This is a Category B project according to IFC's 2012 Environment and Social Sustainability Policy. The proposed project will have limited adverse E&S risks and/or impacts that are site-specific, reversible, and addressed through existing mitigation measures and good international industry practices (GIIPs). Key E&S risks and issues are (i) corporate and company-level ESMS to manage risks and impacts during construction and operations of the soybean crushing plant and warehouses, including contractor E&S management and safe working conditions; (ii) assurance of fair and safe labor and working conditions aligned with PS2 objectives; (iii) process/equipment safety plans, including assessment of explosion risks, HAZOP / Quantitative Risk Assessment (QRA); (iv) resource efficiency; (v) effluent treatment, solid and hazardous waste, noise and air emissions; (vi) emergency preparedness and response plan, including life and fire safety; (vii) stakeholder engagement and  community grievance mechanism; (viii) security issues; and (ix) traceability and risk screening of soybean/corn sourcing, including due diligence of third-party suppliers. 

Environmental and Social Policies. Tiryaki adopted a corporate level E&S Policy and implemented an Environmental and Social Management System (ESMS) aligned with ISO 14001 (Environment), ISO 45001 (Occupational Health and Safety – OHS), ISO 50001 (Energy) management systems and IFC PS requirements. Tiryaki’s EHS procedures cover waste management, air quality and dust control, noise reduction, supply chain management, emergency planning, OHS procedures, risk assessments, and instructions, and accident response, among others, which are aligned with WBG EHS Guidelines (General and Vegetable Oil Production and Processing). The roll-out of corporate E&S policies and management systems to Sama al Manar is scheduled before the commissioning of the plant. Sama Al Manar intends certifying this operation for ISO 9001/22000/HACCP (Quality/Food Safety/Hazard Assessment Critical Control Points), ISO 45001, ISO 14001, ISO 50001, ISO 28000 (Supply Chain) within 6-12 months after plant’s commissioning.

Identification of E&S Risks and Impacts. As per the Ministry of Environment (MoE) of Iraq (Law on Protection and Improvement on Environment, Nº27, 2009), industrial facilities located within the Umm Qasr Port are exempt of an ESIA study according to national regulations. Nevertheless, Sama Al Manar hired a consultancy to conduct an ESIA in October 2022 at IFC’s request. Based on the E&S Management Plan (ESMP) outlined in the ESIA, the company agrees to implement the mitigation measures and management plans through the project life cycle. Capital (CAPEX) and operational expenditures (OPEX) will be confirmed, upon completion of the ESIA, to ensure a time-bound implementation.

E&S Management System and Programs. The construction phase ESMS is focusing on OHS hazards and risk prevention. Based on field observations, the company is implementing these at the project site. Going forward, the company will review and update the construction phase ESMS to include provisions for waste management, working instructions, environmental monitoring, and spill management plan, in line with WBG EHS Guidelines and Good Practice Note (GPN) on Managing Contractors’ Environmental and Social Performance (ESAP#1). The operational phase ESMS is currently under preparation by the Quality/EHS teams and will be completed in line with IFC PS1 requirements (ESAP#1).The ESMS will define the roles and responsibilities of the company, its contractors and third-party suppliers and include: (a) EHS Policies aligned with IFC PSs; (b) risks assessment and management procedure for environment, OHS, and labor/social risks and impacts; (c) organizational EHS/HR function, including capacity and competency for effective implementation; (d) annual workplan for EHS training of employees and contracted workers; (e) emergency preparedness and response; (f) external communication procedures, including a community grievance mechanism; and (g) monitoring and reporting of EHS performance.

Organizational Capacity/Competency. Tiryaki assigned a corporate Quality/EHS manager who oversees E&S risks and impacts associated with the construction of the soybean crushing plant and warehouses to ensure a consistent approach to Quality/EHS issues across all its operations, including in Turkiye. Tiryaki E&S team’s role does not cover for operations outside of Turkiye. Going forward, Tiryaki will strengthen its E&S function for this project by assigning an environmental and OHS coordinator (ESAP#2). Sama al Manar E&S management is led by a team with a HSE manager and an environmental engineer. The team’s capacity will be strengthened with two additional members to be hired before the commissioning of the soybean crushing plant (ESAP#2). Each contractor has its own EHS chief and officers. Staff from various departments are trained on EHS management issues and responsible for safe practices and housekeeping. Performance objectives of all managers include OHS leading and lagging targets (e.g., Loss-Time Frequency Injury Rate (LTIFR), Loss-Time Accident (LTA), near miss and hazardous working conditions).

E&S Training. Tiryaki established a training program to ensure that staff competency levels are maintained and address any gaps. The HR manager updates the training plan, as needed, to include new training needs identified during the normal course of operations. EHS and fire safety training are given to all employees on a yearly basis. Staff engaged in food processing operations will be trained in food hygiene principles and practices. Sama al Manar employees receive site safety induction and emergency preparedness and response trainings. Subcontractor EHS staff delivers similar training for contracted workforces. A training matrix on E&S policies, procedures, management plans is being prepared and will be included in the company’s ESMS (ref. ESAP#1), to be delivered to workforces during operational phase.

Emergency Preparedness and Response. Tiryaki has a documented emergency preparedness and response plan, including dust explosion risks for its existing operations, which was adapted for the construction phase. The roles and responsibilities of employees responsible for evacuation, rescue, and firefighting are defined and displayed at various locations across the construction site. Evacuation route maps, assembly point signs, and water hose reels are placed at appropriate locations. Annual drills including contractors are conducted to ensure the implementation of fire safety measures. Fire precaution measure is implemented in worker and contractor accommodations. Several workers have been trained in fire safety and the operation of fire safety equipment, and construction workers will be required to receive similar training. The above will similarly apply to the operational phase and additionally include flood response and spill response plans in coordination with the port authority (ref. ESAP#1).

Monitoring and Reporting. An EHS monitoring program has been established at Tiryaki’s existing plants in Turkiye in compliance with relevant regulatory requirements, ISO14001, ISO 45001, and ISO 50001. Key Performance Indicators (KPIs) comprise resource efficiency - energy (electricity, natural gas and coal) and water consumption usage per ton of product, OHS leading/lagging indicators (LTIFR, near misses). KPIs reporting is discussed at monthly department meetings and annual management review process as per ISO 14001, 45001 and 50001 requirements. The management review topics include but are not limited to follow-up actions from previous management reviews; resource efficiency reduction targets; incident and accident statistics; review of system updating activities; internal and external audits results; and regulatory compliance allowing senior management to assess the project’s overall EHS compliance and performance. Sama al Manar will implement a similar monitoring and review mechanism, as part of the ESMS, for this project (ref. ESAP#1) covering the operational phase in line with IFC’s PS1 requirements. The monitoring mechanism will also have provisions for internal audits conducted by trained auditing team and external audits conducted by IQR international certification body. Tiryaki management will review the E&S monitoring reports, and audit findings regularly and will define corrective action plan with time-bound implementation schedule and assignment of CAPEX/OPEX, as required.

Supply Chain Risk Assessment and Management. Tiryaki’s primary products are pulses, nuts, and other products (oil seed, animal feed). More than 60% of overall sourcing is international whereas the remaining 40% is domestic. International sourcing is done from contracted farmers for organic products and organized markets (traders) for conventional products. Domestic sourcing is done through brokers. The supply chain departments maintain written specifications for products and requests the following documents to be shipped with every lot of incoming materials: health certificate; Genetically modified organisms (GMO) certificate with the shipment lot number; datasheet including pesticide residues and heavy metals analysis; product specifications; aflatoxin certificate; fumigations certificate; allergen information. Incoming lots are sampled and tested against certificates of analysis. Test results are maintained by the Quality Control Department. As part of IFC’s previous investment and aligned with PS2 and PS6 supply chain requirements, Tiryaki adopted a Supplier Code and expanded the scope of its supply chain’s assessment of suppliers in terms of labor and biodiversity-related risks in addition to the existing quality assessment system. Principles of the code will be reflected in the project’s purchasing process as explained under PS2 and PS6 sections.

 Tiryaki employs approximately 1,300 employees globally including its subsidiary companies. Sama al Manar currently employs 90 employees (50 of them at the project site). The plant construction will employ around 300 workers during peak, including contractors (250, as of Feb 2023). Construction workforce is partially hired under Sama al Manar (technical/design teams) and the balance by three major contractors.

Construction site operates on single shift basis. Shifts are reorganized during summer months to reduce occupational hazards due to climatic conditions. During the operations stage, Sama al Manar workforce will increase to 220 (with 160 employees at the plant). The company plans to employ all required staff and workers on direct payroll of Sama al Manar. The plant operational teams will be structured across three working shifts.

Human Resources Policies and Procedures. Tiryaki has in place an HR policy and procedures consistent with Turkish Labor Code and PS2 requirements. Tiryaki Social Compliance Policy acts as umbrella for guiding group-level operations on working conditions, Code of Conduct, avoidance of child labor and forced labor, non-discrimination and equal opportunities, anti-harassment, and recognition of freedom of association. Sama al Manar HR team developed an HR policy and procedures for the company operations (not inclusive of construction). The HR Policy outlines the terms of employment, work and rest periods, leave, compensation, benefits, recruitment, promotion and termination process, sanctions and disciplinary provisions. IFC’s review identified gaps with respect to contractor oversight, overtime arrangements, statements on avoidance of child labor and forced labor, equal opportunities and non-discrimination, anti-harassment, management of retrenchment, recognition of freedom of association and alternative means to organize. Sama al Manar will update its HR policy/procedures to be aligned with Tiryaki corporate HR framework, Iraq Labor Code and PS2 requirements (ESAP#3). In addition, Sama al Manar will develop a construction site Labor and Working Conditions Policy that will be applicable to all contractors’ workforce. Sama al Manar will include the Labor and Working Conditions Policy in the construction ESMS and the EPC contract and conduct periodic reviews of contractor working conditions and contracts to ensure compliance with its corporate policies (ref. ESAP#1). The company’s current site induction is focused on EHS and provided to the contractors by their own EHS teams. Sama al Manar will develop a company induction program for construction and operations which will inform the workforce on company’s policies, including HR, EHS, Code of Conduct and Grievance Mechanism.

Grievance Mechanism. Tiryaki has in place a Worker Grievance Mechanism developed in line with PS2 that’s accessible to the entire workforce, including contractors. Sama al Manar currently does not have a formal grievance mechanism and grievances are verbally raised to site supervisors or EHS manager and resolved immediately. Sama al Manar will develop and disclose to all workers (direct/contractor), a formal workers’ grievance mechanism (GM) in line with PS2, inclusive of culturally appropriate, confidential, and accessible channels, with possibility to submit anonymously (ESAP#4). The GM will also include suitable mechanisms for receiving and responding to gender-based violence (GBV) and harassment related grievances, with support from a qualified focal person for addressing sensitive grievances.

Workers Accommodation. Except for the workforce hired locally, all the workforce stays at the on-site worker camps. A formal worker accommodation plan was not prepared. The conditions of the worker camps are broadly aligned with PS2 (IFC/EBRD Guidance Note on Workers’ Accommodation), with further improvements needed with respect to consistency of available space/person, access to personal documentation and safe storage space, availability of first aid trained person and infirmary 24/7 and reducing exposure to noise (as some of the camps neighbor container handling operations at the port). Sama al Manar will develop a formal Worker Accommodation Plan in line with PS2 requirements and ensure periodic review of and adjustments in the conditions of the worker camps to align with the plan (ESAP#5).

Protecting the Work Force. Minimum employment age in the Republic of Iraq is 15. As per Tiryaki corporate policies, the project does not employ any workers below 18 years of age at the construction site. Iraq Labor Law prohibits forced and compulsory labor. There are expatriate workers at the construction site from Turkiye, all having freedom of mobility to and from the site. Sama al Manar HR policy and construction site labor and working conditions policy will include statements to prevent any form of child labor and forced labor associated to the project, to be periodically reviewed by internal audits (ESAP#3).

Workers’ Organizations. Tiryaki HR policy recognizes workers’ right to form and join unions and enter into collective bargaining agreement (CBA). Although Sama al Manar HR policy is silent on this aspect, Iraq Labor Code recognizes freedom of association and right to collective bargaining. In the country context, formation of independent unions is restricted as all workers must be part of the government-controlled General Federation of Iraqi Workers. Worker committees are also not common. Sama al Manar HR policy will include provisions to recognize workers freedom of association and collective bargaining as per PS2 and will not discourage any alternative mechanisms that would enable workers’ meaningful participation and negotiation (ref. ESAP#3).

Equal Opportunities and Non-Discrimination. Iraqi Labor Law prohibits harassment, direct or indirect discrimination and any violation of the principle of equal opportunities, in all matters relating to vocational training, recruitment, or the terms and conditions of employment. The law defines discrimination as any distinction, exclusion or preference based on race, color, sex, religion, religious community, opinion or political belief, origin or nationality; and indirect discrimination as any exclusion distinction or preference based on sex, age or health condition, economic or social condition, affiliation to a trade union, and trade union activity and which has the effect of nullifying or impairing equality of opportunity or equality of treatment in employment and occupation. Sama al Manar will prepare a Local Recruitment Plan to ensure hiring operations for the plant are conducted in a manner consistent with principles of equal opportunities and non-discrimination as defined by the Iraqi labor code and PS2, including formally defined criteria and processes (ESAP#6). Contextual risk screening for Iraq indicated high risks with respect to harassment and gender-based violence (GBV) and highlights weak institutional support. Sama al Manar strives to be an equal opportunities employer and has created work opportunities for women at the construction site and company operations while providing needed safety measures. The HR Policy of Sama al Manar will include provisions on equal opportunities and avoidance of harassment, discrimination, and GBV (ref. ESAP#3).

Occupational Health and Safety. Sama Al Manar has a comprehensive and well-implemented construction OHS management plan, procedures, risk analyses, and hazardous work permit system. The plan includes risk assessment, project safety management, pre-job OHS planning, trenching and excavation, work on roads, working environment, standalone working, extreme weather, housekeeping, safety signs, and signals,  work at height, work on fragile roof, lifeline, mobile elevated platform, ladders, scaffolding, mechanical lifting, slinging and rigging, mobile cranes, health hazards, compressed gas, flammable liquid, manual handling, power tools, electrical safety, lock out tag out (LOTO), confined spaces, hot work, personal protective equipment (PPE), arc flash clothing and PPE, emergency, fire prevention, medical treatment.

Accidents and near misses are recorded. Since the beginning of construction, no fatality has happened; two lost time accidents were recorded. Root cause analysis was conducted, and all corrective actions were completed to prevent any reoccurrence. LTIFR (Lost Time Incident Frequency) was 3.7 at the time of site visit, which is below international benchmark (US 2018 sector data - 4.5). Considering the increasing traffic on construction site, pedestrian, forklift, and truck routes will be physically separated following a site risk traffic risk assessment and foggy weather conditions and necessary precautions will be included in the risk assessment (ref. ESAP#1). Operational OHS procedures and hazardous work permit system, based on job hazard analysis are under preparation (ref. ESAP#1). Construction contractors were properly selected according to their experience and past OHS performance. During the site visit, good OHS practices were observed with necessary engineering and behavioral controls in line with GIIPs and safety hierarchy (e.g., securely fixed scaffolds, man lifts and scissor lifts, well-maintained/inspected cranes, PPE use as needed, implementation of hazardous work permits, fire extinguishers, visible evacuation plans, assembly points designated for both employees and each contractor company). Heat stress instruction and hydration program are in place and working hours/resting times are organized accordingly during construction. Drinking water is readily available close to work areas. To avoid any risks related to dehydration, urination awareness charts for workers are being prepared and urine testing will be implemented, especially during the summer season (May-October). In line with PS1/PS2, the company will establish the operational phase OHS management plan and procedures like the above, including the commissioning phase risks (ref. ESAP#1). Workplace noise exposure, thermal comfort, heat, volatile organic compounds, vibration, dust, and light intensity will be measured as per local legislation and WBG General EHS Guidelines. Based on measurements, engineering control, isolation, and PPE use precautions will be implemented (ref. ESAP#1).

Process Safety. The storage of grains represents a combustion risk, owing to the potential for self-heating and ignition. Silo safety for these products, as well as for oil storage, is critical. Dust explosion risk for soybean is low and silo safety measures are implemented for the project. Vegetable oil facilities present the risk of explosion resulting from the volatilization of hexane dissolved in the oil. Three insulated hexane storage tanks (3x120 tons capacity) will be installed for the oil extraction process. The company has prepared safety risk analysis for silos, preparation, extraction, meal warehouse, boiler, and wastewater. The analysis identifies hazards, potential consequences, and existing safeguards with risk ranking performed for the current risk position. Further safeguards are defined in engineering and administrative controls, and the risk is quantified based on the implementation of these additional precautions. The safety risk analysis focuses largely on OHS hazards, however major accident hazards, such as fires, explosions including dust explosions are also highlighted in this analysis. Safety risk assessments and process safety studies should provide further definitions of the magnitude of consequences and efficacy of engineered barriers. Sama Al Manar will (i) ensure EPC Contractor will develop a Construction Management Plan to highlight and set out how OHS risks are to be managed during the construction phase and will meet NFPA 36 (National Fire Protection Association) (Standard for Solvent Extraction Plants), NFPA 61 (Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities) standards; (ii) carry out HAZOP (Hazard and Operability Analyses), SIL (Safety Integrity Level), QRA (Quantitative Risk Assessment), FERA (Fire and Explosion Risk Assessment), and EERA (Escape and Evacuation Risk Assessment) studies; (iii) organize a human factors screening workshop, and prepare hazardous area classification drawings; (iv)  ensure fire and explosion prevention and protection philosophies are well-documented in accordance with good engineering practices, and translated into site operating procedures and corporate training programs (operations phase); (v) develop and implement a permit to work system to manage and control high risk activities including associated standard operating procedures for silo cleaning and other confined space entry activities at silos (operations phase risk assessment will ensure grain engulfment and entrapment hazards are suitably addressed) to minimize the operational safety risks. Furthermore, the company will conduct a pre-startup safety review (PSSR); develop a detailed operational readiness and process start-up program to be fully implemented before commissioning/ commencement of operation; all actions from HAZOP, SIL, QRA, FERA, EERA will be timely completed (ESAP#7).

Supply Chain. Forced labor and child labor risks in the supply of soybean and corn is low in the countries of origin (Brazil and Argentina), due to the mechanical production and harvesting methods. Tiryaki Supply Chain Code have clear provisions against child labor and forced labor in company’s supply chain. Risk assessment and due diligence of third-party suppliers are done. The sponsor only works with reputable suppliers who demonstrate compliance with forced labor and child labor policies. These principles will also be implemented for Sama al Manar soy and corn third-party suppliers.  

 Resource Efficiency. Electricity power requirements (around 3-3.5MW) in processes, air conditioning, and lighting is supplied by the port authority from Umm Qasr Power Plant (29.34 MW gas-fired captive power plant) located at the port. The gas for the power plant is sourced from Basra Gas Company via a dedicated pipeline. Three fuel oil fired steam boilers (one on stand-by) will be installed to meet the process steam demand of 35m3/h. A 14 m3/h of condensate will be recovered and reused according to the design mass balance. The engineering team of Sama Al Manar was investigating low sulfur content fuel oil during the site visit. Automation system, which EPC contractor will install, targets to optimize electricity, water, and steam use.

Greenhouse gas (GHG) emissions. Fuel oil-fired boilers, diesel use in transport fleets, and electricity use from the power plant are the main sources of air emissions. The project's operational direct (Scope 1) annual GHG emissions are expected to be 40,072 tCO2 equivalent. The company will quantify GHG emissions annually from the facilities owned or controlled within the physical project boundary (Scope 1) and indirect emissions associated with the off-site production of energy that the project uses (Scope 2) and report its GHG emissions in Annual Monitoring Report. Quantification of GHG emissions will be conducted using internationally recognized methodologies.

Water supply. Water demand for the process and steam generation is estimated as 72.3 m³/h and will be sourced through three permitted boreholes in the project premises. Groundwater will be treated in a water treatment plant equipped with filtration and reverse osmosis units. This system will reduce most parameters from high levels to acceptable use levels. Considering the water scarcity in Basra province, water use of all process units will be minimized and re-used, wherever possible, as brine generated by reverse osmosis will be re-used as the medium within the cooling water circuit, and condensate will be recovered and reused. The company will carry out a detailed hydrological sustainability assessment of the area to assess risks and impacts on groundwater resources and formulate/implement a water resource management plan (ref. ESAP#1) for the soybean crushing plant.

Wastewater. Industrial wastewater includes process wastewater stream from extraction units, utility operations, and miscellaneous activities, including wastewater from laboratories and equipment maintenance shops. The estimated quantity of wastewater from extraction system is 15 m3/hour. An advanced treatment system (21 m3/hour capacity) will treat the wastewater before being discharged to the sea. The sludge will be dewatered by means of a filter press and disposed of at a designated landfill. Based on technical specification available during this appraisal for the Wastewater Treatment plant, COD (Chemical Oxygen Demand), BOD5 (Biochemical Oxygen Demand), TSS (Total Suspended Solids), O&G (Oil and Grease) design discharge limits of WWTP will meet WBG EHS Guidelines for Vegetable Oil Production and Processing. Domestic wastewater will be collected in an impermeable septic tank and transferred to the municipal WWTP as per local legislation. The company agrees to integrate comprehensive water and wastewater quality management and monitoring programs, as part of the facility’s operational ESMS, which will comply with Iraqi Regulation Nº2 of 2001- Preservation of Water Resources, and WBG General EHS Guidelines (ref. ESAP#1). 

Air Emissions. Principal emission sources are gaseous and particulate emissions from fuel-oil-fired boiler operations, dust results from the processing and handling of grains, including cleaning, screening, and crushing of soybean, and VOC emissions caused by using the oil-extraction process using solvent (hexane). Solvent recovery (>99%) via distillation is part of the process, and the process areas will have exhaust systems at dust generation points. Baseline ambient air measurements and air quality modeling for the construction and operation phases were conducted as part of the ESIA process. In the modeling study, SO2, NOx, CO, and particulate matter (PM) from fuel oil-fired boilers, dust from the process, and VOCs from solvent extraction units are estimated under normal and abnormal operation scenarios. The results align with local legislation and WBG General EHS Guideline limits except for SO2 (scenario assumes fuel oil with 1.5% sulfur content). The company will investigate opportunities to use low-sulfur fuel (< 1% sulfur content) or preferably lower-sulfur fuel (<0.5% sulfur content) for operating boilers. The company will integrate an air quality monitoring program in the ESMS (ref. ESAP#1) to comply with the local legislation and WBG General EHS Guidelines (baseline ambient air SO2 measurements are higher than the limits in WBG General EHS Guidelines due to presence of heavy industries around the proximity of the port).

Hazardous materials management. There is no major hazardous material handling at project site, except for the storage and handling of diesel, fuel oil, and hexane. Containment basins to prevent accidental spillages for fuel tanks were under construction at the time of the site visit. As hexane has a low flashpoint, its storage and handling will be subjected to quantitative risk assessment (QRA) studies (ref. ESAP#7). The company agrees to integrate a hazardous materials management plan, as part of the facility ESMS, that would comply with the local regulations and WBG General EHS Guidelines (ref. ESAP#1).

Noise. Baseline noise measurements were conducted at the project site and a noise model was developed during the ESIA process. The project design includes measures such as engineering controls and acoustic walls for the noisy units and equipment. Upon implementation, this will comply with local legislation and WBG General EHS Guidelines. All material handling and process equipment will be enclosed to reduce noise levels at source.

Hazardous and Nonhazardous Wastes. Hazardous waste includes used batteries, used oil filters, empty chemical and oil containers, and dewatered industrial wastewater treatment sludge whereas nonhazardous waste includes used filters, wooden pallets, empty drums, and containers (plastic and metal), packaging material and organic wastes. The company disposes of its hazardous and nonhazardous waste during construction phase according to the regulations of the port authority. At the project site, properly designated waste collection areas were noted. All hazardous and non-hazardous wastes are collected for disposal by authorized public service agencies. The company will prepare a waste management plan and monitoring program for construction and operational phase ESMS, consistent with applicable local regulations and WBG General EHS Guidelines (ref. ESAP#1).

Pesticide Use and Management. The company’s Quality Department will prepare a pest control management plan following ISO22001/HACCP and IFC’s PS3 requirements (prohibition of WHO Class Ia/Ib products) and integrate it into its ESMS (ref. ESAP#1).   

 Infrastructure and hazardous materials management. The closest human settlement, Umm Qasr residential area located approximately 2 km to the west of the site, has a population of 63,500. No risks or impacts are envisaged to this community due to any unforeseen catastrophic incident or accident (e.g., fire, explosion, hazardous leaks). The company will undertake QRA/HAZOP studies to assess risks before commissioning the plant (ref. ESAP#7).

Road Traffic. Road traffic impacts will be limited to transport of locally sourced construction materials during construction stage, supply of water to worker camp with tanks and worker transportation (three to four buses per day). Rest of the equipment is transferred by vessels directly to the plant site. Induced traffic will be less than 1% per day for the Umm Qasr port, according to the traffic count survey done during ESIA process. Therefore, the project’s traffic impacts are considered negligible. Company’s operational phase ESMS will include regular vehicle checks and defensive driving trainings for the project’ drivers.

Community health and safety. The project is not expected to create a significant influx during construction and operations. Nonetheless, there will be workforce coming outside of Basra (mainly from Turkiye). The plant is away from communities and all the non-local workforce stays at the on-site worker camp with possibility to visit the city on weekly rest days. As part of Sama al Manar HR Policy (ref. ESAP#3), the company will develop a Code of Conduct for employees and contractors that prohibits gender-based violence and will include relevant trainings in the company induction program.

Food Safety Management System. The company is committed to establish a Hazard Analysis Critical Control Point (HACCP) based Food Safety Management Systems as per ISO 22000 Standards and receive HACCP /ISO certifications (ref. PS1) within 6-12 months of commissioning the soybean crushing plant.

Security Forces. The company currently does not have any armed guards and not planning to do so during operations. All guards are direct employees of Sama al Manar and reference checks are done as per company’s recruitment procedure. No arms are allowed within the port premises, and this is strictly regulated. Contextual risk in Iraq related to security forces is high. During operations, plant’s security risks are expected to be different than construction stage due to storage of hazardous and flammable material on site. The company will prepare a Security Risk Assessment (SRA) and Security Risk Management Plan (SMP) for the project, that will consider contextual risks in the country and region, and any potential areas of interaction with local security forces. This will comply with local security related regulations and UN Voluntary Principles on Security and Human Rights (ESAP#8).

 The project is located in the Umm Qasr Port in Basra, which falls within the Persian Gulf desert and semi-desert ecoregion of the deserts and xeric shrublands biome (as designated by WWF). The proposed facility will be built within an industrial zone of the Port in modified habitat, with no overlap with protected areas or priority biodiversity values.

Sustainable Management of Living Natural Resources. Tiryaki has a corporate Supplier Code and risk assessment rating including biodiversity risks, applied during the company’s supplier selection and contractual agreements. Tiryaki’s foreign trade department will execute Sama Al Manar’s commodity purchasing and source soybeans from Brazil, a region where significant conversion of natural habitats for soy cultivation has been a risk for several decades. However, major exporters of soy from Brazil (ADM, Bunge, Cargill, COFCO, LDC) have publicly committed to deforestation-free and conversion-free verification of their products by 2025. Assuming follow-through on these commitments, the risk profile for Brazilian soybeans purchased from these exporters should substantially improve over the coming months. In the interim, verified deforestation-free and conversion-free products are already entering the market.  

Tiryaki will commit to purchasing 100% deforestation-free and conversion-free soy by the second quarter of 2025, if it becomes commercially available in sufficient volume at competitive market prices.  In the interim, Tiryaki will set semi-annual procurement targets based on market availability and pricing, not to be less than 15% of total procurement (ESAP #9).

 Tiryaki has production facilities in Turkiye. If needed, local stakeholders can contact relevant plants or the local directorate of Ministry of Agriculture, for any grievances or inquiries. Customer complaints are followed under the Quality management system. Sama al Manar plant will be Tiryaki’s first large production facility outside Turkiye. Sama al Manar is in a process of establishing a website where project related information will be disclosed to stakeholders. Sama al Manar will develop an external communications procedure, inclusive of a community grievance mechanism which will be disclosed locally (ref. ESAP#1). Sama al Manar will appoint a focal person for receiving and managing external grievances and implementing the communications procedure.

The ESIA study prepared in January 2023 included community surveys that reached approximately 50 people from different professional and educational backgrounds within Umm Qasr residential area. One-to-one consultations were undertaken with stakeholders, including Umm Qasr community residents, Umm Qasr general hospital, Umm Qasr schools, Umm Qasr and Basra Municipality and other public institutions. The ESIA will be distributed locally in printed copies to the local government offices (i.e., Umm Qasr Port authority and Umm Qasr Municipality). During the ESIA process, job opportunities at the plant has been raised as an area of interest from consulted stakeholders. The Local Recruitment Plan will be disclosed to communities as part of the external communications procedure of Sama al Manar (ref. ESAP#6).  

 Company                          Tiryaki Agro Gida Sanayi Ve Ticaret A.S 

Point of Contact              Turkay Tatar 

Title                                   Chief Financial Officer 

Telephone Number        +90-216-3332000  

Email                                 turkay.tatar@tiryaki.com.tr

Mailing Address               Beylerbeyi Mahallesi Semsi Efendi Sokak No: 16 Uskudar 34676 Istanbul - Turkey 

Website                            https://tiryaki.com.tr/