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
Assan owns its existing plants and the recycling plant, which is adjacent to Assan’s Dilovasi Plant, was acquired on a willing seller willing buyer basis. Thus PS 5 Land Acquisition and Involuntary Resettlement is not considered applicable. The existing plants are not in the vicinity of sensitive environmental areas, nor within known historical and/or cultural heritage areas. Therefore PS6: Biodiversity Conservation and Sustainable Management of Living Resources and PS8, Cultural Heritage, are not applicable. There are no indigenous people in Turkey, thus PS7: Indigenous Peoples, is also not triggered.

This is a category B project according to IFC’s Policy on Social and Environmental Sustainability and in line with the previous Assan 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.

The project is expected to have positive environmental impacts as a result of waste recycling and improving energy efficiency.

The key E&S issues include: enhancement and implementation of Assan’s Human Resources Policy and procedures at the newly acquired recycling plant, occupational health and safety during the construction and operational phases, and point source air emissions.

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 / Policy: Assan has a corporate E&S management system in place, including a documented E&S policy and procedures for E&S impact and risk assessment, roles and responsibilities, safe working instruction, waste management, periodical controls and monitoring, emergency preparedness, internal audit and management review. Assan’s E&S system, which is applicable to all of its activities, is certified according to international standards, such as ISO 9001/16649, a quality management system, ISO 14001, an environmental management system, OHSAS 18001, an occupational health and safety management system and ISO 50001, an energy management system; these systems are generally aligned with IFC’s PS requirements as the Company enhanced the associated E&S systems following input from IFC’s as a result of the previous projects. Assan has also developed an implementation plan so as to ensure the E&S management system is applied to the recently acquired recycling plant and the system will be certified according to the same international standards.



Identification of Risks and Impacts and Management Programs: Assan’s E&S system requires all future project’s construction/installation and operational E&S impacts and risks to be evaluated. In line with this requirement, Assan evaluated E&S impacts and risks of the recycling plant prior to acquisition and developed a mitigation plan to manage the identified risks. The plan includes occupational health and safety improvements such as installation of exit signs and equipment guarding. For the other investments within the scope of this project which are at existing facilities, Assan has either conducted or is in the process of conducting E&S impact and risk assessments and based on these is either developing or will develop E&S mitigation plans to manage the identified risks.



Organizational Capacity and Competency: Each plant has its own E&S department consisting of 5 experts in total. There are also “agents” within each plant representing mechanical maintenance, electrical maintenance. R&D, the storage depot, dispatching, mechanical workshop, cast house, cold mill-annealing, sheet production, and foil production, who support E&S staff during daily site checks and monitoring of activities. The individual E&S departments report to Assan’s corporate Human Resources (“HR”) Director. There are full time medical doctors and nurses employed in each plant. A similar structure is being developed for the recycling plant where an expert, who is supported by the Dilovasi plant’s department, has already hired.



Emergency Preparedness and Response: Assan has documented emergency preparedness and response (“EPR”) plans including evacuation, fire prevention, first aid, and response to accidental release of chemicals. Assan worked with a third party life and fire safety (“LFS”) company to evaluate its risks and developed an improvement plan, which will be completed by the
end of 2016. The process equipment, including foil and sheet rolling machines, oil pumps, foil slitting and foil doubling equipment areas, hot/cold foil mills and painting lines are equipped with automatic fire detection and suppression systems. The fire/smoke detection and alarm systems are installed in the plants. Foam type sprinklers and carbon dioxide, argon and/or heptafluoropropane containing automatic suppressions systems are present within the process areas, lubricant/oil and paint storage rooms and in the offices. Assan has a 5 ton fire truck at the Dilovasi plant and each plant has around 50 trained fire fighters in its EPR teams. Mobile fire extinguishers and hydrants are inspected monthly by the E&S team. Emergency drills are performed three times a year. Some 15 small fires/sparks per year reported in the last three years and fire incident trend is reducing (19 in 2013 and 15 in 2015).



Monitoring and Review: E&S performance, including incident rates, scrap ratio, energy consumption of each department is shared on the boards within the production area. The Company score card included departmental incident rates which are reviewed weekly by plant managers. The overall plant performance is reviewed during the monthly E&S committee meetings with in each plant and reported to Assan’s senior management, where management reviews are conducted bi-annually.

Human Resources Policies and Procedures: Assan employs almost 593 employees in the Tuzla plant, 584 in the Dilovasi plant and 55 in the Dilovasi painting line operations. Approximately 15 personnel will be hired for the recycling plant operations. Contractor workers are referenced under “Workers Engaged by Third Parties” section below.



There is a corporate level HR policy and associated procedures in place at Assan, that relate to recruitment, training, performance evaluation, career development, terms of employment, Company rules and job descriptions, and these are generally in line with IFC Performance Standard 2 requirements. The HR policy and procedures are available to all employees either through the Company’s intranet or as employee handbook or both.



Working Conditions and Terms of Employment: Employees involved in actual plant operations work in three shifts per 24 hour cycle, whereas the administrative / office employees works during the week days and a maximum 45 hour per week is not exceed by any worker. All employees have written contracts where the working conditions, terms of employment, wages and benefits provided, working hours, overtime and annual leave are defined.



Workers’ Organization: Although there are no labor unions or collective bargaining agreements in place, according to Assan’s management, employees have the right to freedom of association by Turkish labor laws and have the opportunity to collectively represent to the management any issues that they may have.



Assan’s HR policy clearly states that the Company respects freedom of association and when the revised HR policy was revised to include this it was explained to Assan’s workforce through a program of training designed to raise awareness of the rights and responsibilities imposed on both the Company and employees by the HR Policy. Employee rights are also explained during refreshment trainings and/or through on boarding programs.



There are 4 workers’ representatives for employees in each plant. Workers’ representatives are selected by the employees by voting and representatives meet the HR department bi-weekly and with the respective General Manager monthly.



Non-discrimination and Equal Opportunity: Assan’s HR procedures cover aspects on equal opportunities and non-discrimination on race, ethnical origin, nationality, religion, age, gender and/or physical disability in line with Turkish labor laws requirements.



Retrenchment: Assan is not anticipating retrenchment as the business is growing but the possibility of a retrenchment given the market conditions cannot be excluded. Thus as per ESAP#1, if retrenchment is to occur, Assan shall develop and implement a retrenchment plan acceptable to IFC, in line with IFC’s Good Practice Note on Managing Retrenchment and PS2 requirements.



Grievance Mechanism: The Company developed a formal employee grievance mechanism where employees can directly raise concerns to their managers, to HR and/or use the
employee satisfaction survey. Contractor employees can use the same mechanism. Most of the grievances are related to catering and transportation services. As per ESAP#1, Assan shall however enhance its existing internal grievance system to allow anonymous reporting and communicate this requirement to employees.



Protecting the Work Force: The minimum age for employment is 18 years and there is no forced labor in line with Turkish labor laws.



Occupational Health and Safety: Assan’s existing E&S management system which is being implemented in all plants 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 manual handling, working with melted aluminum, hot works, use of personal protective equipment, chemicals safety, electrical safety, waste management, forklift safety, storage safety and near miss/incident reporting.



Health tests, including respiratory and skeletal system control, chemicals in blood, electrocardiogram, urine tests, liver controls and audiometry checks are performed annually.



As a part of new employee induction and periodic refreshment training, E&S topics such as site safety rules, use of work equipment (cranes, forklifts), welding, working in confined spaces, manual handling, emergency preparedness and response, chemical safety and waste management are provided to all employees. An E&S training plan, including mandatory minimum training of 16 hours per employee per year, is developed and implemented.



The lost time injury frequency rate (“LTIFR” – number of lost time injuries per 1.000.000 worked hour) has improved from 18.0 / 29.1 (Assan staff / contractor workers) in 2013 to 16.9 / 17.3 in 2015. However, LTIFRs are significantly high when compared to good international industrial benchmark of 6.5 (for alumina and alumina production and processing – http://www.bls.gov). The most frequent types of accidents are injuries to hands and arms (cutting, pressing/squeezing). No fatalities have occurred since 2007. The last significant incident which resulted in a permanent disability was recorded in 2013 at the Tuzla plant when an employee lost his hand. The employees has since returned to work at Assan to work in another department. The Company has a target for reducing LTIFR to 10 in 2016 and has started a project called the “Life Safety Project”. The project has a special focus on behavioral safety. A third party consultant is retained for training activities and behavioral safety observations has started. As per ESAP item#2, Assan shall developed and implement a detailed occupational health and safety management plans per each plants, acceptable to IFC, to ensure that lost time injury frequency rates will be improved so as to align accepted industry benchmarks.



There is a near miss reporting system in place where employees can complete a form and submit this through mail boxes. Near miss reports are revie
wed by E&S department and corrective actions are planned as necessary and progress is reviewed during monthly E&S committee meetings. There is an incident investigation system, which includes investigation of the root causes of the work injuries and fires.



In the last three years and as a result of the implementation of the E&S management plans, the occupational conditions have improved at the plants with equipment guarding being installed allied to the elimination of slippery areas which could result in falls. The manual handling of melted metal is very limited and necessary safety measures, including use of proper personal protective equipment, are taken. Safe walking ways, emergency exits and hazards are clearly marked. Housekeeping is generally adequate.



Workplace monitoring program includes drinking water analysis, workplace noise measurements, workplace air quality monitoring, thermal comfort (temperature, humidity) and light intensity measurements. Results, which are in line with local legislations and WBG’s relevant EHS Guidelines guidance values, are reviewed during monthly E&S committee meetings and corrective measures are taken as necessary.



Workers Engaged by Third Parties: There are almost 65 contractors workers in Assan across all operations. Contractors provide services including cleaning, loading and catering. There are contractual requirements referring to Turkish E&S laws and they include clear covenants to ensure that contractors will follow Assan’s E&S management system requirements. The contractors’ who may provide mechanical / civil work and installation services for the project will have the same contractual requirements. Compliance, including PS 2 requirements, is monitored by Assan’s E&S staff, “agents” during daily site tours and / or by security guards at the entrance (such as social security allowance, restriction of child labor/forced labor). In the recycling plant, Assan may convert some external scrap aluminum, which will be provided from aluminum producers / licensed waste collectors. As per ESAP item #3, Assan shall develop contractual E&S requirements for its external scrap aluminum providers, in line with PS2, including restriction of use of child labor / forced labor in their processes.

Resource Efficiency / Energy and Material Efficiency Projects: The main energy source is natural gas and electricity provided through national grid. Assan has implemented several resource efficiency programs since IFC’s first investment. In 2012 and 2013 third party energy audits were conducted in the Dilovasi and Tuzla facilities respectively. The audit findings are developed into projects and relevant studies are started in 2015. As a result, total energy consumption has dropped from 1088 kWh/ton aluminum (“ton Al”) to 966 kWh/ton Al (for cast coils - almost 12 percent improvement), from 330.5 kWh/ton Al to 315 kWh/ton Al (for coil annealing furnaces – almost 5 percent improvement) however, it is increased from 191 kWh/ton Al to 199 kWh/ton Al (for foil annealing furnaces – almost 4 percent increase). A further 4 to 5 percent reduction is expected as a result of activities to implement as result of this new investment.



The products are produced via ingots (80 percent) which are imported, and recycled material (20 percent). Acquisition of the new recycling plant will enable Assan to produce almost 30 percent of its own raw material (“ingots”) from scrap.



Water: Assan’s production processes are not water intensive and mainly used for cooling purposes via a closed circuit system.



GHG Emissions: The main source of greenhouse gas (“GHG”) emissions are from the natural gas fired process furnaces and electricity usage of the plants. Assan’s overall GHG emission is estimated to be around 130.000 ton per annual (“tpa”) equivalent carbon dioxide (“eqv CO2”) and with the completion of the project activities, it is estimated to be around 146.000 tpa eqv CO2.



Indirect GHG emission reduction is estimated based on comparison of emission for primary aluminum production with emission from recycled material. New investment including multi-chamber installation would reduce/avoid 77,000 ton of CO2 annually.

Pollution Prevention

Air Emissions and Ambient Air Quality: There are almost 160 air emission points in the Assan plants. Air emissions are within the national limits for particulate material (“PM”), nitrogen oxide (“NOx”), sulphur dioxide (“SO2”), carbon monoxide (“CO”), hydrogen fluoride (“HF”), chloride (“HCl”) and volatile organic compound (“VOC”). However, in the Dilovasi plant, NOx emissions from the melting furnaces were reported to range from 170 mg/Nm3 to 736 mg/Nm3 and exceed the WBG’s EHS Guideline for Base Metal Smelting and Refining guidance values of 150 mg/Nm3. NOx emissions from the melting furnaces in Tuzla plant, where the same production processes are in place, reported NOx emissions to be ranging from 12 mg/Nm3 to 108 mg/Nm3. As per ESAP item#4, Assan shall review its nitrogen oxide (NOx) emission measurements for the Dilovasi plant and develop a plan, acceptable to IFC, to facilitate use of good international industrial practices including use of low NOx gas burners, use of oxidizing scrubber and / or use of oxy fuel burner
s to ensure that NOx emissions are in line with relevant WBG’s EHS Guideline’s guidance values (if necessary).



As per ESAP item #5, Assan shall review air emission measurements for the recycling plan and develop a plan, acceptable to IFC, to facilitate use of good international industrial practices to ensure that air emissions are in line with relevant WBG’s EHS Guideline’s guidance values (if necessary).Wastewater Treatment: In the Dilovasi plant and Dilovasi paint line both domestic and process wastewater is disposed to the collection network of the industrial zone’s licensed treatment facility. The effluent quality of the industrial zone’s treatment plant is monitored by local authorities and is in line with the local limits. The new recycling plant will discharge its domestic and effluent process wastewater to the same collection network.



The Tuzla plant’s process wastewater and sanitary wastewater are treated in Assan’s biological and chemical wastewater treatment plant (“WWTP”). The treated effluents are discharged to the municipal sewer, managed by the Water and Sewage Administration of Istanbul Metropolitan City (“ISKI”), and comply with ISKI’s relevant discharge limits and the WBG’s General EHS Guideline guidance values.



Storm water is collected separately at all facilities and discharged via the municipal storm water collection systems.



Solid Waste Management: As a part of its existing E&S management system, Assan has a waste segregation system in place where recyclable wastes, such as plastics, cardboards and waste lubricants/oil are recycled by third party licensed waste companies. Hazardous wastes, including waste paints and solvents, lubricant packages, are disposed by licensed waste disposers. The Tuzla plants WWTP sludge is disposed in a licensed landfilled area.



With completion of the project, Assan will be recycling all of its aluminum waste in its recycling plant and convert this for use in its own production processes. In this regard the project includes installation of the dross presses, which will enable Assan to recycle its dross wastes. The investment in new recycling plant will result in increasing the share of external recycled scrap from 0.1% to 11.0%.



Hazardous Materials: Hazardous materials include lubricant/oil used in the production and some maintenance and cleaning chemicals as well as generator fuel. 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.



As per ESAP item# 6; Assan shall developed a process of screening of wastes to ensure that no hazardous materials are accepted at the recycling plant / enter the furnaces.

Community Health and Safety: Dilovasi plant, Dilovasi paint line and recycling plant are located in Dilovasi Industrial Zone, located away from the communities, however, the Tuzla plant is located in proximity to residential areas.



The existing ERP plans included communication with the local authorities during emergencies.

Raw materials and products are delivered via trucks, generally by Kibar’s transportation companies, where there are documented safe driving procedures and ERP plans for spills in place.

The plants are within the vicinity of a known earth quake zone and are enforced in line with the suggestions by the third party seismic experts after the 1999 earth quake which affected the project locations.



Security Personnel Requirements: Security functions are covered by Assan employees. Security staff are unarmed and are trained in the use of force for defensive purposes only. Criminal checks as well as psychological tests are included as a part of pre-employment and periodical health controls.

As the project involves installation of the equipment within the existing plants and as the recycling plant was operational, no detailed consultation process was implemented. As a part of its E&S management systems, Assan has established an external grievance mechanism to address community concerns about the possible adverse impacts of their operations and control measures in place. This will be extended to the new recycling plant. No complains / grievances have been raised from non-governmental organizations (“NGO”) and/or by the community in the last three years.

Assan has a Public Relations Committee which develops an annual program to support educational institutions, medical facilities and families who are in need of financial aids, provision of internship and sponsorship opportunities, interactions with national NGOs and the public, and support to volunteer activities. The Company is an active member of Aluminum Manufacturers’ Foundation of Turkey (TALSAD).

This Environmental and Social Review Summary, and the associated Environmental and Social Action Plan may be viewed at Dilovasi and Tuzla plants which are located at:

Contact Person: HAKAN YAŞA
Company Name: ASSAN ALUMINYUM SAN. & TIC A.S
Address: YAYLA MAH. D-100 KARAYOLU RUYA SOKAK NO:2 34940 TUZLA/ISTANBUL/TURKEY
Email: mailto:Hakan.yasa@assanaluminyum.com
Phone: +90 216 581 1473
Facsimile: +90 216 581 16 32

Broad Community Support is not applicable for this project

Assan-VII(37550) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
Enhance the existing HR policy and procedures to ensure coverage of all PS2 requirements. This will include, but not limited to; a) Development of a retrenchment plan (which will be implemented if a retrenchment will occur), acceptable to IFC, in line with IFC’s Good Practice Note on Managing Retrenchment and PS2 requirements; b) Enhance the existing internal grievance system to allow anonymous reporting and communicate this requirement to employees.	31-Dec-2016	Completed	Completed	9/8/2017
Develop and implement detailed occupational health and safety management plans per each plants, acceptable to IFC to align lost time injury frequency rates with industry benchmarks for such.	30-May-2016	Completed	Completed	4/29/2016
Develop contractual E&S requirements for its external scrap aluminum providers, in line with PS2, including restriction of use of child labor / forced labor in their processes.	30-Jun-2016	Completed	Completed	6/30/2016
Review its nitrogen oxide (NOx) emission measurements for the Dilovasi plant and develop a plan, acceptable to IFC to facilitate use of good international industrial practices including use of low NOx gas burners, use of oxidizing scrubber and / or use of oxy fuel burners to ensure that NOx emissions are in line with relevant WBG’s EHS Guideline’s guidance values (if necessary).	30-Jun-2019	Completed	Completed	5/9/2019
Review air emission measurements for the recycling plan and develop a plan, acceptable to IFC, to facilitate use of good international industrial practices to ensure that air emissions are in line with relevant WBG’s EHS Guideline’s guidance values (if necessary).	31-Dec-2016	Completed	Completed	5/25/2017
Developed a process of screening of wastes to ensure that no hazardous wastes are not accepted at the recycling plant / used in the furnaces.	31-Dec-2016	Completed	Completed	5/25/2017