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.
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
Policy, Identification of Risks, and Impacts
The Company has an EHS policy disclosed on its website (http://www.martur.com.tr/assets/policies/cevrepolitikasimartur-en.pdf ) including commitments to meet national and international environmental and safety standards, applicable to all group staff and operations.
The Company’s expansion projects are mostly composed of acquiring new machines or equipment for production of new orders. Hence, the activities under the scope of this investment do not require EIA process. Martur’s internal E&S risk assessment processes will be applied which are consistent with PS1 requirements.
Management Programs, Organizational Capacity and Competency
Martur has established a group level environmental and social management system (ESMS) certified as per ISO 14001 (environmental management) and ISO 45001 (occupational health and safety). The ESMS incorporates standard operating procedures (SOPs), standardized EHS performance indicators, measurements and audit reports, action plans assigned to individuals and company-wide targets for continuous improvement towards good international industry practices. The ESMS is consistent with the requirements of IFC PSs and commensurate with the risks and issues of company’s operations.
Effective implementation of the ESMS was observed during the recent site visits with competent staff in place. A group level Management Systems Manager and an OHS Manager leads the implementation of EHS requirements in all plants, with support of competent plant level teams.
Emergency Preparedness and Response
Martur has documented emergency preparedness and response plans appropriate to specific potential risks and maintained in accordance with the respective national laws at each individual plant.
The fire detection and suppression systems established at each plant comply with the national building and fire safety codes. Martur regularly performs internal audit of their alarm and life and fire safety passive and active systems.
Monitoring and Review
Martur continues to conduct comprehensive EHS monitoring and of its individual operations vis-à-vis the applicable regulatory requirements and ESMS procedures. Monitoring results are reviewed by the OHS and Management Systems managers in Martur (both facility level as well as group level) and corrective actions are assigned. Ongoing improvements in the system are planned to track corrective action implementation. Top management reviews the KPIs including incidents and accidents, monthly. The data collection forms the basis of annual E&S reporting submitted to the corporate-level senior management, as well as makes part of UN Global Compact Progress Reports which the company is preparing annually.
PS 2 – Labor and Working Conditions
Martur employs over 3,500 staff in its facilities/offices in Turkiye (%28 women). All production and administrative workforce are directly employed. Third party workers are only employed in non-core functions (cleaning, catering, bus transport and some maintenance).
Human Resources Policies and Procedures
No material change has taken place in the Company’s Human resources (HR) policies and procedure or terms and conditions of work as part of new project scope. HR policy, systems and procedures are centrally designed and applied to all the group companies and are consistent with local labor laws and requirements of IFC’s PS2.
Grievance Mechanism
Martur has developed a grievance mechanism procedure for workers in line with IFC PS2 requirements and has rolled-out across all facilities in different countries. Based on recent appraisal findings, the grievance mechanism is observed as not being actively used by Martur employees, as reflected by the limited number of grievances received compared to the size of the headcount.
As per ESAP1, Martur will augment the grievance mechanism for workers (i) to ensure anonymous complaints can be submitted and resolved, (ii) enhancing visibility and accessibility to workers and (iii) developing procedures to log issues raised to union or worker representatives at the plant and corporate level, to be monitored as part of the respective grievance mechanism.
Working Conditions and Terms of Employment
The Company has an Employee Handbook in line with labor laws and IFC PS2 requirements applicable to all operations. Employees either work in a 3 or 2-shift system based on production needs of the section.
Post-pandemic and post-microchip shortage conditions created an accumulated demand in the automotive industry which also affected Martur Turkiye plants, leading to an increase in overtime work. As per ESAP 2, Martur will undertake review of country/plant practices with regards to overtime, identify and assess gaps and develop a group level overtime management procedure and an action plan to comply with national limits (24 hours rest per seven days, 270 maximum allowable overtime per year and maximum night shift of 7.5 hours in Turkiye) and PS2 (overtime being practiced occasionally and based on consent of workers) within a reasonable duration.
Workers’ Organization
The HR policy of the Company recognizes workers’ rights to form or join unions of their own choosing and collective bargaining. Martur employees in Turkiye joined Turk Metal Union as of 2023. There’s an interim CBA is in place and new sector wide CBA negotiations are ongoing which will cover the next two years. With the unionization process, an employee relations manager is appointed, who frequently visits the shopfloor and engages with workers.
Retrenchment
Martur has a centrally developed a Collective Termination procedure which includes a commitment to prepare a retrenchment plan in line with IFC PS 2 requirements (completed under ESAP 2016).
Occupational Health and Safety
The Company’s OHS management systems are described under previous project ESRS (https://disclosures.ifc.org/project-detail/ESRS/41874/martur-ii) and consistent with PS2 requirements. OHS issues are managed by plant level OHS teams under supervision of Martur’s central OHS manager in line with corporate procedures.
Based on last three years’ data, Martur LTIFR remains below the sectoral benchmarks (6 for general manufacturing and 9 for primary metal manufacturing) at group average. Three plants in Turkiye (OSB, Fompak NOSAB and Kutahya Trim) are slightly over the general manufacturing benchmarks. However, all are below the primary metal manufacturing benchmark. No fatalities reported.
As indoor VOC monitoring is a critical part of Martur operations due to materials used in foam production, plastics, and welding, Martur has developed a common workplace monitoring program as part of its previous ESAP requirements to IFC in 2016. It includes common indicators to be measured by an independent company and reported to Martur management, including VOCs, dust, noise, heat, vibration, and light intensity. According to recent workplace monitoring data provided for all Martur plants, the facilities were found to be generally in line with national and IFC standards. Martur is also undertaking improvements in air extraction and ventilation measures to improve air quality within the plants. As an example, successful upgrades were implemented in Akcalar plant and in OSB plant in the welding section in Turkiye in 2017 and in the assembly section of the OSB plant in 2023. As per ESAP 3, Martur will update the Workplace Monitoring Plan (prepared as per ESAP 7 of IFC’s first investment #38025) to reflect the most recent production process changes covering below: i) review and ensure at least annual monitoring of worker exposure to VOCs for welding, foam, plastic and textiles processes; ii) incorporate thermal comfort measurements in Morocco, iii) incorporate heat stress risk assessment and management measures related to climate change (especially for any outdoor activities including construction).
Supply Chain
Martur works with 500 suppliers directly. Martur’s supply chain manual includes E&S requirements consistent with the requirements of IFC PS2, that are signed by each supplier. Suppliers are also required to fulfill self-assessment forms on a regular basis that include detailed questions on these requirements which also include labor and OHS compliance. Compliance with these requirements is monitored by regular on-site audits by the company. Most of Martur’s suppliers are located either in Europe or Turkiye.
PS 3: Resource Efficiency and Pollution Prevention
Resource Efficiency
Martur continues to implement its established energy policy focusing on sustaining energy management system, meeting regulatory and client requirements, increasing awareness of significance of energy efficiency among its employees and using energy efficient machines, equipment, and services.
Resource use is monitored with established key performance indicators (KPIs) such as electricity consumption per unit of frame production. Examples from resource use and efficiency improvement projects in 2022 covers 33% reduction in electricity consumption in Kutahya plant by implementing automatic closure of seat production lines at leisure and 48% natural gas use reduction at fabric washing machine by heat exchange system replacement in Kutahya.
Following continuous improvement principles, the company encourages its employees to submit their suggestions for efficiency improvements in the process through suggestion system available on the environment and OHS boards in production areas.
GHG Emissions
The main sources of greenhouse gas (GHG) emissions in Martur’s operations are natural gas fired process equipment, electricity consumption, and diesel use for backup generators and vehicles with a smaller contribution from the leakages of refrigerant from chiller systems and welding and shield gases (i.e., CO2, oxygen, and argon) used within the process.
The Company is certified as per ISO 14064-1:2007 (GHG quantification) obtained only for the seat manufacturing in Turkiye. Accordingly, 7.35 kg CO2-eq was emitted per unit seat production in 2022. Building upon this effort, Martur will augment its corporate ESMS by developing a GHG quantification and reporting procedure in line with GIIP as per the ESAP 4.
Air Emissions
Main point emission sources of Martur Turkiye operations remain as boilers and furnaces fired by natural gas, and the backup generators using diesel. Monitoring results indicate compliance with the national law and WBG EHS guidelines emission levels. In light of the recent production process and layout changes, and planned expansion works in Turkiye plants, Martur will review and augment the group level ESMS air emissions monitoring and management procedure in accordance with national legal requirements and applicable WBG EHS guidelines as per the ESAP 5.
Water and Wastewater
All Martur Turkiye plants are connected to the industrial zone management or municipal sewage systems which subsequently provide appropriate wastewater treatment before final discharge to the receiving bodies. Process wastewater from dyeing operations in Kutahya plant is pre-treated in an on-site wastewater treatment plant (WWTP) before discharging to the WWTP of the industrial zone.
Solid and Hazardous Waste
Solid and hazardous wastes are stored separately at designated areas within the facilities. Recyclable wastes such as plastics, cardboards, glass are collected and recycled by third- party licensed waste management companies. Hazardous wastes are also separately collected and recovered/recycled where possible and disposed where not possible by the third-party licensed companies.
PS 4: Community Health, Safety and Security
All Martur Turkiye plants are located within organized industrial zones and, hence no significant impacts on health, safety and security of the local community are expected due to current company operations.
Martur facilities involve storage, transport and usage of hazardous chemicals as necessitated by the production processes. The main hazardous materials used in the processes are polyol, isocyanates and other additives for foam production, phosphate, dyes, acids, and alkali neutralization liquids for electrocoating, oxygen, lubricants, grease, mineral and hydraulic oils and, ethyl alcohol for frame production finishing chemicals and lamination ink. Hazardous materials are stored in well-ventilated and isolated chemical storage or waste collection sites. Chemical tanks are equipped with spill pools. Raw material is directly brought by major suppliers who also conduct their own safety checks prior to the transfer. Appropriate fire extinguishing and spill prevention equipment is provided at designated areas. As underlined in PS1 subsection, the Company has documented emergency preparedness plan with repose activities, resources and responsibilities and provided appropriate information to potentially affected third parties within the industrial zone and potentially affected communities.
Martur does not employ any armed security officers. Security at the plants is only used for regulating access to the plant and to the facilities. All security personnel in Turkiye are under Martur’s payroll. Plant specific security management plans are being implemented and approved by local authorities as needed.
