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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
SSL owns its existing plant, while the land adjacent to SSL which will be needed for the neutralization project, has been acquired from the local authorities on a willing seller willing buyer basis and was previously uninhabited waste land contiguous with a major heavy industrial site. Thus PS:5 Land Acquisition and Involuntary Resettlement is not relevant to this investment. The existing plant is within Lukavac and is not in the vicinity of sensitive environmental areas, nor within known historical and/or cultural heritage areas. Therefore, issues related to PS:6 Biodiversity Conservation and Sustainable Management of Living Resources and PS:8, Cultural Heritage, are not encountered. There are no indigenous people in BIH, thus PS:7 Indigenous Peoples, is also not triggered.

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. This is a category B project according to IFC’s Policy on Social and Environmental Sustainability in line with the previous SSL projects. The project is expected to have limited site-specific potential adverse environmental and social impacts that are few in number, largely reversible and that can be readily addressed through mitigation measures. In contrast, the project is expected to have positive environmental impacts including reduction in greenhouse gas emissions, improvement in point source emissions, waste water effluent and waste recycling.

The key E&S issues include: point source air emissions and ambient air quality, waste water effluent quality, emergency preparedness, occupational health and safety during construction and operational phases, community health, safety and security and consultation with affected communities.

Environmental and Social Assessment and Management System and Policy: Sisecam has a corporate level E&S policy and a documented management system in line with IFC’s PS requirements. SSL adopted corporate level E&S policy to its operations and developed operational procedures, safe working instructions and emergency response plans. SSL certified its existing E&S management system in line with international management system standards, including ISO 9001 Quality Management System, ISO 14001 Environmental Management System, OHSAS 18001 Occupational Health and Safety Management System and EN ISO 22000 Food Safety Management System. Additionally, the company has been certified by Halal, Kosher, Fami QS and GMP (FCA-Food Chain Alliance) for production of food grade refined sodium bicarbonate (“NaHCO3“).



Identification of Risks and Impacts / Management Programs: As a part of its existing management system, SSL identifies risks and environmental and social impacts of its operations and projects, including that related to construction activities. Where necessary, SSL then also develops mitigation plans. A third party environmental impact assessment was conducted for the boiler 8 project, and as the neutralization project is under development phase, no environmental impact assessment and/or risk analysis has been performed as yet. As per ESAP item #1, SSL shall however engage with a third party expert to conduct an E&S risk analysis and impact assessment of neutralization project. This will focus on both the construction and operational phases. As per ESAP item # 2, based on the third party’s findings and suggestions; SSL shall develop and agree with IFC on mitigation plans (if any).



Organizational Capacity and Competency: Sisecam has a corporate level E&S organizational structure consisting of a corporate level environmental coordinator and an occupational health and safety department. The corporate structure is responsible for coordination of E&S management system implementation throughout the differing Sisecam plants, and monitoring and report performance to Sisecam’s senior management. SSL, like other Sisecam plants, has its E&S organization, reporting to SSL’s General Manager and dotted line reporting to the corporate E&S team. SSL’s E&S organization includes a QHSE (quality, health, safety and environmental) Manager (who is also responsible for the quality and E&S management system), two ecology engineers and two occupational health and safety engineer as well as two engineers for quality and another two for process control. There are several laboratory technicians reporting to the E&S department as well. SSL’s E&S department is responsible for performing the E&S impact and risk assessments, providing feedback to management on E&S performance and supervising the employees, contractors and operations. The E&S department also provides E&S training to staff as a part of the orientation program and the training program.



There are two director
ates at the corporate level dealing with labor and working conditions; (i) the Human Resources Directorate (HRD); and (ii) the Industrial Relations Directorate (IRD). The HRD handles recruitment, performance evaluation, salary, career planning, organizational capability, personnel development and training, whereas the IRD is responsible for collective bargaining, relations with employee organizations and E&S. In addition to the Group level HR organization, Sisecam’s Soda companies have their own HR Director responsible for both HR and Industrial Relations, to whom the plant level HR manager reports.



Emergency Preparedness and Response: SSL has documented emergency preparedness and response plans including fire prevention, first aid, evacuation and response to spills. Fire training is provided to plant’s fire fighters in different parts of the plant once in every month. There are almost 100 trained first aiders. There are automatic cooling systems on ammonia storage tanks. Mobile fire extinguishers and hydrants are inspected monthly by E&S team. Plant wide drills were not conducted in 2015 as SSL decided to provide support from the municipality’s firefighting team located 800 m away from the plant. Per ESAP item # 3, SSL shall update its E&S emergency response plans to include an annual evacuation / drill plan and provide a copy of the plan to IFC.



Monitoring and Review: Sișecam has a system in place to monitor and review key performance indicators (KPIs), where plants provide data including air emissions results, noise levels, waste amounts, waste water quality, external grievances and fines incurred. As with other Sisecam’s Soda plants, SSL reports on OHS performance (including incident rates) to Sisecam every six months. Environmental data is used to generate reports and/or to provide analysis as and when needed. Although it is not specific to the chemical business, as a part of Sisecam’s Annual Report, E&S performance of the Group is communicated to shareholders and interested parties.



At SSL, the E&S team conduct daily and monthly site inspections. Improvement plans are developed based on the findings whenever necessary. Progress on the improvement plans and E&S performance is reviewed during monthly E&S committee meetings. As a part of the existing management system, annual management reviews are conducted.

Working Conditions and Management of Worker Relationship / Human Resources Policies and Procedures: Ṣișecam has documented corporate human resources (HR) policy and procedures, which are adapted to SSL operations and implemented. SSL’s HR procedures are based on the Bosnian labor law, which is largely consistent with the requirements of IFC Performance Standard 2, and those include the recruitment and selection procedures, terms of employment, working conditions, working hours, payment processing, wage rating; performance evaluation; trainings.



Working Conditions and Terms of Employment/ Workers’ Organization: SSL employs approximately 517 people of which some 10.25 % are females. Administration staff work during the day time, five days a week and other employees are working in three shifts. All employees work 40 hours per week. Approximately 368 employees (72 %) are members of National Chemical and Non-Metallic Industry Union. According to SSL’s management, there is no difference between unionized and non-unionized employees in terms of benefits and salary scales are generally 50 % above the national minimum wage.



As per all legal agreements, contractors are required to adhere to SSL’s HR and E&S Policies, comply with national and IFC’s PS requirements (covering child/forced labor, access to grievance mechanism, risk assessments, trainings, mitigation measures such as PPE, health screening) as further discussed under “Grievance Mechanism” and “Workers Engaged by Third Parties” section below.



Non-discrimination and Equal Opportunity: SSL has strict policies against discrimination on the basis of personal beliefs or other characteristics unrelated to a person’s ability to perform his/her duties, in line with the Bosnian labor law and Sisecam’s corporate ethical values.



Retrenchment: SSL does not anticipate retrenchment, however, it has reduced employment over time as employees who retired were not replaced. Even so, should any retrenchment occur, all requirements will be fulfilled in line with the national labor law, company legislations and collective agreements, and in accordance with IFC’s requirements related to retrenchment.



In 2009, SSL retrenched almost 80 employees. Subsequently a number of retrenched workers brought court actions seeking reemployment, and around one third of the workers retrenched have been reemployed. 57 court cases were filed against SSL, of which SSL lost 43 cases and paid additional compensations, 8 cases were completed on favor of SSL and 6 cases are ongoing.



Grievance Mechanism: SSL’s employees and contract workers can raise their concerns in written form to the management and/or by use of suggestion/complain boxes which allows for anonymous reporting. Employees can raise their concerns through employee satisfaction survey as needed. All grievances are reviewed by the HR department first and legal and related departments are included as necessary. The HR department conducts regular meetings with
union representatives to discuss the grievances and one on one feedback is provided to the interested parties. SSL issues a news bulletin monthly where the information related to grievances and mitigation plans are shared with the employees and contract workers. If the employees and/or contract workers are not satisfied with the action and/or decision, they may initiate formal grievance proceedings through the union and file a law suit in the local court. The locker rooms, bath and food services were improved in 2015 as a result of the grievances raised through the system.



Protecting the Work Force: The minimum age for employment by SSL workforce is 18 years and there is no forced labor in line with BIH’s labor laws. Contractors are required, as per contract requirements, to follow SSL’s E&S management system requirements, including child labor and forced labor.



Occupational Health and Safety: SSL’s existing E&S management system is certified according to OHSAS 18001, which is generally in line with IFC’s PS requirements. There are documented procedures and safe working practices including working at height, chemicals safety, confined space entry, electrical safety, waste management, welding and cutting, manual handling, lifting safety, electrical safety, forklift safety, near miss reporting, incident investigation, and use of personal protective equipment. SSL improved the equipment guarding, walking surfaces and replaced some process equipment which was considered unsafe. There is an ongoing E&S improvement action for ammonia hazards, which includes installation of on line monitoring and alarm system for the process area within 2016.



Health tests are done periodically for the staff and include respiratory and skeletal system control, chemicals in blood and audiometry checks.



As a part of new employee induction and periodic refreshment training, E&S training including topics such as management system requirements, site safety rules, emergency plans, near miss and incident reporting, waste management, chemical safety, hot works, and material handling, is provided.



SSL’s lost time injury frequency rate (LTIFR - number of lost time injuries per million hours worked) has improved in the last years from 21.2 (in 2012) to 7.5 (in 2014). However, in 2015 the LTIFR increased to 12.1, which is significantly high when compared to good international industrial benchmark data (3.5 – http://www.bls.gov). Most of the injuries are related behavioral safety, however, no specific behavioral safety program, other than awareness training was initiated. Thus as per ESAP item #4, SSL shall develop and agree with IFC on a time based occupational health and safety improvement action plan to ensure that the LTIFR will be in line with good international industrial benchmark data of 3.5. The plan shall include a specific focus on behavioral safety as well as conditional safety improvements.



Workers Engaged by Third Parties: SSL hired almost 400 contr
actor workers from 60 companies in 2015. Contractors provided services including civil works, electrical installation, mechanical installations, raw material storage, security, catering, cleaning and gardening. Contractual requirements include clear covenants to ensure that contractors will follow SSL’s E&S management system requirements. Compliance is monitored by security (such as for child labor, insurance) and/or by E&S team during their daily site tours.

Resource Efficiency / Energy and Material Efficiency Projects: SSL has implemented several resource efficiency programs since IFC’s first investment. Its raw material consumption is within the guidance value referred to in the WBG’s Environmental, Health and Safety Guidelines for Large Volume Inorganic Compounds Manufacturing and Coal Tar Distillation.



As a result of energy audit findings, which was conducted in 2013 and 2014, an additional energy efficiency investment program was initiated. The energy consumption is also within the good international industrial practices and it is estimated that, the proposed projects will ensure an additional 1,7 GJ/ton energy savings, especially due to lower coal consumption.



Water: SSL abstracts water from nearby Lake Mondar. Since 2008, SSL reduced its water consumption by 80 %, mainly due to a cooling tower / water recirculation project and its consumption is now below the good international industrial benchmark figure of 50-100 m3 per ton soda ash.



GHG Emissions: The main source of greenhouse gas (“GHG”) emissions are coal used for energy production as well as limestone and electricity consumptions. GHG emissions is estimated to be 1,300,000 ton per annum (“tpa”) Carbon Dioxide (“CO2”) equivalent. Upon completion of the proposed project, due to lower coal usage, GHG emissions reduction of 91,000 tpa CO2 equivalent is expected.



Air Emissions and Ambient Air Quality: The new boiler 8 project includes a flue gas desulphurization (“FGD”) unit and bag filters to ensure that emissions are expected to be in line with WBG Thermal Power EHS Guideline values. For the upgrade/renovation of boiler 7, it is expected that the same type of FGD unit will be used. Upon the completion of the project, it is estimated that sulphur dioxide (SO2), nitrogen oxide (“NOx”) and particulate emissions is expected to be reduced by 82%, 56% and 77% respectively. As per ESAP item#5, SSL will ensure that, design specifications of the upgrade/renovation of the boiler 7 project will be in line with local limits and the WBG’s EHS Guideline for Thermal Power values (including SO2) and provide IFC the design documents to confirm such.



Wastewater Treatment: SSL’s process waste water is discharged from the factory to the “white sea” settling ponds, and from there overflows without treatment to the Spreca River. This is not compliant with local requirements or WBG EHS Guidelines as this effluent is highly alkaline with a pH of around 11.5. Neutralization of these process effluents was required as a condition of permits provided by local authorities to SSL, as well as an action item in the previous IFC project. Local authorities extended the due date for completion of the project to the end of 2017. SSL purchased 62.000 m2 of nearby land for the neutralization of the wastewater. The project is under development stage, with a time line including design tender to be completed by the end of 2016 and the project to be operational by
the June 2017. As per ESAP item# 6, SSL will ensure that design specifications of the neutralization project will be in line with local limits and the WBG’s EHS Guideline for Large Volume Inorganic Compounds Manufacturing and Coal Tar Distillation guidance values, and provide IFC the design documents to confirm such.



The other waste water sources in the plant are, (i) ash and slag containing black sea water, which is settled by use of sedimentation tanks and is discharged to the Spreca River (the effluent quality is in line with local legislation requirements and the WBG’s EHS Guideline for Large Volume Inorganic Compounds Manufacturing and Coal Tar Distillation; and (ii) domestic waste water, which is disposed to the municipal network.



SSL’s existing management system include daily and monthly waste water analysis and corrective actions are implemented when needed.



Solid Waste Management: Upon the completion of the new boiler projects, the carbon content of the fly ash is expected to be less than 1 %, which will allow SSL to sell it to the neighboring cement plant; their requirement is 5 % or lower carbon content. This will result in recycling of 69,000 tons of fly ash per year.



There is a waste segregation system in SSL, where cardboard, paper, plastic, metals are recycled through licensed third party suppliers. Sludge from the white sea areas is kept in the tailing ponds and black sea sludge is disposed by third party licensed companies. Other wastes, including used oil, domestic wastes are either disposed and/or recycled by certified companies, in line with local legislation requirements.



Hazardous Materials: Hazardous materials include ammonia and some maintenance and cleaning chemicals as well as generator fuel, lubricants and oils. There is an ongoing improvement plan for ammonia, which will be completed by the end of 2016. Hazardous chemicals are stored in well ventilated areas, generally within secondary containment and material safety data sheets and safe working instructions are provided to the employees.

Community Health and Safety: For the existing white sea, after the flood in June 2014, the Mining Institute of Tuzla conducted a study on tailing dams/ponds stability and concluded that the risk of the tailing dams collapse is minimal. No study has been conducted for the new neutralization project yet. As per ESAP item # 1 and 2, SSL shall engage with a third party expert to conduct E&S risk analysis and impact assessment of the neutralization project. This will include identification of the impacts on the community health, safety and security. Based on the third party’s findings and suggestions; SSL shall develop and agree with IFC for mitigation plans (if any).



Security: In 2015, SSL outsourced its security to a certified security service provider. Security personnel are trained in the use of force for defensive purposes only and criminal checks as well as psychological tests are included as a part of pre-employment and periodical health controls. As per ESAP item#7, SSL shall commission a review of its security arrangements against PS4 requirements and develop a corrective action plan if necessary in order to bridge any identified gaps.

The land purchased for neutralization project, as well as the existing SSL plant, is adjacent to an existing graveyard, used by local community. No consultation process, other than with the local authorities, has been initiated yet. As per ESAP item #8, SSL shall develop a community engagement and consultation process for the new neutralization project to ensure that affected communities will be informed and their concerns will be addressed (if any) in development of the neutralization project.

SSL maintains good relations with local communities and most of the employees come from the local area and communities are generally aware of the activities through this informal channel.

As part of its E&S management systems, SSL has established an external grievance mechanism to address community concerns about the possible adverse impacts of their operations and control measures in place. Since 2012 there has been several complaints from the local NGOs about the water discharges to the river Spreca and point emissions and related information, satisfactory to local authorities, were provided the interested parties.

The Company will carry out a local disclosure of this Environmental and Social Review Summary and the associated Environmental and Social Action Plan (ESAP), in local language, in parallel to IFC’s disclosure. Contact details for the community engagement representative in SSL Bosnia are as follows:

Contact Person:Mr.Nihad Akeljic, Quality, Safety, Health and Environmental Manager
Company Name: SSL Bosnia
Email: mailto:nakeljic@sisecam.com
Phone: +38735552311
Facsimile: +38733552704
http://www.sisecam.ba

Broad Community Support is not applicable for this project

SSL Bosnia IV(37515) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
SSL shall engage with a third party expert to conduct E&S risk analysis and impact assessment of the neutralization project. This will focus on both the construction and operational phases and identification of the impacts on community health, safety and security and acceptable mitigation measures where necessary. (Condition of second disbursement).	31-Dec-2016	Completed	Completed	9/18/2017
Based on the third party’s findings and suggestions on the E&S risk analysis and impact assessment of the neutralization project; SSL shall develop and agree with IFC for mitigation plans (if any).	30-Jun-2017	Completed	Completed	9/18/2017
SSL shall update its E&S emergency response plans to include an annual evacuation / drill plan and provide a copy of the plan to IFC.	31-Dec-2016	Completed	Completed	9/18/2017
SSL shall develop and agree with IFC on a time based occupational health and safety improvement action plan to ensure that the LTIFR will be in line with good international industrial benchmark data of 3.5. The plan shall include a specific focus on behavioral safety as well as conditional safety improvements. (Condition of first disbursement).	20-Jul-2016	Completed	Completed	9/6/2016
SSL will ensure that, design specifications of the upgrade/renovation of boiler 7 project will be in line with local limits and the WBG’s EHS Guideline for Thermal Power values (including SO2) and provide IFC the design documents to confirm such.(Condition of second disbursement).	31-Dec-2016	Completed	Completed	9/18/2017
SSL will ensure that design specifications of the neutralization project will be in line with local limits and WBG’s EHS Guideline for Large Volume Inorganic Compounds Manufacturing and Coal Tar Distillation guidance values and provide IFC the design documents to confirm such. (Condition of second disbursement).	31-Dec-2016	Completed	Completed	9/18/2017
SSL shall commission a review of its security arrangements against PS4 requirements and develop a corrective action plan if necessary in order to bridge any identified gaps.	31-Dec-2016	Completed	Completed	9/18/2017
SSL shall develop a community engagement and consultation process for the new neutralization project to ensure that affected communities will be informed and their concerns will be addressed (if any) in the development of neutralization project.	31-Dec-2016	Completed	Completed	9/18/2017