IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social E&S Policies. Cimsa has established an overarching corporate Integrated Management System (IMS) policy defining its E&S objectives and provides a framework for E&S assessment and management processes Human Rights Policy, Equality Diversity Inclusion Policy, and Policy on Combating Domestic Violence are also in place. Strategy, policies, and management system certificates are published on the Cimsa website (E&S polices are available at https://cimsa.com.tr/en/sustainability/).
E&S Management System and Programs. Cimsa has established an IMS certified per ISO9001 (Quality management), ISO 14001 (Environmental management) ISO 45001 (Occupational Health and Safety management) and ISO 50001 (Energy management) covering the HQ and all production plants. Cimsa’s IMS is consistent with the objectives of the IFC’s Performance Standards (PSs) and commensurate with its operations’ E&S risks and issues. As part of the IMS, Cimsa’s EHS procedures cover waste management, alternative fuel management, air quality, and dust control, environmental monitoring, greenhouse gas (GHG) emissions management, water management, supply chain management, emergency planning, contractor management, OHS procedures, risk assessments and instructions, and accident response, among others. In line with its IMS procedures, the company Company prepares contractor site-specific EHS management plans as part of each investment.
Identification of E&S Risks and Impacts. The Company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements. Cimsa’s IMS’ environmental management procedures include the identification of environmental risks arising from its activities and the development of suitable environmental mitigation and management measures. The EIA is not required for decarbonization projects at this scale by national legislation. As per the Turkish EIA Regulation, solar power plants with a capacity higher than 10MW require an EIA study. Accordingly, Cimsa has initiated the process by submitting the EIA Application File to the Ministry of Environment and Urbanization (MoEU) in August 2023 for the 10.8MW solar PV plant that will be built adjacent to the Eskisehir Plant as part of the decarbonization investments (https://eced.csb.gov.tr/jsp/ek1/47019). According to the EIA for the solar PV plant, the E&S risks and/or impacts are limited, site-specific, and addressed through existing mitigation measures and good international industry practices. In addition, “EIA Not Required” Decision for the solar PV plant (4.16 MW) at the Mersin Plant was obtained from the national authority in 2021 as part of the Factory Modernization Project EIA Application process. As the national EIA process does not focus on social impacts, the company will augment its environmental management procedure by including a social impact assessment procedure for its projects in line with the requirements of IFC PS1 as per ESAP item #1.
Organizational Capacity/Competency. Cimsa has established EHS organizational structure. A sustainability department has been established as part of the HR general directorate at the HQ. The sustainability department comprises a group Sustainability, EHS Group Manager, an OHS manager, a sustainability executive, a sustainability expert, and an environmental executive. The Environmental Management Units are established at each plant, and plant environmental leads directly report to the Plant Managers and have dotted reporting lines to the Sustainability, EHS Group Manager. Plant OHS leads directly report to the OHS Manager. The Cimsa OHS team is composed of 17 OHS officers; in addition, workplace doctors, nurses, paramedics, and ambulance drivers are also readily available at the factories. Various contracted consultancy companies provide external services on legal compliance, climate and water management, carbon and water footprint, and hazardous material management at corporate and plant levels. Furthermore, as per ESAP item #2, Cimsa will strengthen the sustainability department organizational structure at the corporate level to include a senior social expert, by augmenting reporting lines.
E&S Training. Cimsa has a comprehensive training program to ensure employees’ environmental and OHS awareness and competency The training status of the factory employees is monitored by the Plant Environmental Leads and the HR team. In addition, courses on gender equality awareness, domestic violence and fire safety are periodically offered to all employees. Subcontractors’ EHS staff delivers similar training for contracted workforces.
Emergency Preparedness and Response. Cimsa has a corporate-level documented emergency preparedness and response plan/framework (EPRP) to guide operational facilities. In addition, plant-level EPRPs are developed and being implemented. The roles and responsibilities of employees for evacuation, rescue, and firefighting are defined in the plant-level EPRPs and displayed at various locations across the sites. Evacuation route maps, assembly point signs, and water hose reels are placed at appropriate locations. Annual drills tailored to each location, including contractors, are conducted to ensure the implementation of fire safety measures. Satisfactory number of workers for each shift have been trained in fire safety and the operation of fire safety equipment. Furthermore, emergency training covering natural disasters has been provided to 500 employees in collaboration with AKUT (Turkish Search and Rescue Organization). Emergency containers, including earthquake emergency equipment, are installed at each plant. Going forward, the Company will review and update its plant-level EPRPs to ensure flash floods, climate change-derived risk in the region, and associated impacts such as spills and life safety in line with WBG’s General and sector specific EHS Guidelines and PS1 as per ESAP item #3.
Monitoring and Reporting. An EHS monitoring program has been established at Cimsa’s plants in compliance with relevant regulatory requirements and its IMS E&S performance indicators for each plant. Key Performance Indicators (KPIs) comprise resource efficiency (electricity, fuel, renewable energy, and alternative fuel consumption), CO2 emission per ton of product, water consumption usage per ton of product, waste generation, OHS leading/lagging indicators (Lost Time Incident Frequency Rate (LTIFR), fatalities), gender equality (percentage of woman employees). Annual management review meetings are organized to assess the Company's overall E&S performance and sustainability goals and projects.
Performance Standard 2: Labor and Working Conditions
Cimsa employs 959 direct workers, of whom 547 are blue-collar workers. Female employees are 50% at HQ and ~13% overall. All production-related activities are undertaken by direct employees. The contractor workforce is only used for activities such as security, cleaning, catering, waste preparation, etc.
Human Resources Policies and Procedures, Working Conditions and Terms of Employment. Cimsa has adopted an HR policy and procedures consistent with the national law and requirements of IFC PS2. The code of conduct prohibits gender-based violence and sexual harassment in the workplace, and violation of this rule is investigated following the established disciplinary procedure.
Cimsa is not hiring migrant or seasonal workers; all workers are provided with indefinite-term employment contracts. Workers work 45 hours per week in three shifts, and overtime work is paid per national regulations and Union Collective Labour Agreement. The company guarantees minimum base wages for all workers with a comprehensive benefits package including family and child allowances, annual leave, and religious holiday packages. The minimum wage offered by Cimsa is above the minimum wage established by Turkish regulations.
Workers’ Organization. All blue-collar workers are members of the Türkiye Cement, Ceramic, Sand, and Glass Industries’ Workers (CIMSE-IS) union and are covered by the collective bargaining agreement (CBA). Each plant has union representatives, and the CBAs are renewed every two years. There is a collective labour agreement valid for 2 years as of January 2024.
Non-discrimination and Equal Opportunity. The Company has an equal opportunity and non-discrimination policy. As reflected in the CoC, the Company does not discriminate against employees based on their language, race, color, gender, political opinion, belief, religion, age, or physical disability and offers them equal opportunities. Cimsa requires all prospective employees to demonstrate proof of age - 18 years or older and contractually requires contractors to do the same. The Company is a signatory of UN Women’s Empowerment Principles (WEP). The presence of female employees in various sections of the production activities is increasing, with the Company’s vision to have gender-balanced employment. Provisions regarding equality at work principles are also added to supplier and subcontractor service procurements. The grievance mechanism is suitable to capture harassment-related issues. In 2019, Cimsa participated in the Business Against Domestic Violence (BADV) project carried out by SAHOL in partnership with the Sabanci University and published the Policy on Combating Domestic Violence.
Grievance Mechanism. Cimsa has formal and well-established grievance mechanisms allowing anonymous submissions. All direct employees and contractors can report grievances through a hotline (Dialog), e-mails, or online forms. All plants have placed several suggestion boxes at locations throughout the facilities to allow employees to submit anonymous suggestions or complaints. Additionally, employees report their grievances to union representatives, who follow an escalation procedure for addressing workplace issues. If the issues raised through grievance mechanisms need a systematic solution, a “problem assessment and monitoring report” is prepared and followed up by the relevant departments.
Occupational Health and Safety. Cimsa has a comprehensive and well-implemented OHS management plan, procedures, risk analyses, and hazardous work permit system. The plan includes risk assessment, contractor safety management, pre-job OHS planning, housekeeping, safety signs and signals, work at height, lifeline, mobile elevated platform, ladders, health hazards, chemical handling, manual handling, power tools, electrical safety, lock out tag out (LOTO), confined spaces, hot work, personal protective equipment (PPE), ammonia use and handling, fire prevention, medical treatment.
Occupational exposures such as noise and dust exposure, indoor workplace air quality, temperature, periodic replacement of air conditioning filters, and similar factors at each location are monitored yearly. Licensed companies prepare occupational hygiene reports for each plant annually. Measured parameters are in line with national workplace standards and WBG General EHS Guideline limits. For the working positions with the elevated workplace parameters satisfactory engineering control and organizational measures have been implemented and PPE provided.
Accidents and near misses are recorded. Root cause analysis was conducted, and all corrective actions were completed to prevent reoccurrences. Initiatives such as Gemba Safety Walks and Cimsa Cares were started to increase OHS awareness. The average LTIFR of the three plants progressively decreased from 2018 to 2023 (from 8 to 2.95). In the last three years, LTIFR was 2.87, 3.74, and 2.95, respectively, well below the sector average (9 for cement and concrete product manufacturing - US data). One fatality has been reported for the last three years, in the third quarter of 2023. Accident investigation and root cause analyses were conducted, and an action plan was prepared, 90% of which is currently completed.
Contractors are 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 (LOTO, PPE use as needed, implementation of hazardous work permits, fire extinguishers, safety signs, visible evacuation plans, assembly points designated). The Company will take the necessary actions to ensure adequate PPE is available at the ammonia storage areas and conduct regular inspections to ensure its compliance with WBG General EHS guidelines, as per ESAP item #4.
Given that climate projections suggest that the country will experience an increase in the number of hot days and heatwaves will become more intense and prolonged in the coming years, the plants will prepare procedures based on plant-specific heat stress risk assessment and the working hours/resting times will be organized accordingly, including contractor employees, as per ESAP item #4.
Quarries sites are isolated, all necessary safety measures are taken. As part of the quarries’ traffic management plan, the presence of traffic speed limit signs for trucks will be increased for all quarries’ access roads, as per ESAP item #4.
Since Türkiye is a country with earthquake risks, following the devastating earthquake in February 2023, the Company hired a certified building inspection company (Stas Engineering) to inspect and assess all facilities and relevant structures against earthquake resistance. A time-bound action plan has been prepared to mitigate the risks in a year (no significant issues found, but some idle buildings, like water storage buildings, need to be demolished).
Workers Engaged by Third Parties. All third-party workers (security, housekeeping, catering, etc.) are to respect and follow the same labor and OHS standards applied to the Cimsa direct workers. All contractor workers are required to 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 and OHS risk assessment of the contractor company, are maintained in the contractor management system. The contractor workforce has access to the Company’s grievance mechanism. Any accidents or incidents associated with third-party employees are recorded and monitored.
Supply Chain Management. Cimsa adopted a Supplier Code, a Responsible Procurement Policy and a supply chain due diligence procedure. The Company expanded the scope of its supply chain assessment of vendors beyond the existing quality assessment system, to identify, manage and remediate supply chain risks associated with child and forced as well as any other significant safety and human rights risks and impacts consistently with the requirements of IFC’s PS2. Çimsa has more than 20,000 approved suppliers in its system. Cimsa engaged with 1,773 of them in 2022 and 96.5% of 1,773 were local companies. The Company also collaborates with Dow Jones to manage supply chain risks, including human rights and Environmental, Social, and Governance (ESG) and reported that the principles of the supply chain code and procedure will be reflected in the project procurement process, including for solar PV panels. Cimsa is familiarized with the solar PV supply chain related labor risk. Going forward, as per ESAP item#5, the Company will review and update its procedures to ensure that the suppliers are timely and effectively informed about the existing policies and procedures implemented by Cimsa, including the solar PV industry’s labor risks and a formal process for supplier engagement, remedy, or disengagement in case of non-compliance that are not addressed to be in line with IFC’s PS2 requirements.
Performance Standard 3: Resource Efficiency and Pollution Prevention
Cimsa monitors energy, water, and raw material consumption through SAP systems and monthly performance reports. The total electricity consumption of all Cimsa plants was 639,370 MWh in 2023, an approximately 1% reduction compared to the previous year. So, the specific electrical energy consumption per ton of cement (consisting of grey, white, and CAC production) at all plants was 99kWh/t, which is in the industry benchmark of 80-105kWh/t. The total electrical energy consumption for clinker grinding at the Eskisehir and Mersin Plants was 45kWh/t cement, which is within the industry benchmarks (28-45kWh/t cement). The Company has achieved 1,495MWh (0.057 TJ thermal and 1,479 MWh electricity) energy savings through its energy efficiency projects, while renewable energy resources supplied 54% of the total electricity demand of all plants in 2023 (50% is provided by geothermal energy sources certified with the International Renewable Energy Certificate (I-REC)).
Cimsa increases alternative fuel usage by replacing carbon-intensive fossil fuels with low-carbonaceous biomass, tires, domestic waste, and waste-derived fuels. Each plant has waste incineration licenses issued by the MoEU. When the content and amount of waste changed, the operational licenses are renewed after the probe work and air emission testing, confirming the plants' compliance with the national air emission limits and ambient air quality. At the Afyon Plant, an alternative fuel supply investment was initiated in February 2022, targeting a 22% alternative fuel usage rate by overall Cimsa operations in 2022. The actual achievement was 29% in 2023, exceeding the target. At the Mersin plant, RDF stocking and feeding investments and optimization studies are expected to increase Cimsa’s alternative fuel usage ratio to 35% in 2025 and 40% in 2030. In addition to alternative fuel, Cimsa uses wastes and by-products of other industries with rich mineral content to achieve its circular economy targets and reduce raw material consumption. Furthermore, the use of decarbonized raw materials leads to reduced CO2 emissions during calcination.
Greenhouse gas (GHG) emissions. Natural gas, low sulphur coal, fuel oil, diesel, petroleum coke, and electricity use from the grid are the primary emission sources from Cimsa operations. The Company has a zero GHG emission target by 2050. Cimsa monitors CO2 emissions at each plant annually and reports emission results in its annual report. Its participation to the Global Cement and Concrete Association (GCCA) allows the Company to benchmark its performance against industry standards. Scope 1 (direct) GHG emissions from Cimsa operations are reported to be 4.85 Mt CO2eq while Scope 2 (indirect) emissions are 138,513 tons CO2eq in 2022. A 19% reduction is observed in Scope 1 emissions when compared to 2021. In 2022, as a result of its decarbonization strategy, Cimsa achieved 11% and 8% reduction in net CO2 emissions related to grey cement, compared to 2020 and 2021. In addition, 7% and 5% reduction were achieved in net CO2 emission related to consolidated cementitious material compared to 2020 and 2021, respectively. Total CO2 emissions decreased by 21% between 2021 and 2022 thanks to the reduction in emission intensity.
The Project is anticipated to result in an approximately 494,901CO2 eq tons reduction in Scope 1 + Scope 2 emissions and will help Cimsa meeting its sustainability targets: 1) carbon emission reduction of 42.1% by 2033 (compared to the base year of 2021) and 2) net-zero carbon emission by 2050. Furthermore, the Project will contribute to circular economy principles, waste reduction/recovery, increased energy efficiency and renewable energy transition.
Water supply. Water consumption in Cimsa’s process is mainly linked to the cooling process needs. The total water consumption of the three cement plants was estimated as 3.17 million m³ in 2022 (3,134,152 m³ groundwater extracted from wells and 4,881 m³ from the municipal network). The water consumption was 1,140,096 m³ at the Mersin Plant, 1,577,813 m³ at the Eskisehir Plant, and 122,761 m³ at the Afyon Plant.
Cimsa has initiated a Smart Water Metering Project to reduce water consumption throughout the production process, benchmarking Best Available Technologies (BAT) for cement production and water stewardship. Cimsa has targeted a 25% reduction in water use in 2023. As part of the project, measurement devices will be installed by March 2024 at wells and specific points at plant units to identify water consumption and leakages to benchmark water use amounts and develop projects to decrease the consumption. Furthermore, hybrid cooling (combined wet and air cooling) reduces water demand for cooling.
Wastewater. The plants generate only sanitary wastewater, as cooling water is recirculated. The treated sanitary wastewater has been re-used for cooling of exhaust gases at the Eskisehir Plant since 2015 and at the Afyon Plant since 2018, leading to zero discharge. The Mersin Plant treats sanitary wastewater on site and discharge into a dry river in compliance with the operational Discharge Permit. The effluent quality is analyzed, bi-monthly, for total suspended solids (TSS), biochemical oxygen demand (BOD5), chemical oxygen demand (COD), and pH by an accredited laboratory. The results of effluent monitoring indicate compliance with the national effluent standards and WBG General EHS Guidelines. All plants are equipped with drainage systems that collect stormwater run-off separately and discharge after pre-treatment into the municipality stormwater network.
Air Emissions. The main emission sources of cement production consist of i) dust from crushing, screening, and grinding processes as well as rotary kiln process and ii) combustion gases such as nitrogen oxides (NOx), volatile organic compounds (VOCs), total organic carbon (TOC), metals, hydrogen fluoride (HF), hydrogen chloride (HCl), dioxin and furan from rotary kiln combustion process. In addition to the periodic monitoring of stack emissions (every two years as per the Industrial Air Pollution Control Regulation), continuous monitoring is in place for the following air emissions parameters at stacks; particulate matters (PM), NOx, SOx, NH3, TOC, HF and HCl emissions. All stacks have hybrid filters (electrostatic filter and bag filter) to control air emissions and prevent pollution. Cimsa has a filter maintenance and replacement program. Furthermore, when the SCADA system identifies a decrease in filter performance, an inspection is carried out, and as a result, on-demand maintenance and/or replacement is performed as needed. According to the air emission and ambient air quality monitoring performed in 2023, all parameters are in line with the local legislation and WBG EHS Guidelines limit values (General EHS Guidelines, WBG EHS Guidelines for Cement and Lime Manufacturing (2022) and WBG EHS Guidelines for Thermal Power Plants (2008) for the combustion sources with capacity > 50MWh) at all three plants. In addition, air emission monitoring reports for quarry sites show compliance with local and WBG EHS Guidelines limit values for dust and settling dust during normal operations and blasting.
According to the site visit findings, adequate dust suppression measures are applied within the factory perimeters and quarries. Trucks transferring raw material between the quarries and plants are always covered, and quarry access roads are watered hourly for dust suppression. A 25% reduction in NOx emission load has been achieved by selective catalytic reduction systems and process optimization, while alternative fuel usage achieved a 50% reduction in HCl emissions in 2020. Cimsa uses wastes as an alternative fuel in compliance with national RDF, Additional Fuel, and Alternative Raw Material Communiqué No. 29036 dated 20.06.2014. Therefore, when planning to increase the capacity or change the content, the Company is obliged to carry out burning tests to be approved by the MoEU, in addition to quarterly monitoring reports. Cimsa implements a burning test procedure in line with EU legislation (EC, Directive 2010/75 EU). Waste samples and results of analysis carried out by accredited laboratories are obtained before the burning test. Moreover, Cimsa conducts further analysis on the samples at its quality control laboratories, testing for calorific value, ash, moisture, volatile matter, and chlorine content. Continuous monitoring of emissions is carried out for O2, NOx, CO, Dust, TOC, SO2, HCl and HF during the burning test. In addition, periodic emission monitoring is carried out for the same parameters and heavy metals. Monitoring results show compliance with the national air emission standards and WBG EHS Guidelines for Cement and Lime Manufacturing (2022) limits.
Hazardous materials management. Hazardous materials stored and handled at Cimsa’s plants include oil & grease for maintenance and ammonia for Selective Non-catalytic Reduction (SNRC). The ammonia solution (25% concentration) is stored in a dedicated area within tanks at each plant. Cimsa has specific procedures for safely handling, filling, and transporting ammonia.
Noise. Periodic ambient noise monitoring is carried out at plants and quarries every two years in line with local legislation. The Company conducts more frequent noise monitoring campaigns at the quarries to ensure compliance with the law. No exceedance has been identified to date. All quarries have blasting management plans and relevant instructions. Controlled blasting by electronic capsules is carried out at the quarries based on raw material demand. The sensitive noise receptors are informed before blasting. Furthermore, occupational noise exposure is monitored annually, and no exceedances have been reported.
Hazardous and Non-Hazardous Wastes. Cimsa is developing projects to reduce and reuse solid wastes such as rocks, clay and sand formed during cement production processes and hazardous and non-hazardous wastes. During the site visits to the Mersin and Eskisehir Plants, practices were observed, in line with WBG EHS General Guidelines. Cimsa applies an Industrial Waste Management Plan. The Company ensures compliance with local regulations and aim at waste reduction, recycling, and safe disposal. Different waste types are segregated at source, and proper transportation, collection, and storage are implemented. In 2022, around 136 tons of hazardous waste and 2,969 tons of non-hazardous waste were generated at Cimsa plants. 86% of the generated waste was recovered, either in terms of waste or energy recovery. The hazardous and non-hazardous waste not reused at the plants are collected for disposal by licensed environmental service providers.
Quarry Sites Closure & Rehabilitation. Cimsa operates 16 quarries for raw material extraction in Türkiye. Two quarries were visited during the site visits to Mersin and Eskisehir. The Company has developed Quarry Site Closure and Rehabilitation Plans in line with the recovery of nature and the rehabilitation requirements of the Mining Regulation No. 32040. As per ESAP item #6, Cimsa will review and revise the Quarry Site Closure and Rehabilitation Plan to ensure its compliance with the WBG EHS Guidelines for Construction Materials Extraction and GIIP to meet the objectives of physical, chemical, and ecological habitat integrity, including estimated timelines and cost.
Performance Standard 4: Community Health and Safety
Community Health and Safety. The project is not expected to create a significant workforce influx. The Eskisehir Plant will conduct community E&S risk analyses before installing ground-mounted solar panels and will reflect mitigation measures in the construction plan.
Life and fire safety. Life and fire safety measures has been integrated in the design of the plants and fuel substitute waste preparation units such as physically isolated buildings, ex-proof electrical equipment and installations, min. two emergency exits and doors to allow fire brigade trucks entrance, fire extinguishing systems, sprinklers, lightning rods, warning signs; and labelling. The company has documented emergency preparedness and response plans compliant with national law and standards for RDF preparation and storage areas and fuel substitute waste located within the plant premises (Official gazette Date: 29.06.2024 No 29036).
Road Traffic. The Company has a traffic management procedure, plans, and conducts regular vehicle checks. Defensive/safe driving trainings are provided to all drivers.
Security Forces. The Company employs 77 licensed and unarmed security personnel at all sites contracted from a private company (Securitas). They are trained and certified per local regulatory requirements (Law No. 5188). 380 CCTV cameras are in use at the facilities.
