There are no anticipated risks and potential impacts, due to the proposed investment, associated with the following Performance Standards:

PS 4 Community Health, Safety and Security: the site is located in an industrial area with no public access, and no incremental community health, safety or security risks were identified;

PS5: Land Acquisition and Involuntary Resettlement: the Project is located on the land within the current footprint of the port and no land take is required;

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

PS8: Cultural Heritage: the Project is located in an established industrial zone with low risk of biodiversity impacts and no impacts on cultural heritage;

PS7: Indigenous Peoples: there are no indigenous peoples in the Project’s area of influence.

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

This is category B project according to IFC’s Policy on Environmental and Social Sustainability because the Project is aimed at refinancing a bond and financing general corporate expenses in a brownfield asset (the port) and will not change the risk profile of the existing investment, involving limited E&S risks which can continue to be mitigated using standard engineering and E&S practices.

Environmental and Social Assessment and Management System and Policy

MIP has a corporate E&S policy and an environmental and social management system, ISO 14001 and OHSAS 18001 certified. Furthermore, the port meets the requirement of the International Ship and Port Facility Security Code. The ESMS is comprehensive and include relevant operational procedures, covering equipment operation safety, emergency preparedness and response, ship unloading/loading, E&S requirements for contractors, hazardous material management, solid and hazardous waste management. Based on IFC’s review, there are evidences of a robust implementation of the ESMS on the ground.

Identification of Risks and Impacts

The Environmental Impact Assessment (“EIA”) assessment for the expansion project in 2013 was carried out in compliance to Turkish regulations and reviewed against IFC requirements and a set of proposed mitigation measures designed to address identified gaps by an international E&S consultant. The mitigation measures identified in the EIA were implemented during the port expansion phase and have informed the relevant management measures for the port operations.

As required under its existing ESMS, MIP conducts environmental and occupational health and safety risk assessments for operations, where risks (e.g. working with heavy vehicles, chemicals, confined spaces) are identified and need to be mitigated.

Management Programs 

As per the agreed ESAP under the existing investment, MIP developed and implemented a construction phase environmental management plan for the expansion project. The required supplementary study assessing impacts associated with dredging activities was carried out and a biodiversity conservation and monitoring plan, a waste management plan and a hazardous materials management plan were developed and implemented.

The company has established management programs that describe mitigation and performance improvement measures and actions that address the identified environmental and social risks and impacts of the company’s operations which include standard operating procedures (SOPs), work instructions and inspection/audit program.

As part of its approach to risk assessment and management, the company has upgraded the drainage systems and revised the relevant plans to prevent flooding and associated adverse impacts, also in consideration of climate change risks.

Procedures and instructions are communicated to relevant personnel and appropriate training is provided to all employees.

Organizational Capacity and Competency

MIP has an effective and adequate E&S organization, directly reporting to the CEO. The EHS department is staffed by full-time safety and environmental engineers. Specifically, there are about 40 EHS staff which are managed by a qualified and experienced EHS manager. The EHS team is responsible for MIP’s own terminal operations as well as oversight of the operations of other port tenants (all tenants are required to comply with site rules and Turkish requirements). Trainings on environmental awareness, waste management etc. are provided regularly to all staff.

Emergency Preparedness and Response

The company has a documented on-site emergency preparedness and response plan (EPRP), consistent with IFC’s Performance Standard 1. The plan addresses relevant emergency scenarios (e.g., chemical spills, oil spills within the harbor, fire and explosion, natural disasters), their consequences, communications channels including neighboring communities and local authorities, roles and responsibilities for the credible scenarios; and evacuation procedures.

MIP has a security management plan with defined security risks and procedures. These procedures lay down operational protocols for security management of the port which include emergency communication and response. Security personnel are recruited, trained and managed through corporate security management unit in line with Turkish regulations and good international practices. Furthermore, MIP provides trainings on public relationship. Security personnel are examined regularly regarding to their physical, technical and psychological capabilities. The customs police are also at the port handling all the visitors (ship passengers and crew) that disembark at the MIP port. Overall, key roles and responsibilities for the security team include overall security management at MIP terminals including cargo and containers, and traffic regulations and management, according to an approved traffic scheme. Based on available information, there is no evidence of significant security incidents involving the security guards of MIP and local community members.

The site is monitored 24/7 through closed circuit TVs which also feeds information to a trained emergency response team. A dedicated emergency response specialist is part of the EHS team. In case of an emergency, MIP firefighting teams on site intervene with their own equipment and there is also an ambulance and medical center on site. If required, local fire authority is also noticed/informed for support.

Emergency drills are conducted regularly, and evacuation plans are visible plant wide, which involve the MIP in-house fire brigade, neighboring facilities, and the local fire brigade according to a scenario. All staff receive appropriate training on the implementation of EPRP. Fire extinguishers, hydrants are in good conditions and regularly maintained.

There is an ammonia pipeline passing through the port and belonging to a third party, a fertilizer company located 4 km away from the port. The third party company has its own dock to unload ammonia from vessels and transfer ammonia via the pipeline to the plant. According to MIP, specific emergency drills are carried out twice a year for accidental scenarios involving the ammonia pipeline and regular maintenance of the pipeline is performed by the fertilizer company. The fertilizer company conducted a Quantitative Risk Assessment which was shared with MIP. Accordingly, MIP identified and has implemented safety measures including warning signs, gas detection sensors, and other protections to minimize the risk of interferences with and damages to the pipeline (such as truck height sensor on the pipeline bridge), and annual maintenance by a licensed specialized company. The port’s staff, whose duty station is in the area crossed by the pipeline, have periodic training on the subject matter. As per agreed ESAP, the company will update its emergency preparedness and response plan and will coordinate with the third party operator of an ammonia pipeline crossing the port footprint, including relevant prevention, preparedness, and response measures, with due consideration of the needed assistance and collaboration with the Affected Communities, local government agencies, and other relevant parties (ESAP#1).

Monitoring and Review

MIP has a system in place to monitor and review key environmental, health and safety performance indicators including occupational health and safety, noise, air emissions, drinking water quality, effluent waste, storm drainage and contaminated runoff management, traffic management, generation and management of solid and hazardous waste.

Monitoring results are in line with local legislation requirements and relevant WBG’s EHS guidelines values. The company reports on standard safety related key performance indicators (KPIs) such as lost time accidents, work permits review, etc., and safety inspections are done periodically. MIP is also audited on a regular basis by the port authorities and Ministry of Environment and Urbanization. Non-conformities are monitored and extensively followed up by the management.

MIP currently employs a total of about 1950 direct employees and 900 contracted workers, as of September 2019. Third party workers are employed in main business operations as well as other supporting activities including cleaning and security.  A total of about 180 security staff contracted are working at the port for a private security company, Tepe Guvenlik (http://www.tepesavunma.com.tr/en/) with appropriate licenses to fulfill port security management in line with international security requirements for ports.

Human Resources Policies and Procedures

MIP has a human resources (HR) policy and HR procedures, as required by the local labor laws and consistent with provisions of IFC PS2. The HR policy defines general principles of freedom of association, training, and development, equal employment opportunities, performance management, non-discrimination, non-engagement of child labor and forced labor. The HR procedures are related to recruitment, probation, job descriptions, training, performance review, promotion, health benefits (insurance), salary and compensation working hours, resignation, retrenchment and termination are included in an employee handbook. HR policy and procedure trainings are incorporated in the induction of new employees and are available on intranet.

Working Conditions, Term of Employment, and Worker’s Organizations

All MIP workers below management level are members of the Maritime Union. There is a collective bargaining agreement in place between the union and MIP which is reviewed every three years. All employees receive a copy of their employment contract at time of employment that includes basic terms of employment such as contract duration, annual leave, wages and benefits and term for termination of the employment.

Non-discrimination and Equal Opportunity

The company’s HR policy specifies the commitment to diversity, non-discrimination and equal opportunity. As per policy, all hiring, and promotions are merit-based, and MIP does not make employment decisions on the basis of personal characteristics.

As outlined in its code of ethics and discipline procedures, any type of discrimination, violence and harassment are prohibited in MIP and in case of a violation discipline procedures are implemented. Additionally, MIP’s direct employees are trained on code of ethics principles. As per ESAP item #2, MIP will provide training on gender based violence for all staff (direct and contracted) including private security guards to increase awareness among the workforce. 

Grievance Mechanism

MIP has a formal employee grievance mechanism that is managed by the HR department. Grievances can be raised by the workers through the worker union representatives, an application form available on intranet, written and verbal communication to HR, and a dedicated phone number of the internal audit department. Any worker with concerns or feeling for unfair treatment are encouraged to report to the management or HR. This is also applicable for all contracted workers in the port. All the grievances are formally recorded, and MIP is committed to handling every grievance on a fair and equitable basis. The employees are informed of this procedure during induction.

Protecting the Work Force

The company has corporate policies against hiring of workers below the age of 18 years and forced labor. The HR teams check birth and school certificates during the hiring process. These requirements are also applicable to contractors and their subcontractors.

Occupational Health and Safety

As part of the ESAP for the first investment, existing OHS procedures were revised in accordance with IFC Performance Standard 2. The management system, which is certified OHSAS 18001, includes all relevant elements including work permits, personal protection equipment, material/tool handling etc. The company conducts job hazard analyses for all the key jobs and accordingly identifies and requires implementation of the risk mitigation measures. These have been documented through work instructions and SOPs and are prominently displayed throughout the facility. The company has a training program, including induction training and annual refreshment trainings.

There is an incident reporting mechanism in place which records all reportable injuries, first aid cases, near misses and lost time accidents along with cause of accident, immediate action taken, and correction actions planned and implemented. Lost Time Injuries Frequency Rates (LTIFR) at the port for 2018 was 14.98, below the international benchmark (18.5) for the sector. Port workers and users are required to wear appropriate personal protective equipment (PPE) on site. To strengthen the enforcement to use of PPE in high risk areas within the terminal for staff, crew, visitors, truck drivers and third part inspectors, MIP developed an occupational safety brochure for truck drivers entering the port. This covers basic safety rules which are required to be followed by truck drivers as well as ship crew and other third parties. MIP has also developed, and proposed to the authorities, a penalty system to minimize unsafe behaviors/actions inside port facilities by truck drivers.

Contractors working on site are required to operate with a permit to work system based on a risk assessment undertaken in relation to their work activities. Contractor and sub-contractor agreements include employment conditions and requirements to meet MIP HSE requirements.

Resource Efficiency and GHG Emissions

Electricity is supplied by industry zone’s grid, complemented by diesel-fired back-up generators. To reduce electricity consumption, the company switched to LED lighting in the offices and within the port; Rubber Tired Gantry cranes are being converted from diesel fuel to electric power. Furthermore, solar panels are used to complement and provide power for uses such as hot water supply in kitchen, and supply of electricity in the engineering building.

MIP tracks carbon dioxide (CO2) equivalent emissions on a monthly basis via a corporate reporting system; based on energy consumption data available, the total GHG emissions calculated are about 28,000 tonnes of CO2e/year.

Water Use and Wastewater Treatment

At MIP, water is mainly used for sanitary purposes, firefighting and cleaning mobile equipments. Bilge water is collected, it is treated on-site, treated clean waste water is discharged to the municipal sewage network for further treatment. The sludge is removed by a third party company.  Washing water of vehicles (empty container handlers, Terberg, MHC, forklift etc.) is collected in catch basins with oil-water separator and treated. Treated clean waste water is discharged to the municipal sewage system. The water quality is monitored by yard inspectors and storm water runoff free of contamination is discharged to the sea. Sewage and grey water that are taken from ships using the port is discharged to the municipal sewage network. 

Air Emissions and Noise

The company monitors dust (PM10) and noise as per local regulatory requirements. The levels measured are consistent with WBG EHS guideline values.

Solid and Hazardous Waste Management

The bulk of the wastes dealt with by MIP as port operator are those generated by ships, which port is licensed to collect. If other types of waste need to be removed, MIP applies for permission to do so from the relevant authorities. The company has a license to store wastes on site on a temporary basis, after which they are removed by licensed waste management contractors. Solid waste (e.g. plastics, scrap metals, waste paper) and hazardous wastes (e.g. drums, batteries) are segregated effectively and disposed by a licensed third party. Secondary containments were implemented to all waste oil or hazardous materials storage drums/containers.

Maintenance dredging is seldom needed at the port. Once needed, the company carries out the required assessments and applies for the necessary environmental permits from the local governmental agencies. After dredging is permitted, it is conducted by a licensed company. Sediments are tested for their quality and, if parameters are within the limits approved by the authorities, dredged material is discharged to an authorized location. 

Hazardous Materials Handling

Hazardous materials are stored in the port’s maintenance yard and typically include oils, diesel fuel and degreasing agents used in maintenance activities, with secondary containment, and material safety data sheets (“MSDS”) posted nearby.

Hazardous and flammable cargos, such as industrial chemicals, are stored in an open area within the port and handled in accordance with International Maritime Dangerous Goods Code. Proper firefighting equipment is available.

 MIP holds monthly meetings with the municipality, port authorities, Ministry of Environment and Urbanization, and the governor of Mersin to discuss E&S matters. Minutes of these meetings are kept, and no significant environmental and social issues have been reported in recent years.

MIP has an existing external grievance mechanism accessible from its web site and phone, which provides external stakeholders with the opportunity to ask questions, make suggestions or file a complaint. Any complaints and suggestions are dealt with by the Public Relations office & Marketing department, evaluated and directed toward the relevant department(s) for a response.

MIP developed a Stakeholder Engagement Plan (SEP) for the construction phase of the expansion project. The plan identified key stakeholders and engagement channels. As part of this proposed investment, the SEP will be updated with respect to: (i) stakeholder mapping; (ii) identification of key concerns and expectations; (iii) community grievance mechanism; (iv) details on engagement strategy, information disclosure, monitoring, reporting and keeping the records and (v) ongoing disclosure of information to key stakeholders. (ESAP#3).

Contact Person: Stef De Wild

Company Name: Mersin Uluslararasi Liman Isletmeciligi A.S.

Address: Yenimahalle 101.Cad. 5307 Sk. No:5, Mersin - Turkey

Email: sdwild@mersinport.com.tr

Phone: +903242412900