This is a category B project since the project is expected to have limited site-specific potential adverse E&S impacts that are few, largely reversible and that can be readily addressed through mitigation measures. Key E&S aspects include (i) adequacy of the E&S impact assessments and permitting; (ii) the company’s and contractor’s E&S management capacity; (iii) labor & working conditions including OHS aspects and labor rights of both direct and indirect workers, workers grievance mechanism & contractor management, and nondiscrimination and equal opportunities for women, gender-based violence, the company’s HR policies; (iv) emergency planning; (v) ability of the Project to meet applicable national and international GIIP and PSs in view of the current and future developments that may involve KBAs, (vi) waste and hazardous chemicals management at the project site and potential impacts on soil, surface water and groundwater, (vii) stakeholder engagement & grievance mechanism; (viii) community health and safety; (ix) impacts on livelihoods of affected communities, (x) potential land acquisition for reconstruction/construction of new distribution lines and construction of EV stations.

   PS1: Assessment and Management of Environmental and Social Risks and Impacts

Policy: Enerjisa Enerji 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. There is a corporate QHSSE Policy (All policies can be accessed via the link: Policies | Enerjisa Yatirimci Iliskileri (enerjisainvestorrelations.com), which reiterates the company’s commitment to providing a safe and healthy workplace for employees and minimizing adverse impacts on the environment, and these include for example environmental related policies (water, energy management, health and safety), Human Rights Policy, HR and Policy on Zero Tolerance toward violence (specifying gender-related violence and harassment), etc.

Considering inherent ES risks with electricity distribution companies (“DISCO”) operations, Enerjisa Enerji will develop, as per ESAP #1, a standalone biodiversity policy to meet GIIP and PS6 requirements and strengthen its commitment within the Health and Safety Policy. It will also develop and implement Traffic and Road Safety Policy.

The procurement policy covers issues such as environmental responsibility, social governance, human rights, GBVH, forced labor, child labor, H&S, compliance and monitoring. The company effectively passes on all these E&S requirements to its contractors, which has significantly improved contract terms, site monitoring using various tools including remote monitoring technologies, and continued training for contractors.

Environmental and Social Management System: DISCO companies, namely, Baskent EDAS, Toroslar EDAS and AYEDAS have certified Environmental, Energy and Occupational Health and Safety Management Systems (ISO 14001; ISO 45001; and ISO 50001). Esarj has its own Integrated Management System policy and environmental impact assessment and management process. Esarj also has an ESG organizational structure, has completed ISO 14001 and ISO 45001 certification, and also set KPIs for health, safety, and environmental issues. Esarj has been audited on Labor and Working Conditions and has a Supply Chain Analysis Report. While many existing plans and procedures are generally in compliance with IFC PSs, DISCO and Esarj subsidiaries will, respectively and as applicable (ESAP #1 and #2), develop and/or update existing sustainability framework and several plans and procedures as per PSs.

Identification of Risks and Impacts: Enerjisa Enerji identifies E&S risks and impacts mainly in line with national E&S regulatory requirements. Since the activities performed as part of DISCO business, such as construction of new power lines, can be associated with significant environmental impacts e.g proximity of protected areas, such as Ramsar sites and national parks in the distribution regions, may pose risks to bird populations, Enerjisa has developed and implements an internal “Environmental Impact Assessment Procedure”. To align its practices with GIIP and IFC PS1 and PS6 requirements, Enerjisa Enerji has agreed, as per ESAP #3, to develop corporate-level procedures for Identification of Risks and Impacts commensurate to the risk of existing and new/future infrastructure.

The Social Risk Assessment (SRA) that Enerjisa prepared in 2020 will, as per ESAP #1, be updated, and a corporate procedure developed, implemented, and reported on, by considering the social impacts in the earthquake zone including GBVH. As per ESAP #12, Enerjisa will update the supply chain management system and develop a procedure that clearly defines the roles and responsibilities, audits of their suppliers and their reporting frequency to Enerjisa. As part of the Esarj commitment under ESAP#2 to establish an overarching policy defining the environmental and social objectives and principles that guide the project to achieve sound EHS performance, it will establish and maintain a process to identify and mitigate the environmental and social risks and impacts of its projects.

Climate Risk Assessment: Enerjisa Enerji assesses its climate risks and opportunities in line with the Task Force on Climate-Related Financial Disclosures (TCFD) framework and requirements. In this context, two climate scenarios (<2oC and 3.5-4oC) are taken into consideration. All impacts related to these risks and opportunities are taken into consideration and ranked according to their degree of impact. Mitigating actions and measures are determined for risks and opportunities, monitored and current risk and opportunity scores are periodically reviewed. Enerjisa Enerji and its subsidiaries DISCO and Esarj will, as per ESAP #15, conduct a detailed climate change risk assessment of climate change impacts on physical assets and on workers’ occupational health and safety and the environment.

Management Programs and Plans: Enerjisa Enerji environmental and social issues are managed by different departments ie. management and planning of Environmental, Health and Safety (EHS) issues are under the responsibility of the EHS and Sustainability Departments and are managed through established management systems in place. The management and planning of expropriation related works are under the responsibility of the Real Estate and Expropriation Department and conducted in line with the Real Estate and Expropriation Procedure. Human Resources (HR), Customer Relations and Investor Relations are managed by the respective departments according to written policies and procedures in place. Recommendations for the development and or update of the plans related to environmental and OHS issues are provided under the relevant sections of ESAP. The Social Management and Monitoring Plan Document (SMMP) prepared in 2020 was not incorporated into an institutional procedure and thus was not implemented. The SMMP should be updated, as per ESAP #1, to develop a corporate procedure for implementation and reported on by considering the social impacts of project operations in the earthquake zone.

Organizational Capacity and Competency: At the corporate level, Enerjisa Enerji has a well designated structure with several committees and working groups in charge of planning and monitoring. The distribution business unit of Enerjisa has a centralized structure with the General Manager overseeing three distribution companies, namely, AYEDAS, Toroslar EDAS and Baskent EDAS. The EHS teams of DISCO units collaborate with the relevant departments at the corporate level, primarily the Sustainability Department, to improve the existing systems. Social issues are mainly managed through the corporate level department, i.e. HR, real estate and expropriation, corporate communications, investor relations and customer relations departments. However, it is unclear how DISCO’s and Esarj EHS related activities and processes at the project level are identified and integrated into the decision-making process at Enerjisa corporate levels. To address this gap, as per ESAP #4, Enerjisa will establish the “ESAP Committee” to ensure the implementation and reporting of the project ESAP items and the establishment of coordination between departments and will as per ESAP#5, enhance the organizational capacity of DISCO in terms of biodiversity management. Similarly, for the Esarj unit, the organizational capacity should be developed and/or enhanced to ensure that supplier/contractor management and other related processes are well managed. To fulfill ESAP #12 requirements related to supply chain, Enerjisa will continue to build capacity of the suppliers/contractors.

Emergency Preparedness and Response: Enerjisa Enerji has developed an Emergency Preparedness and Response Procedure (EPRP) at the corporate level. After the earthquake in Toroslar region, the distribution company was expected to meet urgent needs quickly. Enerjisa representatives in coordination with the state agency AFAD (Disaster and Emergency Management Presidency) updated its EPRP i.e “Extraordinary Situation Action Plan Procedure” has been informed by AFAD suggestions and developed to manage these processes. As per ESAP#2 Esarj will be responsible for development of a separate site-specific Emergency Preparedness and Response Plans, respectively, to cover construction and operations phases for the project.

Monitoring and Review: As part of the corporate ESMS, Enerjisa Enerji is conducting regular monitoring and reporting via its Sustainability Report set of specific indicators i.e. renewable energy purchased, natural gas consumption, diesel consumption, consumption in vehicle fleet operations, total energy consumption, water consumption and discharge, GHG emission, OHS statistics including gender related indicators like employment ration between female and male, etc. As per relevant ESAP items, Enerjisa and its subsidiaries will need to update and or develop monitoring systems and plans including e.g. (i) social management and monitoring plan that has to be transformed into a corporate management procedure, implemented and regular monitoring reports conducted according to defined KPIs, with social monitoring data, where applicable, presented in a gender disaggregated format, (ii) monitoring and evaluation system in Esarj unit covering a contractor management system, which defines the frequency of contractor audits and monitoring & reporting activities.

Contractors and Sub-contractors Management: As per ESAP #1, the client will prepare the Contractor Management Plan (CMP) that includes IFC E&S requirements, national legislation obligations required by the activity and documentation cascaded down into (sub)contractors’ scope of work through inclusion into tender documentation, contracts and their procedures during construction and operation.

PS2: Labor and Working Conditions

Enerjisa employs approximately 11,500 direct employees as of January 2024. 32% of white-collar and 1% of blue-collar employees are female. Toroslar Distribution company employs 4,360 direct employees, of which about 4% are female. The number of employees at Toroslar Distribution rapidly increased due to the immediate need for electricity service damaged by the destructive earthquake on 6 February 2023.

Human Resources Policies and Procedures, Working Conditions and Terms of Employment, Workers' Organization: Enerjisa has robust policies and procedures in relation to human resources and applicable to their employees, which cover working conditions, health and safety, gender and equal opportunities, grievance handling, child labor, forced labor, and freedom of association consistent with PS2. Enerjisa has a Code of Conduct summarizing all workplace policies and requirements, accessible online at:

https://www.enerjisainvestorrelations.com/medium/Content/File/2614/enerjisacodeofconduct.pdf

Enerjisa employees are free to join workers’ organizations of their choosing without interference and to bargain collectively. All blue-collar workers of distribution companies are covered by the collective bargaining agreement between Enerjisa and Turkiye Energy, Water and Gas workers union (TES-IS). Esarj is not unionized and have no worker representatives.

Non-discrimination and Equal Opportunity: Enerjisa has extensive and exemplary work on non-discrimination and equal opportunity, as expressed in their policies, and has competent staff managing these programs. The company is a signatory of the UN Women's Empowerment Principles (WEPs). Both men and women are trained in the code of conduct, induction, OHS and related vocational trainings. As per ESAP #7, Enerjisa will provide gender training to all its employees, including blue-collar workers, as part of their Gender Roadmap. The Company has also developed an Equal Opportunity Action Plan that covers distribution companies and Esarj employees to be implemented in 2024. Diversity and Inclusion Policy is available at:

https://www.enerjisainvestorrelations.com/medium/ReportAndPresentation/File/407/diversityandinclusionpolicy.pdf

Grievance Mechanism: Enerjisa has a formal internal grievance mechanism in place. Direct employees can report grievances through hotline, e-mail, mobile apps, online HR platform, or union representatives. Contractors' employees can also submit their grievances through the Contractor Communication Platform. There is a need for both distribution companies and Esarj to adopt Enerjisa’s corporate grievance procedure and mechanism into their operations and record each grievance, including the grievances related to physical attack incidents mentioned below, in a grievance log in line with IFC PS2. As per ESAP #6, the Client will improve its grievance log by recording, monitoring, and analysing the grievances of direct and contracted employees of each distribution company and Esarj. The Client will, as per ESAP#7, establish a separate GBVH-specific grievance mechanism and assign focal points in each business unit. Grievance mechanism related to GBVH will include a hotline managed by a 3rd party company to provide psychological, medical, and legal assistance.

Occupational Health and Safety: Enerjisa has a well-structured OHS management system aligned with ISO 45001 standards. The Company conducts job hazard risk analysis for construction and operations, implements preventive and mitigation measures accordingly. Adequate personal protective equipment, onboarding and on-the-job training are provided to all the employees and contractors’ employees, commensurate with the job risk. A digital OHS management system that includes risk assessment, corrective/preventive action follow-up, incident reporting, and inspection modules is in place. Unsafe behaviours are analysed and communicated with the employees. OHS site inspections are performed on a regular basis including contractors and records are kept. As per ESAP #10, Enerjisa will conduct a comprehensive third-party audit of welfare, life and fire safety conditions in earthquake zone container cities, that have been established to temporarily accommodate the survivors of the earthquake and adopt recommended actions and develop procedures for managing health, safety, and welfare conditions in container cities. Enerjisa’s overall LTIFR has decreased in the last couple of years, however, there has been an increase in medical treatment and first aid accident types in recent years which is in close correlation to the increase in the number of Enerjisa employees due to increased business activity. There has been a downward trend in the number of near misses over the last three years. No fatal accident occurred in Enerjisa or its contractors in 2023.

Interviews with the electricity consumption metering personnel in the field revealed that they are subjected to acts of assault by civilians from time to time while carrying out their work (meter disconnection, loss and theft detection, etc.). There were 50 physical attack/assault incidents in 2021, 57 in 2022, and 35 in 2023. While Enerjisa has implemented various support measures and protocols to address instances of violence or harassment, there remain challenges related to legal recourse and employee awareness of their rights and the Company's legal obligations. As per ESAP #11, a specialized procedure will be prepared to be followed in case of violence/assault risks or incidents, and this procedure and legal regulations regarding Enerjisa’s obligations will be communicated to the employees. Enerjisa will analyse the possible business practice solutions in consulting with field personnel and relevant external stakeholders such as local/national public authorities and sector associations.

Workers Engaged by Third Parties: Enerjisa works with 84 contractor companies in three distribution companies with 6237 workers. Of that number there are 29 contractor companies in Toroslar region with approximately 3,500 employees a year. Esarj has 4 contractor companies with 216 workers. Contracted works include mainly construction companies but also armed security services, logistics, cleaning, and system operations. Construction companies may vary from one year to the other as they are selected by the national authority mostly based on financial terms. Contractor contracts generally cover the commitment to follow Enerjisa’s HR policy and Code of Conduct (CoC), including the prohibition of forced labor, child labor, gender-based violence, and harassment. All third-party workers operating at Enerjisa’s sites, including construction sites, are to follow the labor and OHS standards, with the oversight of the procurement and OHS departments. Any accidents or incidents associated with third-party employees are recorded and monitored by the company.

The company manages and audits only contractors selected directly by Enerjisa through the Workforce Management Audit Form/Checklist adopted from IFC/EBRD Workers' Accommodation: Processes and Standards twice a year. However, Enerjisa has limited monitoring and audit capacity over construction companies that are hired through the tender process by the national authority and that may change every year. As per ESAP item #9, Enerjisa will undertake a gap analysis of existing procedures against IFC's Managing Contractors' Environmental and Social Performance Good Practice Note (GPN) and prepare a Contractor Management Plan to be tailored to each distribution company and Esarj and that will include on-site audits (ESAP #8) for all contractors including construction companies and integrate Code of Conduct compliance into the existing Contractor Performance Evaluation Form. Consequently, as per ESAP #1 and #2, the client will update existing procedures in its business units that include IFC E&S requirements for (i) auditing process of sub supplier contractors and (ii) cascading these requirements down into (sub) contractors’ scope of work through inclusion into tender documentation, contracts and their procedures during construction and operation. The client will include legally binding obligations in the EPC/O&M contract (and subcontractor contracts) to require compliance with the obligations of relevant national legislation, relevant construction management plans, as well as IFC PS requirements.

Supply Chain: Enerjisa has a Third-Party Relations Policy that defines the requirements on human rights, from its suppliers and business partners. The Company also has a Supply Chain Code of Conduct to be signed by its suppliers as a part of the contract. Third-Party Relations Policy is available at: https://www.enerjisainvestorrelations.com/medium/ReportAndPresentation/File/2446/thirdpartyrelationspolicy.pdf

The Client’s supply chain includes solar PV panel and EV charging station suppliers. To ensure its suppliers follow Enerjisa’s human rights and HR policies, the Company has initiated a solar supply chain gap analysis and has been working on a Supply Chain Management System based on IFCs’ standards. While the Customer Solution business i.e. development of distributed generation capacities/solar panel is not part of the project, Enerjisa will, as per ESAP item #12, map suppliers with high risk of forced labor and child labor in their primary supply chain and prioritize preparing a physical audit plan for these suppliers in consistency with PS2 by 2024 Q4. If child labor or forced labor cases are identified, Enerjisa will take appropriate steps to remedy them first or disengage from those suppliers as a last resort option. Enerjisa will continue monitoring its primary supply chain on an ongoing basis to identify any significant changes. In addition, compliance with Enerjisa’s Ethics Rules and Code of Conduct will be integrated into the existing Supplier Performance Evaluation Form as a selection criterion.

PS3: Pollution Prevention and Abatement

Resource Efficiency and Greenhouse Gas (GHG): All Discos are ISO 50001: Energy Management System certified. The main source of GHG emissions during the project construction phase include combustion from fuel-powered construction machinery, such as vehicles, machinery, and consumption of grid electricity, while during operations, GHG are mostly related to el. power distribution and losses in the process (technical and theft). The client will implement vehicles fleet restructuring / replacement to reduce GHG emissions related to this activity. Enerjisa’ s Sustainability Report (2022) revealed that, Scope 1, Scope 2, and Scope 3 GHG emissions associated with its operations have been calculated in accordance with GHG Protocol. In the calculations, the CO2 equivalent factors consisting of CO2, CH4, N2O, HFCs (SF6 and refrigerant gas) were used. The Scope 1 and Scope 2 emissions for 2022 were reported as follows: (i) Scope 1: 45,280 (tCO2e), (ii) Scope 2: 1,590,692 (tCO2e). As per ESAP #13 Enerjisa units will implement climate strategy and follow GHG emission reduction targets publicly committed. In relation to use of fluorinated greenhouse gases e.g. SF6 and HFCs, which have significantly higher potential for global warming than that of carbon dioxide (CO2), Enerjisa will ensure full compliance with new Regulation on Fluorinated Greenhouse Gases ( ESAP #13 and 14)

Water & Wastewater Management: The main source of water supply is from the potable water municipal grids. The Company monitors its water consumption and all sanitary wastewater discharges. As per ESAP #14 Enerjisa will ensure that it has sewage connection permits for all assets.

Pollution Prevention and Control: Electricity distribution operations in Turkiye are not listed in Annex 1 and Annex 2 of the “Environmental Permit and Licenses Regulation”. As such, DISCOs have no obligation to hold an environmental license or permit as no industrial air emission source (except generators and notification requirements regarding their operating hours) or industrial wastewater discharge is associated with distribution facilities and office buildings. Pollution prevention is fully embedded within the Company’s certified ISO 14001:2015 Environmental Management System, with several management programs and plans designed to minimize adverse impacts on human health and the environment, including for areas under the direct control of the Company, and areas managed by contractors and subcontractors. The Company’s’ ISO 14001 system maintains a legal register to monitor the applicable legislative requirements. As good practices Enerjisa should ensure as per ESAP #14 that the stormwater collection channels within the project premises are equipped with oil separators.

Solid and Hazardous Waste and Material Management: The main types of hazardous waste generated by the electricity distribution operations include transformers and capacitors containing PCBs, discarded equipment containing or contaminated by PCBs, cables containing oil, coal tar and other dangerous substances, absorbents, filter materials (including oil filters), wiping cloths, protective clothing contaminated by hazardous substances. The hazardous waste e.g. in Adana Logistics Center A is temporarily stored up to 180 days as per legislative requirements. Enerjisa sends the hazardous waste to companies authorized by the relevant ministry (MoEUCC) for final disposal/treatment. For example, hazardous waste containing PCB is collected and decontaminated, if needed, by a licensed company. However, there is no specific procedure within the existing ESMS for PCB management. While Enerjisa is not obliged by the national relevant legislation to do so, it should start practicing “duty of care” principles i.e. how the transformers are handled by the licenced companies / what is the ultimate disposal option for PCB containing equipment and ACMs (asbestos containing materials) already identified in some building. As per ESAP#14 Enerjisa (i) will revise its waste management procedure to reflect “duty of care” regarding the hazardous waste ultimate disposal, with detailed process flows for asbestos and PCB; and (ii) will also develop an inventory of PCB containing transformers and inventory of SF6 containing breakers.

PS4: Community Health, Safety and Security

Enerjisa has different programs and measures to identify and manage risk to the communities and public associated with its distribution operations and operations of Esarj business units. It also obligates its contractors to conduct community health and safety risks analysis before work starts and to have OHS staff on site, ensure PPE usage for all workers, and conduct environment and road safety training before work begins. Enerjisa has also conducted a third-party assessment on the effects of electromagnetic fields on people living in the immediate vicinity of high voltage distribution lines and transformers and found it to be below the exposure limits for public exposure to electric and magnetic fields (published by the International Commission on Non-Ionizing Radiation Protection (ICNIRP)). As per ESAP #16 and #17, Enerjisa distribution units and Esarj business units will develop a community health, safety risk assessment and plans to effectively manage and monitor the risks related to third parties, including launching awareness campaigns in the Toroslar region to prevent third-party accidents.

Infrastructure and Equipment Design and Safety: All newly constructed and/or planned facilities are designed by professional companies to comply with Earthquake Code and Fire Prevention Code and in compliance with national regulation related to fire protection. As per ESAP #18 Enerjisa will ensure that all buildings are resistant to earthquakes, asbestos free, and have adequate system and technical provision to safeguard against fire risks.

Process and Product Safety: DISCO units are implementing important programs to improve the technical quality of the existing system, which also has positive implications for health and safety. Supervisory Control and Data Acquisition (SCADA) system is in place at each distribution company. The SCADA system is integrated with OMS (Outage Management System), which allows the integration of customer outage calls into the system, displaying outage calls and orders on Geographical Information Systems maps and assigning the orders to the maintenance teams over OMS. The SCADA allows for continuous monitoring of the grid and remote shutdown or transfer of electricity when needed, which also helps reduce occupational accidents related to electricity. Management of technical (occurring during transmission of electricity) and commercial losses (thefts by third parties / public by tempering the meters or by an illegal and unauthorized access to the electricity grid) is another key elements in DISCO business which requires technical improvements in the distribution network and engaging with stakeholders and public in order to inform these groups of the risks and hazards and avoid fatalities among public due to unauthorized access to el. grid. A review of recorded accidents revealed that electric shocks caused by high voltage (HV) and low voltage (LV) lines are the most trending type of accidents. As for the Esarj business lines, in order to adequately manage operational risks (the risk of a potential fire, electrical shock hazard, and hand burns due to overheating), the client needs to prepare (ESAP#19) a product safety improvement plan for EV chargers covering the entire product life cycle and all future phases, including product safety certification processes and onsite usage of the products. This plan allows Esarj to review its suppliers more deeply and ensure product safety. Esarj is also requested to prepare and deliver, as per ESAP #19, training to improve road safety practices (including contractors).

Traffic safety: Traffic accidents involving Enerjisa vehicles/drivers are notable at Toroslar EDAS in 2023. As per ESAP #20, Enerjisa’s business units including its contractors, will improve road safety risk assessment / develop road safety management plan that should include incident notification and investigation procedure in case of fatalities. A road safety management plan should also include provision for assessing contractors' traffic-road safety competence and include monitoring of contractors’ performance.

Security Personnel: The Company’s facilities such as substations and distribution operation bases are fenced and monitored through a CCTV system. Private company is retained to provide security services in line with the provision of the “Law on Private Security Services (Law No: 5188)” to Toroslar EDAS. The workplace security procedure describes the security measures to be taken at workplaces, security guards, electronic security, physical security, procedural security issues. In total, 197 security personnel (5 of them women), out of which 179 are armed security guards, work at 26 points throughout Toroslar EDAS. Armed personnel receive training on Human Rights. Procedures are in place to report and act on different level of security risk situations, including protocols to engage public security forces, if necessary. As per ESAP #16, Enerjisa will conduct an internal gap analysis between the requirements of national legislation, international requirements (e.g., Code of Conduct) and relevant requirements of IFC PS4 ( e.g. use of force, security screening of staff, training, etc) in consideration of all types of operations performed by Enerjisa and revise the existing practices and relevant security procedures to include training on e.g. awareness gender and GBVH, which should be reflected, as necessary, in the revised procedures i.e. Security Management Plan.

PS5: Land Acquisition and Involuntary Resettlement

Enerjisa has a Real Estate and Expropriation Procedure, which was prepared in 2014 and has been revised to ensure compliance with the international standards, including IFC PS5. The impact of expropriation for construction of energy distribution lines is minimal, as the expropriation primarily occurs for pole locations. The landowners can use the area outside the foundations of the poles, even after expropriation. The construction of the energy distribution lines is carried out by contractors selected by Enerjisa and accepted by Türkiye Electricity Distribution Corporation (TEDAS). In order to minimize potential adverse impacts during construction of the distribution lines, Enerjisa will, as per ESAP#21, enhance its Land Acquisition Procedure to include, among other things, consultation with affected people. Under the ESAP #22, for Esarj charging stations site selection process, the client is requested to establish a set of site selection criteria in a planned manner, including criteria covering social risks.

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

Enerjisa operates in three distribution regions that cover 14 provinces in central, northwestern and southern Turkey. The total length of distribution lines equal to 318 thousand km. The existing infrastructure is predominantly located in urban centers, however, some of the above-ground distribution lines fall within Legally Protected and Internationally Recognized Areas. The company has been insulating distribution lines and poles based on outage data to minimize bird-related outages across their distribution network. Enerjisa has also been working with Doga Dernegi, the local BirdLife partner, and conducting insulation works in areas that have been identified to be in high-risk areas for priority bird species by the NGO.

As per ESAP#1, Enerjisa will develop and implement a Biodiversity Policy and Biodiversity Management Plan (BMP), including a Screening Procedure, as part of its updated ESMS. For identification of risks and impacts, the Screening Procedure will be developed in line with IFC PS1 and PS6 requirements and will define and implement mitigation measures commensurate to the risk of existing and new infrastructure. The procedure will also define when to conduct a feasibility study on “wildlife friendly” pole/line design with the support of qualified experts. Any new development of distribution lines in future will be limited to modified rural habitat or in urban areas, avoiding high-risk areas for biodiversity. IFC financing will not be used for any (re)construction within biologically highly sensitive areas, namely World Heritage Site and Alliance for Zero Extinction (AZE) sites.

For the existing electricity distribution infrastructure in Legally Protected and Internationally Recognized Areas, Enerjisa will conduct a screening in line with PS6 to identify high-risk areas for wildlife electrocution through further engagement and consultation with experts/stakeholders, including Doga Dernegi. As per ESAP#23, the Company will insulate poles and lines in these high-risk areas within the Protected Areas in line with a schedule to be determined based on the outcomes of the screening, which will also determine the length of distribution lines and number of poles to be insulated, as well as required time and workforce to do the insulation.

   Enerjisa has two levels related to Stakeholder Engagement i.e. (i) Enerjisa Corporate Stakeholder Engagement Framework (2022) and (ii) project specific Enerjisa Toroslar Stakeholder Engagement Plans (2024)). Main responsibility for engagement with external stakeholders lies within Corporate Communication and Customer Relations departments. External stakeholders and community members can reach out to Enerjisa to submit their grievances or information requests through Alo186 (24/7 hotline), WhatsApp line dedicated to the mukhtars of neighborhoods, petition, Enerjisa mobile application (for customers), Enerjisa’s social media accounts, and corporate email addresses. In addition, all employees, and other stakeholders of Enerjisa can report cases of non-compliance with the Code of Ethics to Enerjisa Enetik via email: ENETIK@enerjisa.com, ethics notification form at www.enetik.enerjisa.com, by phone: +90 (312) 573 55 55, by fax: +90 (312) 573 55 55, or by mail: P.K. 2 06510 Emek/Ankara. They can also notify via the Sabanci Holding line. The head of the Internal Audit Department is the only person authorized to access notifications and is responsible for the security, confidentiality, and management of all notification channels.

Under the Corporate SEP, stakeholder engagement activities are conducted, monitored and reported by the distribution companies monthly or annually depending on the activity, which informs the Corporate SEP Monitoring Report. Enerjisa’s Social Risk Assessment (SRA) Guide includes risk assessment at the distribution company levels, which also covers community stakeholder engagement and grievance management, and potential social impacts re to the community health and safety, land acquisition and involuntary resettlement.

Toroslar SEP is designed following the Corporate SEP, while also enhancing it to better suit its specific context and requirements i.e engagement methods that should be gender inclusive, engagement frequency guidelines, and predefined targets and evaluation criteria into its own stakeholder engagement process. However, the Toroslar SEP does not have information on regular consultations with communities and information sharing and training programs to ensure workers’ safety while conducting necessary metering work. Community level information sharing, training and capacity building need to be addressed and included within the scope of SEP. Thus, in order to address identified gaps, Enerjisa will as per ESAP#1, prepare specific stakeholder engagement plans including for its distribution units in Ayedas, Baskent, and update Toroslar Stakeholder Engagement Plan to include a dedicated section and stakeholder engagement strategy focused on (i) the external assaults against its employees, (ii) women and other underserved groups of stakeholders and address awareness of GBVH as well as partnerships with relevant organizations on the ground to minimize bullying and GBVH against employees, (iii) update the NGOs identified to include Nature Association for biodiversity, and regularly update of the Corporate Stakeholder Engagement Plan. Similarly, under ESAP #2, the stakeholder engagement process of Esarj business lines, respectively, should be improved and or developed, so to establish a procedural approach that adheres to IFC PS1, which will result in improved stakeholder engagement process and better management of grievances and requests received.