MMI and Alarko included right to terminate the contracts and / or charge fines in case of a breach.



IU will use third party companies for services mainly for maintenance and/or inspections including elevators in the stations, security at the gates and for the cleaning of stations. IU requires all contractors to comply with the requirements outlined in the contracts. This includes provisions for compliance with national law on labor and working conditions and IU’s other EHSS management system requirements.

Resource Efficiency and water consumption: For the construction and operational phases electric energy will be supplied by the national electric grid. There will be standby generators, for TBMs and for the emergency lighting and ventilation in the tunnels for the construction phase. There will be standby generators and UPS systems for emergencies during the operational phase.



During the construction phase, the main source of water consumption will be related with tunneling operations and workers consumption (hygiene, etc). Water consumption is estimated to be around [1,000] m3/day by TBMs. For concrete production it is estimated to be [216] m3/day. Water will be provided by the public water network served by Istanbul’s Water and Sewerage Authority. For the operational phase, water will only be used for cleaning and domestic needs.



Energy (fuel consumption by the vehicles and electric usage) and water consumption during the construction phase will be monitored as a part of EHSS management plan and will be reported to MMI and Alarko’s management. For the operational phase, IU will extend its resource consumption monitoring and management program into the operation of the new metro facilities. Project technical specifications include new energy efficient electrical systems such as electrical escalators that will utilize the most energy efficient options available in the market.



Green House Gases (GHG): The project is expected to have positive impacts on GHG emissions as it will replace fossil fuel powered vehicles (including buses) with an electric railcar system. By the Client’s assessment, phase 1 and phase 2 will prevent transportation for 177,000 to 230,000 km per year that will result in GHG reductions of 108,000 to 140,000 / tons CO2 equivalent per year.



Effluents: Wastewater discharges from sanitary facilities (both for construction and operational phases) and from dewatering of tunneling operations will be discharged into the public sewerage network in line with the permits received from MMI, the authority according to Turkish legislations in force.



Hazardous materials and waste management: There is no significant use of hazardous materials related with the construction and operational phases. Hazardous chemicals include fuel for the construction vehicles and for the backup generators, oil and lubricants for the vehicles and equipment, cleaning solvents. As a part of their existing systems, Alarko and UI will implement a chemical safety management system where; (i) hazardous chemicals will be stored in portable, skid-mounted, fuel oil storage tanks with secondary spill containment basins; (ii) all construction sites and construction storage yards will be equipped with spill containment and clean up kits; (iii) Alarko and IU will provide the training necessary for their effective deployment and (iv) material safety data sheets will be made available for the employees.



During the construction phase, the most significant n
onhazardous waste will be excavation waste from tunneling operations. Hazardous wastes will include maintenance wastes from the TBM and heavy construction vehicles, waste oil, packaging wastes including waste solvents and painting containers, cement addictive and batteries. Hazardous wastes will be stored in closed containers made of materials compatible with the contents and placed in specially designated areas with secondary containment and protection from the direct sunlight. Other types of non-hazardous solid waste generated during the construction and operational phase of the project will includes general domestic waste, cleaning waste and newspaper and other packaging materials left in the railcars. All wastes, including excavation, domestic and hazardous wastes will be disposed/recycled in line with Turkish Environmental Legislations by/at licensed companies/sites. As a part of EHSS management systems’ monitoring process, waste amounts will be reported monthly to Alarko’s management and to EMAY, and finally to MMI. IU has its own monthly monitoring system and amounts will be reported to its management monthly during the operational phase.

Community Health and Safety: The proposed project will be constructed within the highly populated city center. As a contractual requirement, MMI required Alarko to develop an EHSS management plan focusing on community safety. Alarko’s EHSS management plan includes construction safety measures to protect the public, including use of fencesand other access control measures near construction areas, traffic safety, control of construction vehicles, clear demarcation and proper illumination of these areas and provision of safety information to visitors where appropriate. Alarko also prepared an “urban areas construction work plan”, which is approved by local authority, in this case MMI. Alarko’s plan include use of sea vessels and moving excavation wastes at night in order to prevent traffic congestion. Construction site monitoring programs include ambient noise and dust measurements in order to monitor impacts on nearby communities. Alarko will work with reputable third party companies to monitor vibration and any ground subsidence which might occur on the surface as a result of TBM and NATM operations. Monitoring results will be reported monthly to Alarko’s management and to MMI through EMAY. As discussed under PS2, explosives which will be used during NATM operations will be transported to site by a certified third party company and will not be stored on site. Charge amounts will be calculated by authorized third party company and mining/tunneling engineers will supervise the explosions.



Internationally accepted standards have been incorporated into the design criteria and specifications for stations, ventilation and emergency systems, including U.S. National Fire Protection Agency Standards, European Norms, Turkish Standards related to the Protection of Building from Fire and U.S. Transportation Department requirements. This includes fire resistant walls, smoke evacuation, electromagnetic compatibility, and installation of gas-based sprinkler systems in signal rooms.



For the operational phase, platform separator door systems will be installed at the station platforms in order to prevent access of the passengers to the metro line as the line will be operated automatically. The trains will be operated with an average operational speed of 36 km per hour. There will be CCTV camera system which can be monitored from two control centers, and the railcars can be operated from those centers in case of emergencies.



Infrastructure and Equipment Safety: MMI’s construction quality assurance program including on-going testing for concrete mix quality, steel materials quality, and on-going geotechnical monitoring during tunneling.



As the project area is classified as a high-risk earthquake zone (Earthquake Region Class 1), an earthquake analysis has been conducted by a reputational certified third party company and measures against earthquake risk are incorporated into the project structural design criteria and specifications.



Community Exposu
re to Disease: IU’s community safety / hygiene program includes weekly disinfection of the escalators, elevators, railcars and the stations.



Emergency Preparedness and Response: Design criteria of the stations include installation of emergency lightning, backup generators, emergency alarms, portable fire extinguishers and hydrant system. Each station will be equipped with 180 m3 of water reservoir which is calculated to be sufficient to provide water to fire suppression systems in the tunnel and station for about 60 minutes. Stairs, elevators and escalators will be designed to evacuate passengers within 6 minutes to the ground and/or within 4 minutes to a safe area. Exits will be clearly marked and there will be posters with in the railcars/stations showing the unsafe behaviors and the safety rules in line with IU’s existing EHSS management system, current practice and Turkish legislations in force. IU conducts evacuation drills and fire exercises with city fire brigade service at the existing lines periodically. Emergency plans include communication with the local authorities in case of emergencies.



Site Security: MMI’s, Alarko’s and IU’s security personnel are unarmed and trained in the use of force for defensive purposes. MMI, Alarko and IU are using a third party security service providers. The recruitment process is in line with Turkish legal requirements related with “special security forces legislation”, including pre-employment and periodical psychological tests. The risk posed by these personnel to the public is regarded as being minimal; in fact part of their role is to safeguard passengers and pedestrians.

According to MMI and IU, the project has been communicated to interested parties and affected communities through MMI’s webpage, city bill boards, by media advertisements and at the existing stations by billboards and through railcar screens.. As part of the city planning, the project has been consulted on with various interested bodies. However, as the project did not require an EIA process, no documented stakeholder engagement meetings were conducted with records showing the attendees, and/or concerns raised and related mitigation plans.

Both MMI and IU have a formal public grievance mechanism, termed “Beyaz Masa”, through which affected communities can raise and register their concerns through their webpages (http://www.ibb.gov.tr, http://www.istanbul-ulasim.com.tr), and /or by a call center (number 153). In addition, interested parties can raise and register their concerns through a “Citizen Communication Center” by face to face interactions, phone, fax, telephone and / or through the web site. MMI has to provide any additional information about the project to any interested parties according to Turkish legislation, namely “Information Right Law (number 4982, date Oct, 09th, 2003). MMI and IU are planning to provide ongoing reporting about the project through their webpage, through city / existing station billboards and via railcars screens.

In line with its existing system, Alarko has an external grievance mechanism. This includes registration of all concerns raised and review of the issue by the EHSS team and related departments, development of a mitigation plan which is approved by a project manager and senior management and provision of feedback to interested parties. Although Alarko hasn’t received any formal grievance yet, on October 3rd when the company started to fence the construction area in Findikli park, a group of people, led by representatives of some chambers of professionals, raised their concerns about the usage of the area for construction and its impact on trees. .As per MMI’s existing procedures, MMI Public Relations Department informed residents, NGO’s and institutions on the ground about the construction works.

As per the ESAP action #4, MMI will establish communication points/desks at potential construction sites before and during the construction phase in order to allow interested and affected parties to raise their project related concerns related to issues such as construction disturbances and traffic re-routing. In addition, as per ESAP action#5, MMI will revise/improve and implement its Public Relations Plan (Stakeholder Engagement Plan) in line with IFC stakeholder engagement requirements. This plan, currently in draft form, will identify and address key project stakeholder groups and communities which already raised concerns; make provision for disclosure of relevant project information to ensure affected parties better understand the nature, duration and risks/impacts associated with the project; outline the stakeholder consultation process to be implemented on an ongoing basis and present a project grievance mechanism that allows for third parties to raise concerns and objections concerning the project and receive replies within a reasonable time period and detail. MMI will coordinate its grievance redress process with Alarko and will keep records of each engagement activity throughout the project.

This ESRS will be available at the “MMI Metro Line phase 2” construction sites and at the station entrances when it is operational. For more information please contact:

Name : Hasan Pezuk
Address : IBB Ek Hizmet Binasi M. Nezihi Ozmen Mah. Kasim Sok. 34010 Merter Istanbul
Tel :+90 212 449 41 75
Fax : +90 212 449 41 80

Email : mailto:hasan.pezuk@ibb.gov.tr

Broad Community Support is not applicable for this project

MMI Metro Line(37093) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
MMI will ensure that, IU will review and extent the scope of its EHSS management system to include MMI Metro Line, Kabatas Mecidiyekoy operations and provide IFC a copy of the system documents. This will include (but not limited to); (i) planning of the manual railcar operations in case emergencies as the new railcars will be operated automatically, without a driver; (ii) a chance find procedure in line with IFC’s PS8 requirements to define the steps to follow in case of finding any archaeological / cultural property.	31-Mar-2019	In progress	Due date revised as agreed with IFC Client
MMI will ensure that, IU develops an environmental impact assessment and occupational health and safety risk analysis with a special focus on occupational health and safety risk analysis for the operational phase of Kabatas Mecidiyekoy line.	31-Mar-2019	In progress	Due date revised as agreed with IFC Client
IU will nominate EHSS officer responsible for the overall EHSS aspects during operational phase.	31-Mar-2019	In progress	Due date revised as agreed with IFC Client
MMI will establish communication points/desks at potential construction sites before and during the construction phase in order to allow interested and affected parties to raise their concerns related to issues such as construction disturbances and traffic re-routing.	31-Jan-2016	Completed	Completed	1/30/2016
MMI will revise/improve and implement its Public Relations Plan (Stakeholder Engagement Plan) in line with IFC stakeholder engagement requirements. This plan, currently in draft form, will identify and address key project stakeholder groups and communities which already raised concerns; make provision for disclosure of relevant project information to ensure affected parties better understand the nature, duration and risks/impacts associated with the project; outline the stakeholder consultation process to be implemented on an ongoing basis and present a project grievance mechanism that allows for third parties to raise concerns and objections concerning the project and receive replies within a reasonable time period and detail. MMI will coordinate its grievance redress process with Alarko and will keep records of each engagement activity throughout the project.	31-Jan-2016	Completed	Completed	1/30/2016
MMI will ensure that Alarko updates its Human Resources Policy and procedures in line with IFC PS2 requirements. This will include (but not limited with); (i) Inclusion of a statement to policy confirming employees’ rights to freedom of association; (ii) Review and revision of its internal grievance mechanism to allow anonymous reporting and redress of workers and sub-contractor grievances.	31-Jan-2016	Completed	Completed	1/30/2016
MMI will prepare a Physical & Economical Resettlement Framework for the metro stations. Prior to construction of the each station infrastructure, a Physical & Economical Resettlement plan will be prepared in line with Physical & Economical Resettlement Framework. The plan will include consultation with the affected business owners, and will describe the magnitude of economic displacement, the consultation process to be conducted, and the entitlement and compensation criteria for various categories of affected people.	31-Jan-2016	Completed	Completed	1/30/2016