The company will comply with the applicable international regulations and standards of the air transport sector, including ICAO Standards and Recommended Practices, as well as with Serbian legal requirements, including any regulations and standards determined by the Serbian Civil Aviation Directorate (CAD) and technical requirements with respect to airport certification, construction and operation, which include reference to the IATA Airport Development Reference Manual (ADRM).

Policy

The Sponsor has a well-established environmental and social (E&S) policy framework which is publicly available on their website. In 2015, VINCI Airports SAS launched AIRPACT environmental policy that encompasses two pillars. The first pillar defines four main targets: (i) Airport Carbon Accreditation, (ii) ISO 14001 certification, (iii) energy intensity reduction by 20% of VINCI Airports between 2013 – 2020 and (iv) promoting a biodiversity conservation and sustainable management. The second pillar defines performance improvements program required for airports operated by the Sponsor in respect to: environmental and social management, reduction of water and energy consumption, improvement of waste sorting and recovery, noise management, biodiversity protection and preventing environmental contamination.   

Currently ANT does not have an overarching E&S policy. Consistent with its policies at the group level, the Concessionaire will establish an overarching E&S policy defining the environmental and social objectives and principles for ANT. The policy will be consistent with the principles of IFC’s Performance Standards and VINCI Airports’ E&S policy.  The company will communicate the policy to all levels of airport organization (ESAP item #1). 

Identification of Risks and Impacts

The company has undertaken an E&S due diligence assessment and a life and fire safety assessment (L&FS) of the ANT assets and operations to identify risks and impacts, to evaluate effectiveness of the management systems in place and its alignment with IFC’s Performance Standards and to review local regulatory compliance. The E&S due diligence identified corrective actions required that the company intends to implement.

A social baseline focused on ANT direct area of influence, with special focus on residential houses located in the proximity of the airport, including any unplanned settlement, has not been commissioned to date; the gap is addressed in ESAP item #2 and will include among other data sets: local demographics; current employment statistics; number of people employed at ANT; perceived community needs / expectations from the project; and identification of disadvantaged or marginalized groups that may be disproportionately affected by project construction and operations. As discussed in detail under Performance Standard 5, the company will also commission an assessment of the environmental and social impacts of land acquisition.

The identification of risks and impacts for the components of works program such as the temporary runway, natural gas-fired combined heat and power plant, wastewater treatment plant, and airport building is currently in the screening phase to define the scope of full-blown assessment. As addressed in ESAP item #3, the E&S assessments of the works will be performed to meet Serbian EIA legislation and IFC’s PS1 requirements. On the basis of the outcomes of the E&S impact assessments, the EPC Contractor will develop and implement the relevant construction E&S management plans (ESMPs), as required under ESAP item # 4.

Management Programs and Organizational Capacity

Since 2015, ANT operations have been based on management systems in line with ISO 9001:2008, ISO 14001:2004 and OHSAS 18001:2007. The airport has also adopted an Integrated Management System (IMS) Policy, stating management’s commitment to ensure that the quality, environmental and health and safety aspects of its operations are coordinated and managed in an integrated manner to ensure improved efficiency and effectiveness of the organization. However, to date the integration of the three management systems is limited. A review of the management systems revealed some gaps between the environmental aspects of relevance, as identified in the ISO 14001 documentation, and existing procedures in place. The CA defines an obligation for VINCI to upgrade the ANT management system to comply with new ISO 14001:2015 and ISO 45001:2018. The upgraded management systems will include an operational ESMP which will be defined and developed based on the results of the E&S assessments and will ensure compliance with IFC’s Performance Standards. The operational ESMP will include, among others, all required environmental monitoring programs for airport operations (ESAP item #5)  

The present ANT organization reflects a fragmentation of responsibilities and duties related to management of environmental, social health and safety aspects between different departments. The Concessionaire will (i) perform an analysis of the existing organizational capacity and (ii) based on outcomes upgrade the ANT E&S organizational structure. The Company will employ a qualified E&S manager as per ESAP item #6.  

Monitoring and Review 

As part of its upgraded management system, VINCI will establish procedures and allocate resources to monitor and measure the effectiveness of the ANT management programs and compliance with related Serbian legal requirements and/or contractual obligations and operational environmental and social management plans and activities. Further, the Concessionaire will document monitoring results and identify corrective and prevention actions in the amended management programs.

 Human Resources Policies and Procedures
A human resources (HR) policy and HR procedures in line with Serbian Labor Law are in place at ANT. The Serbian labor law reflects a commitment to the eight fundamental, four governance and 64 technical ILO conventions Serbia has ratified. The policy states the company’s commitments in all human resources areas including employees’ selection, training and education and career development. The policy also states the commitment to establishing and implementing a human resources management system which is materialized in a HR procedure in line with the Serbian Labor Law requirements. The employee rights and entitlements (including those pertaining to wages, working hours, overtime arrangements and compensation, benefits etc.) are communicated at employment and documented in individual work agreements signed with each employee as well as in a Collective Work Agreement.

Working Conditions and Terms of Employment

The Collective Work Agreement in line with the Serbian Labor Law is in place and addresses wage and benefits, wage deduction, hours of work, breaks, rest days, overtime arrangements and compensation.  Salary levels are defined based on position, education, specific requirements and responsibilities for the position and experience.

At the time of appraisal ANT had a total number of 1,716 direct employees of which 515 employed for definite period of 24 months, and 1201 employed for indefinite period. Additionally, ANT employs 654 staff in temporary jobs of maximum 120 days through third-party (youth) organizations (366 positions) and directly (288 positions). The Concessionaire will meet the requirements of the CA and Serbian labor law and, as part of the process, will engage with all its workforce to meet the requirements of IFC’s Performance Standard 2. 

Workers’ Organizations

Employees of ANT are free to join workers organizations. There are five workers unions established at ANT and 1,259 employees are enrolled as members is one of these organizations. There are regular monthly meetings held between ANT management and all the labor unions’ representatives.  A Collective Work Agreement is in place, signed between ANT members and these organizations and registered with the Ministry of Construction, Transport and Infrastructure of Serbia. The Collective Work Agreement is periodically revised and agreed between parties, and currently valid until 2019.

Non-discrimination and Equal Opportunities

As per the HR Procedure and information provided by the ANT representatives, employment is based on equal treatment and non-discrimination without reference to gender, age, nationality, race, religion, political affiliation, social origins, and family conditions. Wage levels are set in the Collective Work Agreement and are determined based on education, position, specific requirements and responsibilities for the position and experience. These are in line with non-discrimination principles and are not in correlation the gender, nationality, religion or other personal aspects of the employees.

Of the 1,716 total direct employees at ANT, 591 (34%) are women. 34 management positions (35.8%) are occupied by women, of which five (23.8%) represent top management positions and 29 (39.2%) are intermediate management positions.

The HR aspects of the works program will be addressed by the Construction ESMP that will be developed by the contracted EPC contractor as per ESAP # 4.

Child and Forced Labor

The child and forced labor aspects are appropriately regulated in Serbia. ANT complies with the Labor Code provisions and no child or forced labor aspects were identified.

Retrenchment

If any retrenchment of staff is required, an analysis of feasible alternatives to retrenchment as defined by ESAP item # 7 will be carried out. If no viable alternatives are identified and retrenchment is required, a Retrenchment Plan is to be defined by the company in line with the Labor Code of Serbia, and IFC PS2 provisions. Any such Retrenchment Plan will be developed in consultation with the workers unions and the Employment Agency. 

Occupational Health and Safety (OHS)

Since 2015, ANT has been managing OHS aspects in line with Serbian legal requirements and according to a management process accredited in line with OHSAS 18001:2007. The company will update the ANT OHS management system to comply with ISO 45001:2018. A target of zero accidents has been set by VINCI and, to achieve this and adequately monitor and improve ANT OHS performance, the company will: (i) update OHS risk assessment and procedures for all working positions; (ii) update OHS training program; (iii) update work-related accident repose plan; and (iv) update work-related injury recording procedure, using an internal monitoring tool (BaSAFE) used by the Sponsor at corporate level, as per ESAP item # 8.

Workers Engaged by Third Parties
Employment conditions for workers employed by the EPC Contractor will be consistent with principles included in the ANT HR policy and Procedures. Where possible, the EPC Contractor will be asked to prioritize employment of members of local communities.

Resource Efficiency

The company aims at developing and implementing an ISO 50001 energy management system for ANT which will result in more efficient use of energy. As a first step towards that objective, the Company will perform energy efficiency audit for ANT and, based on outcomes, define corrective actions (ESAP item # 9).

Greenhouse Gas (GHG) Emissions

The current operation at the airport contributes about 41,700 t CO2-equivalent per year in terms of GHG emissions.  VINCI Airports’ environmental policy (AIRPACT) commits to achieving Airport Carbon Accreditation for every airport in the portfolio, and the Company will work to attain this commitment at ANT as well. Upon replacing the existing heavy-fuel boiler plant with the new combined cooling, heat and power plant included in the works program, the CO2 emissions of ANT will be reduced by about 15,400 t CO2 yearly. VINCI is also planning a further reduction of about 2,500 t CO2 yearly upon the installation of the planned photovoltaic system by 2021.

Pollution Prevention
Air Emissions

The main stationary air emissions source associated with ANT operations is represented by the heavy oil fuel-fired boiler plant. The boiler plant consists of three operational boilers with the capacity of 9.3 MW each. ANT performs boiler plant emissions monitoring once a year, at the beginning of the heating season. As part of the project works, the Concessionaire will replace, by 2020, the existing plant with a cleaner and more efficient natural gas-fired system (consisting of three boilers) supplemented by a trigeneration unit with an output of 1,560 kW electrical and 1,580 kW thermal associated with an absorption chiller of 1,230 kW to generate electricity, heating and cooling. The total capacity of the trigeneration plant will be 44 MW thermal.  As part of the upgraded operational management system, the Company will establish an environmental monitoring program including air emission monitoring in line with Serbian regulation and applicable and relevant World Bank Group EHS Guideline requirements (ESAP item #5). 

Liquid Effluents

Sanitary wastewater generated by ANT is discharged, without treatment, into a municipal sewer system, which discharges the wastewaters into the Sava River. The storm water runoff from the paved areas and de-icing effluents are discharged, without pre-treatment, into Galovica Creek, a Sava River tributary. As per ESAP item # 10, VINCI will: (i) design and install a wastewater treatment plant, consisting of a moving bed bioreactor, for treatment of sanitary wastewaters with an approximate capacity of 750 m3/day; (ii) install a containment pond for storm water; (iii) install oil-water separators to treat storm water runoff from areas with potential for hydrocarbon spills; and (iv) install a containment pond for collection and proper treatment of wastewater from the de-icing platform.

As part of operational ESMP, the Concessionaire will define and implement a wastewater monitoring program in line with the Serbian legal requirements and applicable and relevant World Bank Group EHS Guideline requirements (ESAP item #5). 

Noise

As mentioned above a relevant number of residential houses, including some unplanned settlements, are located in proximity of the airport. These residential properties may potentially be exposed to noise impact from airport operations and may require implementation of noise prevention and control measures.

Aircraft landing and taking off are the main source of noise pollution. As per Noise Protection Act (OG 36/09 and 88/10) and Air Transport Law of Serbia (OG 66/15), adequate response to monitor and mitigate impacts of airport generated noise is the responsibility of several stakeholders, including public authorities e.g. Serbian Ministry of Transport, Serbian Ministry of Environmental Protection, Serbian Agency for Environmental Protection, Civil Aviation Directorate (CAD), air traffic control, airport operator, and airlines.

IFC was informed by CAD that noise mapping for ANT and the relevant noise mitigation plan in line with the requirements of the European Union Directive 2002/49 will be finalised by the end of 2020 by the Ministry of Environmental Protection and Ministry of Transport. As per information made publicly available by CAD, noise mitigation measures for ANT and flight operations, which are currently enforced, include take-off restrictions in the direction of Belgrade city and provision of aircraft noise certificates by airlines for approval by CAD.

As part of the actions under its responsibilities and control, the Concessionaire as ANT operator will prioritize the development and implementation of 24/7 noise monitoring program. Noise will be monitored using permanent noise monitoring stations and other tools such as departure monitoring, flight track profiles, use of the PCA (Point of Closest Approach) (ESAP item #11). As part of its commitment to noise pollution abatement and control, the Concessionaire will develop a noise mitigation plan for ANT in close cooperation with CAD (ESAP item #11).  The noise mitigation plan will be informed by the adoption of a Balanced Approach as required by the relevant EU directive (Directive 2002/30/EC of the European Parliament and of the Council of 26 March 2002 on the establishment of rules and procedures with regard to the introduction of noise related operating restrictions at Community airports). The EU Balanced Approach for managing airport operations noise comprises four principal elements: making airplanes quieter by setting noise standards; managing the land around airports in a sustainable way; adapting operational procedures to reduce the noise impact on the ground; and, if required, introducing operating restrictions. The noise mitigation plan among others will take into consideration the following mitigation actions: (i) in close collaboration  with Air Traffic Control and other key stakeholders listed above aircraft takeoff and landing routes will be reviewed to take into account the type of aircrafts in use and the current situation in terms of local sensitive noise receptors, including residential areas that have gradually encroached towards the limit of the airport; (ii) work with Air Traffic Control to review the flight zones and introduce more accurate methods and measures of aircraft control; (iii) airport operating times will meet governmental regulatory requirements; (iv) where noise is attributed to airside or groundside operations, distance attenuation and screening will be adopted where practicable; (v) all equipment e.g. auxiliary power units and ground support vehicles will be maintained in good working order; performance specifications for noise for new equipment, wherever possible, to ensure that the procured item is noise controlled; (vi) engine idling on the terminal aprons will be kept to a minimum; (vii) noise monitoring stations will be established based on predominant wind directions; noise sources; flight path, and population and noise contour modeling will be performed; (viii) a grievance management and monitoring system will be established, including the identification of designated person responsible for complaint investigation and resolution, and will be made publicly available; (ix) based on the monitoring results, sound insulation will be installed at selected households that are exposed to excess noise, if needed. The noise mitigation plan will clearly define roles and responsibilities of the company and other relevant parties and will define all necessary coordination mechanisms among relevant stakeholders for the implementation of the measures. 

The Concessionaire will promote the establishment of an ANT Environmental Advisory Committee (ESAP item #12) and will actively coordinate with relevant Serbian authorities and stakeholders for the implementation of the noise mitigation plan.

If the actions defined in the noise mitigation plan are not sufficient to meet noise standards that will be established by the GoS and will be applicable in the future, in accordance with the Air Transport Law (OG 66/15) the Concessionaire, as ANT operator, will be authorized to apply for the consent by CAD to implement and collect a noise surcharge for airlines (in accordance with Article 202 in the Air Transport Law) to offset the cost of any compensation or noise mitigation program.

The noise aspects of construction program will be addressed by construction ESMPs that will be developed by contracted EPC contractor as per ESAP item # 4

Solid and Hazardous Waste Management 

A waste management plan for ANT was approved by Serbian authorities in 2014. The E&S due diligence found that management practices at the airport for both hazardous and non-hazardous wastes require improvements. VINCI, as part of works program, will improve solid waste management at ANT by: (i) construction of a waste sorting building, (ii) construction of two non-hazardous waste storage areas, (iii) construction of a hazardous waste storage area, and (iv) update of the airport waste management plan in line with the local legal requirements and relevant and applicable WBG EHS general and sector guidelines as per ESAP item #13.

Construction waste generated by the works program will be managed by contracted EPC Contractor under the construction ESMP as required under the ESAP item # 4.

Hazardous Material Management

Hazardous materials used at ANT are mainly hydrocarbons, oils, lubricants, metal degreaser and de-icing agents, and fuels represent the main hazardous materials stored and handled. The airport operates a fuel tank-farm located in the central part of the airport premises. It comprises eight above-ground storage tanks and two underground storage tanks, with total capacity of 990.5 m3. Upgrade of the fuel tank farm is part of the works program. Based on hazard assessment outcomes, the Concessionaire will develop and implement a hazardous material management plan and spill prevention and response plan that are commensurate with the potential risk present. This plan will be part of the operational ESMP as per item # 5.   

Historical Pollution

Areas of concern for potential historical pollution at the ANT include: the fuel tanks farm, former wastes storage area, old transformer stations, current solid waste open storage area, heavy oil-fired boiler plant, and equipment maintenance areas. The company will address E&S risk, particularly in respect to historical liabilities e.g. soil, groundwater contamination, as required and under the conditions agreed with the GoS. The Concessionaire will ensure that an environmental site assessment (ESA) is carried out. In that respect, at the time of appraisal, a specialized consultant (ERM) performed a Phase I ESA in accordance with the scope of ASTM International Standard E-1527-13. The Phase I ESA identified four areas at the site with the presence or likely presence of hazardous substances or petroleum products in, on, or at a property and eight areas of potential concern. A Phase II ESA in accordance with ASTM E1903 will be carried out to provide information on the site environmental conditions. Based on Phase II ESA outcomes, the company will prepare and implement required decontamination activities in accordance with Serbian legal requirements as per ESAP item #14. 

Management of Grassed Areas

Pesticides are used at ANT for management of grassed areas for bird deterring and bird strikes control purposes. The activity is performed based on International Bird Strike Committee (IBSC) recommendations, including a long grass policy. Proper selection, storage and handling of herbicides following the hazardous materials storage and handling management practices in the General EHS Guidelines can prevent / mitigate risks of soil, surface and underground water contamination. Therefore, the Concessionaire will perform an assessment of the current use and management of pesticide, herbicides and other agricultural chemicals and based on outcomes develop and implement an integrated plan for the management of grassed areas, as per ESAP item #15.                                                  

Public Safety Zones 

The highly infrequent, but potentially catastrophic, failure of aircraft during the landing and takeoff cycle may potentially to affect local communities located in the proximity of ANT as noted above. The purpose of establishing public safety zones for ANT in accordance with good international industry practices will be to protect the local communities and the public at large from hazards associated with aircraft and airport operations and mitigate the relevant risks. The Concessionaire will proactively engage and collaborate with the responsible Serbian authorities to: (i) calculate risk and identify a quantifiable risk contour off the ends of ANT runway based on runway use statistics correlated against international crash data, (ii) identify and establish ANT public safety zones, and (iii) reflect established ANT public safety zones in the land use planning and zoning of the airport plans as per ESAP item #16.

Emergency Preparedness and Response 

An emergency response procedure prepared in line with the Air Transport Law is in place. It addresses aircraft safety (e.g. incidents, accidents) and security (terrorism, hijacking, explosive devices etc.). The procedure defines the course of action for response to emergency situations and describes cooperation between ANT and public services including police, emergency situations directorate, civil aviation directorate, flight control etc. A fire protection plan is available in accordance with the Law on Fire Protection (OG 111/09) and addresses course of action and evacuation procedure in case of fire events. The company will review and update the emergency response procedures, to ensure that they meet national requirements and IFC’s Performance Standards, as per ESAP item #17. The procedure will also address natural disasters (earthquake, inclement weather etc.) in accordance with the Emergency Situations Law.

Infrastructure and Equipment Design and Safety

For the proposed investment, life and fire safety (L&FS) of publicly accessible buildings, such as the existing ANT terminal buildings, was a key aspect of IFC’s review. As part of their pre-concession preparation, the Sponsor contracted a specialized consultant to perform a L&FS audit against an internationally accepted life and fire safety (L&FS) standard such as NFPA 101 Life Safety Code, NFPA 415 Standard on Airport Terminal Buildings, Fueling Ramp Drainage, and Loading Walkways, NFPA- 5000 Building Construction and Safety Code, and NFPA 13 - Standard for the Installation of Sprinkler Systems.  The L&FS audit did identify some actions requiring immediate attention, primarily related to improved signage and monitoring/maintenance of fire detection and suppression systems, compartmentalization. The company will implement the corrective actions as per ESAP item # 18. L&FS improvements requiring structural changes will be addressed through the works program.
 

The Concessionaire will construct a new terminal as extension of the existing and its design will be in accordance with the national life and fire safety code of Serbia and internationally accepted life and fire safety (L&FS) standard as required by the relevant section of WBG General EHS Guidelines. A Life and Fire Safety Master Plan for the terminal will be developed and approved by third party specialized consultant acceptable to IFC as per ESAP item # 19. During operations, the company will maintain compliant life and fire safety conditions in all public facilities and periodically undergo audits by the relevant government agencies. A Life and Fire Safety Evacuation Plan will form part of the suite of ANT’s emergency preparedness and response plans.

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

The primary risk to community health and safety identified for the project construction works is associated with road traffic safety generated by the transport for construction materials, equipment and workers to and from the ANT. The EPC Contractor will develop, implement and maintain a traffic management plan that will define safety measures to minimize impacts on community health and safety outside the concession area, as part of the construction ESMP required under ESAP item, # 4.

Security Personnel 

Security related to airport visitors and passengers and protection of airport perimeter will be managed by a security contractor hired by the Concessionaire. All security employees will be screened, trained on Voluntary Principles of Security and Human Rights and have access to the Company’s Code of Conduct and grievance procedures. As a high-security zone, the airport is also guarded by government security forces to prevent sabotage, potential terrorist attacks and violation of immigration laws. Government security services act in accordance to their specific instructions and laws, which aim at preventing any breach of security and security abuses, and these services are independent from the airport operations and the company. The Concessionaire will coordinate its activities with the military and other security services and receive necessary clearances for personnel access to the runways and various other airport facilities. In addition to site security, the airport also hosts the representatives of customs and border patrol services and will coordinate with the respective agencies certain aspects of development of the project, such as design of the terminal and contractors’ access to site.

 The nearest protected area is an Important Bird and Biodiversity Area, IBA site RS040, Usce Save u Dunav (Sava and Danube Confluence). The distance between the ANT runway and the nearest part of the IBA is approximately 4 km to the east, in the direction of Belgrade. The IBA incorporates two legally protected areas: Velico Ratno Ostrovo (landscape of outstanding quality) and Zimovaliste Malog vranca (Pygmy Cormorant wintering site, a portion of the IBA site).

The IBA trigger species are tree Least Concern IUCN status species, including Black-crowned Night-heron (Nycticorax nycticorax) and White-tailed Sea-eagle (Haliaeetus albicilla), both breeding species, as well as the Pygmy Cormorant (Microcarbo pygmaeus), a wintering species.

Given the location of the protected areas and other areas with habitats including significant biodiversity value with respect to the airport, the E&S due diligence of ANT assets and operation practices did not identify significant risks related to the conservation of natural habitats or sensitive species. The E&S impact assessment required for the works program will include the development of a baseline and an assessment of risks and impacts on biodiversity in alignment with EU Habitats and Birds Directives, as applicable, and IFC’s PS 6. As needed, mitigations and monitoring measures will be developed as part of the E&S assessment process.

The Concessionaire will also conduct an assessment of ecological management aspects at ANT, including aspects such as bird and other wildlife deterring and suppression, vegetation management, pesticides/herbicides/agricultural chemical use and biodiversity monitoring. The outcomes of assessment will be reflected in the E&S assessment and relevant ecological or biodiversity management plan, consistent with IFC requirements, good international industry practices, and relevant policies of the Company.