This is a category B project according to IFC’s Policy on Social and Environmental Sustainability and in line with the previous Assan projects. The project is expected to have limited site-specific potential adverse environmental and social impacts that are few in number, largely reversible and that can be readily addressed through mitigation measures.

The key E&S issues include: (i) effectiveness of the Company’s management and monitoring systems to assess and manage E&S risks and impacts from its operations; (ii) management of occupational health and safety risks during construction and operational phases; (iii) consistent management of labor and working conditions including supply chain; and (iv) monitoring and management of air emissions and (v) resource efficiency measures.

The Company’s corporate E&S management system is certified as per ISO 9001 (valid until 11/2023) a quality management system, ISO 14001 (valid until 10/2025) an environmental management system, ISO 45001 (valid until 10/2025) an occupational health and safety management system and ISO 50001 (valid until 04/2025) an energy management system across all facilities. The E&S management systems is regularly audited internally and externally by independent certification institutions to confirm accreditation. 

Assan has adopted E&S policies that guide a wide range of E&S related topics, publicly available at: https://www.assanaluminyum.com/en/about-us/our-company-policies. These policies cover issues related to the environment, energy, OHS, human resources, food security, risk management and information security. The company sets out its sustainability strategy based on 2025 targets (https://www.assanaluminyum.com/en/sustainability/assan-aluminyum-sustainability-strategy) that relate to key performance areas such as water and energy efficiency, emissions and waste reduction, OHS, gender and supply chain compliance.

The Tuzla and Dilovasi plants have its own dedicated Occupational Health and Safety & Environment (OHS&E) teams. The Dilovasi plant has a team of 12 OHS&E professionals and the Tuzla plant has 6 OHS&E professionals. The plant’s OHS&E departments report to Assan’s corporate Human Resources (HR) Director. There are full-time medical doctors and nurses employed at each plant.

Assan has documented emergency preparedness and response (EPR) plans including evacuation, fire prevention, first aid, and response to accidental release of chemicals, natural disasters, work accidents, poisonings and engagement with respective authorities for any emergency case. These plans have been revised in 2022 mainly to cover construction and operational emergency risks of planned investments under the project.

Assan employs 692 direct workers in the Tuzla plant of which 83 (12 percent) are female and 975 in the Dilovasi plant of which 27 (3 percent) are female. The project is expected to create 125 additional employments. There are almost 163 contracted workers in Assan across all operations to provide cleaning, loading, catering and security services. Ongoing construction efforts involve additional 130 contracted workers at the peak time at the Dilovasi and Tuzla plants.

Assan has a corporate level HR policy disclosed at its website https://www.assanaluminyum.com/en/career/our-human-resources-policy and associated procedures in place that relate to recruitment, training, performance evaluation, career development, terms of employment, company rules and job descriptions, and these are in line with IFC Performance Standard 2 requirements. Assan’s HR procedures cover aspects on equal opportunities and non-discrimination on race, ethnical origin, nationality, religion, age, gender and/or physical disability in line with Turkish labor laws requirements which prohibits employment of child and forced labor. The HR policy and procedures are available to all employees either through the company’s intranet and as an employee handbook.

Employees involved in actual plant operations work in three shifts per 24 hour cycle, whereas the administrative / office employees work during the week days and a maximum 45 hour per week. All employees have written contracts where the working conditions, terms of employment, wages and benefits provided, working hours, overtime and annual leave are defined.

Assan HR policy clearly states that the company respects freedom of association. There are no labor unions or collective bargaining agreements in place but there is a worker representative mechanism which enables the workers to raise their claims and concerns via 9 elected representatives (5 in the Dilovasi plant and 4 in the Tuzla plant) to HR department and the respective General Manger during monthly meetings.

The company has a formal employee grievance mechanism where employees can anonymously or directly raise concerns to their managers, to HR and/or use the employee satisfaction survey. Contractor employees can use the same mechanism.

The Company’s occupational health and safety (OHS) management system is certified as per ISO 45001 OHS management plan documented procedures and safe working practices including manual handling, working with melted aluminum, hot works, use of personal protective equipment, chemicals safety, electrical safety, waste management, forklift safety, storage safety and near miss/incident reporting. Health tests, including respiratory and skeletal system control, chemicals in blood, electrocardiogram, urine tests, liver controls and audiometry checks are performed annually.

As a part of new employee induction and periodic refreshment training, E&S topics such as site safety rules, use of work equipment (cranes, forklifts), welding, working in confined spaces, manual handling, emergency preparedness and response, chemical safety and waste management are provided to all employees. An E&S training plan, including mandatory minimum training of 16 hours per employee per year is developed and implemented.

The lost time injury frequency rate (“LTIFR” – number of lost time injuries per 1.000.000 worked hour) is calculated as 7.71 for the Dilovasi plant and 5.11 for the Tuzla plant by December 2022 which is close to sector international benchmark of 6.5 (for alumina production and processing – www.bls.gov). However, the LTIFR for contractors involved in ongoing construction works is 44.56 which is significantly higher than the sector international industrial benchmark of 6.5 (for heavy and civil engineering construction). Therefore, as per ESAP item #1, Assan will develop and implement a time-based OHS action plan, acceptable to IFC, to reduce the current LTFIR for contractors and the Dilovasi plant to align with the respective sector international industrial benchmarks.

Workplace monitoring program includes drinking water analysis, workplace noise measurements, workplace air quality monitoring, thermal comfort (temperature, humidity) and light intensity measurements. Results obtained, are in line with local legislations and WBG’s relevant EHS guidelines guidance values.

There are contractual requirements referring to Turkish E&S laws and they include clear covenants to ensure that contractors will follow Assan’s E&S management system requirements. The contractors who may provide mechanical or civil work and installation services for the project will have the same contractual requirements. Compliance, including PS 2 requirements, is monitored by Assan’s E&S staff.

Principal sources of supply for key raw materials (primer, semi-finished and scrap aluminum) of Assan are mainly from Türkiye, Asia including Russia and China, Europe and the Gulf Region. Assan has a supply chain policy outlined in its Purchasing Department Code of Business Conduct which is compliant with IFC PS 2 requirements on use of child or forced labor and OHS risk management aspects in the primary supply chain. Assan’s supply chain department is responsible for implementation of this policy requirements. Supplier performance monitoring and evaluation is undertaken at holding level by the purchasing department of Kibar Holding, which is the parent entity of Assan. As per ESAP item #2, Assan shall revise its vendor selection procedure to include respective E&S requirements, in line with IFC PS2, including restriction of use of child and forced labor in their processes, in the supplier screening criteria and reflect those requirements in the supplier contracts.

The main energy source is natural gas provided through national grid.

The main source of greenhouse gas (“GHG”) emissions is from the natural gas fired process furnaces and electricity usage of the plants. Assan’s overall GHG emissions are estimated to be 156,800 tonnes GHG for 300,000 tonnes of FRP and expected to be 188,200 tonnes GHG with expansion to 360,000 tonnes of FRP.

Water consumptions for finished goods will increase from current 1.32 m³/t to 1.39 m³/t after the new investments. Assan will offset current water consumption in the Tuzla plant by 20 percent through operating the reverse osmosis system. 

There are 7 combustion and 168 process emission point sources in the Tuzla and Dilovasi plants.  Air emission monitoring performed in 2020 indicates compliance with the national regulatory limits for particulate material (PM10), nitrogen oxide (NOx), sulphur dioxide (SO2), carbon monoxide (CO), hydrogen fluoride (HF), hydrogen chloride (HCl) and volatile organic compound (VOC).  However, PM10 for some of air emissions point sources in the Tuzla and Dilovasi plants varied between 5.5 and 20 mg/Nm3 and exceeded the limit value of 5 mg/Nm3 defined by the WBG EHS guidelines for Base Metal Smelting and Refining. Therefore, as per ESAP item #3, the company will develop and implement time bound cost effective technical measures, acceptable to IFC, to ensure PM10 and PM2.5 point source emissions comply with the WBG EHS guidelines for Base Metal Smelting and Refining. 

Regular ambient noise measurements are conducted by a third-party accredited laboratory, at the nearest receptor locations to the Tuzla plant. As per the last noise measurement report of 2019, the maximum increase in background noise levels is 3 dB at the nearest off-site sensitive receptor which is in line with WBG’s General EHS Guideline guidance values.

The process wastewater and sanitary wastewater in the Dilovasi plant is discharged to the industrial zone sewage system and treated in industrial’s zone wastewater treatment plant (WWTP). The effluent quality of the WWTP is monitored by local authorities and is in line with the local regulatory requirements. The process wastewater and sanitary wastewater in the Tuzla plant are pretreated in at site WWTP. The treated effluents are discharged to the municipal sewer, managed by the Water and Sewage Administration of Istanbul Metropolitan City. The Company completed construction of a wastewater recovery system (reverse osmosis) in the Tuzla plant which is expected to be fully operational around end of the first quarter of 2023. The Company expects to recycle and reuse about 20 percent (87.5 m3/day) of the total wastewater of the Tuzla Plant (360 m3/day) by that date.

Storm water is collected separately in all facilities, pretreated in oil and sand traps and discharged to storm water collection system.

Assan has a solid waste management system in place where recyclable wastes, such as plastics, cardboards and waste lubricants/oil are recycled by third party licensed waste companies. Sludge from the WWTP in the Tuzla plant and hazardous wastes, including waste paints and solvents, lubricant packages, are disposed by licensed waste disposers.

Assan is also recycling its aluminum waste in its recycling plant and convert it to its own production. An increase in scrap (including internal scrap) usage is expected from 36 percent to 40 percent when the new investments are commenced.

Hazardous materials include lubricant/oil used in the production and some maintenance and cleaning chemicals as well as generator fuel. Hazardous chemicals are stored in well ventilated areas, and material safety data sheets and safe working instructions are provided to the employees.

Vehicles carrying raw and scrap materials to the plants are checked by licensed door type and handheld radiation detectors. Safe working instructions are also available in case of a radiation alarm.

All new facilities to be constructed within the scope of the project are located in the existing premises of the Dilovasi plant is located in the Dilovasi Industrial Zone. The Tuzla plant is located within the close vicinity of the residential areas, however, the investments program for this plant does not include any new building construction.

The plants are located within the known earthquake zone, and they are reinforced in line with the suggestions by the third party seismic experts after the 1999 earthquake which affected the project locations. The rolling mill plant, high bay storage and locker room buildings are designed in line with the national Regulation on Buildings to be Built in Seismic Zones (Official Gazette date/no:18.3.2018/30364).

Raw materials and products are delivered via trucks, by Kibar Holding’s transportation companies. The transportation companies have documented transport management plans which defines vehicle, driver, and journey related practices and ERP plans for spill and accident scenarios.

Security functions are covered by 33 Assan employees for the Dilovasi plant. For the Tuzla plant, security service is contracted out to a contractor company with 34 security guard. Security staff are unarmed and are trained in the use of force for only defensive purposes.

The company engages with stakeholders on as needed basis. As the project involves new investments within the premises of existing plants, no detailed consultation process was implemented. Assan has an external grievance mechanism in place that can be accessed by stakeholders to express their complaints and concerns through the website link https://www.assanaluminyum.com/en/contact/contact-form, and e-mail addresses and phone numbers available for each plant. Assan did not receive complaints / grievances from non-governmental organizations (“NGO”) and/or by the surrounding communities in the last two years. As noted, Assan discloses its environmental and social performance through sustainability reports accessible at https://www.assanaluminyum.com/en/sustainability/sustainability-reports.

Contact Person: Ms.Zeynep Sarsan

Company Name: Assan Aluminyum Sanayi ve Ticaret A.S.

Address: Yayla Mah. D-100 Karayolu Ruya Sokak No.2

Email: zeynep.sarsan@assanaluminyum.com

Phone: +902165811200

Facsimile:+902165811630