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
All of Martur’s facilities are already operational for some years now and no greenfield developments are foreseen under the project at the time of the appraisal. The project will involve only installation of new machines in the existing industrial premises, and no new land will be required for the proposed expansion project. As such, there will be no physical or economic displacement of people and involuntary resettlement. Furthermore, most of the Martur and its subsidiaries’ locations are within or near to well established industrial areas, and no impacts on biodiversity are expected. Similarly, there are no indigenous peoples or areas of high cultural heritage value in the project area of influence. As a result, PSs 5, 6, 7 and 8 are not considered applicable to this project.

In accordance with IFC’s Environmental and Social Review Procedure and Policy on Social and Environmental Sustainability the project is categorized as a 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 E&S management and monitoring systems covering all its operations and facilities; (ii) consistent management of labor and working conditions, and operational health and safety (OHS) procedures and practices across all the facilities; (iii) monitoring and management of air emissions, waste, wastewater and hazardous materials, and iv) and community health and safety in case of potential emergencies.

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:

As part of its commitment to Global Compact principles and its responsibilities towards clients’ sustainability programs, the company adopted corporate E&S policies applicable for Martur Turkey and Fompak facilities. This policy disclosed in the company’s website (http://www.martur.com.tr/assets/policies/policies-environment.pdf) covers commitment on legal compliance, increasing OHS awareness and performance, environmental risk assessment and mitigation, resource efficiency and sustainability.



As per the attached ESAP action item #1, the scope of the E&S policy shall be amended to articulate its commitment to comply with IFC PS and a clear statement regarding the applicability of this policy to cover all the facilities of Martur and subsidiaries.



Identification of Risks and Impacts:

The company’s expansion projects are mostly composed of acquiring new machines or equipment for production of new orders. Hence, according to environmental impact assessment (EIA) regulation in the countries of operation, the existing facilities of Martur and its subsidiaries are out of the scope of EIA requirements. However, Martur uses an E&S due diligence assessment checklist to evaluate OHS, waste generation, energy efficiency, maintenance, and quality documentation criteria for each new project. In case of larger investments, such as establishment of new assets or large expansion of existing plants, the company works with local consultants to undertake a full-fledged EIA study as required by regulations and/or evaluate potential negative E&S impacts and development of the corrective actions prescribed by authorities to avoid, mitigate or compensate identified adverse impacts.



Management Programs:

While, the scope of application and implementation of the management system varies, most of Martur’s subsidiaries have basic management systems in place to ensure compliance with the local legal requirements, that is commensurate with the scale and complexities associated with operations at each facility. However, the E&S management system is not consistently implemented across all the facilities and subsidiaries of Martur.



For instance, Martur’s central corporate E&S management system only cover its 7 facilities in Turkey and rely on plant/subsidiary based management systems for its other operations. Moreover, Martur facilities and Fompak in Turkey and Romania are certified for international E&S management systems such as ISO16949, quality management system; ISO 14001, environmental management system and OHSAS 18001, OHS management system, and ISO 50001, energy management system.



Consistent with the IFC requirements and its corporate policy as specified under ESAP action item#2, Martur will conduct a review and gap analysis of existing management systems across all facilities and develop an action plan to implement corporate level policies and standard operating procedures (SOPs) that will build upon the existing management systems across
various facilities, to achieve consistent E&S management and performance. For this purpose, Martur will, at minimum, develop SOPs at corporate level for (i) corporate oversight for E&S and OHS related regulatory compliance, (ii) establishing and oversight for company-wide targets for continuous improvement in E&S performance towards good international industry practices and (iii) compiling standardized E&S key performance indicators (KPIs) collected from all facilities as the groundwork for group wide E&S reporting (ESAP#2)



Organizational Capacity and Competency:

Environmental and OHS issues in Martur facilities as well as its subsidiaries at Bestal, Indesta and Berk in Turkey are managed by an environmental management team composed of three environmental specialists as required by Turkish environmental law. Environmental specialists from this team pay visits to the plants 2-3 times every month and conduct bi-monthly meetings with the staff responsible for environmental and OHS management including production mangers, shift supervisors and safety teams at each plant.



At least one full time OHS specialist is working in every Martur premises and they work in collaboration with the environmental management team. In addition, health and safety committees are established in the company’s every facility in Turkey as required by the local law. Fompak, Martur Romania, Algeria and Russia have their separate environmental and OHS teams that are currently out of direct purview of the environmental management team. .



As per ESAP action item#2 and #3, the company will therefore formalize its corporate E&S organizational structure covering all the facilities of Martur and its subsidiaries by designating a qualified E&S coordinator/manager at the corporate level to ensure that consistent E&S and OHS management systems are implemented, monitored and reviewed at all operations of Martur and its subsidiaries.



Emergency Preparedness and Response:

Emergency preparedness and response plans appropriate to specific potential risks including life and fire, safety, earthquake, sabotage and terrorist attacks, explosion, natural disasters, environmental contamination and traffic accidents are documented and maintained in accordance with local laws at each individual plant. These emergency plans further details instructions on how to react in an emergency situation, the roles and responsibilities of emergency situation coordination units, communication mechanism to be used, relevant contact people and numbers and description of fire extinguishing equipment.



The fire detection and suppression system established at each plant varies according to the type of the operations run. In this respect, all of the plants have automatic and manual fire detection systems; sprinkler or dry fire extinguishing systems. For chemical tanks used in foam production, nitrogen blanket system is utilized. Emergency equipment including manual alarm, extinguishing equipment
, detectors, fire hydrants are controlled and necessary maintenance is implemented regularly. Fire drills are also implemented regularly.



Monitoring and Review:

Martur conducted comprehensive internal due diligence of its individual operation vis-à-vis the applicable regulatory requirements and has developed environmental monitoring and measurement plans for its each facility. The monitoring parameters include emissions, workplace conditions, hazardous wastes, recyclable wastes, electricity, natural gas water and diesel consumptions, maintenance applications such as lifts, forklifts, boilers, tanks and compressors, personnel health controls such as x-ray scanning, audio tests, blood tests, periodical health check-ups, respiratory function tests are annually conducted.



Furthermore, internationally certified Martur and Fompak plants are also monitored for the identified E&S performance indicators such as lost time incidents and related statistics, solid and hazardous wastes, electroplating sludge, water and energy consumption, training statistics.



Monitoring results are reviewed by the general manager in Fompak and quality management systems director in Martur. Top management reviews the KPIs including incidents and accidents, monthly. As spelled out in the ESAP action item #2, Martur will update its internal reporting system, develop formats for EHS reports approved by Martur senior management and provide the report templates that will compile qualitative and quantitative performance data across all its subsidiaries. This will form the basis of annual E&S reporting to be submitted to the corporate-level senior management, as well as for the public disclosure through sustainability reporting whenever the company choses to do so in the future.

Martur employs around 4,850 as of 2016 all in its facilities/offices including its subsidiary companies in Turkey, Russia, Romania and Algeria, as well as its design offices in France, Italy, Germany, Russia and Romania.

Third party workers are employed in cleaning, catering, bus transport and some maintenance services. Only in Romania, many of blue-collar workers (403 of 420) are engaged through an employment agency based on short-term contracts. All other employees are engaged through long-term contracts.
The company expansion is expected to create a 17% increase in Marturs workforce directly and new jobs at its suppliers.

Human Resources Policies and Procedures:
Human resources (HR) policy, systems and procedures are centrally designed and applied to all Ustunberk Holding companies and are consistent with local labor laws and IFC PS2. Corporate HR department coordinates with the HR teams at each facility and ensures that necessary adjustments are made to align with the national laws of the country.

Compliance of facilities with labor laws of respective locations is currently followed through compliance charts in Turkey and this system is expected to expand to other locations of Martur and the subsidiaries as specified under ESAP #6 under PS2.

All workers engaged by the Company are given employees handbook together with the labour contract, which articulates their rights under Turkey, Russia, Romania and Algeria labor regulations respectively, and any applicable labor agreements, including working hours, compensation, benefits, maternity, holiday and disciplinary procedures, ethics code, HR policy, performance management, training, health and safety policy, company presentation and certifications, emergency management and corporate social responsibility (CSR) policy.

Grievance Mechanism:
There are different channels for receiving and addressing worker grievances in Martur and subsidiary facilities. Grievances can be received through the worker representatives system which is currently present only in the facilities in Kutahya, Bursa and partially in Romania. A suggestion system is present in all facilities, accessible through SAP (via kiosks for blue-collar workers) or suggestion boxes, which seems mainly focused on quality improvement.

For all the facilities in Turkey, there is an ethics e-mail for reporting violation of business ethics policy by any personnel, provided by Ustunberk Holding. These submissions are handled by the Ethics Committee reporting to the chairman of the board. The employees are informed of this procedure during recruitment however, visibility of the ethics e-mail was not observed in the facilities.

In cases where none of these channels is prevalent, the general practice is to raise the grievances with supervisors or HR teams. As per ESAP action item #4, Martur shall develop a formalized grievance mechanism including a procedure for receiving and handling grievances, which will be implemented and communicated identically across all its locations, covering both direct and contractor employees. This formal grievance process provides alternatives for employees to raise concerns other than to immediate supervisors and allows grievances to be presented anonymously without the risk of oppression.

Workers Engaged by Third Parties:
Martur has a contractor management policy and handbook applicable to all its subsidiaries. All contractor workers are required to abide by OHS rules of Martur and show proof of their social security registration as required by their contracts. The records of all contractor workers and the contractors regulatory compliance as well as the environmental risk assessment of the contractor company are maintained in the contractor management system.

For all facilities, catering, transport, cleaning, construction and some maintenance services are contracted. Moreover, as specified in the previous sections, many of blue-collar workers (403 of 420) in Romania are employed through an intermediary agency (IHM Total Consult). Martur management sees this as a transitionary arrangement due to being a new entrant to Romanian market and states that they aim to directly employ the trained workforce in the long run. IHM Total Consult is one of the largest employment agencies operating in Romania, working with several well-known national and multinational clients. As per their contract explaining their duties and rights, the workers are entitled to working hours, wage and annual paid leave rights as rest of Martur workers.

There are specific hygiene and evaluation procedures for the catering services and the contractors are required to be ISO 22000 HACCP (Hazard Analysis and Critical Control Points) certified. All contractors are annually audited. They are also shadowed by in-house employees in charge of catering and transport.

All contractor employees to work in Martur or subsidiary sites are required to undergo a 2 hours OHS training and additional trainings based on the specific requirements of the site. They have to score 70% marks from the following examination to have access to sites. The managers/owners of contractor companies are also trained once per year.

Main logistic supplier for Martur and subsidiaries is Rento fleet management, which is another Ustunberk Holding company. A risk analysis report for the fleet services in Bursa is prepared, all transportation employees receive OHS training and guidelines, including each transportation workers obligations and responsibilities. There are no major accidents reported.

Working Conditions and Terms of Employment:
The company has established Employee Relation Procedures and has a HR Manual in line with labor laws and IFC PS2 requirements applicable to all operations. Employees either work in a 3 or 2-shift system based on production needs of the section. In the 3-shift system, each employee works in shifts of 7.5 hours with lunch and two short breaks, for 6 days of the week. In 2-shift system, each employee works in shifts of 9 hours for 5 days of the week. During the month of August, production is halted for 2 weeks in all locations and workers are given their annual leaves. Other paid annual leave rights are defined in the employee handbook based on minimum requirements specified in national regulations.

Blue-collar workers wage is calculated based on their hourly work. The hourly rates are determined each year based on several factors: inflation rates, type of work, seniority of employees, union rates for relevant sectors, sectoral benchmarks, and minimum wage in respective countries.

In line with the overtime procedure, overtime work requests are communicated to workers at least one day in advance and a formal request has to be made through the SAP. Overtime payments are being made in line with country specific regulations.

Fringe benefits are offered depending on country or location, including bank promotions, food or fuel supply for the family, social gatherings etc. Workers can also benefit from the workplace dietician and the psychologist. Food during working hours is offered either in plant cafeterias or in the form of lunch tickets. Bus transport is also provided.

Workers Organization:
Martur and subsidiary employees are considered free to become member of the unions, though this is not explicitly articulated in the HR policy of the company. Currently there are no active workers unions at any of the Martur or subsidiary facilities in Turkey and abroad.

Martur implements its own employee representation system. Representatives elected through secret votes for each group of 30 workers, have direct semi-annual meetings with top management. Pay rises and fringe benefits are negotiated in these meetings without constituting a formal collective bargaining agreement, also the companys overall strategies are shared. Representatives, also work with HR department regularly. The worker representatives system is currently present in Bursa and Kutahya and it is anticipated to be expanded to other locations. A similar system and a formal collective bargaining agreement is in place only for white collar workers in Romania, as it is required for companies employing more than 20 workers.

As per ESAP action item #5a, Martur shall include a statement in its HR policy and the employee handbook to express recognition and respect of employees rights to join a lawful organization of their own choosing and commitment to comply with the laws pertaining to freedom of association and collective bargaining across all its locations, whether there is a representation system or not.

Non-discrimination and Equal Opportunity:
Martur has a business ethics policy disclosed on its website, covering all its operations, committing to ensure a fair work environment, being an equal opportunity employer, respecting privacy of employees and confidentiality of their information, and also expressing intolerance for any discrimination based on language, race, sexual and political orientation, belief, religion, sect, age, physical disability and other reasons whatsoever.

Martur management is committed to raise share of women employees to 35%, which is currently 25%. Seat cover sewing sections in Pitesti (Romania) and Kutahya (Turkey) were observed to be composed almost 100% by women. In both locations, Martur had a positive impact in economic empowerment of women, by training and recruiting housewives to become wage earners. Kindergarten is provided to employees kids in Kutahya as required by national regulations in Turkey. Screening of local regulations defining conditions of womens employment, maternity rights, night work, and specifications regarding establishment and operation of kindergartens and breastfeeding rooms is coordinated by Martur HR department for all Martur and subsidiary operations.

Retrenchment:
Martur generally has an increasing number of workforce. However, as the car industry is prone to impacts of economic crisis, only major retrenchment had occurred in following the 2008 global crisis. A case by case approach was adopted towards each worker, providing them retraining, transfer or compensation schemes. As per ESAP action item #5b, Martur shall incorporate into its HR policy/procedures a formal statement regarding its retrenchment policy expressing commitment to prepare a plan when necessary applicable to all its subsidiaries, in line with IFCs Good Practice Note on Managing Retrenchment and PS2 requirements.

Protecting the Work Force:
The Business Ethics Policy and Rules of Martur applicable to all its operations states that `employment of children is strictly prohibited and may not be tolerated`. The HR policy states corporate minimum working age as 18 years old and involves adequate verification mechanisms for workers both in Martur facilities and contractors.

Only in Algeria where national laws permit hazardous work between 16-18 years old, Martur currently has two out of 99 employees within this range who are only assigned simple legwork in assembly operations and trainees from vocational schools in other locations. As per ESAP action item #6, Martur shall develop a documented HR procedure for its facility in Algeria, for managing adolescent workers; which will include (i) a list of the hazardous operations based on a complete risk assessment, where adolescent workers between 16-18 years old, shall not be allowed to work in line with its corporate HR policy and, (ii) maximum allowable 40 hours of work per week subject to the work being age appropriate, nonhazardous, not jeopardizing their physical, mental or moral health. Martur will also integrate these procedures into its OHS management procedures.

Martur is not employing any forced labor, in line with its business ethics policy and relevant country regulations.

Occupational Health and Safety:
All the facilities of Martur (7 in number) and its subsidiary Fompak (5 facilities) have implemented OHSAS 18001 management system including Martur Romania. Facilities of their subsidiaries viz. Bestal, Berk, Indesta in Turkey and Martur Internationals facilities in Russia and Algeria (in total 5 plants) currently do not have such certified OHS management systems.

The OHS management system including a screening and monitoring mechanism for OHS related regulatory requirements; as well as improvement plans based on risk assessment exist in the certified plants. These risk assessment studies identify source of the environmental impact/hazard/risk; potential root causes; exposed persons, environment, material or facility; potential risks with risk calculation table; related legal requirements; corrective actions identified and implemented; responsibilities and risk calculation after corrective actions.

Martur aims to minimize any equipment related incident by choosing proper technologies. The forklifts and automated guided vehicles (AGV) are equipped with speed control mechanisms (maximum 10 km/hr) and photocell system to avoid collisions by auto-stopping. The pressing and metal stamping machines used manually by workers in Bestal are equipped with photocells and censors to avoid hand trapping.

Martur and subsidiaries have adequate organizational capacity to plan, manage and audit OHS issues at company and plant level. OHS issues are managed by plant level OHS teams supervised indirectly by Marturs central OHS team and are generally observed to be in line with corporate procedures, national and the OHS risks of the operations of respective facilities. During site visits, strong OHS implementation was observed in all visited facilities in Turkey and Romania with adequate signage, demarcated walking ways, SOPs backed by regular peer-audits and OHS team audits. The degree of personal protective equipment (PPE) respect, voluntary audits and housekeeping varies among facilities and somewhat weaker implementation was observed in non-certified plants. The difference in OHS management was also based on different requirements imposed by OEM clients (some including peer-audits, specific awareness and award programmers etc.). As discussed under ESAP action item #2 PS1, Martur will conduct gap analysis for its OHS non-certified facilities vis-a-vis the certified facilities, and develop an improvement plan, SOPs for monitoring and audit procedures for the currently non-certified facilities.

Due to absence of a common workplace monitoring program, different practices are observed depending on country regulations, and the manufacturing process. In Romania, for instance, indoor air quality is measured instantaneously to check the amount of isocyanate, a hazardous chemical used in foam production which cause indoor VOC emissions. In Turkey, for similar process sections it is measured every two years as required by the national law together with heat, vibration, noise and light intensity measurements.

According to the workplace monitoring data for 2014 provided for all Martur and subsidiary plants in Turkey, the facilities were found to be generally in line with national and international standards (OSHA “ National Occupational Safety and Health Administration, NIOSH - National Institute for Occupational Safety and Health etc.). The indoor measurements for Algeria have not started and for Russia very basic reporting is available at this stage.

As per ESAP action item #7, Martur shall develop and implement a common workplace monitoring plan to be applied to all its subsidiaries, that cover at least annual monitoring of workplace including temperature, vibration, noise, illumination and volatile organic compounds (VOCs) in the workplace as per the World Bank Group (WBG) General EHS Guidelines. Moreover, for the workstations which involve working with hazardous substances (e.g. methylene chloride, isocyanate and others) this monitoring plan will include regular monitoring of relevant parameters (such as VOCs) to verify effectiveness of the air extractors and subsequent treatment of gas stream for removing VOCs.

Furthermore, as per ESAP action item #8, for its workstations that involve working with hazardous substances, Martur and subsidiaries shall review its air extraction and ventilation systems vis-à-vis the specific local regulatory requirements, the WBG EHS Guidelines on Metal, Plastic, Rubber Products Manufacturing; and the permissible short term exposure limits specified by OSHA for hazardous substances mentioned above. Depending on the outcomes of this review, the company shall take necessary measures such as: upgrade the air extraction, ventilation and appropriate gas treatment systems; restricting access / presence of any personnel without proper PPE in the area, and removal or complete isolation of unequipped workstations.

Martur has a zero incident policy and OHS incidents are among the monthly KPIs followed by top management for all Ustunberk Holding companies. The incident reporting system that also covers the contractors, tracks near misses and first aid incidents as well as lost time incidents. The reporting system in Algeria and Russia are about to be established. The frequency of lost time accidents are observed to be higher than international benchmark reference values in some facilities of Martur, but generally fall within benchmark values for Turkey. To reduce this gap, Marturs corporate environmental management team will conduct a thorough root cause analysis for the OHS performance gaps among the facilities, and develop an action plan that would involve more frequent audits, trainings and awareness programs and also update its OHS audit procedures to be consistent among all facilities as per ESAP action item #9.

As part of its workplace health and safety measures, Martur also pays attention to improve work ergonomics. Such ergonomics measures implemented at facilities range from trainings to OHS team members, conveyors and lifting supports to fit the operations into golden zone of workers, standing supports and ergonomic carpets for sewing workers who stand all day. Bearing in mind that ergonomic practices are not evenly present around all Martur facilities and considering the repetitive and intensive nature of the operations, Martur shall also develop an occupational disease monitoring program supported by necessary awareness raising measures and ergonomic supports to be applied to all its facilities as part of its workplace monitoring program as described in ESAP action item #8.

Supply Chain:
Martur has supplier screening mechanism for its facilities in Turkey, mainly focused at the contracting stage by requesting environmental and OHS risk assessment of the supplier and social security records of its employees.

Resource Efficiency:

Martur has established an energy policy indicating maximizing of energy efficiency goal of the company and means to achieve this goal such as: sustaining energy management system, meeting regulatory and client requirements, increasing awareness of significance of energy efficiency among its employees and using environment friendly – energy efficient machines/equipment and services.



To reduce water and energy consumption, the company has established several projects such as digital lighting control system, heat recovery system in compressors to warm up water, rain water collection system at the roofs, use of second quality water where possible etc. Potable water consumption, electricity and natural gas consumption of the employees and relevant mitigation actions are also continuously monitored.



In addition to these, process specific resource consumption data and mitigation measures are identified at plant and process basis. Accordingly, during 2015-2016, textile and yarn process water consumptions have been reduced by 15% and 7%, respectively.



Similarly, natural gas consumption in the stenters has been reduced by 3%. The company has implemented heat recovery systems from hot water system and waste stack gas emissions, installation of energy and water efficient machines and equipment and various isolation applications to achieve these results.



Water, electricity, natural gas and chemical consumptions in electrodeposition department are also monitored and mitigation actions are identified. Accordingly, reductions in water (12%), electricity (5%) and natural gas (4%) consumptions have been observed as a result of the implemented mitigation measures during 2015-2016. Chemical consumption is another indicator monitored in the electrodeposition process. Further reductions are expected, as a result of the pending action items identified in the scope of the 2016 management plans.



Following continuous improvement principles, the company encourages its employees to submit their suggestions for improvement in processes in terms of energy, water and resource consumption efficiency, through suggestion system available in the environment and OHS boards in production areas.



GHG Emissions:

The main source of greenhouse gas (GHG) emissions are from natural gas fired process equipment and electricity consumption in the plants, with a small contribution from the leakages of refrigerant from chiller systems. The main energy sources utilized in car seat production are natural gas, electricity, diesel used for backup generators and vehicles, welding gas and shield gases (i.e. CO2, oxygen and argon) for 2015.



In Martur, ISO 14064-1:2006 GHG verification statement has been obtained for only seat business. Accordingly, direct and energy indirect emissions of seat business are calculated as 2260 and 4482 tones CO2 equivalent for 2011, respectively.



Using the IFC’s Carbon Emission Estimator Tool (CEET), the total GHG e
missions from all the existing facilities of Martur and its subsidiaries have been estimated as 9890 tons CO2 equivalent per year. Actual records will be used to review amounts of tons CO2 equivalent per year that will be emitted from the expansion project once it is implemented and becomes operational.



Air Emissions:

Air emissions from Martur facilities are from the boilers and furnaces, fired by natural gas, and from the backup diesel generators.



The company has retained 3rd parties to conduct emission measurements at all applicable Martur plants and its subsidiaries in the scope of the environmental permit process in Turkey. According to the latest results, the company operations are in compliance with Turkish and Romanian regulations. The measurements are implemented once in two years in Turkey and twice a year in Romania facilities. According to the timeline, the company will submit updated emission measurement results in the annual monitoring reports, regularly.



Water and Wastewater:

As per the environmental permit conditions, the process wastewater from catephoretic coating, textile dyeing from Martur facilities, is discharged to the sewage system of the industrial zone management or city networks which subsequently provide appropriate wastewater treatment before final discharge to the receiving bodies.



Martur’s integrated seat production plant in Kutahya, where textile/yarn dyeing operations take place, have its own treatment system before its discharges to the treatment system of the industrial zone.



Solid and Hazardous Waste:

Solid and hazardous wastes are stored separately at designated areas within the facilities. Recyclable wastes such as plastics, cardboards, glass are collected and recycled by 3rd party licensed waste companies. Hazardous wastes are also separately collected and recovered/recycled where possible and disposed where not possible by the third party licensed companies.

Most of Martur facilities are located within organized industrial zones. Martur Romania plant is in 4 km distance to Cateasca village and Algeria plant is in the Es Senia district of Oran, generally populated by industrial facilities. Berk vehicle conversion plant is found within a residential development area in Bursa. The facilities located in industrial zones are often in close proximity with other facilities which host several workers.



Hazardous Materials Management and Safety:

The main hazardous materials used for all the processes for car seat manufacturing are polyol, isocyanates and other additives for foam production, phosphate, dyes, acids and alkali neutralization liquids for electroplating; oxygen, lubricants, grease, mineral and hydraulic oils and, ethyl alcohol for frame production finishing chemicals and lamination ink.



All Martur sites involve storage, transport and usage of hazardous chemicals as necessitated by the production processes. Hazardous materials are stored in well ventilated and isolated chemical storage or waste collection sites. Chemical tanks are equipped with spill pools. Material safety data sheets (MSDSs) and safe working instructions are provided to employees and kept in visible places. Raw material is directly brought by major suppliers who also conduct their own safety checks prior to the transfer. Appropriate fire extinguishing and spill prevention equipment is provided at designated areas.



Emergency Preparedness and Response:

Key risks from Martur operations to surrounding communities/facilities include fire, explosion and chemical/gas spills which would result. Powder dyes used in textiles, isocyanates used in foam are categorized as highly flammable substances which emit toxic fumes in case of a fire like most of other chemicals used in Martur operations. No specific provisions are observed in Martur’s facility based emergency preparedness and response plans (EPRPs) addressing possible risks and mitigation measures towards nearby communities/facilities other than emergency alarms which are already in place.

As per ESAP#10, Martur shall update the EPRPs for all facilities to ensure that risks posed to nearby communities and facilities are addressed by specifying means of alerting, disclosing information and providing cooperation in mitigation and extinguishing measures towards the communities, industrial zone administration, and adjacent facilities in case of any emergency in Martur facilities. Martur also needs to complete the EPRPs for its Algeria and Russia facilities in this respect.



Security Personnel:

Martur does not employ any armed security officers. Security at the plants is only used for regulating access to the plant and to the facilities. All the security personnel are under Martur’s payroll and subject to relevant company procedures and regulations.

The company maintains various social projects through support and finance contributions to education and training, providing internship and scholarship, and economic problems and improve the infrastructure within rural districts where Martur operates. In order to maintain its lead in the manufacturing techniques, the company is constantly in liaison with nearby education institutes to establish internships and in order to follow and apply new developments. The company, supports its employees’ successful children by providing scholarships.

For all Martur’s operations, Martur management puts special emphasis on providing employment at local level, especially to people from close-by impoverished communities and women, by establishing collaboration with local authorities. Examples of such collaboration was observed during site visits in Kutahya and Romania. Martur also has a social investment program at local level focused on education currently for its operations in Turkey, which in time is intended to expand to its international operations as well.

Martur is a member of the United Nations Global Compact and disclosing an annual sustainability report (http://www.unglobalcompact.org/system/attachments/cop_2015/195551/original/MARTUR-COP covering E&S aspects of its operations.

Mr. Yalcin Turker
Address: Eski Buyukdere Cad. Park Plaza No:14, Sisli/İstanbul, Turkey
Telephone: +90 212 345 0025
Email: mailto:yturker@martur.com.tr

Broad Community Support is not applicable for this project

Martur(38025) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Martur shall amend the scope of its environmental and social (E&S) policy to articulate its commitment to comply with IFC performance standards (PS) and a clear statement regarding the applicability of this policy to cover for all facilities and subsidiaries.	31-Dec-2016	Completed	Completed	12/31/2016
Further, Martur will conduct a gap analysis and develop an action plan to implement corporate level policies and standard operating procedures (SOPs), updated internal reporting system, formats for environment, health and safety (EHS) reports etc. as described in Environmental and Social Review Summary (ESRS), to achieve consistent E&S and operational health and safety (OHS) management and performance across various facilities.	30-Sep-2017	Completed	Completed	9/30/2017
Designate a qualified E&S coordinator/manager at the corporate level to ensure the E&S management system is implemented, monitored and reviewed at all operations of Martur and subsidiaries consistently.	31-Mar-2017	Completed	Completed	3/31/2017
Martur shall develop a formalized grievance mechanism and procedure which will be implemented and communicated identically across all its locations, covering both direct and contractor employees. This formal grievance process provides alternatives for employees to raise concerns other than to immediate supervisors and allows grievances to be presented anonymously without the risk of oppression.	31-Dec-2016	Completed	Completed	12/31/2016
Martur shall make necessary revisions its human resources (HR) policy/procedures and add statements that express a) recognition and respect of employees’ rights to join a lawful organization of their own choosing and commitment to comply with the laws pertaining to freedom of association and collective bargaining across all its locations, whether there is a representation system or not; b) its retrenchment policy and commitment to prepare a plan when necessary applicable to all its subsidiaries, in line with IFC’s Good Practice Note on Managing Retrenchment and PS2 requirements.	31-Oct-2016	Completed	Completed	10/31/2016
Martur shall develop a documented HR procedure for its facility in Algeria, for managing adolescent workers; which will include (i) a list of the hazardous operations based on a complete risk assessment, where adolescent workers between 16-18 years old, shall not be allowed to work in line with its corporate HR policy and; (ii) maximum allowable 40 hours of work per week subject to the work being age appropriate, nonhazardous, not jeopardizing their physical, mental or moral health. Martur will also be required to integrate these procedures into its OHS management procedures.	31-Dec-2016	Completed	Completed	12/31/2016
Develop and implement a common workplace monitoring plan for all its subsidiaries that cover at least annual monitoring of workplace including temperature, vibration, noise, illumination and volatile organic compounds (VOCs) in the workplace as per the World Bank Group (WBG) General EHS Guidelines. Moreover, for the workstations which involve working with hazardous substances (e.g. methylene chloride, isocyanate and others) this monitoring plan will include regular monitoring of relevant parameters (such as VOCs) to verify effectiveness of the air extractors and subsequent treatment of gas stream for removing VOCs.	30-Jun-2017	Completed	Completed	6/30/2017
For its workstations involving hazardous substances, Martur and subsidiaries shall review its air extraction and ventilation systems vis-à-vis the specific local regulatory requirements, the WBG EHS Guidelines on Metal, Plastic, Rubber Products Manufacturing; and the permissible short term exposure limits specified by Occupational Safety and Health Administration (OSHA) for hazardous substances mentioned above. Depending on the outcomes of this review, the company shall take necessary measures such as: upgrade the air extraction, ventilation and appropriate gas treatment systems; restricting access / presence of any personnel without proper personal protective equipment (PPE) in the area, and removal or complete isolation of unequipped workstations.	30-Jun-2017	Completed	Completed	6/30/2017
Martur will conduct a thorough root cause analysis for the OHS performance gaps among the facilities, and develop an action plan that would involve more frequent audits, trainings and awareness programs and also update its OHS audit procedures to be consistent among all facilities.	31-Mar-2017	Completed	Completed	3/31/2017
Martur shall update the Emergency Preparedness and Response Plans (EPRP) for all facilities to ensure that risks posed to nearby communities and facilities are addressed by specifying means of alerting, disclosing information and providing cooperation in mitigation and extinguishing measures towards the communities, industrial zone administration, and adjacent facilities in case of any emergency in Martur facilities. Martur also needs to complete the EPRP for its Algeria and Russia facilities in this respect.	30-Jun-2017	Completed	Completed	6/30/2017