PS5 does not apply as there is no land acquisition requirement for the greenfield developments of the proposed investments. There is no biodiversity conservation or significant natural resource management issues in relation to PS6; PS7 and PS8 do not apply as there are no indigenous peoples or cultural heritage sites in the areas of influence of the project.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012). The E&S risks and impacts associated with this project are limited, site-specific, largely reversible, and can be readily addressed through generally accepted mitigation measures and good international industry practices (GIIP). Key E&S issues and risks reviewed as part of IFC’s appraisal include: (i) company’s monitoring and management systems to assess and manage E&S risks and issues from its operation and those related to construction of new production facilities, solar power plants and supply chain management of alternative waste fuels and cotton; (ii) assurance of fair, safe and healthy working conditions including gender based  aspects, freedom of association and occupational health and safety; (iii) emergency preparedness and response; (iv) resource efficiency measures; (v) monitoring and management of air emissions, waste and wastewater and hazardous materials; and (vi) company’s stakeholder engagement activities related to E&S aspects.

Environmental and Social Assessment and Management System

The project companies established overarching policy consistent with the objectives of the Performance Standards (PSs).  Sanko Tekstil, Super Film and Cimko have established the Integrated Quality, Environment, Health and Safety (QEHS) Management System certified as per ISO 9001 (quality), ISO 14001 (environmental), ISO45001 (occupational health and safety) and ISO 50001 (energy management) standards. The QEHS Management Systems are aligned with the objectives of IFC PS1 and commensurate with the scale and E&S impacts of their respective operations. The EHS compliance team conducts regular internal audits to review effectiveness of the QEHS programs and procedures and augment them based on monitoring. In addition, annual third-party audits are conducted to ensure compliance with ISO requirements.

Identification of Risks and Impacts

As per the Ministry of Environment, Urbanization and Climate Change (MoE) of Turkiye (EIA Regulation, official gazette no:29186 of 2014), Sanko Tekstil’s and Super Film’s greenfield facilities are exempted from the E&S impact assessment (EIA) requirement.

All facilities have obtained the necessary provincial and regulatory certificates, permits and/or licenses from the MoE, including construction permits, emission permits, sewage connection permits, RDF, waste oil co-incineration permits for cement facilities’ rotary kilns and temporary hazardous waste storage permits.

Organizational Capacity and Competency

The production facilities established EHS organizational structure of at a minimum, an environmental engineer and an OHS engineer. The OHS engineers at Cimko have Occupational Safety Specialist A-class certificate, while the others have B-class certificate from the Ministry of Labor and Social Security. The OHS engineers at the Cimko and Super Film facilities have also NEBOSH (National Examination Board in Occupational Safety and Health) International Certificate.

The facility level EHS engineers report to the Sanko Holding level sustainability department which was established at the beginning of 2023.

Emergency Preparedness and Response

All production facilities have documented emergency preparedness and response plans (EPRP), including sector specific risks (e.g., cotton dust fire and explosion risks for textile production facilities) for their existing operations, which are also adapted for the construction phase of the investments. 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 hose reels have been placed at appropriate locations. Annual drills including contractors are conducted to ensure the implementation of fire safety measures. Spill response is also part of emergency plans and spill kits are readily available on sites. The EPRP framework will apply to the greenfield plants and expansions.

Monitoring and Review

As part of the QEHS, production facilities have established EHS monitoring programs. Key Performance Indicators (KPIs) comprise energy (electricity, natural gas, and coal) and water consumption per ton product, LTIFR (Lost Time Incident Frequency, near misses reported, Reporting KPIs is conducted internally at monthly department meetings and during the annual management review process about the results of monitoring and corrective actions, if needed. New facilities will establish a similar monitoring and review mechanism, as part of their E&S management system (ESMS).

Sanko Tekstil, Super Film and Cimko each, publishes annual sustainability reports on their websites (https://www.sankotextile.com/sustainability/,https://www.superfilm.com/medya/haberler-duyurular-ve-etkinlikler/haberler/super-film-2020-2021-surdurebilirlik-raporu-yayinlandi/, https://www.cimko.com.tr/Content/documents/surdurulebilirlik/tr/Surdurulebilirlik_Raporu.pdf).

Sanko Tekstil has 7.150 direct employees of which 1.650 (23 percent) are female, Super Film has 645 direct employees of which 37 (5.7 percent) are female and Cimko has 1.440 direct employees of which 59 (4 percent) are female. The greenfield plant investment of Sanko Tekstil in Gaziantep is expected to create around 475 new jobs while the new plant of Super Film in Kirklareli creates 150 construction jobs (currently at peak) and is expected to create 155 jobs when it is operational.

Human Resources Policies and Procedures, Working Conditions and Terms of Employment

Sanko Tekstil, Super Film and Cimko have their own standalone HR policy and code of conduct consistent with the requirements of PS2 and national law. Gender based violence and sexual harassment at workplace are prohibited by the code of conduct and violation of this rule is investigated following the established disciplinary procedure. 

Sanko Tekstil, Super Film and Cimko are not hiring migrant or seasonal workers, all workers are provided with indefinite term employment contract. Workers do work 45 hours per week in three shifts and overtime work is paid in accordance with the national regulation. For all workers, the companies guarantee minimum wages supported with a comprehensive benefits package including family and child allowances, annual leave, and religious holiday packages. The minimum wage in all Sanko Group companies is higher than the official minimum wage in the country.

Workers’ Organization

Workers are covered by the collective bargaining agreements between the Trade Unions of Turkiye Textile, Knitting, Garment and Leather Workers (TEKSIF); Turkiye Cement, Ceramic, Sand and Glass Industries’ Workers (CIMSE-IS); and Turkiye Petroleum, Chemistry and Rubber Workers (Petrol-Is). Each plant has union representatives and the collective bargaining agreements which are renewed every two years.

Non-discrimination and Equal Opportunity

All companies have an equal opportunity policy. As reflected in their code of conducts, the project companies do not discriminate the employees based on their language, race, color, gender, political opinion, belief, religion, sect, age, physical disability, and they offer them equal opportunities. The companies also comply with the national labor law requirements for non-discrimination and employ a certain number of disabled people as required by the law. As identified in the ESAP item 1, Sanko Tekstil, Super Film and Cimko will conduct an assessment of gender equality in the work place including hiring policies, mechanisms and channels and legal, economic, or sociocultural barriers that can be addressed to support recruitment and retention of women and will develop a gender action plan to identify actions to be taken for improvements that could be made in making jobs equally accessible to both men and women and finally, to increase the number of women employees in each plant.

Grievance Mechanism

Each project company has a documented grievance mechanism and adopts an open-door policy and, as reported, employees can directly communicate their concerns to management. All plants have placed a number of suggestion boxes at locations throughout the facilities to allow employees to submit anonymous suggestions or complaints. As well as these internal grievance mechanisms, external worker protection mechanisms are ensured by the national labor laws and union activities where relevant.

Occupational Health and Safety

All existing plants operate in accordance with ISO 45001 which includes risk assessments, accident root cause analysis, corrective and preventive action plans, reporting, and management review. Each project company has formulated an OHS policy and has developed respective procedures, instructions, and forms based on risk assessments in line with Turkish OHS Law (No: 6331). The companies have common OHS indicators and goals in all plants to maintain high OHS performance while aiming to reach zero occupational accidents and zero occupational disease targets. In Cimko Narli cement facility, the company is using artificial intelligence (AI) software in daily operation to identify production zones with higher OHS risk, and alert employees and management to potential occupational hazards. Super Film has a public OHS portal (isg.superfilm.com) reachable by employees, visitors, and contractors.

The companies perform regular workplace monitoring of noise, personal dust exposure, thermal comfort, illumination, and air quality including volatile organic compounds where applicable in line with international and local regulations/standards. In some workplaces, such as cement packaging and boiler house, the noise and/or dust levels are higher than the permitted local standards. Specific Personal Protective Equipment (PPE) such as dust masks, earmuffs plug etc. are used when engineering controls are not possible to eliminate the risk for exceedance points. During the IFC site visit, it was observed that OHS risk assessments are available for all working areas and LOTO (Lock Out Tag Out) procedures are effectively implemented. Operational OHS procedures and a hazardous work permit system is in place (hot work, confined spaces, work at height etc.).

There is no fatality or long-term disability reported for the last three years for textile, flexible packaging film, and cement plants. The average Lost Time Incident Frequency Rate (LTIFR) for textile plants is 8.15 for the last 12 months which is higher compared to the international industry benchmark (4-US Data). The LTIFR for Super Film operations is 7.8 which is higher compared to the benchmark (5.5-US Data). The average LTIFR for cement operations is 10 which is slightly higher than the benchmark (9).

As per ESAP item 2, Sanko Tekstil and Super Film will conduct OHS audits in accordance with national laws, WBG EHS guidelines and ILO sectoral code of practices to identify the corrective actions required to reduce current LTIFRs. 

The construction company Poligon has its own EHS management system and construction E&S management plan. The LTIFR fort 2022 was 5.63 which is below construction industry average (7.5-US data). No fatality or long-term disability was recorded by Poligon for the last three years. At the construction site visit, good OHS practices were observed with necessary engineering & behavioral controls in line with GIIPs and safety hierarchy (e.g., securely fixed scaffolds, well-maintained/inspected equipment, use of PPE, implementation of hazardous work permits, fire extinguishers, isolated walkways, visible evacuation plans, assembly points designated etc.).

At all facilities, some 20 percent of the staff has been trained as first aiders and a first aider is available at each shift. Staff also undergoes medical examinations twice a year, including lung screenings and audiometric tests.

Given that climate projections suggest that the region will experience an increase in the number of hot days and heatwaves will become more intense and prolonged in the coming years, the companies will prepare procedures based on the heat stress risk assessments and the working hours/resting times will be organized accordingly as per ESAP item 3.

Workers Engaged by Third Parties

All third-party workers including construction workers are required by contracts to respect and follow the labour and OHS standards as those followed by the full-time workers. All contractor workers are required to abide by OHS rules of the project companies and show proof of their social security registration as required by their contracts. The records of all contractor workers and the contractor regulatory compliance as well as the environmental risk assessment of the contractor company are maintained in the contractor management system. The contractor workforce also has access to the company’s grievance mechanism. Any accidents or incidents associated with third-party employees are also recorded and monitored.

It’s reported that all companies’ HR departments ensure that all contractors receive their salaries and are afforded their rights in line with local labor legislation.

Supply Chain

Sanko Tektil, Super Film and Cimko have in place a supply chain management system including policy, risk screening and mitigation procedures and supplier code of conduct addressing the harmful use of child labor and forced labor and OHS requirements. The Sanko Tekstil’s and Super Film’s supply chain and social accountability performances are audited by international programs such as SEDEX (Supplier Ethical Data Exchange) and BCI (Better Cotton Initiative).

Sanko Tekstil is an approved member of the Better Cotton Initiative (BCI) which promotes measurable improvements in the key E&S aspects of cotton cultivation and processing to make it economically, environmentally, and socially sustainable including prohibitions against of child and forced labor and OHS. 20 percent of total cotton procurement is BCI certified. Denim subsidiary of Sanko Tekstil, ISKO is the only denim mill in Europe with bluesign® approved fabrics, which is known as the highest standards for textile industry. Sanko Tekstil aims to convert its raw material 100 percent sourced by sustainable materials such as pre/post-consumer textile waste, organic, and BCI certified by 2030. The company enhanced its supply chain management system and procedures in terms of E&S aspects and ensured compliance of suppliers with IFC PS2 as part of the previous investment by including a risk-based supplier auditing procedure in its supply chain management system. As of May 2023, procurement percentages are as follows: Turkiye (34%), Greece (33%), Azerbaijan (15%), US (8%), Australia (2%), others (8%). In case a supplying country or a region has high risk of harmful child labor and/or forced labor; the company will, where practicable, work with suppliers to avoid child labor in harvesting and where this is not possible will search for new suppliers in lower-risk regions.

Super Film relies solely on industrial suppliers for the main raw materials; Biaxially-Oriented Polypropylene (BOPP) and Biaxially-oriented Polyethylene Terephthalate (BOPET) film granules and has a list of approved suppliers for the raw materials and consumables. Approval process involves quality assessment of materials and sustainability of the supply. Super Film is an AB category member of SEDEX (a non-profit membership organization dedicated to driving improvements in ethical and responsible business practices in global supply chains) and is being periodically audited against their standards that include prohibitions to child and forced labor and significant safety risks.

Cimko and Sanko Tekstil have in place a sourcing policy that addresses child and forced labor and will conduct due diligence on the suppliers of solar PV systems (32 MW solar panel system in Cimko Narli plant premises and total 8.45 MW two roof-top solar panel systems above two facilities of Sanko Tekstil in Gaziantep) to assess compliance against PS2 supply chain requirements.

Resource efficiency

Sanko Tekstil: Sanko Tekstil operations under the Project scope include yarn production, dyeing and recycling facilities.

Sanko Tekstil recycles post- and pre-consumer textile materials for yarn production. Today’s yearly capacity of 80k tons will be scaled up to 200k tons/year by the end of 2024. The new recycling facility in Gaziantep will meet the growing circularity need of the textile market and enhance Sanko Tekstil’s recycled fiber engineering. Around 30 percent of cotton fibers are recycled. Sanko Tekstil’s target is to produce yarns with up to 100 percent recycled fiber content with open-end spinning technology. The expansion of spinning capacity is planned to be increased from 250 to 400 tons/day. Pet bottle recycling unit produces polyester flakes and chips which can be melt spun into fibers. The solar PV installation is expected to replace 20 percent of the electricity demand. Sanko Tekstil cooperates with Turkish cotton farmers and ginners in organic and regenerative cotton farming and owns about 100 hectares of farmland for experimenting organic cotton farming and increasing harvesting efficiency.

The “Smart Factory” initiative was started two years ago for the digitization of management and control of productivity, energy use, and quality. The energy intensity of the new line is expected to be around 10 percent below the industry average of approximately 3.50-4.00 kWh/kg. Sanko Tekstil commits to meeting EDGE or LEED certification criteria in the greenfield ring spinning mill in Gaziantep.

Super Film: Super Film’s existing Gaziantep plant produces BOPP, BOPET and cast PP films with approximately 140,000 tons/year capacity production.

Electricity which is used in production, air conditioning, and lighting is supplied from the national grid. The total annual consumption of the existing plant is 72,202,670 kWh in 2022. Natural gas and coal are used for heating systems, the total annual consumption of the plant is 328,820 m3 and 12,919 tons, respectively, in 2022. The thermal oil heater with the fluidized bed combustion system utilizes 0-10 mm fine coal and circulates 90 tons of thermal oil at 250 0C in a closed system. As part of the continual improvement principle of ISO 50001, Super Film’s Gaziantep plant has developed a robust energy management initiative which has produced over 150 implemented improvements in energy efficiency since 2016 (close to 10 percent energy efficiency improvement), with more than 50 under implementation. Energy efficiency projects include the replacement of the chiller, heat recovery, condensate cleaning system, replacement of old motors and pumps with energy efficient ones, extrusion melt isolation etc.

The greenfield plant in Kirklareli will have 60,000 tons annual production capacity of BOPP. The plant utilizes Best Available Technology (BAT) from leading vendors (the main supplier is Bruckner) including the use of recycled PET plastic to boost material circularity, reducing the need for virgin PET. Super Film cooperates with resin producers, converters, and FMCG (Fast Moving Consumer Goods) companies to develop recyclable solutions and higher use of recycled content. The new BOPP line is estimated to consume 15 percent less energy than the existing facility in Gaziantep. Natural gas will be used for heat generation. Electricity consumption is estimated at 55,000,000 kWh and will be supplied by the national grid.

Super Film commits to meeting EDGE or LEED certification criteria in the greenfield plant in Kirklareli.

Cimko: The upgraded WHR plant, alternative fuel arrangements (e.g., waste tires, used oils, refuse derived fuel from textile and pulp industries, WWTP dewatered sludge) with mechanical waste feeding systems, and energy efficiency measures (ceramic ball usage, cement mechanical dispatch system) will reduce the total amount of primary fuel (coal) needed in cement production, while the solar PVs will reduce the amount of grid electricity used. Cimko has reported its target to reach 60 percent use of alternative fuels by 2030 in its Narli plant. Operation of existing RDF facility located in the Narli plant has direct impact of reduction of the current fossil fuels use. The RDF facility has operational license which includes criteria for waste acceptance with the minimum calorific value of waste and maximum concentration levels of specific pollutants.

Cimko has also its water-saving initiative which aims at minimizing the water use. For instance, in its Narli plant, 54,000 m3/year of water is saved by harvesting stormwater for cooling purposes of cement mills.

Green House Gas (GHG) emissions

The project’s total carbon footprint, direct (Scope 1) and indirect (Scope 2) emissions, is estimated to reach 2.71 million tons of CO2-eq annually. The majority of the project emissions will come from cement production (i.e., Cimko Narli plant), corresponding to 2.64 million tons of CO2-eq annually. It will be followed by the emission of 35,750 tons of CO2-eq at Sanko Tekstil and 34,000-ton CO2-eq at Super Film’s Kirklareli plant, annually. The new textile recycling plant in Gaziantep will be emitting 4,930 tons of CO2-eq annually.

Majority of emissions of Cimko’s Narli plant emissions, ca. 69 percent, will be non-energy process emissions occurring in the clinker production process. For the rest of the facilities, electricity use is the dominant source of emission. Thanks to energy efficiency improvements in Cimko’s Narli plant and solar PV plant installations in various capacities at the project facilities; annual net emissions of the project will be negative, -121,300 tons of CO2-eq.

The companies will continue monitoring their direct GHG emissions in accordance with the internationally recognized methodologies, also where required expanding the monitoring scope to include indirect emissions. Verified reports and the annual carbon footprint of the project facilities will be shared with IFC in the annual monitoring report (AMR).

Air Emissions

Sanko Tekstil’s Gaziantep and Adiyaman textile facilities use electricity for production and heating purposes.

Super Film’s Gaziantep plant performs monitoring of air emissions (COx, NOx, SOx, PM (Particulate Matter), and VOCs from adhesive tape unit) in line with the environmental permit.  Monitoring results for 2023 indicates compliance with the local regulations and the applicable WBG EHS Guideline values. Coal-burned boiler stack has an active online emission monitoring system and connected to the MoE’s portal as required by the local regulation (Regulation on the Control of Industrial Air Pollution, 3 July 2009).

Greenfield plant of Super Film in Kirklareli will use natural gas (4,550,000 tons/year) and electricity from the grid and is required to apply for an emission permit before operations start, as per the local regulation. The company reported that according to the EPC contractor’s guarantee, emissions will comply with local regulations and WBG EHS General Guideline values.

Air pollution control system for the cooler and bag filters for the cement mills and kiln are effectively operated at the Cimko’s Narli plant. Closed clinker stock halls prevent dispersion of dust. A continuous air emission monitoring system has been installed at the rotary kiln’s main stacks. Cimko’s Narli plant obtained A-class emission permission from the relevant government authorities. In addition to continuous monitoring of air emission of kiln stacks, periodical air emission and ambient air quality monitoring are performed by accredited laboratories. Review of the available monitoring results of air emissions and ambient air quality indicates compliance with the national legal requirements and WBG EHS Guidelines for Cement and Lime Manufacturing (2022) values. 

Cimko is planning to increase the use of alternative fuels up to 60 precent comparing with the current 20 percent. Hence, when the project achieved use of 60 percent alternative fuels, as per ESAP item #4, Cimko will submit to IFC the results of burning test and if necessary, implement technically and financially feasible process and emission control measures to achieve compliance of air emission levels with the national legal requirements and WBG EHS Guidelines for Cement and Lime Manufacturing (2022).

Water and Wastewater

For Sanko Tekstil’s and Super Film’s greenfield plants, water will be supplied from the municipal network. Water will be used only for cleaning purposes and domestic consumption. Process stages of Sanko Tekstil do not include considerable water use except for the dyeing unit. State of art dying equipment led to less water usage, eventually achieving full water circularity as mentioned above in the resource efficiency section.

Water for the Cimko operations is sourced from groundwater wells within the plant premises and continuously monitored at regular intervals via analyses performed by an accredited laboratory. As per the circular letter issued by the MoE, the company performed a field analysis of watershed geometry. Cimko started to use the water collected within the watershed's boundaries for watering concrete roads after the physical treatment.

In all facilities, process and domestic wastewater is pretreated in onsite chemical and/or biological treatment plants before discharge to sewer systems which are connected to municipal or industrial wastewater treatment plants. Effluent quality is monitored, and results indicate compliance with the local effluent discharge limits to sewage systems.

All existing plants are equipped with drainage systems that collect stormwater run-off separately and discharge to the municipality stormwater network.

Solid waste management and hazardous materials

Sanko Tekstil, Super Film and Cimko have hazardous and non-hazardous waste management procedures including a system of appropriate sorting, handling, storage, and disposal which are consistent with applicable legal requirements and objectives of PS3.

During the site visits to three project companies’ selected facilities, proper implementation and practices were observed in line with IFC WBG EHS General Guidelines. Wastes are segregated and stored in temporary storage areas with proper containment (110 percent coverage capacity. MSDSs (Material Safety Data Sheets) were translated into Turkish, and emergency absorbents were observed to be readily available in all required areas. Hazardous waste is stored separately from non-hazardous waste in special labeled containers and disposed to licensed companies authorized by regulatory agencies. Domestic waste is collected by municipality and disposed of to the municipality landfill. The companies have waste reduction/recycling/reusing targets. For example, Cimko has recycled 97 percent of non-hazardous waste, and reused 74.6 percent of hazardous waste for energy.

Super Film’s greenfield facility in Kirklareli will not have any process waste. All process losses will be reused in the production. Packaging materials will be sent to a recycling facility. Repairment and maintenance workshop waste and waste oils will be stored in a temporary storage area with containment and will be disposed of by licensed companies in line with local legislation (Regulation on the control of hazardous waste Official Gazette. 25755, 14 March 2005). Outdoor areas will be asphalted, and spill kits will be readily available on the site. The company will prepare a hazardous and non-hazardous waste management plan as required by law.

Noise

Sanko Tekstil and Super Film are located in industrial zones and have not significant outdoor noise sources. Cimko reported measured values of noise emissions and vibrations for both the cement facility and adjacent quarry in Narli. All measured values are within the local regulatory limits.

Quarry sites Closure & Rehabilitation

Cimko has a quarry site EHS management plan including a quarry site closure and rehabilitation action plan as per the recovery of nature and rehabilitation requirement of Mining Regulation No 32040. Cimko will review and revise the quarry sites closure and rehabilitation plan to ensure its compliance with WBG EHS guidelines for Construction Materials Extraction and Good International Industry Practice (GIIP), to meet the objectives of physical, chemical, and ecological habitat integrity and including estimated timelines and cost (ESAP item #5).

Community Health and Safety

Sanko Tekstil and Super Film plants in Gaziantep are located within industrial zones which are not surrounded by community settlements, hence no significant impacts on health, safety and security of the local community are expected due to current operations of these companies. The new plant of Super Film in Kirklareli will also be located in an area allocated for industrial development. The closest human settlement to Cimko’s Narli cement facility is Akcakoyunlu village located approximately 1.5 km to the east of the site. The village is also in some 3 km distance from the limestone quarry site of the Cimko cement plant in Narli. No risks or impacts are envisaged to this community due to any unforeseen catastrophic incident or accident (e.g., fire, explosion, hazardous leaks).

Sanko Tekstil, Super Film and Cimko have traffic management plan, transportation safety procedures in place for prevention of road accidents and providing safe transportation of its employees, products, raw materials and wastes. The outsourced transportation fleet of Cimko cement plant in Narli consists of 200 trucks. The plant has a direct connection to the main road so that the route used for the transportation from and to the cement plant does not pass through any community settlements. The transportation companies are contractually asked to follow the transportation safety procedures of Cimko including vehicle safety checks, speed limits, safe driving practices and the drivers were provided with relevant trainings about the procedures.

Infrastructure and Equipment Design and Safety

On 6 February 2023, two earthquakes at magnitudes of 7.5 and 7.8 struck southern and central Turkiye and northern and western Syria. The epicenter was 37 km west–northwest of Gaziantep. All existing facilities of Sanko Tekstil, Super Film and Cimko are located within the affected provinces (Kahramanmaras, Gaziantep and Adiyaman). None of the production facilities or office buildings collapsed or the staff working during the night shift was impacted but some machineries were moved and damaged. Unfortunately, more than 100 staff died at their homes. The plants started to work full capacity in a short time (1-2 weeks). Sanko Holding commissioned engineering consultants to investigate the production facilities and office buildings in the affected area following the earthquakes. As per ESAP item #6, Sanko Tekstil, Super Film and Cimko will submit to IFC the consultants’ report on the structural safety of their existing facilities and office buildings including reinforcement and refurbishment needs identified for each asset and a time bound implementation plan.

Food Safety Management System

Super Film is certified with BRCGS (food safety global standard for packaging of food) which specifies specific safety, quality and operational criteria for food producers and suppliers.

Security Personnel

Sanko Tekstil, Super Film and Cimko outsource the security services from Sanko Private Security Company, another subsidiary of the Sanko Group. Sanko Tekstil and Super Film do not use armed security. Cimko deploys armed security as its plant in Narli, which is located in a rural area. Cimko has a clearly defined written protocol as to the use of armed force and the 104 armed security personnel of the plant in Narli are licensed and regularly trained and certified as per the local regulatory requirements.

Each Project Company has its own sector-based stakeholder mapping and analysis and identified engagement requirements for their stakeholders. The external stakeholders of the Sanko Group companies are identified at facility level based on the location of the assets and their implications over the nearby communities. Sanko Tekstil Gaziantep facility and the facilities of Super Film do have grievance mechanisms and specific hotline numbers accessible to all stakeholders (www.sankotextile.com and https://www.superfilm.com/en/communication/) as they are all located in industrial zones. Cimko’s Narli facility is located on the lands owned by the company at a 1.5 km distance to the local communities. The company has a stakeholder engagement plan identifying consultation and information disclosure requirement to the local communities. The company’s stakeholder engagement plan including an internal and external grievance mechanism is disclosed on its website (https://www.cimko.com.tr/Sustainability/Sustainability). Cimko conducts surveys towards local communities and other stakeholder groups where they operate, both for receiving input related to their business activities and to carry out social responsibility projects in line with community needs and expectations in fields ranging from women and youth empowerment and education.

As mentioned above, Sanko Tekstil, Super Film and Cimko disclose their E&S performance through annual reports and sustainability reports. All these reports are accessible at the companies’ websites.

Contact Person: Ozde Demirturk

Company Name: Sanko Holding

Address: Sani Konukoglu Bulvari Uzeri Burak Mahallesi No:223 Sehitkamil GAZIANTEP

Email: ozde.demirturk@sanko.com.tr

Phone: +90 342 211 30 00 (Pbx)

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