There are no foreseen greenfield developments or physical expansions of the terminal required for the current project. The installation of additional equipment for capacity increase will take place within the existing footprint of the terminal. As such, there will be no physical or economic displacement of people and involuntary resettlement. Similarly, no impacts on biodiversity are expected. There are no indigenous peoples in the project area of influence. The port area is in the vicinity of some cultural heritage sites, but no impacts are expected as no construction or expansion activities are planned.  As a result, there are no risks and impacts related to Land Acquisition and Involuntary Resettlement (PS5), Biodiversity Conservation and Sustainable Management of Living Natural Resources (PS6), Indigenous Peoples (PS7) or Cultural Heritage (PS8).  

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.

 In accordance with IFC’s Policy on Social and Environmental Sustainability, the project is assigned Category B because a limited number of specific E&S impacts may result, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Key E&S issue and risks associated with the project include: (i) the company’s operational E&S management and monitoring systems and capacity; (ii) management of labor and working conditions, and operational health and safety (OHS) procedures including contractor workforce; (iii) terminal traffic management; (iv) the impact of the project operations on the nearby communities’ health, safety and security.   

 Asyaport has an operation phase environmental, health, and safety management plan (ESMP) in place that includes procedures meeting the commitments set out in the Turkish EIA that was prepared before construction of the terminal, the Concession Agreement, Turkish regulations, particularly with respect to MARPOL 73/78, as well as PSs and relevant sections of the applicable WBG EHS Guidelines. The ESMP includes waste and wastewater management plans, an emergency response plan, OHS procedures, traffic management plan, and noise, dust and illumination monitoring. The terminal has implemented ISO 9001 (quality), ISO 14001 (environment), OHSAS 18001 (occupational health and safety) certified management systems. The terminal additionally has ISO 50001 (energy) and SR10 (social responsibility) management certificates, as well as Greenport certificate from Turkish authorities and Ecoports PERS certificate from Lloyd’s Register.

The Turkish Occupancy Permit of the Port places a broad requirement on the terminal to put in place the necessary measures to prevent environmental and marine pollution during the period that the property is being used (until 2058). The project is currently compliant with relevant local legislation. Additionally, adjoining land is under the ownership of the Turkish Republic, particularly the coast and its beaches which are accessible to the public. The environmental, health and safety and social responsibility policies of Asyaport are aligned with PS1 and disclosed on company website: http://www.asyaport.com/en-US/intagrated-management-system/1255870.

The project does not require any permit or approval from environmental authorities according to national legislation for the additional equipment to be purchased.

EHS monitoring of operations vis-à-vis the applicable regulatory requirements and company policies is done periodically. The monitoring parameters include lost time incidents and related statistics, workplace conditions, trainings, solid and hazardous wastes, recyclable wastes, resource use etc. However, review and oversight of senior management over the E&S monitoring process is limited and rests on sponsor’s EHS site audits once per year. As per ESAP item 1, Sponsor’s oversight and EHS auditing of terminal will be increased by way of site visits on semi-annual basis and periodic review of EHS aspects by the Board, commensurate to project’s performance.

The company has an EHS team composed of environmental, quality, health and safety on-site specialists and off-site consultants. While the team is composed of qualified staff, there is a need for increased corporate senior guidance in enforcing site level EHS procedures and requirements on employees and contractors and liaising with company management on needed actions for prompt implementation. As per ESAP 2, the sponsor will strengthen terminal’s EHS implementation and monitoring capacity by appointing a senior EHS advisor to support the team in strengthening daily on site EHS supervision in line with international good practices, preparing corrective action plans, and ensuring timely implementation and monitoring reports for the management.

There are several training programs in place offered to Asyaport staff and contractors, including training on environmental management, first aid, health and safety, working at height and International Maritime Dangerous Goods Code.    

 As of September 2019, Asyaport has 491 direct employees and 239 contractor employees working in three shifts 24 hours per day. The company’s two main permanent contractors, Cetin and Serinoglu, both well-established companies in Tekirdag, provide security, catering, cleaning, drivers and operational support (e. g., lashing/unlashing, maintenance). Blue-collar workforce in the terminal are all male, while the company has a better representation of women in white-collar and management positions, although not exceeding 10%. Asyaport has a human resource (HR) policy and accompanying procedures, aligned with PS2, that are publicly available on its website: http://www.asyaport.com/en-US/human-resources-policy/1255913  Each employee is provided with a contract outlining the terms and conditions of their employment including, but not limited to, payments, working hours, rest periods and leave, benefits, overtime, disciplinary procedures.

There are no labor unions representing workers at the project; however, Asyaport does not discriminate against those who wish to belong to unions as per their HR policy. Asyaport developed a functioning worker grievance mechanism, that also allows for anonymous filing, in line with PS2 and appointed a contact person to monitor and track grievances. The company also provides other platforms for workers to express their concerns and expectations regarding working conditions.  

The company has well-established OHS procedures in place, coordinated by the EHS team. The team prepares an annual OHS action plan that includes periodical checks, meetings of OHS committee, maintenance and measurement activities, and risk assessment reports. Asyaport’s accident reporting system includes determination of root causes and corrective actions for lost time accidents as well as near-miss reporting. Lost Time Injuries Frequency Rates (LTIFR) at the terminal for 2018 is 26.48. This is below the national average but significantly above international benchmark (12.5) for the sector. The LTIFR is higher among contractor workforce assigned in lashing/unlashing work and the accidents were mainly related to hand-injuries. Asyaport is currently working on an action plan based on a review of hand injuries statistics, identification of common root causes, and an analysis of available PPE and its use while identifying additional PPE needs and exploring alternative PPE features.  The action plan calls for the development of daily site OHS inspection plans and enforcement measures; and for providing on the job and visual trainings on safe working instructions for high-accident prone areas (manual transportation, lashing/unlashing, etc.). It is noted that contractor workforce has a high turn-over rate and a lower skill level, which have an impact on the effectiveness of OHS trainings provided and require a higher level of supervision. Daily OHS supervision and inspections on site have not been sufficient, and Asyaport has recently hired an additional OHS specialist to be assigned for this work. As per ESAP 3, Asyaport will develop a framework for monitoring and reducing non-compliance situations with OHS procedures and injuries among the contract employees.  The framework will include measures such as but not limited to: developing site supervision plans and enforcement measures; reviewing selection criteria and retention measures for qualified lashing/unlashing workers; setting key performance indicators (KPIs) for the results of the program; and developing additional actions as needed to reduce substantially lost-time accident rates.

There is a management plan for the traffic within the port, which was prepared by the operations team. The plan established a one-way traffic system throughout the terminal area to avoid any head-on collisions. All truck drivers are provided with relevant instructions on traffic management at the entrance gates and they are required to comply with the Port Safety Instructions that include behavioral and safety measures, such as non-smoking, prohibition of alcohol, wearing of PPEs, respecting pedestrian lanes, seat-belt wearing requirements etc. The terminal traffic management plan defines specific pedestrian zones; enforcement is challenging and violations were observed.  In addition, ground marking of traffic lanes, pedestrian lanes, signage, enforcement of seat belt use (by 3rd party drivers as well as Asyaport personnel) and compliance with speed limits are areas of improvement identified during the review. Asyaport has started to implement relevant corrective actions which include improving the identification of the pedestrian lanes, improving warning signs (traffic routes, no vehicle access, no pedestrian access and maximum speed limits), training of security guards to monitor and enforce traffic management plan through CCTV and walk through, and seat belt use enforcement. These measures need to be enhanced by implementing seat belt controls at the port gates and retrofitting of seat belts for the drivers of the existing container carriers at the. As per ESAP 4, Asyaport will implement the required actions to improve port traffic management and safety, including regular monitoring reports, inspections and additional actions required for seat belt compliance, and will provide IFC with the relevant completion report.

Asyaport is undergoing periodical external audits on labor compliance and occupational health and safety by the Ministry of Labor and Social Security. The most recent audit carried out in 2018 did not identify any non-compliances. Asyaport is also being audited under SA8000 (social accountability) certification protocols, comprising labor compliance, working conditions and corporate social responsibility (CSR) policies.

Asyaport’s HR policy includes commitments on non-discrimination and equal opportunities. Additionally, the employee code of conduct prohibits any violence, harassment or treats; violations are sanctioned through disciplinary procedures. These policies are all part of workers’ inductions. Asyaport has a grievance mechanism generally consistent with PS2, that allows any harassment related grievances to be communicated anonymously,  but there is no specific procedure to handle harassment related grievances. As per ESAP 5, Asyaport will develop and implement an equal opportunities action plan including: providing specific training to grievance officers and general awareness to employees on harassment and bullying; updating the grievance mechanism to include specific treatment of harassment/gender-based violence grievances; engaging with female employees on their concerns regarding transportation and safety; and exploring opportunities for hiring more women in port operations.  

 Asyaport measurements of dust, NO2, SO2 emissions, noise and vibrations are in overall compliance with local regulatory limits and aligned with the relevant guideline values as defined in the relevant sections of the WBG General EHS Guidelines and the WBG EHS Guidelines for Ports, Harbors, and Terminals.

Solid waste is currently segregated on site, with scrap metal being sold to dealers and wastepaper being given to collectors. Tires are collected by a specialized, licensed waste management company. The remaining wastes are given to the Municipality of Barbaros. Asyaport has a waste management plan for operation. The terminal has a temporary solid waste facility for the storage of solid waste coming from vessels, before they are transferred to the Municipality of Tekirdag for disposal.

Hazardous materials comprise oils and lubricants, paint, thinners and polishes used for maintenance purposes. Hazardous materials are stored in suitable areas, are inventoried, properly labeled, and material safety data sheets (“MSDS”) posted nearby. Staff awareness about the handling of these materials are improved through trainings on Maritime Dangerous Goods Code. Waste oil is removed by a specialized waste management firm.

Asyaport has a Hazardous Materials Management Plan and Oil Spill Response Plan. There is no bulk storage or transfer of hydrocarbons on site. There is spill equipment on site and the company has entered into a contract with a specialist firm to provide oil spill response support.

In addition to possible spills, a risk is posed by the handling of containers loaded with dangerous materials. The project has a dangerous goods management plan and implements training to ensure proper implementation of site. Furthermore, any dangerous cargo at the port is required to be cleared in advance with the Port Authority and is also verified by X-ray controls of Customs Authorities on site.

Asyaport’s emergency response plan includes a fire fighting plan. Proper fire-fighting equipment is available on site. The plans have been developed in coordination with the local authorities, such as the Tekirdag Fire Department and the Port Authority.  No emergency accidents/incidents or spills have occurred at the terminal since operations started in 2015.

Domestic sewage is sent to a buried septic tank, which is emptied by a contractor. Company also monitors wastewater from the catering contractor on a monthly basis.

A wastewater treatment plant, operated by a third party, is in place to handle effluent from the terminal’s facilities, but also to handle ship-generated sewage. The treated effluents from the wastewater treatment plant are discharged into the local municipal sewage network.

MSC cargo ships generally have onboard waste treatment facilities and use strategically located waste management facilities, the closest of which is in Malta. Bilge water is run through an oil separator before being sent to a storage tank. The separated oil and water are then taken off-site for disposal by a licensed contractor.

The terminal has a stormwater drainage system to reduce possible risks on water quality and provide spill control and containment, through oil and sediment separation from the stormwater drainage.

Non-potable water for domestic use is sourced from the municipal water system. Potable water is sourced from bottled water.

No dredging is required for the project as the new equipment will be installed within the existing footprint of the terminal.

As per ESAP 6, Asyaport will improve waste monitoring in the terminal through the following actions: developing waste monitoring procedure and relevant template to record all types of waste streams, their storage, handling, and final disposal/recycling in compliance with national and international requirements; and performing periodic audits of waste management contractors, to ensure they operate in compliance with local requirements and consistent with the relevant provision of this Performance Standard.

Most of the equipment used during operations are electrical, with electricity supplied through the existing power grid. A 6 MW gas-fired generator supplies back-up power.

The terminal is studying the possibility to feed in directly electricity to berthed vessels (“cold-ironing”), so they will not be contributing to air emissions. Vehicles will continue to use Euro diesel during operation. The company monitors, under the EHS monitoring plan, its use of diesel and other fuels, as well as the electricity taken from the grid. The project does not report on GHG emissions as the emissions are below 25,000 tons of CO2.

There is a 40-45 m buffer zone between the end of the terminal and the nearest houses, where no containers are stored. Noise is monitored, as is typically required for environmental permits in Turkey. Truck movements in and out of the port follow a Traffic Management Plan (see PS4).

Lighting, dust and noise from the terminal area can have an impact on surrounding residential receptors, some of which are exposed to them from their location on a nearby cliff. These parameters are being periodically measured and measurements available are in compliance with the applicable and relevant national limits. Some community complaints were recorded in the past regarding disturbance from the back-up reverse driving beepers or alarms installed on cranes during night-time; the company addressed these concerns by reducing the volume of the alarms.   

 The company is mitigating community health and safety risks through their management system.  A beach area to the west of the terminal site has been built up as construction progressed.  It is surrounded with  houses used during summer months.  Local authorities have prohibited any ships to use or transit this side of the port to protect the communities / users of the beach from health and safety risks. Currently there are no clear barriers or passage control between the port berths and the beach, but Asyaport has in place a surveillance system for all areas around the quay through CCTV 24 hours to avoid any trespassing. As part of its CSR and community engagement activities, Asyaport carries out periodic beach cleaning / waste picking-up with participation of its own staff as well as cleaning of the swim area.

As noted, the terminal is primarily (80%) for the trans-shipment of containers rather than import into Turkey and it will stay as such after the capacity increase. Thus, truck traffic associated with the project is expected to be limited. For transloading activities, Asyaport is currently using a Municipal road that passes through villages to connect to the highway and will start to use the highway extension once it’s completed by the General Directorate of Highways (expected for mid-2020). The land adjacent to this highway extension is not intensely populated; few houses and agricultural fields are located nearby.

The company, in collaboration with local municipal authorities, has developed a traffic management and routing plan applicable to all export, import, contractors and suppliers. The plan is also enforced by local authorities through inspections and check points around the port area and within the city of Barbaros.

Asyaport employs security guards through a contractor (Cetin) under supervision of an experienced security manager directly hired by Asyaport. Patrolling security guards are unarmed. A site security management plan is in place; security guards are trained in technical, operational procedures as well as communications and human rights principles in alignment with UN Voluntary Principles. Disciplinary processes of Asyaport apply to all security guards for any violations. Both community and worker grievances mechanisms are in place to capture such concerns.  

 Asyaport has periodic interaction with communities through its CSR activities focused on sea and beach cleaning, university engagement, local hiring and procurement, as well as through its grievance mechanism and public information activities.

Asyaport implements an external grievance mechanism, accessible through its website, e-mail, phone or face-to-face: http://www.asyaport.com/en-US/suggestions-and-complaints/1255925.

The project has a stakeholder engagement plan in place, including an analysis of stakeholders and engagement methods. The plan does not include important stakeholder groups such as truck drivers, surrounding communities, etc. This plan needs to be updated for operations to match possible stakeholder concerns and risks that may arise due to planned capacity increase at the port. As per ESAP 7, Asyaport will undertake an update of its Stakeholder Engagement Plan. These updates shall include a) stakeholder mapping; b) strengthening the community grievance mechanism and increasing awareness of the affected communities, including the ones affected by the new access road construction and operation, c) engaging with relevant government authorities to install floating barriers and warning signs on the beach side near the terminal quay , d) engaging with truck drivers and developing safe driving awareness campaigns. 

 Contact Person: Özlem Bentürk

Company Name: Asyaport Liman A.S

Address: Barbaros Mahallesi Denizciler Sokak No :10 Süleymanpasa /TEKIRDAG

Email: obenturk@asyaport.com

Phone: 0533 328 40 79

Facsimile: 0282 273 19 29