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

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. The environmental and social (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 aspects reviewed as part of IFC’s appraisal include: (i) Marport’s E&S management system and capacity to assess and manage E&S risks and impacts from its operations; (ii) working conditions for employees and contracted workers, including freedom of association and gender/GBV; (iii) management of occupational health and safety (OHS) policies and practices; (iv) emergency response plans including fire, floods, spill prevention, and risk management; (v) disposal of effluent and solid waste, hazardous material storage, and handlings of dangerous cargoes; (vi) impacts of the berth expansion and cargo operations on the marine ecosystem in the Ambarli Port (including dredging and erosion); (vii) impacts on nearby communities and community engagement activities; and (viii) climate change.

Marport has corporate Environmental and OHS policies that are in line with IFC Performance Standards (PS). The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national E&S regulations.  Furthermore, Marport has EHS and social operational procedures, which are generally in line with IFC PS. The company is certified for ISO 9001:2015 (Quality), ISO14001:2015 (Environmental), OHSAS45001:2018 (OHS), ISO10002:2018 (Customer Satisfaction and Complaints Handling), and ISO27001:2017 (Information Security) management system standards. The company also maintains a QDMS (Quality Document Management System) where the E&S management programs are monitored, applicable international maritime laws, national laws, and regulations are followed up, and project-related E&S information is shared with all employees.  Annual audits of ISO 9001, ISO14001 and ISO 45001 management systems are carried out by a third-party auditor, and no significant non-compliances have been identified to date.

Responsibility for Marport’s E&S management resides with the Business Development, Quality and EHS Manager reports to the Corporate President. The EHS department comprises five employees, including the EHS Assistant Manager, an environmental engineer, two OHS experts, and a documentation officer. 

The company has a structured EHS training program for all staff, including contractor workers, covering aspects such as health and safety, hazards and risk analysis, international code for the maritime transport of dangerous goods in packaged form, first aid, fire safety, spill response, and vehicle safety.

Altas retained an environmental consultancy to prepare an environmental impact assessment (''EIA'') covering port and terminal-level upgrade and dredging activities for the four terminals operating within the Ambarli Port Facility, including Marport. Each terminal’s activities were assessed through independent EIA chapters. This EIA was approved by the EIA General Directorate of the Ministry of Environment, Urbanization, and Climate Change on 04/18/2019 (Decision No:5465).

Additionally, as part of its ESMS, Marport has defined E&S specifications for the project. Marport’s EHS team will oversee the correct implementation of the project’s OHS and environmental standards in line with the company’s contractor E&S specifications and management measures defined in the EIA and the construction contractor will assign a dedicated EHS expert for the project.

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.

As per ESAP item #1, Marport will update its construction E&S management plan in line with IFC PSs, World Bank Group EHS Guidelines (General and Port, Harbours and Terminals), and IFC’s Good Practice Note: Managing Contractors' Environmental and Social Performance.

Marport has a well-developed E&S monitoring program. As part of the corporate Environmental and OHS management systems, the company monitors key performance indicators (KPIs) such as water, electricity, fuel, LPG consumptions, packaging, hazardous and non-hazardous wastes, community complaints, LTIFR (Lost Time Incident Frequency) and LTISR (Lost Time Incident Severity Rate) and record of near misses and injuries. The KPIs are reported monthly to the company’s management team as part of a “benchmark” program, and OHS notifications are reported weekly to TIL’s corporate E&S Director.

Altas has prepared an Emergency Response Plan against fire and accidental spillages for the whole Ambarli Port. Marport has also developed a separate Emergency Response Plan. The roles and responsibilities of various teams responsible for evacuation, rescue, firefighting, onshore and onshore/offshore spill responses etc. are defined and displayed at several locations across the facilities. Fire alarm call points, evacuation route maps, and hose reels have been placed at many locations. Three emergency response and nine spill response containers are placed at various easily accessible locations in the Marport Terminal. Marport has also a contract with Arpas (company that provides joint spillage response services) for equipment/vehicle support for marine pollution prevention. ISPS (International Ship and Port Facility Security) Code is also complied with, and prevention measures are implemented. Joint and independent periodical drills for various scenarios are performed during daytime and night shifts.

Climate change-related risks include sea level rise (some projections suggest sea level rise in the port area could increase 0.18 meters by 2038 and 0.40 meters by 2079 under RCP4.5 climate change scenario); however, the company reported that berth floor height is 3 m above sea level and safe against such risk. Marport will integrate in its ESMS, specific risk screening and assessment procedure for identifying and addressing any climate-related risks as per ESAP item #2.

 Marport has 875 employees of which 51 (5.8%) are female. There are four operations subcontractors working for Marport with 461 employees. The other subcontractors providing security, cleaning and catering services have 121 employees. The current investment program is not expected to result in any change in the existing workforce structure of Marport and its operations subcontractors.

Marport’s commitments to labor are summarized under the ‘Corporate Company Policies’; ‘Code of Ethics and Compliance Booklet’, both available at https://marport.com.tr and in “Code of Ethics and Compliance Procedure”. Marport’s HR policy and procedures are consistent with the national labor regulations and IFC PS 2 requirements, and cover working conditions, fair remuneration, OHS, non-discrimination, prevention of child and forced labor, code of conduct, freedom of association, and a workers’ grievance mechanism.

Each worker receives a written contract that describes the working conditions and terms of employment followed by induction trainings including OHS and environmental awareness. Operations positions work in three shifts, and overtime work is not required. Workers are compensated as per national regulations. All employees are enrolled in the mandatory social insurance scheme and also provided with private health insurance in addition to other benefits such as transportation, food and education assistance.

The company does not prohibit worker’s freedom to associate and right to form and join workers’ organizations. The company policies commit to providing equal opportunities in all aspects and do not tolerate discrimination, harassment, or mobbing of any kind based on color, religion, gender, national origin, age, disability, political benefits, marital status, sexual orientation or family responsibilities. Marport employs 26 disabled staff. The company’s HR team also monitors its contractors’ compliance with applicable labor laws and compliance with related contract clauses.

Marport has a workers’ grievance mechanism that is accessible to all employees through Marport’s mobile application (Limon); an ethics hotline and through suggestion boxes placed in common areas. The Code of Ethics and Compliance Procedure allows anonymous complaints, identifies how whistleblowing mechanism and grievance redress process work, ensures confidentiality of the complainants and prohibits retaliation against employees who raised a concern.

The construction contractor in charge of works at berth #7, which is 95% complete, has 46 workers and two sub-contractors at the site. The tendering process has already been completed for the construction works of the rest of the project’s components. The new construction is expected to have approximately 100-120 workers at site by December 2022. Labor and working conditions of all third-party workers, including security, cleaning and catering and also workers employed by the construction contractor are to comply with labour and OHS standards specified in the company’s contractor E&S specifications and local regulations.

The contractor workforce also has access to the company’s grievance mechanism through suggestion boxes placed in common areas. Any accidents or incidents associated with third party employees are also recorded and monitored. Construction workers are provided with accommodation within Marport’s premises in the port. The current worker accommodation conditions are in line with PS2 requirements and Marport will maintain the current accommodation standards for the workers of upcoming construction works. As noted above, the company will strengthen its corporate-level contractor management procedure such that it is alignedwith IFC’s Good Practice Note on Managing Contractors E&S Performance as per ESAP item #1.

Marport has established its OHS management system along with the ISO 45001:2018. The OHS performance is managed and monitored through the QDMS system under the EHS Control Plan. OHS management system addresses the relevant areas like training, auditing, personal protective equipment (PPE) management, risk assessment (Fine-Kinney method), drills scheduling, dangerous work permits, lock out tag out, hazardous substances management, KPI identification, and near miss and accident recording. 

The company’s current risk analysis includes aspects such as loading and unloading, vehicle traffic, confined spaces, hazardous chemicals, work at height, lifting and hoisting of equipment, work on slippery floors as well as the transportation of massive items.

There have been no fatalities reported over the last 3 years. LTIFR (Lost Time Incident Frequency) is below the sector average. Contractor accidents are also recorded. At the time of IFC’s visit, with about 95% of the construction of berth 7 extension completed, no lost time accidents were recorded. Buoyant life jackets, safety harnesses, fire extinguishers, and spill kits were in place in the construction area. The company’s contractor selection process considers OHS performance. Internal traffic arrangements of the terminal were designed to isolate vehicles and pedestrian movements. Workplace measurements (noise, vibration, dust, thermal comfort, lightning) were carried out in 2019 and repeated in 2022, November and will be repeated after the project is completed.

The day-to-day OHS issues at each site are handled by the OHS Experts with the support of the other team members. The contractor has assigned an OHS Chief to oversee construction on site.

The company’s operations primarily involve container off-loading, on-loading, handling, transport, and storage in port borders and do not result in significant quantities of waste and direct emissions.

As awarded by “Green Port” certificate by  the Ministry of Transport and Infrastructure, Marport provides recycling of all waste streams. Wastes are segregated and collected in designated areas with appropriate containment basins.

Dangerous containers are transported, handled, stacked, and stored according to the relevant IMO International Convention and International Maritime Dangerous Goods (IMDG) Code (2004) and there is no bulk storage or transfer of hydrocarbons on site.

Domestic wastewater is treated by the biological wastewater treatment plant (WWTP) and discharged to the sea. Stormwater accumulated around the maintenance workshop is collected by a separate pipeline and discharged to a chemical WWTP equipped with the units of screening, oil traps, coagulation, oil skimmers, and filter press, before discharge to the sea. Both domestic and industrial wastewater monitoring results were noted to comply with the national discharge standards and WBG IFC E&S General Guidelines. Furthermore, the company will include chemical WWTP failure scenarios in its emergency and spill response plans as per ESAP #3.

Ship-generated effluents such as sewage, bilge/ballast wastewater, and vessel-cleaning wastewater are collected, treated, and discharged by a certified third party in line with Marpol’s codes. Refueling for the ships is provided by fuel companies under the supervision of Ambarli Port Authority.

The primary source of electricity is the national grid, Air conditioning units and LPG are used for heating purposes. Because LPG combustion leads to low oxides of nitrogen (NOX), carbon monoxide (CO) monitoring of these parameters is not required by law. The construction works and vehicle movements have been restricted to one shift during daytime to reduce noise impacts. Therefore, the anticipated impacts on the communities are expected to be minimal.

The company reported that the project will include about 456.670 m3 of dredging: (i) to -14.5 m adjacent to berth 3 [current min draft 12m]; (ii) to -15 m in the inner basin adjoining berths 4/5 and 6 [current min draft 11m]; and (iii) limited dredging to -16.5 m in the outer basin adjoining berth 7 [current min draft 15m]. Dredging is localized to the Marport terminal basin and therefore, is unlikely to trigger potential changes to the wider coastal regime.

As per EIA, an Environmental Management Plan for dredging activities was prepared by specialized consultancy firm in October 2022. Dredging will be carried out by excavating with a backhoe dredger mounted on a barge and the excavated dredged sediment cannot be used as filling material. Therefore, they will be hauled with a split barge to the ministry-designated disposal location in Silivri, which is 21 nautical miles away from the construction site. Dredged sediment will be hauled to the disposal location with a leakproof split hopper barge and disposed of by opening the split with a defined low navigation speed as required by the plan. Heavy metals (arsenic, copper, mercury, zinc, cadmium, chrome, lead, nickel) and PCB (Polychlorinated biphenyls) were measured in the sediment samples by an accredited company and found that they are well below Marmara Sea disposal limits. Baseline seawater characteristics of the disposal area were defined in the plan and regular monitoring will be carried out by the company after disposal in line with relevant legislation.

The port authorities reported that the Ambarli Port Facility has a stable coastal environment and does not require periodic maintenance dredging to maintain marine access, as the access channel is along the natural seabed, not dredged.

GHG emissions were calculated as 16,784 tons of CO2e in 2021. After the project becomes operational, with the purchasing of electricity-driven STS cranes, the annual GHG emissions per TEU are expected to be decreased.

All upgrade works are mostly offshore and within the current operational boundaries of the port where access is restricted. The offshore area of the Marport facility and vessel manoeuvring waters are prohibited for all boats and regularly controlled by the port security boats and coast guards of the Security Control Center run by Altas. The dock area is restricted to access. 

The closest settlement is a newly developed housing complex which has not been inhabited yet and located c. 200 m away from the boundaries of the Ambarli Port and c. 500 m from Marport’s construction. The project will not contribute to any increase in road traffic as the project will not increase the current operational capacity of Marport.

Marport has deployed 30 security personnel of its own and contracted out 52 additional security guards, all are unarmed. Personnel screening and management protocols are included in the Port Facility Security Assessment and the Port Facility Security Plan developed as per the requirements of ISPS protocol. The trainings of security personnel include communication, crowd management and control, and ISPS.

A public hearing was held for the project EIA in 2017. The participants raised concerns about the transportation route of Marport, methods for disposal of dredged sediments and the project’s impacts on the marine species. The concerns raised during the public hearing meeting were addressed in the relevant sections of the EIA.

Marport manages its external stakeholder relations through communication and suggestions procedures developed as part of its integrated management system certified against respective ISO standards including ISO:9001 Quality and ISO:10002 Customer Satisfaction since 2010. Marport identifies its main stakeholders as employees, customers, suppliers, public institutions, and nearby communities and follows suitable communication methods targeting each group. The company’s grievance mechanism is accessible to all stakeholders (https://marport.com.tr/iletisim) and a specific hotline number is available on its website.

Contact Person: Filiz Karaoguz, Investment and Corporate Relations Coordinator       

Company Name: Marport Liman Isletmeleri Sanayi ve Ticaret A.S.           

Address: Marmara Mahallesi Liman Caddesi No:53/1 Beylikduzu, Istanbul, Turkiye       

Email: filiz.karaoguz@marport.com.tr        

Phone: +902128665200