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

Based on the site visit to the Lahore (Pakistan) and Corlu (Turkey) plants, and discussions with CCBPL & CCI, this project will have limited potential adverse environmental and social impacts which are site-specific, reversible and easily addressed through agreed mitigation measures. The project impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Environmental and Social (E&S) Sustainability Policy. The project will be designed to avoid, minimize and manage E&S risks and impacts of the company’s operations in compliance with Pakistani legal and regulatory requirements, IFC’s Performance Standards (PSs) and applicable World Bank Group (WBG) General and sector-specific Environmental, Health and Safety (EHS) Guidelines.

Key E&S risks associated with these kind of investments are: (a) food safety and HACPP certification; (b) effectiveness of the company''s management systems, including its internal capacity and staffing, to undertake the project in a manner that is consistent with IFC Performance Standards; (c) resource efficiency and pollution prevention; (d) workplace and ambient noise and labor and occupational health and safety programs; (e) third party workers / supply chain occupational health and safety and labor issues; and (g) life, fire and traffic safety. The information about how these potential impacts will be addressed by CCBPL is summarized in the paragraphs that follow.

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.

Policy: CCI has adopted a corporate level EHS policy statement indicating the three main priority areas for the business which include: energy management & climate protection, water management and sustainable packaging. The CCI corporate EHS policy also includes the scope of application covering all CCI its subsidiary employees, contractors, subcontractors, sales and distribution agencies, third parties involved in CCI operations as well as CCI visitors and all premises where any CCI business run, the EHS standards more stringent of applicable legal requirements including local regulations, all CCI HSE standards or TCCC requirements they abide to, CCI’s 12 golden safety rules on safety, emergency procedures, traffic safety, job safety, use of PPEs, risk assessment and contractor management and roles and responsibilities as required in PS1. A shorter version of the policy statement is available to public on the website of the company

(http://www.cci.com.tr/UserFiles/pdf/2015/CCI_Environment_Policy_Statement-07072015.pdf). CCBPL has

adopted the corporate EHS policy and ensures implementation at all its operations in Pakistan. The Company has provided relevant NOCs (No Objection Clearance) against clearance of EIAs, and IEEs for post “Pakistan Environment Protection Act (PEPA) 1997” activities that include extension/expansion of already operational plans and phase II of Multan plant issued by respective Environment Project Agency. CCBPL will streamline its internal monitoring and reporting system in compliance with regulatory requirements of EPAs for Multan plant as per ESAP #3. CCPBL already has a system of internal monitoring and reporting. A copy of these reports will be submitted to IFC.



CCI’s policy also indicates commitment to certify the quality, environmental and occupational health and safety as well as food safety management systems with internationally recognized standards (i.e. ISO 9001 (quality), ISO 14001 (environment), OHSAS 18001 (occupational health and safety) and ISO 22000 (food safety)). In this respect, all Turkey operations are certified with ISO 9001:2008, Food Safety System Certification (FSSC) 22000, OHSAS 18001:2007 and ISO 14001:2004. All the Pakistan operations (except Multan plant) have OHSAS 18001 and ISO 14001. The target completion date for Multan plant to complete the certification against these international standards is by YE 2017. The Faisalabad, Gujranwala, Karachi, Lahore and Rahim Yar Khan Plants are audited in 2015 and 2016 for recertification for most of the standards. According to the audit results, there are no material non-conformities at the plants



Identification of Risks and Impacts: As part of its management system, CCI integrated a procedure to undertake an E&S assessment of all new investments. This assessment includes environment, technical and safety issues aspects. The Company retains consultancy services for undertaking these EHS assessments. Risk assessment studies were implemente
d according to the relevant SOP of the management system in place in for all the plants in Pakistan. The SOP clearly defines the details, responsibilities, method of risk assessment and the means for elaboration of the results for environmental and health and safety risks for Lahore Plant and other production facilities in Pakistan. As part of this investment, CCBPL will include social aspects in its risk assessment and broaden the scope of application to all of the operations in Pakistan as per ESAP action item#2.



Management Systems & Programs: In 2010, CCI started using the “Coca-Cola Operating Requirements System” (KORE) system, which is a management system designed by the Coca-Cola Company (TCCC) improving performance at its operations. The system integrates quality, environmental, food safety and OHS issues into the key operational requirements. In the scope of this system, the global quality organization performs risk determination and conducts, quality, environmental and safety audits at manufacturing facilities around the world. Specific audits are conducted for compliance, systems, certification and surveillance. The Company shall develop and implement a time bound action plan to eliminate/minimize the risks related to the findings of the audits and risk assessments implemented regularly, as per ESAP action item#1.



The KORE system adopts several different standard operating procedures (SOPs). For the Pakistan facilities the following SOPs have been defined depending on the type of operations: ozone depletion and air pollution, spill prevention control, water resource management, storm water pollution, solid waste management, hazardous material management and wastewater treatment. With the KORE system integrating existing ISO management systems as well, the Company adopted management systems policy which indicates commitment to meet the standards determined by TCCC and make efforts to exceed the standards and stakeholder expectations while acting in compliance with all the legal requirements regarding quality, occupational health and safety, environment, food safety and energy. This is also a requirement in the “bottling agreement” with TCCC. Documentation regarding the management system including the policy statements, management programs and work instructions are all available online to the employees via the company portal.



Water management and strategy is one of the key focus areas for the TCCC as it is one of the most significant resources for its production. Therefore, TCCC is committed to improve the water efficiency through its operational advancements by 25 percent by the end of 2020 (compared to 2010 figures). CCI follows TCCC’s global water strategy focusing on improving production facility performance through water efficiency, reducing water use ratios and reuse, replenishment of used water, maintaining 100% compliance in wastewater treatment, protection of watersheds. Based on the strategies of Environment and Water
Management Work Group, the plants operational excellence groups develop and implement water efficiency projects to reduce water usage ratio (WUR).

In 2006, TCCC joined the UN Global Compact Initiative, a strategic policy initiative for businesses that are committed to aligning their operations and strategies with ten universally accepted principles in the areas of human rights, labor, environment and anti-corruption. As part of the programs, CCI has implemented water conservation programs at its plants.



In the scope of TCCC policy and management programs, all of its bottling plants are required to conduct a local source vulnerability assessment (SVA) and develop a source water protection plan to mitigate water related risks. With this assessment, potential impacts of water usage and related wastewater discharge as well as vulnerabilities to community sources of water are identified. As of 31 December 2014, all CCI plants had completed their SVA studies in all countries of operations. The assessment is to be conducted in every five years.



Energy management and climate protection are the priority areas in CCI’s sustainability strategy. For that purpose, CCI sets reduction targets for energy use and GHG emissions, identify and implement energy reduction measures and explore low-carbon technology alternatives to achieve its targets. All the plants in Turkey are rewarded with TS EN 50001 energy management system certificate. Energy reporting is divided in two categories: (i) energy consumption for core operations (i.e. bottling), (ii) all other processes at the plants. Energy usage ratio (EUR) (MJ/L) is one of the key KPIs that is tracked for energy efficiency.



The Coca-Cola system launched a global initiative in 2013 named “reduce the CO2 emissions embedded in the drink in your hand by 25% by 2020” aimed at reducing GHG emissions across its entire value chain. For Turkey operations, CCI have had its GHG emissions verified by an independent company in line with ISO 14064-3 requirements. The emissions reported include emissions from plants, offices and vehicle fleet in Turkey. For the operations in Turkey, ISO 14064-1 certificate indicating that 108,777 tCO2e (tons CO2 equivalent) is released due to its soft drinks manufacturing and distribution activities has been obtained in 2014.



In the scope of the sustainable packaging approach of CCI, the Company follows three principle of (i) reducing amount of material and energy used for packaging material and using recycled materials as much as food safety principles allow, (ii) establishment of a sustainable infrastructure for post-consumer packaging recover and recycling and (iii) exploring alternative renewable materials such as Plant Bottle. Plant Bottle is a product that uses plant-based materials up to 30% in content instead of petroleum and fossil fuels to produce key ingredient in the plastic.



Organizational Capacity and Competency: Each CCI operations and plants have their own env
ironmental and safety coordinator for managing E&S issues and they are efficiently guided and coordinated by CCI management.



In 2015, CCI Sustainability Steering Committee has been established. This committee is responsible for setting annual sustainability targets, reviewing quarterly performance on KPIs for the operations of all CCI subsidiaries, including the company, and approving data for disclosure. The functional heads of CCI at both group and country level integrate the sustainability targets into the functional objectives and ensure implementation. This committee is supported by “Environment and Water Management Working Group” and “Climate Protection and Energy Management Working Group” which are responsible for development of strategies and roadmaps for increasing efficiency, identification of annual and short-term environment and climate protection goals, implementation of improvement measures to achieve environmental goals, and conducting climate change and water risk assessments in CCI Turkey.



CCBPL provides orientation training to all newly recruited personnel. The orientation training includes job safety rules, plant hazards, food safety and health responsibilities, environmental requirements and emergency response training relevant to the employee''s job responsibilities. Refresher training is also available to relevant staff depending on the training needs identified by the functional heads in coordination with Human Resources (HR) or when changes occur to equipment, process, management system documents, environmental and safety management system requirements and roles and responsibilities. The trainings are provided internally or externally whenever necessary. The EHS mandatory training activities are identified according to the position of the employees and include EHS policy, procedures, hazard identification and incident reporting, emergency response plan, use of PPEs, types of fires and controls, whereas KORE module includes more job specific trainings such as hot work, material handling equipment, fork lift operations/lift truck, flammable liquids, fleet management, compressed gas management, work permit system, safe driving, heavy lifting equipment, risk assessment and ergonomics. The target date for implementation of the training for each module and target audience are identified in the annual training plan.



Emergency preparedness and response: The Company has implemented an emergency preparedness and response plan, including a fire safety plan, and covering all emergency aspects in line with the requirements of IFC Performance Standard 1. Drills are planned for each plant annually and include situations such as confined space entry, boiler, ammonia leakage, first aid, fire and earthquake, chemical spill, emergency response for fall from height, flammable liquid, gas cylinder leakage and fire, respiratory and security. The two of the six CCBPL plants located in the industrial zone are subject to the Industrial Zo
ne Emergency Plans and others are in relative isolation from significant human settlements. Based on CCPPL’s risk assessments, there is no potential impacts in case of any emergency.



Monitoring and Review: CCI plants are exposed to internal and external audits. Internal audits are implemented once a year unless any unusual activities (e.g. introduction of a new production line, serious incidents) happen, while ISO audits are varying according to the type of the certificate. KORE audits are always implemented as unannounced by TCCC representatives.

CCI releases Sustainability Report including information on sustainability achievements, KPIs, goals and commitments, environmental and health and safety figures in different countries, success stories, human resources policy and workplace rights policy and relevant figures. The safety, health and environmental (SHE) indicators are regularly reported to TCCC on monthly basis like specific KPIs (Key Performance Indicators) including water, wastewater generation, solid waste energy usage solid waste recycling ratio (%) and CO2 emissions. The goals and commitments are concentrated on the priority areas as energy efficiency, GHG emissions, water stewardship, packaging and waste and environmental compliance with legal and TCCC standards. The Company shall include all of its Pakistan operations into this monitoring and review program as per ESAP action item#4.

Employment Data: CCBPL has close to 5000 employees (including third party contractual staff) out of which around 94% are male and 6% are female. The turnover rate of the Company is low. Employees are hired from the surrounding areas but this is not specifically stipulated in the company’s HR policy. CCBPL is divided into nine departments on the basis of function namely supply chain, commercial finance, human resources, business technologies, public affairs, internal audit, legal, and the GM office.



Human Resources Policies and Procedures: CCI across all its countries has adopted the Work Place Rights (WPR) as its internal HR policy. The WPR is based on United Nations Universal Declaration of Human Rights, International Labor Organization’s Declaration on Fundamental Principles and Rights at work and the United Nations Global Compact as well as local standards where applicable laws and regulations provide more stringent standards. WPR includes freedom of association and collective bargaining; prohibition of forced labor; commitment not to employ children (under 18); discrimination against race, sex, color, nationality and social origin, religion, age, disability, sexual orientation and political view; working hours and wages; commitment to safe and healthy workplace; workplace security and community and stakeholder engagement. The WPR is communicated to all CCI employees in 2013 in English and local language in all countries of operation and also made available online at the Company website (http://www.cci.com.tr/IK/workplace_rights_at_cci). Head of HR at the CCI level is responsible for implementation of the WPR across all CCI countries, reporting to the Chief Executive Officer (CEO) of the Company. The corporate level HR department has established a directorate to implement the WPR in all operations of CCI and relevant training is provided to HR associates and managers during orientation period.



CCBPL supplements CCI HR policy with country specific policies. Company’s HR policy covers the necessary information and guidance for HR related policies and procedures which are combined within a hand book and is also available to all the employees on the company’s portal. CCBPL confirmed through a legal opinion dated June, 7, 2016 that all its operations are in full compliance with ILO requirements and IFC PS2 requirements regarding its own works force, third party workers and workers engaged by the client’s primary suppliers.



Working Conditions and Terms of Employment: CCI is a part of PIR (Pay in Range) market surveys conducted by a third party on wages/salaries for corporate sector and CCI uses this as a benchmark for setting salary scale of CCBPL employees. Employees work 5 days a week in offices and 6 days at plants in two, 8-hour shifts and are given a break for lunch. During peak season, a third 8-hour shift is added. Overtime is voluntary. Each facility is having a provision of clean drinking water, toilets separate for men and wo
men, a cafeteria with food, sufficient indoor seating (with ceiling fans/ACs) and first aid system with company own ambulances.



Workers’ Organization: The “Coca-Cola Beverages Workers Union” grew out of the organizing efforts of the IUF- (International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers'' Associations), the union membership includes permanent/full time workers employed in plants and sales centers across Pakistan (non-management level excluding third-party contractors). All blue collar workers are unionized. Elections held after every two year and a Collective Bargaining Agreement (CBA) also takes place after every 2 years, consistent with the Industrial Relations Act of 2012 and PS2, the next CBA’s revision due in July 2017. There have been no strikes related to employee discontentment since inception of the company. CCBPL respects the requirements of the Collective Bargaining Agreement, in consistent with PS2 requirements.



Non-discrimination and Equal Opportunity: The Company has (i) a policy on non-discrimination and equal opportunity as a part of its Work Place Rights Policy and (ii) policy on work place harassment by following “The Protection against Harassment of women at Workplace Act 2010” and formulated a Harassment Committee at each facility to promote a harassment-free workplace. There is a facility of separate washrooms for women and day care centers at offices and plants.



Retrenchment: In case the implementation of the project requires staff optimization, CCBPL will assess alternatives to retrenchment prior to implementing any collective dismissals. If collective dismissals are unavoidable, the Company will develop and implement a retrenchment plan consistent with PS 2 to reduce adverse impacts of retrenchment on workers. The retrenchment plan will be based on the principles of non-discrimination. All outstanding payments, social security benefits and pension contributions, and severance payments will be paid on or before termination of the working relationship to the workers.



Grievance Mechanism: The Company adopts an open door policy and grievances are managed through union representatives. There is a formal procedure in the form of an ethics helpline which is also available via email service. Furthermore, there is an online ER/IR Portal for the same in which people can voluntarily give their names or not while leaving their grievances. The HR department is responsible for dealing with the work related issues of workers (non-management staff) as well as with management level employees’ grievances.

CCBPL undertakes Employee Engagement Surveys regularly with high employee participation rates to get feedback and to improve its HR management practices. The results of most recent 2015 survey showed a positive increase in sustainable engagement.



Protecting the Work Force: All CCBPL employees and those hired through third-parties are above the national legal minimum
age of 18. As part of the hiring process, all employees are required to provide evidence of their age. The Company does not employ forced or compulsory labor and working overtime is only on a voluntary basis.



Occupational Health and Safety: CCBPL is committed to ensuring that all facilities are operated in a manner that is safe and healthy for all employees, as reflected in the company’s HSE Policy. Company has developed Safety and Evacuation plan for each facility (offices, plants, sales centers, warehouses), SOPs for emergency response, SOPs for managing incidents/accidents, SOPs for apprising CCI and its facilities, employees and visitors, SOPs for third parties (contractors, sub-contractors, sales and distribution agencies); SOPs for Risk Assessment. OHS is monitored by EHS staff of the Company. All the employees and contractors go through the standard orientation module at the time of joining. Shift start trainings are also provided at plants. Training plans are developed and mandatory periodic and yearly job specific EHS training are organized for employees. CCBPL conducted periodic training for distributors’ staff in the use of PPEs. Other activities involve Hazard Assessment, Drive Safely, Fire Safety and Risk Assessment. In terms of the fleet i.e. drivers safety the Company will ensure that a) safety belts are installed / functional in all vehicles used in company’s business operations and b) fire extinguishers are installed, in all trucks owned by company or distributers third parties transportation, as per ESAP #5.

Workers Engaged by Third Parties: The CCBPL procures service of third parties for non-core functions through an open competition and based on formal, exclusive contractual agreements. There are standard clauses included on labor and working conditions, labor laws and EHS in the contract agreements of all service providers and contractors. The Company also conducts annual performance evaluation to review compliance with the terms and conditions of contracts. CCBPL use best commercial efforts to provide technical assistance to these entities in the form of equipment, process improvements, human resource development and EHS to improve their operations efficiency. However our due diligence confirmed that there is still room for improvements as stipulated in the ESAP #6



Guidelines for Suppliers: Major supplies of CCBPL include sugar, resin, concentrate, closure and crown, glass bottles and coolers and major service providers include distributors, transporters, sales agents, security and catering agencies. CCI has established supplier guiding principles (SGP) to be applied at all country operations. The SGP sets out minimum requirements CCI expects its suppliers to adhere to and addresses the following key areas: laws and regulations, child labor, forced labor, abuse of labor, freedom of association and collective bargaining, discrimination, wages and benefits, work hours and overtime, health and safety, environment and
demonstration of compliance. SGP has been a part of the supplier agreements since 2002 for TCCC and the direct suppliers to bottlers including CCI. The suppliers are audited by audit team of TCCC and CCI regularly and TCCC routinely utilizes independent parties to assess supplier performance according to SGP. The audit results are reported to TCCC’s global audit team and tracked by the CCI’s authorized personnel. The suppliers are expected to implement the corrective actions where they fail to comply with the SGP requirements and if not successful, TCCC and CCI has the right to terminate the agreement with the supplier. The results of the audits are also reported publicly with the sustainability report. According to 2014 results, 17 direct suppliers were audited in Pakistan and 82% of compliance was achieved. The suppliers were provided with the corrective action plans for remediation of the areas to be improved and follow-up visits were organized. CCBPL is committed to continue auditing its supply chain periodically based on risks and in case of any con-compliance including child labor, committed to take necessary actions and/or change suppliers within a reasonable time period.

All of CCBPL’s existing facilities are located in industrial urban, peri-urban or agricultural areas where basic infrastructure and utilities (electricity, sewerage systems, and solid waste collection) are supplied by relevant municipalities. The most recent update of the risk assessment has been implemented in January 2016 and the Company has accordingly designed mitigation and improvements measures in areas like occupational health and safety including use of PPEs and traffic accidents in PET lines, management of WWTP and emissions from the bottling operations.

Resource Efficiency:



Process water for all of CCBPL plants is sourced from underground wells. Average daily consumption was recorded approximately as 2900 cubic meters (m³) per day in 2015. Throughout CCBPL’s plants, water use is carefully monitored through a water balance diagram. Consumption has been gradually reduced from 2.67 liters of water per liter of product in 2011, to 1.78 liters of water per liter of product in 2015. This value is well below international benchmark figures for beverage industry, 2.69 L/L recorded in 2012 (3blmedia.com/media/other/BIER_2013_Benchmarking_Publication_0.pdf) Water conservation projects implemented in CCBPL include reuse of reverse osmosis reject water and satellite system installation. The future water conservation program includes reuse of forward and back wash of carbon purifiers, reuse of mixer vacuum pump water and some technological improvements in lines.



GHG emissions for Pakistan operations has been traced since 2014 and accordingly, emissions due to electricity consumption is recorded as 27,095 CO2e whereas emissions due to stationary combustion emissions, fleet emissions and fugitive emissions from coolers and cooling systems is 35,554 CO2e. CCBPL will continue to develop energy and water conservation programs as the other companies in the TCCC system and will annually report about relevant initiatives and performance indicators.



The wastewater discharge per liter of product in Pakistan is recorded as 0.56 L in 2014. The effluent of Lahore Plant is treated via physio-chemical and biological treatment systems before the wastewater is discharged to Hudiara drain an industrial drain crossing the borders from India and is heavily loaded with pollutants. The effluent quality in terms of temperature, pH and dissolved oxygen in Lahore is continuously monitored. According to the latest external wastewater quality measurement results of Lahore plant in 2015, wastewater discharged is in line with KORE standards, Pakistani National Environmental Quality Standards (NEQS) as well as WBG EHS Guideline values. The Company is compliant with all the local regulatory laws. For IFC PS requirements and WBG EHS Guidelines, the Company will provide the necessary documents to be reviewed by IFC as described in ESAP action item#7 and it will mutually be agreed on a further deadline for CCBPL to take necessary actions to eliminate the deviations if
not in compliance with IFC PS and WBG EHS Guidelines.



In Pakistani operations power is sourced primarily from the grid, in addition to small standby diesel generators in all facilities to ensure consistent power supply, and reduce machine down time. The company will provide additional information on the energy efficiency programs followed in other Pakistani facilities and will ensure that they seek for energy conservation measures in the operations as a part of the CCI’s policy for energy efficiency as described ESAP action item#7



CCI aims to reduce the amount of energy consumed per refrigerator and switch to HFC-free cooling equipment that contain refrigerants with low global warming potential within the scope of 2020 energy management and climate protection targets. In CCBPL operations R134A, R407 and ammonia are used at manufacturing plants as refrigerant. These refrigerants are acceptable under the Montreal Protocol. There are no governmental restrictions for the refrigerant amount used in Pakistan. Maintenance and operations of coolers are implemented by the sales point owner but gas and procurement of the spare parts are done by CCBPL.



Stack emissions from diesel generators in Lahore plant has been measured and analyzed by a laboratory, as required by National Environmental Quality Standards (NEQS). Regarding stack emissions, CCBPL is compliant with all local regulatory laws. For WBG EHS Guidelines, the Company will provide the necessary documents to be reviewed by IFC as described in ESAP action item#7 and it will mutually be agreed on a further dead line for CCBPL to take necessary actions to eliminate the deviations if not in compliance with WBG EHS Guidelines



The working environment is also indicated to be tested for temperature, vibration and illumination. Regarding workplace monitoring data to improve the monitoring plan so as to include all relevant parameters identified on the basis of OHS risk assessments implemented at each facility (e.g. noise, particulate matter, CO and ammonia leaks), CCBPL is in compliance with all local regulatory laws. For WBG EHS Guidelines, the Company will provide the necessary documents to be reviewed by IFC as described in ESAP action item#7 and it will mutually be agreed on a further dead line for CCBPL to take necessary actions to eliminate the deviations if not in compliance with WBG EHS Guidelines



The hazardous and solid waste management procedures and relevant provisions on handling and disposing are described in the SOPs. It is indicated by the client that 98% of the solid waste generated is being either recycled or re-used by third party contractors approved from local authorities. Regarding solid and hazardous waste management, CCBPL is in compliance with all local regulatory laws. For PS and WBG EHS Guidelines, the Company will provide the necessary documents to be reviewed by IFC as described in ESAP action item#7and it will mutually be agreed on a further dead line for CCBP
L to take necessary actions to eliminate the deviations if not in compliance with PS and WBG EHS Guidelines

Transportation Safety Management: CCBPL owns a fleet of trucks for direct distribution, while 99% distribution is undertaken by distributors (several hundred across Pakistan). CCBPL does traffic safety management through a number of measures i.e. defensive driving training for drivers (i) by third parties to their drivers (ii) by CCBPL (iii) by National Highway Authority, license checking, fitness for work, annual drug testing, parking protocols, and route hazard assessment. CCBPL has a system for accidents recording, corrective actions and their implementation. Good distribution companies get incentives for doing good job in terms of traffic safety.



Food Safety Impacts and Management: The activities at CCBPL plants are performed in accordance with the principles and practices of Hazard Analysis Critical Control Points (HACCP) for which all plants have received FSSC/ISO 22000. This reduces risk related to hygiene and food safety and mitigates potential impacts to the community. As part of HACCP requirements, the design of each of the processing line at the facility is organized such that products move from “dirty” to “clean” areas to avoid contamination and is undertaken by pumping raw materials stored in bulk tanks through each step of the process and filling of the finished product is undertaken through automated processes, thus removing the potential for contact between workers and the finished product. Procedures are in place for ensuring daily cleaning of equipment and removal of solid waste. All staff have received training on food safety issues and have been issued the necessary work clothes (clothes, gloves and hair coverage) commensurate with the extent of contact with the finished product.



Emergency Preparedness and Response: The Company has Emergency Preparedness and Response Plans, and as explained in section PS1, no communities are affected by emergency situations based on the information made available by the company.



Security Personnel: Each site is equipped with a Closed-Circuit Television (CCTV). The security guards are employed through a licensed third party (OHSAS18001 and ISO9002 certified) service contractor. Currently there are sufficient numbers of security guards in 2, 12-hour shifts. The security company has a HR policy and its own SOPs which also outline the requirements for security guards i.e. criminal background checks prior to joining, formal training in the use of licensed weapons and health and safety, and organize regular quarterly training for the security guards. Security assessment is carried out for each new facility and a mechanism for recording, investigating and reporting potential incidents is in place. CCBPL has hired security personnel equipped with arms to secure their premises. There have been no incidents related to armed security guards and the surrounding communities. Company’s security staff keeps close contact with local police to get updates on security situation. TCCC ensures that all
of its bottlers adapt and implement Incident Management and Crisis Resolution (IMCR) procedure. CCBPL has established a special department IMCR which is implemented in all operations to deal with all reputational risks / threats. IMCR procedure outlines the potential incidents and business risks and strategies that are being used to manage the risk associated with those potential incidents, identifies the persons that will be involved in managing incidents and provides a communication framework for reporting incidents and communicating with internal and external stakeholders.



Stakeholder Engagement: All CCBPL facilities are located in industrial and agricultural zones and in relative isolation from significant human settlements. CCBPL has not undertaken a formal stakeholder mapping exercise nor developed a formal stakeholder engagement plan. The Company has mapped out its primary stakeholders (consumers, employees, industrial customers, local authorities and NGOs), based on an assessment of the mutual interests of the stakeholders and the Company. It undertakes structured engagement (with some more intensively than with others) with its most important stakeholders, to stay up-to-date in terms of their expectations, what is most important to them, and relevant developments. As per ESAP#8, CCBPL will formalize its stakeholder plan and implement the stakeholder engagement plan (SEP) including a grievance mechanism for stakeholders.



Under its CSR activities, the CCBPL has been implementing three flagship projects on 3 global themes (i) 12 water filtration plants have been installed in different cities of Pakistan and 8 more will be installed by end of 2016 (approx 20,000 users per water treatment plant). CCBPL bear the cost of O&M for one year and between first year communities are trained to take over O&M in the 2nd year including cost (ii) 321 Bhago (run) project has been operating in 30 low-income schools by inspiring and equipping teachers and youth with the tools to develop healthy and active habits i.e. sports used as a tool for youth development (iii) Zarya (source) under this program, 5 customized rickshaws (Zeenat Gari) are provided on interest free credit to women of low income group, Rs.250,000/credit to each woman, to be paid back in easy installments, this fund will remain revolving among other women. The second project that runs under the banner of Zarya is Tabeer Store. Women are given small loans to set up grocery stores in their communities. To Date 10 stores have been set up in Lahore and Gujranwala.

Stakeholder Engagement: All CCBPL facilities are located in industrial and agricultural zones and in relative isolation from significant human settlements. CCBPL has not undertaken a formal stakeholder mapping exercise nor developed a formal stakeholder engagement plan. The Company has mapped out its primary stakeholders (consumers, employees, industrial customers, local authorities and NGOs), based on an assessment of the mutual interests of the stakeholders and the Company. It undertakes structured engagement (with some more intensively than with others) with its most important stakeholders, to stay up-to-date in terms of their expectations, what is most important to them, and relevant developments. As per ESAP#8, CCBPL will formalize its stakeholder plan and implement the stakeholder engagement plan (SEP) including a grievance mechanism for stakeholders.

Farhan Khurshid Malik
Coca-Cola Beverages Pakistan Limited
26 FCC Syed Maratab Ali Road Gulberg IV Lahore
mailto:fkmalik@ccbpl.com.pk
0092 423 575 6845-9

Broad Community Support is not applicable for this project

S.no	Description	Anticipated Completion Date	Status
1	CCBPL to develop and implement time-bound action plans to eliminate/minimize specific OHSE risks identified as a result of regular risk analyses and compliance audits for all production facilities in Pakistan operations	06/30/2017	Completed
2	CCBPL to integrate social aspects (related to water conservation and health impacts on community due to discharge) into the current risk assessment procedure of all production facilities	12/31/2016	Completed
3	CCBPL shall submit its internal monitoring and reporting system in compliance with regulatory requirements of EPAs for Multan Plant.	12/31/2017	Completed
4	CCBPL shall submit its internal monitoring and reporting system in compliance with regulatory requirements of EPAs for all other operations	12/31/2016	Completed
5	Monitoring & Reviewing : CCBPL shall include all of its Pakistan operations into CCI’s Sustainability Report	12/31/2016	Completed
6	Occupational Health & Safety: CCBPL will ensure that all contracts with its distributors and third parties transporters include “installing functional safety belts and fire extinguishers in all vehicles owned by company or distributers, third parties transportation	12/31/2017	Completed
7	Workers Engaged by Third Parties / Supply Chain: CCBPL to provide compliance audit report (by itself or engaging 3rd party) of primary suppliers / contractors /distributors to verify status of compliance with CCBPL’s SGP, terms and conditions of their agreements with CCBPL and local laws and regulations (starting from a sugar industry for 3Q16) on labor and working conditions including occupational health and safety and environmental protection; frequency of the audits will be based on performance of every supplier/contractor/distributor and can range from one to every three years.	07/31/2017	Completed
8	Workers Engaged by Third Parties / Supply Chain: Based on the results of audits CCBPL shall ensure the development and implementation of a corrective action plan by them in the non-complaint areas including recommendation for training or change of suppliers	06/30/2017	Completed
9	Workers Engaged by Third Parties / Supply Chain: Based on the results of audits CCBPL shall ensure the development and implementation of a corrective action plan by them in the non-complaint areas including recommendation for training or change of suppliers	12/31/2017	Completed
10	CCBPL will provide the necessary documents to be reviewed by IFC and it will mutually be agreed on a further dead line for CCBPL to take necessary actions to eliminate the deviations if not in compliance with IFC PS and WBG EHS Guidelines: (i) Information on waste water management practices at all facilities in Pakistan i.e. effluent quality, means of treatment, and compliance with local regulation and WBG EHS Guidelines (ii) Providing additional information on the energy efficiency programs followed in all the facilities, except Lahore Plant, in Pakistan and if there is none, seeking for energy conservation measures in the operations as a part of CCI’s policy for energy efficiency (iii) Provide additional information on the stack gas emissions including but not limited to emission sources at each plant, number and capacities, emission monitoring reports, and compliance with local regulation and WBG EHS Guidelines (iv) Provide information on the workplace monitoring data and improve the monitoring plan so as to include all relevant parameters identified on the basis of OHS risk assessments implemented at each facility (e.g. noise, particulate matter) (v) Provide information related to solid and hazardous waste management in Pakistan operations, including but not limited to waste management plans, waste types, amounts, final disposal of the wastes (e.g. recovery, reuse, disposal options)	09/30/2016	Completed
11	CCBPL shall formalize and implement its stakeholder engagement plan (SEP) including a grievance mechanism for stakeholders. (including clients, suppliers, contractors, distributors, service providers, regulatory and government agencies, and certification organizations)	09/30/2017	Completed