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 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 – Cultural Heritage

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

PS 5 – Land Acquisition and Involuntary Resettlement
In accordance with the last plans provided by the concessionaire, no land acquisition will be required for imminent works, as all upgrade and expansion will be undertaken in the current concession areas. As part of the E&S management system, the concessionaire will develop a land acquisition and livelihood restoration framework (LALR) that will highlight principles and responsibilities that will guide land acquisition for future works or any other scenario where land is required. The LALR is specified under PS1.

PS 7 – Indigenous Peoples
No indigenous peoples are present in the areas surrounding the project site.

The appraisal has confirmed this to be a category B project, i.e. business activities related to existing, operational assets 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 appraisal has assessed that none of the fourteen airports across Cluster A and B is associated with any known complex or unresolved E&S issue and for the risks that have been identified, the client E&S management system and the agreed E&S Action Plan (ESAP) provides appropriate mitigation. As indicated above, no increase of physical footprint to accommodate expansion or modernization is currently planned at any of the 14 airports. The concession agreement also addresses E&S risk, particularly with regards to historic liabilities e.g. soil contamination. In such cases, Fraport Greece will either be indemnified against pre-existing conditions or compensated for the cost of mitigation.

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

E&S aspects of operations at the fourteen airports across Cluster A and B are being assessed and will be managed primarily through the systems that Fraport Greece is establishing, although the terms of the concession agreement recognize the state’s responsibility toward pre-existing conditions, such as soil contamination. Fraport Greece will either be indemnified against these or can claim compensation for the cost of their mitigation. Claims need to be submitted within three years from the Concession Commencement Date (CCD), estimated as on or around January 31, 2017



Policy

At a corporate level, Fraport has a well-established E&S policy framework which is publicly available through their website. These include adherence to the ten principles of the UN Global Compact and the ILO Core Labor Standards, with associated Fraport codes of conduct on implementation for both employees and suppliers. Fraport also publishes an integrated financial and sustainability report and reports against the G4 framework of the Global Reporting Initiative (GRI).



Fraport Greece has developed a series of linked, complementary policies to the corporate structure, including an over-arching environmental policy and specific ones addressing water use; energy efficiency; wastewater management; solid waste management and biodiversity. These are currently in draft (with the majority of other E&S management system components), with an expectation that they will come into force in the first three months of the concession period (see ESAP # 1).



Identification of Risks and Impacts

As part of their own due diligence, the concessionaire has undertaken survey work to inform themselves of the current environmental baseline at each airport. This will allow them to both negotiate with the state regarding indemnification or compensation for existing liabilities and plan for ongoing operational management from CCD (see Environmental and Social Assessment and Management System). ESAP #3 will ensure that the environmental baseline is completed in accordance to lender requirements, including the use of the WBG EHS Guidelines for Airports as a reference.



A social baseline for each of the airports has not been commissioned to date: this is addressed in ESAP # 3 and to include (at site level): local demographics; current employment statistics; number of people employed at each site; seasonal occupancy (e.g. residents vs tourism) in area impacted by airport operations; perceived community needs / expectations from the project and identification of disadvantaged or marginalized groups. It is anticipated that the baseline can be completed as desk-based assessment relying on published data sources including recent census data and the consultation undertaken to date by the concessionaire.



As indicated in the project description, Fraport Greece is taking over operational assets and with no current plan to expand th
e overall physical footprint at any site to accommodate expansion or modernization. The existing operation of the airports are permitted and controlled by the government from an E&S perspective through provision of ‘Environmental Terms’ (ET) that are standards to which the airport operating company must adhere and are based on the environmental baseline conditions (as reported in the original EIA prepared for each site as part of the initial ET permit application process). Modification dossiers can be prepared and submitted to extend the duration of the ET or to make amendments in the event of changes being made to site operations. Where changes are being made with significant environmental and social implications, a new EIA could be requested. The concessionaire is currently working through the ET for each airport, ensuring that they are current (some modification dossiers have been pending approval for several years and other are due to expire at the end of 2016) and that they reflect Fraport Greece as the operator. The completion of this process is addressed in ESAP # 4 together with the need to consolidate the findings of the baseline studies and ET requirements into an E&S assessment document that can inform management plans. The assessment will consider both imminent works and proposed changes to operating schedules and hours (of particular importance to the social baseline).



ESAP # 9 addresses the potential for future construction/expansion (beyond the scheduled imminent works) and the need for such activity to be assessed and managed in accordance with the requirements of PS1.



In order to accommodate changes in design that would require additional land take, the concessionaire will develop a land acquisition and livelihood restoration scoping (LALR) document that will highlight principles and responsibilities for land acquisition, including private sector responsibilities under government-managed resettlement. The LALR will identify the main gaps between the Fast Track Law (3894/2010) and IFC Performance Standards and how these will be addressed. The LALR will then inform the site specific land acquisition and livelihood restoration plan if this becomes a reality at any of the 14 sites. These requirements are addressed in ESAP # 4.



Management Programs

As described above, Fraport Greece will be taking over operational assets that are currently being managed to meet operational permit requirements under Greek legislation, with ongoing E&S assessment providing details of gaps between current performance benchmarks and those required by IFC/the lender group.



Fraport is a successful airport operating company which has extensive experience of implementing appropriate environmental and social management systems in line with both local and international standards (see Policy). At the corporate level, Fraport is committed to third party certification for environmental management (ISO 14001, EU Eco Management and Audit Sc
heme), although a target deadline for Fraport Greece has yet to be set. Ahead of CCD, Fraport Greece is developing specific management policies for a broad range of E&S topics (see Policy): these will be operationalized via site level plans and procedures and this requirement is addressed in ESAP # 2. An E&S ‘roadmap’ drives this process, including organizational structure and budget. Continuation (and review and update) of this approach is addressed by ESAP # 1. . Provision of adequate budget for E&S management within the financial model is addressed in ESAP # 5. For airports with planned construction works, ESAP # 6 requires the development of a Construction Environmental Management Plan (CEMP) to include all mitigation measures identified during the impact assessment process.



Organizational Capacity and Competency

Fraport Greece has assigned overall management responsibility for environment to an environmental manager, health and safety to the human resources manager and social to the CSR/public relations manager. Once the concession period starts, day to day operational E&S management at each airport will be assigned to two coordinators, although the ultimate responsibility will reside with the airport manager. Demonstration of adequate capacity and competency at both Fraport Greece and airport/site level is addressed in ESAP # 5.



Emergency Preparedness and Response

Many of the existing emergency preparedness and response plans (EPRPs) at airport level are out of date or do not provide adequate detail. Fraport Greece is therefore developing a new EPRP framework, which is scheduled to be drafted before CCD. The framework will consider emergency scenarios with the potential to influence up to an 8km radius from the airport boundary. Work to date has already indicated the need to increase the number of firemen available to respond at each site. See PS4 for further details.



Monitoring and Review

A budget for operational E&S monitoring has been entered into the financial plan, with its adequacy determined by the outcome of the various assessments, planning and review process described previously. Fraport corporate monitoring requirements (to inform its GRI reporting commitments) will also be applied to Fraport Greece. The demonstration of adequate capacity and competency (see above) will also include management review.



Due to the large number of sites and the diverse lender group, a lender’s technical advisor (LTA) will be appointed and their scope of work will include E&S monitoring. The LTA appointment will be captured in the investment documentation. It is anticipated that the LTA contract will be in place for duration of the imminent works phase (and then the need for continuation will be reviewed).

Human Resources Policies and Procedures

Fraport Greece has established a human resources (HR) department with the mandate to oversee the development and implementation human resources policies and the recruitment process at both headquarter and operational level. The concessionaire finalized a social policies ‘roadmap’ that will drive the development of policies, procedures which will be consistent with Greek labor legislation, Fraport’s corporate policies and ILO standards as addressed in ESAP # 11.



To date, a code of conduct has been prepared and four social policies (labor working policy, grievance policy, human resources policy and disciplinary policy) are available in a draft form; once finalized, they will included into employment contracts and clearly communicated to all workers before the commencement of the employment.



The concessionaire will set up a corporate grievance procedure that will be rolled out on a phased manner on the airports after CCD. At site level, airport managers will be the main channel to receive and address concerns from employees and third partiese.g contractors, passengers and communities (see ESAP # 7). Each airport manager will be also responsible of maintaining and updating grievance level and inform the corporate HR department about status and closure.



Working Conditions and Terms of Employment

Fraport Greece estimates that approximately 350 Hellenic Civil Aviation Authority (HCAA) employees are currently performing the services that would become Fraport Greece’s responsibility at the 14 regional airports.



Since early 2016, Fraport Greece started to implement its HR strategy and staff critical positions, with a target of 80% recruitment of such before CCD. The working and labor conditions policy outlines principles that are consistent with national legislation and PS2 requirements.



Workers’ Organizations

Fraport Greece’s code of conduct (CoC) recognizes workers’ rights to form and join association without any interference and to bargain collectively. The CoC is an integral part of the employment agreement and each employees receive a copy as part of their employment contract.



Non-discrimination and equal opportunities

At corporate level, Fraport has well established policies referring to commitments on diversity and non-discrimination in respect of human rights, cultural, ethnic, social, political affiliation and workplace diversity. Fraport Greece will develop comparable procedures for its employees that will be implemented in each airport within the timeframe instructed in ESAP # 11.



Retrenchment

Fraport Greece are seeking to recruit HCAA workers who are willing to join under new contractual terms and clauses. According to Fraport Greece, there is no retrenchment currently planned as current HCAA employees who are not willing to accept positions with Fraport Greece retain employment rights within the public sector.



Since August 2016, the concessionaire has been engagi
ng HCAA employees in relations to job opportunities after the takeover of the concession. Draft terms and conditions of new contracts have been explained and new job profiles have been presented. A special section for current HCAA employees has been created on Fraport Greece’s website to facilitate the application process of employees who are willing to join the new organization.



If a large number of HCAA key staff choose not to take up employment with Fraport Greece, then airports may experience a shortage of staff that could inhibit operations. To mitigate this risk, the concessionaire will monitor any potential gaps during the staffing campaign up to CCD and will start an ORAT (organizational readiness activation and transition) training to upskill new workers on safe execution of new roles on sites. Fraport Greece will also develop an employment plan in consultation with HCAA that will map out the transition from one workforce to another (see ESAP # 10).



Occupational Health and Safety

The EHS management systems roadmap that guides Fraport Greece’s work includes the development of an OHS plan ready for operation at CCD. This will include the good international industry practice and performance benchmarks required by the lender group, including WBG EHS Guidelines for Airports.



Current occupational health and safety issues associated with the 14 airports operation primarily include noise (taxiing aircraft, auxiliary power units), physical hazards (baggage/cargo handling) and chemical hazards (fuel handling, maintenance). During site visits, a number of improvements to OHS (e.g. slip/trip hazards, signage, machine guarding) were identified and these will be addressed through the ‘quick wins’ program that Fraport Greece has developed for the first few months of the concession period. Training for new employees will also focus on safe methods of work. ESAP # 12 formalizes the IFC/lender group expectation in terms of OHS management.



The OHS aspects of construction or expansion works will be addressed by the CEMP (see Management Program in PS1 and ESAP # 6).



Fraport Greece will also put in place a workplace monitoring program to prevent risks and potential impacts on workers’ health during the operations.



Workers Engaged by Third Parties

Approximately 150 workers for Cluster A and 140 workers for Cluster B will be employed by the EPC contractors at the peak of construction for imminent works. Their employment conditions will be consistent with principles included in the concessionaire’s HR policy. Where possible, the EPC contractor will be asked to prioritize employment of members of local communities and if technical skills are not available, people from other islands and in cities in Greece. During construction, workers accommodation will be provided in hotels and rooms available in the proximity of the sites. Availability of rooms during low touristic season has been previously assessed by the EPC contractors.



The risk of hiring migrant labor with inappropriate contractual terms by third parties will be mitigated through screening that will be undertaken by the airport superintendent as an ongoing routine activity, and addressed in ESAP # 9.



Existing contracts with companies for air fuel and handling services will be transferred to Fraport Greece for Cluster A and B. For new duty-free and duty paid spaces after security control, Fraport Greece will negotiate revised contractual terms with the existing exclusive concessionaire for duty free areas (Hellenic Duty Free Shops - HDFS). The duration of new contracts will be maintained until the current expiry date of the exclusivity concession (end 2047) between HDFS and the Hellenic State. Contracts of existing duty free areas will be maintained until the end of the exclusivity concession.



In relation to food and beverage (F&B) units on the airside and commercial spaces on the landside, such as pharmacies, car rentals and other retail, Fraport Greece will enter into new commercial agreements, for a maximum duration of one year, before the start of imminent works. Post imminent works completion, Fraport Greece will engage with existing tenants to explore opportunities for future collaboration. The employment plan described in ESAP # 9 will include an assessment of third party contracts.



Fraport Greece committed to develop audit procedures and key performance indicators (KPIs) for its contractors to ensure compliance with national labor legislation and PS2. During the social baseline assessment, the concessionaire will also assess the pool of potential local contractors and subcontractors for general maintenance works in each island and will be included in a database for future opportunities.

Resource Efficiency

Fraport corporate has made commitments to resource efficiency across its operations (see Policy section in PS1). These commitments will be applied in Fraport Greece, although the deadlines for some are yet to be set (e.g. the Airport Council International - ACI airport carbon accreditation).



Fraport Greece’s due diligence has identified a number of areas where there is potential to reduce the resource footprint of operations at airport sites. A number of specific policy statements have also been developed (water use; energy efficiency; wastewater management; solid waste management) to formalize this opportunity.



GHG Emissions

The Fraport Greece long term goal for GHG emissions is ACI accreditation (see above), aligning with the commitment of Fraport corporate for Level 2 (reduction) or higher (optimization; neutrality). Level 1 is for mapping and given the proposed changes to operating hours and flight numbers, the GHG emissions baseline will increase from that generated by current (HCAA) operations.



Principal sources of GHG emissions at the airport (i.e. not those associated with flights) are aircraft taxiing/movement on the ground; ground traffic; airport infrastructure (including terminal and auxiliary power units (APUs) and construction activities. ESAP #14 requires Fraport Greece to formalize their plans for GHG emissions and if they exceed 25,000 mtpa CO2e; to quantify direct emissions on an annual basis in accordance to internationally recognized methodologies and good practice.



Water Consumption

Water supply to airports is provided either via a network (municipal or private), or via boreholes (Samos, Skiathos, Rhodes, Mykonos, Santorini and Mytilene – all Cluster B). As with the ETs (see Identification of Risks and Impacts in PS1), Fraport Greece is reviewing and where necessary, applying for current, valid permits for each water source. A draft water policy (see PS1) commits Fraport Greece to monitor; assess and where feasible, implement water reduction opportunities; monitor contractor water use, collaborate with others and report to stakeholders on their performance. The initial step will be to develop a water usage baseline as current consumption figures for each airport are not known.



Pollution Prevention

Noise represents the most significant pollution source for airport operations. For the fourteen airports within the concession agreement, no routine noise measurement survey data has been provided to the concessionaire.



While an airport operator has little control over the type of aircraft (and related noise level), there is an ability to control other factors, including physical (e.g. baffling/shielding) and procedural (e.g. preferred routes for taxiing, landing and take-off, although options are limited on single runway, smaller airports which represent the vast majority covered by the concession agreement). As part of its due diligence and environmental baseline work (see P
S1), Fraport Greece has commissioned a noise baseline survey, due for completion by the end of October 2016. The results of the baseline will guide Fraport Greece’s strategy on noise management and reduction and will also help them with indemnification or compensation related to any existing issues related to noise pollution (e.g. cost of insulating properties already adversely affected by current (HCAA) operations). As specified in ESAP # 4, the assessment of noise impact will also consider imminent works and proposed changes to operating hours and flight frequencies.



As the airport sites are all currently operational, air emissions associated with aircraft movements, use of energy facilities/boilers, traffic travelling to/from the airport, use of air conditioning units and APUs already occur. However, the intended changes and upgrades to the airports may have an impact on air quality levels both during construction, through dust creation and truck/vehicle emissions, and also operationally where changes to the capacity of the airport result in additional emissions from increased aircraft and vehicle movements. This is most likely to occur in airports where more significant modernization and capacity expansion is taking place, such as Aktio (Cluster A).



Greek regulation on ambient air quality implements EU Directive 2008/50/EC and it sets air quality limits for NOX, SO2, PM10, PM2.5, benzene, lead, ozone and CO. Fraport Greece has not been provided with a complete data set for ambient air monitoring across all 14 airports and therefore current compliance to limits is not known. With the exception of Thessaloniki (Cluster A), the other airports are small; not situated in major urban areas and subject to coastal breezes to help dissipate emissions – however more needs to be known about local climatic conditions and proposed changes to airport operations in order to effectively manage this issue. Ambient air quality monitoring is therefore part of the environmental baseline work and will be conducted in the first peak traffic period, as addressed by ESAP # 3.



Ground contamination is either known or suspected at a number of airport sites. To allow for the appropriate indemnification/compensation under the pre-existing conditions clause of the concession agreement, Fraport Greece is commissioning a baseline survey to quantify ‘existing contamination’ as defined in the concession agreement. This includes historic/legacy contamination, ongoing contamination and the potential for future contamination from any potential source identified as defective (e.g. an underground storage tank). Asbestos containing materials will also be quantified through the survey.



Wastewater Treatment

Wastewater treatment in airports is performed either via a dedicated wastewater treatment plant (WWTP - Thessaloniki, Aktio, Chania, Kefallinia and Kavala in Cluster A and Mytilene and Kos in Cluster B), or via a connection to the municipal sewage system (
all others). According to information obtained during the site visits, in airports where a WWTP exists, a subcontractor is responsible for its operation on behalf of the HCAA. Wastewater treatment is covered by the ET (see PS1) but there has been little oversight, particularly of WWTP performance.



For all 14 of the airports, blue waters from the aircraft are collected in cesspits and directed, without any treatment, to the WWTPs or to the municipal sewage system. The site visits identified the need for biological treatment maintenance at Kos and a new sludge storage tank at Aktio to allow for a capacity expansion to cope with high season demand. Fraport Greece has developed a waste water policy statement that commits the company to pre-treatment at all sites; increase grey water recycling; routinely monitor discharges and ensure that on site contractors and leaseholders (e.g. food and beverage concessionaires) also comply with the terms of the policy. ESAP # 13 requires Fraport Greece to operationalize this statement via a wastewater treatment maintenance and upgrade plan for all airports, using both the ET and the WBG EHS Guidelines for Airports and the General EHS Guidelines as references for good international industry practice and performance benchmarks.



Solid Waste Management

Day to day airport operations produce several types of solid waste, with upgrade and construction activity adding others - of which some may be hazardous (e.g. asbestos containing materials). Legal requirements for solid waste management are addressed in the ET for each airport and Fraport Greece has developed a specific policy that commits the company to set performance targets for solid waste management; to publicly report on its recycling rates and to ensure that agreements with suppliers, contractors and subcontractors specify the need to comply with policy requirements.



General waste (including recyclable packaging materials) is picked up and managed by municipal authorities. At some airport locations there are constraints on the municipal side however: for Kerkyra (Corfu) for example, there is no licensed landfill on the island. Potentially due to such constraints, the site visits identified ‘stockpiled’ wastes on site e.g. construction waste, used tires, end-of-life vehicles and equipment (some of which belonged to the former Olympic Airways). As part of the indemnification/compensation agreement with the state for pre-existing conditions (see PS1), Fraport Greece is developing a waste inventory for each airport site.



Fraport Greece will collaborate with the municipal authority for each airport site and develop and then implement a solid waste management plan. This will ensure clarity on respective roles and responsibilities. This will addressed as part of ESAP # 1,2 and 3.



Hazardous Materials

Airport operations include the storage and handling of fuels (e.g. jet fuel, diesel and gasoline) associated with aircraft fueling activitie
s as well as ground support vehicles. Fuels are stored in both aboveground tanks (e.g. Thessaloniki in Cluster A) or underground storage tanks (e.g. Mykonos in Cluster B) and conveyed to dispensing locations, via aboveground or underground piping systems. Accidental releases can occur during transfer or leaks due to tank and piping containment failure (e.g. corrosion of steel components or faulty construction and installation). The baseline survey for existing contamination (see above) will quantify this risk.



Other hazardous materials used on site include fire suppression foams and powders (surface water contamination risk) and oils, lubricants and other chemicals used in aircraft or ground support vehicle maintenance. Asbestos containing materials are also known to be present at some sites (see section on contamination under Pollution Prevention). The solid waste management policy that Fraport Greece has developed is also applicable to hazardous waste, including the obligations of contractors, subcontractors and suppliers.



Pesticide Use and Management

Airfield maintenance will be predominantly manual i.e. physical clearing of undergrowth and regular cutting of grass verges. Routine use of pesticides or herbicides is not anticipated.

Community Health and Safety

As existing, operational airports, community health and safety issues are part of current day-to-day management by HCAA. When the concession period commences, Fraport Greece will inherit this responsibility and in addition, the community health and safety aspects linked to modernization and/or expansion. The social baseline survey (see Identification of Risks and Impacts in PS1) will help to identify priorities in this area, as well as Fraport’s stakeholder engagement program and ongoing work on emergency preparedness and response, traffic management and the existing contamination baseline study. All of these are detailed in other sections of this document.



Infrastructure and Equipment Design and Safety

For this proposed investment, life and fire safety (L&FS) of publicly accessible buildings i.e. terminal buildings is the key consideration. As part of their pre-concession preparation, Fraport Greece’s consultants have undertaken L&FS reviews at each airport in order to (1) review existing fire safety licenses; (2) identify pre-existing conditions in order to negotiate for compensation from the state; and (3) identify priority L&FS improvement to be undertaken as part of the ‘quick wins’ program (see Overview of IFC’s Scope of Review). The L&FS review did identify a number of actions requiring immediate attention from CCD, primarily related to improved signage and monitoring/maintenance of fire detection and suppression systems. L&FS improvements requiring structural changes will be addressed through the imminent works program. The budgeting of required L&FS improvements was still being finalized at the time of compiling this ESRS document.



Fraport Greece has drafted a ‘White Paper on Fire Safety Design of Airport Terminals’ to define the company’s program in this area. It details the areas of the Greek Fire Code that cause difficulties for operation, in part due to its generalized nature (i.e. not specific to airport terminals). For areas where Fraport Greece will apply for an exemption, an alternative fire code is proposed, most typically NFPA 101 (an internationally recognized standard from the USA). The final version of the white paper will be reviewed and approved by a qualified L&FS expert retained by IFC – this is addressed in ESAP # 15. For new construction, Fraport will use both local code and an internationally accepted code to inform design.



Hazardous Materials Management and Safety

Facilities for storage and handling of fuels associated with aircraft activities and ground support vehicles are located within the concession perimeter with no significant risks or impacts on safety of surrounding communities.



The primary risk to community health and safety identified for imminent works is associated with road traffic safety generated by the transport for construction materials, equipment and workers to and from the concession. As a result of an internal preliminary assessment, the c
oncessionaire will develop a traffic management plan that will define safety measures to minimize impacts on community health and safety outside the concession area, as part of an integrated occupational health and safety management system addressed in ESAP # 12.



Emergency preparedness and response

For all its operations worldwide, Fraport has developed a general safety management system manual and aerodrome manual template in reference to emergency response plans. Appraisal visit highlighted that specific emergency plans are critical considering that most of the airports are situated within highly touristic areas and some of them are located within Greek islands, which carry a certain degree of isolation in terms of transportation and health care infrastructures. Fraport Greece will develop site specific plans to facilitate timely and appropriate response to potential emergencies occurring on the immediate vicinity of the airports. The airport operation supervisor will oversee the implementation of the plans through training sessions for both internal and external stakeholders. In the five airport that are currently serving military operations (Chania, Kavala, Aktion and Thessaloniki in Cluster A and Samos in Cluster B), emergency response plans will be developed and implemented in coordination with the Hellenic Air Force (HAF). Each emergency response plan will be disclosed to neighboring authorities.



Security Personnel

Security related to airport passengers and protection of airport perimeter will be managed by a security contractor hired by the concessionaire. All security employees are screened, trained on Voluntary Principles of Security and Human Rights (VPSHR) and have access to the concessionaire’s Code of Conduct and grievance procedures.



In Chania, Kavala, Aktion, Thessaloniki and Samos, the military operations act in accordance to the Hellenic Law which is independent from airport operations. The airport operations supervisor will be in charge of the coordination between surrounding communities and HAF (see ESAP # 16).

Protection and Conservation of Biodiversity

Present plans do not envisage new land take and footprint expansion at any of the fourteen airport sites – therefore potential biodiversity impact related to land use are limited to activities within the current footprint of each site. This land comprises modified habitat, of which the majority is already hard paved (concrete or asphalt). The ongoing environmental baseline work (see ESAP # 3) will inform Fraport Greece of the sites with sensitive biodiversity receptors.

Protected or Recognized Areas

The LTA has also reviewed this issue and advised the lender group on the potential biodiversity risks. These can be characterized as occurring in the ‘zone of influence’ i.e. off-site but impacted through aircraft movements (approach and take off), noise, surface water runoff, dust or other activities emanating from airport operations. Key sites are those which are adjacent to protected areas (primarily Natura 2000 designated sites driven by the EU Habitats Directive). These comprise Kerkira (Corfu – Cluster A) – the lagoon and coastline immediately to the west and south; Kavala (Cluster A) – coastal and marine habitats; Aktio (Cluster A) – the Limni Voulkaria, adjacent to the southern boundary and a site of community importance and part of a wider mosaic of habitats that comprise the Ethniko Parko Ygrotopon Amyrakikou National Park (IUCN classified as Category VI: a protected area with sustainable use of natural resources). A special protected area under the Bird Directive is located in the north-west quadrant of the park; Zakynthos (Cluster A) – prohibition on nighttime flights (10pm to 5am) to reduce light pollution on the beaches in the National Marine Park of Zakynthos which runs along the western and northern coast of the island. These are egg laying beaches for the Mediterranean sub-population of the loggerhead turtle (IUCN status Least Concern, due to the long term conservation measures that have been implemented to protect it).



Sustainable Management of Living Natural Resources

Management plans will also be required to minimize bird strikes at each airport. This is of particular importance for Aktio (Cluster A), given the significance of the area for birdlife. Thessaloniki, Skiathos and Kerkira-Corfu (all Cluster A) and Samos (Cluster B) are also at elevated risk for bird strike. This is addressed in ESAP # 17.



Fraport Greece has drafted a biodiversity policy statement, which states the company’s commitment to assess its impacts on biodiversity; to take a precautionary approach; to ensure contractors, sub-contractors and suppliers meet policy expectations; to support scientific work on biodiversity and to identify opportunities to promote good biodiversity management practice through collaboration and knowledge sharing. For the airport sites where the current or future ‘zone of influence’ has the potential to affect protected areas, Fraport Greece will collaborate with othe
r stakeholders in order to promote and enhance the conservation aims and effective management of the areas. These actions will be included in the site specific management programs (see ESAP # 2 and 6).

Protection of Cultural Heritage in Project Design and Execution

Presence and discovery of archeological sites is common within infrastructure projects in Greece and management of cultural heritage sites is regulated by the national legislation (L.3028/02), which is consistent with PS8.

While the many of the airports have cultural heritage structures within the airport boundaries (e.g. old churches and small archaeological structures), Mytilene, Samos, Kos, Rhodes (all Cluster B) and Kerkira-Corfu (Cluster A) runaways and terminals are located within recognized archaeological designations under Hellenic Law.

Should expansion works beyond the current footprint be required, the following sites have been identified to have potential interference and impact on cultural heritage, which will need to be mitigated:

Kerkira: the current airport footprint is in close proximity with the archaeological site of the City of Kerkira;

Samos: part of the airport concession overlaps with areas which are part of the two declared archaeological sites of Heraion and Pythagoreion;

Kos: airport is located within the limits of the proclaimed archaeological site of Antimachia.

Expansion works beyond the current footprint at these airports would have potential implications and would need to meet national law and PS8 requirements for the protection of archaeology, including mitigation and management of new archaeological findings during excavations.

Project’s Use of Cultural Heritage

To date, Fraport Greece has not produced a corporate policy for the management of cultural heritage. As documented in ESAP # 18 a corporate level cultural heritage policy, inclusive of a chance find procedure, will be developed in coordination with the Hellenic Ministry of Sport and Culture. In addition, for cultural sites within the current airport concession boundaries, communities will be consulted to manage public access to site via site specific stakeholder engagement plans (see ESAP # 7.

The concessionaire has completed an inventory of cultural heritage sites that are located within or in the proximity of the 14 airports. During imminent works, Fraport Greece will use the inventory to inform site-specific Cultural Heritage Management Plans (CHMPs) in cooperation with Hellenic authorities and collaborate with the authorities and affected communities in order to contribute to the conservation aims and effective management of the sites. EPC contractors will be contractually required to adhere to the CHMP requirements. This is addressed in ESAP #2 and 6.

Stakeholder Mapping /Analysis
A public relations department has been created by the concessionaire in August 2016 with a mandate to draft a corporate stakeholder engagement plan and oversee its application at all 14 airports. A stakeholder mapping has been completed and appropriate communication means have been associated with each category of stakeholders. A roadmap for consultations has been prepared and will be implemented from October 2016. The roadmap will be consolidated into a formal Stakeholder Engagement Plan (SEP) which allocates responsibilities to site based staff for interaction with internal and external stakeholders in each airport (see ESAP #7) and includes a grievance mechanism for the affected communities, which will be operationalized by the concessionaire.

Consultation
After the signing of the concession agreement, Fraport Greece has consulted with central authorities for matters related to the renewal of environmental terms and project master plan developments. As part of the SEP, Fraport Greece will develop and update site specific consultation plans that will consult surrounding communities on project schedule, proposed design changes, and possible mitigation measures in relations to related to traffic, noise and air pollutions.

Information Disclosure and Ongoing Reporting to Affected Communities
Under the terms of the concession agreement, Fraport Greece has a specific responsibility to produce and disclose an “annual report on environmental strategy which must be submitted to the Ministry of Environment within three months from the end of each calendar year and published on Fraport’s website. This requirement will be captured in the company’s public disclosure policy and SEP. As part of the public disclosure policy, Fraport Greece will disclose information on environmental management and implementation of the ESAP to surrounding communities on an annual basis (see ESAP #8).

Contact Person: Kelly Pyrpyli, Environment Expert
Company Name: Fraport Greece
Address: 10, Germanikis Scholis Athinon Str, 151 23 Maroussi, Athens, Greece
Email: mailto:K.Pyrpyli@fraport-greece.com
Phone: +30 211 2121141

Broad Community Support is not applicable for this project

Greek Airports(37655) Supervision Disclosure Snapshot – Version 5
Description	Anticipated Completion Date	Status	Comments	Completion Date
Environmental and Social Management System (ESMS). The concessionaire will ensure that an adequate ESMS aligned with ISO 14001, OSHAS 1800 and GIIP is developed prior to imminent works.	30-Apr-2019	Completed	Completed	10/21/2020
Site Specific- Environmental and Social Management Plans (ESMS). In coordination with HCAA and other stakeholders, the concessionaire will prepare and implement site-specific environmental and social management systems (ESMSs) that will be based on mitigation measures identified in the ESIAs.	30-Apr-2019	Completed	Completed	3/31/2020
Environmental and Social baseline. The concessionaire will prepare the scope of work for a supplemental environmental and social baseline which assesses E&S aspects beyond those governed by the concession agreement and which also reflects WBG EHS guidelines for airports.	31-Jan-2017	Completed	Completed	6/1/2017
Update of Environmental and Social Impact Assessment. The concessionaire will update the environmental and social impact assessment (ESIA) for imminent works at all sites in line with PS 1 requirements. The updated ESIA will also include:i) a land acquisition and livelihood restoration framework which highlights the principles, risks, potential budget, timetables and resourcing implications that will trigger potential site-specific plans if additional land is required; ii) an assessment of direct and indirect impacts and risks on biodiversity at each airport site.	31-Jul-2017	Completed	Completed	8/31/2017
Organisational Capacity. The concessionaire will develop an appropriate EHS organisation at corporate and site level commensurate to project risks. A budget for E&S management will be included in the financial model.	31-Jan-2017	Completed	Completed	1/2/2017
Management of Environmental Risks during Construction. The concessionaire will prepare an construction environmental management plan (CEMP) to be agreed and implemented by the EPC contractor. Priority plans are EHS as part of operational site management and community H&S.	31-Jul-2017	Completed	Completed	4/27/2018
Stakeholder Engagement Plan and Grievance Mechanism. The concessionaire will finalize stakeholder engagement (SE) and grievance management (GM) procedures in line with PS1. The SE and GM procedures will identify key stakeholders in each airport, tools for engagement and roles and responsibilities at operational (site) level	31-Jan-2017	Completed	Completed	10/24/2016
Reporting and Disclosure. The concessionaire will implement site specific stakeholder engagement plans that will include ongoing (annual) reporting to neighboring communities regading management of E&S risks and changes to the E&S baseline (e.g through changes in operating hours).	31-Jan-2018	Cancelled	Changed project circumstances mandated cancellation of this task
Environmental and Social Risks Assessment for Future Works. Before the commencement of all future works , the concessionaire will undertake an E&S risk assessment in line with Performance Standard 1.	31-Jan-2021	Postponed	Changed project circumstances mandated a delay of this task
Local Employment Plan. In consultation with HCAA, the concessionaire will finalise an employment plan documenting the proposed approach to staffing at each airport before CCD.	31-Jan-2017	Completed	Completed	12/5/2016
HR Policies and Procedures. The concessionaire will finalise and implement the HR policy framework in line with Performance Standard 2.	31-Jan-2018	Completed	Completed	7/3/2017
Occupational Health and Safety System. The concessionaire will develop and implement an occupational health and safety management system aligned with OSHAS 18001, Hellenic Law and relevant paragraphs of the WBG EHS guidelines (General, Airports)	30-Apr-2019	Completed	Completed	6/30/2020
Waste water treatment plan. The concessionaire will prepare an assessment for upgrading waster water treatement sites or divert to municipal works in seven selected airports. Baselines are Greek legislative requirements and relevant parameters in WBG EHS Guidelines for Airports. A process for treatement of airplane blue water to be integrated to the upgrade analysis at each site.	31-Jan-2017	Completed	Completed	7/3/2017
GHG emissions and climate change. The concessionaire will prepare a regional assessment of the effects of climate change and climate adaptation vulnerabilities for at each airport. If specific issues are identified, Fraport Greece will include appropriate studies and mitigation measures into the masterplan documentation. Comply with IFC and corporate reporting expectations if GHG emissions from Fraport Greece operations exceed 25,000mtpa CO2e.	31-Jan-2018	Completed	Completed	12/4/2017
Life Fire and Safety. The concessionaire will develop and implement a life fire and and safety plan in line with Greek legislation and WBG EHS guidelines (General, Airports).	31-Jan-2017	Completed	Completed	12/5/2016
Engagement with Security Forces. The concessionaire site managers will engage with military operations in selected airports related to identify and jointly manage of environmental, safety and security risks to the affected communities.	31-Jul-2017	Completed	Completed	1/30/2018
Wildlife management. Fraport Greece will develop and implement management plans for species triggering biodiversity risk (in particular to Golden Jackal in Samos and impact of birdstrike in areas with high potential for sensitive bird species, including protected areas).	31-Jul-2017	Completed	Completed	7/3/2017
Cultural Heritage Procedure. In coordination with the Hellenic Ministry of Culture and Sport, the concessionaire will develop a cultural heritage policy and implementing procedures at site (airport) level. To include chance finds and all other relevant requirements of Performance Standard 8.	31-Jul-2017	Completed	Completed	9/29/2017