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.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Autoport identifies and manages its E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements. Autoport has an integrated management system certified per ISO 9001 (quality), ISO 14001 (environmental), and ISO 45001(occupational health and safety - OHS). In addition, Autoport’s port security framework is certified in accordance with the International Ship and Port Facility Security (ISPS) Code. Autoport maintains a Quality Document Management System (QDMS) where the implementation of OHS programs, which align with national laws and regulations, is monitored. The QDMS is accessible to all employees where project-related risks and impacts are available online. As per ESAP#1, Autoport will update its ESMS to manage the environmental, health and safety, and social-related risks and impacts of the project in line with IFC PS1.
As part of the ESMS update to address the risks and impacts associated with construction activities, Autoport will prepare the following project specific construction and operations phases management plans: (i) Dredging Management and Monitoring Plan; (ii) Biodiversity Management Plan; (iii) Worker’s Camp Management Plan; and (iv) Climate Risk Management Plan. In addition, Autoport will update its existing ESMPs for both construction and operations phases, as appropriate to the Project’s context, including: (i) Occupational Health and Safety Management Plan; (ii) Waste Management Plan; (iii) Noise Management Plan; (iv) Water and Wastewater Management Plan; (v) Stormwater Management Plan; (vi) Air Quality Management Plan; (vii) Hazardous Material Management Procedure, (viii) Traffic Management Plan, (ix) Community Health and Safety Management Plan, (x) Security Management Plan; (xi) Emergency Response Plan; (xii) Procurement Procedure, and (xiii) Change Management Procedure, in line with IFC Performance Standards, and WBG EHS General Guidelines (2007), and WBG EHS Guidelines for Port, Terminal and Harbors (2017). (ESAP #2 and #3), Autoport finalized its contractual agreement with the engineering, procurement, and construction (EPC) contractor, which included the E&S responsibilities and commitments of the EPC contractor and its subcontractors, in line with the IFC PS, relevant WBG EHS Guidelines, and considering aspects of IFC's Good Practice Note for Managing Contractors' Environmental and Social Performance. The EPC contractor will (i) develop its own ESMS in line with the project’s ESMS; (ii) establish an HSE team, including an Environmental Specialist and a Health and Safety Specialist, and (iii) prepare the Contractor’s CESMP in line with that of the Autoport’s C-ESMP (ESAP #4).
The project's EIA report was prepared in line with regulatory requirements and submitted to the Ministry of Environment, Urbanization, and Climate Change (MoEUCC) for final approval (https://eced.csb.gov.tr/jsp/ek1/44557#). The EIA Approval was obtained from the Ministry of Environment, Urbanization, and Climate Change in July 2025. As per ESAP #5, Autoport will undertake supplementary studies to comply with IFC PS requirements. The will include (i) social impact assessment to further assess traffic impact, noise and vibration impact on communities; (ii) gender-based violence risk assessment; (iii) labor audit; (iv) noise baseline and modelling; (v) OHS risk assessment; (vi) E&S risk assessment of the reclamation fill material source (vii) dredging risk assessment, including sediment sampling and dispersion modelling. As per ESAP#2, the project will develop and implement a chance find procedure to be used if it encounters archaeological resources during construction activities.
Autoport's in-house HSE team comprises an HSE Manager, two HSE specialists, and one medical doctor. The team oversees the Autoport operations and HSE performance of the existing subcontractors. The team is hiring other personnel to assist with the construction and operation of the expansion project. A community liaison officer (CLO) will be appointed to lead the project's community consultations, external grievance mechanism, and information disclosure in line with the stakeholder engagement plan (SEP). utoport hired additional an environmental specialist and health and safety specialist to support the implementation of the project's ESMS and ESMPs.
Autoport’s existing monitoring program is in line with regulatory requirements, including monitoring of safe working hours, incident records, emergency drills, and OHS training undertaken by workers. As part of the ESMS update, Autoport will establish key performance indicators (KPIs) for environmental, OHS, and social aspects during construction and operations, to be integrated into each management plan and aligned with IFC PSs and relevant WBG EHS Guidelines (ESAP #2 and ESAP #3).
Autoport has an Emergency Response Plan (ERP) for the existing port operation. The plan includes responses to injuries, load falls, fires, and explosions from ships and vehicles, port activities, spills, earthquakes, floods, suspicious packages, diseases, and civil and political unrest. The company has an Emergency Response Team that undergoes periodic training in accordance with national legislation. Emergency drills are performed on-site every six months. The Kocaeli Derince-Yenikoy Region has its own coastal facilities response plan, which provides emergency response services to marine pollution in the region through a third-party contractor. As per ESAP #2, Autoport will update its ERP to include simultaneous construction-operations phase activities and to consider risks, including fire, earthquake, ship collision, and engine malfunction, for major vessels. Autoport will engage with nearby communities on the risks and mitigations accordingly as part of its Stakeholder Engagement.
Fire alarm call points, evacuation route maps, fire extinguishers, and hose reels have been placed at appropriate locations in the existing port. In line with ESAP #6, Autoport will engage a qualified third party expert to conduct a life and fire safety (LFS) audit of the existing port buildings and warehouses, consistent with GIIP. Based on the audit findings, Autoport will implement the recommended measures to ensure adequate firefighting protection, including the installation of internationally certified per-and polyfluoroalkyl substances (PFAS) free fire-fighting foam system, as applicable.
PS2: Labor and Working Conditions
Autoport has a total workforce of 248 personnel, comprising 86 direct employees and 162 contractor employees, of whom approximately 6% are female. The project is expected to require an additional 90 contractor workers at peak construction. The EPC contractor has not yet been engaged. Autoport’s current risk assessment and monitoring of the contractors’ performance is limited to OHS and emergency response. To assess compliance with the PS2, a third-party labor audit will be conducted three months after the start of construction period (ESAP #5).
Autoport has an HR policy in line with local labor laws and IFC PS2, covering working conditions, fair remuneration, OHS, non-discrimination, prevention of child and forced labor, a code of conduct (CoC), and a workers’ grievance mechanism. The HR Policy also commits to freedom of association. While no formal trade union or workers’ representative structure is currently in place, consultation indicated that workers are aware of management’s open door policy, are able to raise concerns directly, and do not perceive a need for union representation. As per ESAP #7, Autoport will further strengthen its HR Policy and develop detailed procedures to operationalize compliance with national laws and IFC PS2, including (i) compensation and benefits; (ii) recruitment and hiring, including the recruitment and retention of women and prevention of gender disparity; (iii) trade unions and collective bargaining; (iv) non-discrimination & equal opportunity; (v) diversity and inclusion; (vi) prevention of GBVH; (vii) employee grievance management; (viii) collective dismissals, renumeration, overtime recording and payment; and (ix) the procedure will also inform workers that they can form or join a workers’ organization of their choice, and that they can elect workers representatives as per national laws and regulation; and develop the written induction procedures for the new workers, subcontractors, and visitors of the expansion project. As per ESAP #8, Autoport will update its CoC to align with IFC PS2, describing expectations for the behavior of direct and contracted workers outside the work site and in the host community, including specific provisions on GBVH.
All workers receive a written employment contract outlining working conditions and terms of employment, followed by induction training, including OHS. Operational staff work on a three shift basis. Overtime is infrequent; where applicable, it is voluntary, recorded, and compensated in accordance with national regulations. Autoport assigned an HR staff with appropriate qualifications and experience to monitor all labor issues for direct workers, contractors, and subcontractors, and manage the company’s compliance with Labor Laws and IFC PS2 requirements.
Autoport has a Code of Ethics and Compliance Procedure, which provides multiple channels for employees to submit suggestions, concerns, or complaints to the ethics line including: (i) Autoport ETIK phone number; (ii) email via etik@autoport.com.tr, (iii) use of Autoport's Limon Mobile Application; and (iv) port complaint drop boxes. The ethics line allows employees to raise concerns and suggestions anonymously. An Ethics and Compliance Committee is in place to handle notifications received through the Ethics line. As per ESAP #9, a grievance mechanism (GM) procedure will be developed to describe these different communication channels and implement specific reporting lines. There will also be a dedicated GM for cases of discrimination and GBVH that align with a survivor-centered approach. The GM procedure will apply to all direct and contracted employees and will include measures to guard against retaliation. All workers, contractors, and subcontractors will be made aware of how to access the GM through the training program.
As per ESAP#10, Autoport will appoint a GBVH focal personnel to handle GBVH cases within the workplace and community and engage a qualified GBVH expert to provide targeted training to the GBVH focal personnel, Autoport management, and HR team, to strengthen institutional oversight and capacity to address GBVH risks of the project.
Autoport has an HSE Control Plan prepared in compliance with national legal requirements. Autoport OHS programs include OHS risk identification, job hazard analysis, control implementation, and monitoring of working conditions and accident statistics. The HSE performance is managed and monitored through the internal QDMS. The OHS team, the medical doctor, and the relevant operations team undertake the risk assessment. The OHS team validates each reported incident as part of the process. There have been no fatalities reported over the last three years. LTIFR (Lost Time Incident Frequency) is below the sector average. Workplace measurements (noise, vibration, dust, thermal comfort, lightning) are carried out by a third-party accredited company, and periodic health checks are conducted by a workplace doctor as per the regulations. As per ESAP #2, the project’s OHS Management Plan will be updated to include identification and risk management during the simultaneous construction and operations phases, including a review of risks related to heavy vehicle movement and loading and unloading operations. It will also establish the OHS monitoring requirement per WBG EHS Guidelines for Ports, Harbors, and Terminals (2017). As per ESAP#11, Autoport will also prepare a detailed maintenance program for each piece of port equipment to reduce OHS risks associated with its use.
During the project construction period, the EPC contractor will establish temporary site offices and workers’ accommodation within the existing project footprint. Nearby communities raised concerns regarding potential risks GBVH associated with an influx of contractor workers.
As per ESAP #2, Autoport will develop a worker’s accommodation plan and monitoring program in line with the IFC/EBRD Workers Accommodation: Process and Standards guideline (2009) to manage quality of basic services and workers’ health and safety. As per ESAP #6, a LFS audit will also be undertaken for the workers’ accommodation.
Labor and working conditions of all third-party workers, including security, cleaning, catering, and workers to be employed by the construction contractor, shall comply with labor and OHS standards specified in the company’s E&S specifications, CoC, and local regulations. Any accidents or incidents associated with third-party employees are recorded and monitored. The contractor workforce has access to the company’s grievance mechanism through the Ethics line. Contractor workers also participate in periodic OHS training and emergency drills. As per ESAP #4, the Contractor’s C-ESMP to be developed will cover the OHS and other PS2-related issues for the project’s construction workforce.
PS3: Resource Efficiency and Pollution Prevention
Noise monitoring was undertaken as part of the EIA for sensitive receptors near the project site, in line with regulatory requirements. The EIA noise baseline is above the WBG EHS Guidelines for one receptor. As per ESAP#5, Autoport will engage a noise specialist consultant to conduct an additional baseline monitoring program prior to the start of construction and to undertake a noise modeling assessment that factors in noise levels from vehicles and equipment to be used for construction works, including backfilling, dredging, and piling. The results of the noise modeling will define the noise abatement to be implemented by the project and reflected in the Noise Management Plan for the C-ESMP and O-ESMP (ESAP #2 and # 3).
The project is expected to increase the annual ship traffic from 200 to 250. Each of the ships will be required to directly coordinate with Izmit Waste and Residue Treatment Inc. (IZAYDAS), for the collection and disposal of all ships’ waste within the scope of MARPOL 73/78. IZAYDAS has been mandated by the local government to collect all ship waste within the Municipality's borders and treat it. The Waste Management Plan will include the construction and operation of temporary waste storage facilities for project construction and operational wastes. The management plan will monitor compliance by the corresponding waste treatment providers with national laws and regulations, and their conformance with GIIP (ESAP #2 and ESAP #3).
Hazardous waste generated during operations and maintenance work are managed in line with local regulations, segregated in accordance with regulatory waste codes, and disposed of by licensed collectors. Hazardous and flammable cargo, such as industrial chemicals, is not handled on site. The fuel and oil spill containment measures within the existing port are to be improved to align with good engineering practices, including the provision of an inflammable wall between compartments and increasing the capacity of the secondary containment (ESAP #14).
The stormwater is discharged directly into the sea through two channels along the main pier without treatment or monitoring. The regulatory requirement does not include a specific provision for stormwater monitoring. As per ESAP #13, Autoport will install a spill containment system, including an oil-and-water separator to treat stormwater prior to discharge. The stormwater management plan will include the standard operating procedures for maintaining the spill containment system and the water monitoring plan (ESAP #2 and ESAP #3).
The project capital dredging will generate approximately 487,000 m3 of spoil materials. As per ESAP#5, Autoport will undertake dredging risk assessment studies, including dredge material characterization to identify potential environmental risks and inform appropriate disposal and management measures. The studies will include: (i) vertical profile sampling of the dredging depth, and (ii) sediment dispersion modeling to assess impacts in the marine environment. As per ESAP#2, the project will develop a dredging management and monitoring plan (DMMP) that is compliant with the local regulations, IFC PS, and consistent with the WBG EHS Guidelines for Ports, Terminals, and Harbors (2017). The DMMP will be submitted to the Ministry of Transport for approval prior to the start of the dredging works and will be incorporated into the E&S obligations of the dredging contractor.
PS4: Community Health, Safety and Security
The closest residential area to the project is approximately 500 m away and is generally composed of vulnerable elderly people. There are also primary and secondary schools in the residential area. Two artisanal fisherfolk were observed during the site visit fishing within the ports' exclusion area.
The project's road network will experience increased traffic volume due to construction material deliveries to the site. Traffic impact is one of the key concerns raised during the EIA consultation and during IFC’s interviews with local stakeholders. As per ESAP #5, the EIA traffic impact assessment will be supplemented to further assess community risks in line with IFC PS4 and WBG EHS Guidelines and quantify anticipated increases in traffic volumes or associated noise and dust impacts along community roads. Autoport will also update the Traffic Management Plan as per ESAP #2 and ESAP #3 to include road safety risk assessment, driver assessment and training programs to minimize accidents, noise, and dust impacts on communities and workers.
The Autoport Security Plan approved by the General Directorate of Marine Affairs of the Ministry of Transport in 2020 is in line with International Ship and Port Facility Security (ISPS) Code requirements. Autoport engaged a private security company at the site, which is contracted in line with the Law on Private Security Services. There are 26 unarmed security guards deployed at the project site. Since it is a bonded/customs area, there is also a 24-hour customs guard (state authority) responsible for the port's security. All security personnel receive relevant security and safety training from the company, including stress management, crisis management, and code of conduct. Autoport will update the Security Management Plan to incorporate risk assessment procedures for community security risks posed by third parties. It will also include training and awareness programs on GBVH issues and the disproportionate use of force (ESAP #2 and # 3).
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The project is located on the Marmara coast of Turkiye, where the terrestrial components fall within the Anatolian conifer and deciduous mixed forests ecoregion of the Mediterranean Forests, woodlands, and scrubs biome, and the marine section is part of the Marmara Sea bioregion (Resolve, 2017). The Marmara Sea and Islands are a Legally Protected Area, designated as a Specially Protected Area of Mediterranean Importance (SPAMI) under the Barcelona Convention.
The coastal and terrestrial parts of the project site are in Modified Habitat, where the grassland habitat has been highly degraded, and the land collapsed during the 1999 earthquake. The marine project components will include expanding the existing berth, located in a mix of Natural Habitat, composed of infralittoral fine sands and muddy areas, and Modified Habitat, composed of fill rocks and steel piles from previous marine construction activities. Based on marine surveys conducted within the scope of the EIA, the area's intense turbidity is not suitable for the growth of macrophyte species. Therefore, except for benthic species observed on the pier poles and artificial surfaces, no other priority biodiversity values were recorded in the area, although marine species, specifically marine mammals, are known to occupy the wider area in the Marmara Sea.
Priority biodiversity values associated with the project include European Hake (IUCN Mediterranean Red List VU) and Cirsium balikesirense, an endemic plant species identified in the coastal grasslands but requiring further confirmation of its taxonomy and distribution in the area. IFC Natural Habitat No Net Loss (NNL) requirements will apply to these priority biodiversity values.
Autoport will develop and implement a construction-phase Biodiversity Management Plan (BMP), which will set forth measures to address data gaps related to the endemic plant species on the coast and mitigate impacts on all priority biodiversity values, including those that are associated with the Marmara Sea and Islands SPAMI that could potentially be impacted during disposal of dredge material into designated spoil disposal areas (ESAP#14). Underwater noise and vibration are expected to occur due to pile driving, filling, and dredging activities during the construction phase, and vessel activities during the operations phase. To minimize impacts related to underwater noise and vibration, pier piles will be selected in line with GIIP implementing low noise/low vibration construction technologies to reduce noise at source, and use of passive acoustic monitoring (PAM) during construction, and limiting pile driving and other high noise activities with marine mammals are present within 1000 meters and any other underwater construction when mammals are present within 500 meters, in line with good international industry standards. These will be reflected in the project’s BMP and DMMP. During the operations phase of the project, Autoport will continue to monitor the port area for the presence of marine mammals to avoid vessel strikes.
The marine project components will include expanding the existing berth, located in a mix of Natural Habitat, composed of infralittoral fine sands and muddy areas, and Modified Habitat, composed of fill rocks and steel piles from previous marine construction activities. Based on marine surveys conducted within the scope of the EIA, the area's intense turbidity is not suitable for the growth of macrophyte species. Therefore, except for benthic species observed on the pier poles and artificial surfaces, no other priority biodiversity values were recorded in the area, although marine species, specifically marine mammals, are known to occupy the wider area in the Marmara Sea.
In line with PS6 requirements on legally protected areas,, Autoport will also support the development and/or implementation of conservation or research programs within the Marmara Sea SPAMI in cooperation with relevant stakeholders (e.g., MoEUCC, Turkish Marine Research Foundation (TUDAV), WWF Turkiye) as part of the BMP to support the conservation objectives of SPAMI (ESAP#15).
