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
Management System and Identification of Risks and Impacts
E&S Policy: GRT has an environment, health and safety (EHS) commitment at the corporate level, based on which each facility develops its own EHS policy and procedure considering local conditions and legal requirements. GRT Türkiye will also develop its own E&S policy consistent with GRT China corporate ES commitment and adapted to meet Turkish regulatory requirements, IFC Performance Standards as per ESAP#1.
Identification of Risks and Impacts: GRT identifies and manages E&S risk and impact associated with its operations primarily through compliance with applicable national standards and E&S regulatory requirements. GRT Türkiye will be required to identify and manage risks in accordance with IFC PSs. Although the project does not require EIA per Türkiye national law, an Environment and social impact assessments (ESIAs) align with IFC PS have been developed for the project.
Under Türkiye local regulations, GRT must obtain the following licenses for the plant: i) land use permit, ii) EIA opinion, iii) construction permit and building license, iv) environmental noise permit, v) wastewater discharge and/or air emissions permit, vi) Industrial Waste Management Plan approval, vii) agreements with licensed waste management companies, viii) private security permit. All these elements will feed into the final ESMS.
Management Programs: GRT manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements regarding pollution prevention (e.g., VOC treatment, hazardous waste treatment), occupational health and safety, labor rights, gender-based violence prevention, supply chain management, life and fire safety(L&FS), and machinery plans. GRT has a management system certified as per ISO9001:2015 (Quality), ISO14001:2015 (Environment), ISO45001:2018(OHS), ISO5001:2018(Energy management). GRT has not established any management systems, policies, or procedures for Türkiye project operation yet. As per ESAP #2, GRT will implement a PS1 aligned operational stage ESMS integrating the EHS practices already in China and adapt to Türkiye national law and align with IFC PS covering elements such as (but not limited to); (i) operational ES management programs; (ii) emergency preparedness and response; and (iii) monitoring and review.
GRT Türkiye will hire EPC contractor for project construction. As per ESAP#3, GRT Türkiye will develop the EPC contractor agreement and monitor its performance in line with IFC’s good practice note on Managing Contractors’ Environmental and Social Performance, IFC PS, GRT Türkiye ESMS. GRT Türkiye will also require the EPC contractor to develop and implement a robust suite of site-specific construction ESMP, emergency response and preparedness plan (EPRP) based on the ESIA defining site-specific mitigation & monitoring measures for construction stage and in line with the E&S provisions of its contract (ESAP #4). ESMP and EPRP will address aspects such as dust & noise control, waste management, wastewater management, use of heavy vehicles, traffic management, hazardous material management, emergency preparedness and response, occupational health and safety, labor and living conditions, and others for construction phase, based on which EPC contractors manage E&S impacts associated with construction activities.
Organizational Capacity and Competency: At each facility, GRT has an EHS committee chaired by the General Manager. The EHS team is under the EHS committee composed of dedicated EHS officers and representatives from relevant internal departments, with KPIs distributed to different departments. All new staff, including contractors, are subject to EHS on-board training. Other internal training courses (such as EHS and OHS) are held on a rotational basis. GRT also regularly engage qualified third party to review equipment safety. GRT Türkiye will build adequate EHS organizational capacity by integrating China practice and align with Türkiye local regulation. As set forth in ESAP#5, GRT Türkiye shall ensure adequate EHS capacity and hire an EHS Manager to oversee the Türkiye project construction and operation management and implementation of its updated ESMS.
Emergency Preparedness and Response: Major emergency situations associated with GRT's business operations may include fire, leakage or spills of hazardous materials, and natural disaster. GRT has documented an emergency preparedness and response plan (EPRP) covering scenarios, emergency management flow, identification of roles and responsibilities, implementation of emergency drills, etc. The GRT Türkiye facility will also develop its construction phase EPRP (as per ESAP#4) and operations phase EPRP (as per ESAP#2)
Monitoring and Review: As part of the current ESMS, GRT established monitoring programs which include pollution prevention (e.g., point source emissions, workplace air quality and noise levels, waste handling/disposal), resource consumptions and occupational health and safety (OHS) tracking with established key performance indicators (KPIs). These KPIs are compiled by the EHS department and shared with the plant general manager. For Türkiye greenfield project, ES monitoring indicator will be outlined in the project ESMS as per ESAP#2.
PS 2 – Labor and Working Conditions
GRT now has 1,371 full-time employees in China, with about 76% male and 24% female. 88% are in non-managerial and non-supervisory roles. All employees have written contracts. There are no plans for major workforce retrenchment. For Türkiye greenfield project, currently there is a small team engaged on project development. The construction phase will engage 200 workers; operational workforce is estimated as 190. A labour management plan has been prepared as part of project ESMP.
HR Policies and Procedures: While GRT has a set of HR policies at the corporate level, HR function is largely decentralized to each manufacturing facility in a coordinated manner to meet the local regulatory requirements. As set forth in ESAP #5, GRT Türkiye will adopt the corporate level HR policy and procedures that will be tailored to comply with Turkish local regulations and PS2. This shall include the specific aspects such as; i)staff manual with terms of employment align with Turkish national law, ii)work schedule and overtime management align with Turkish law, iii)freedom of association, iv) Grievance Redress Mechanism for all labor (including third-party labor), v)GBVH policy and procedure on management of cases of sexual harassment, including defined channels for reporting, receiving, reviewing and responding to these, while ensuring confidentiality of the complainant, vi) steps for induction and training on benefits and rights prior to signing of contract agreements, vi) accepted GIIP for work place and OHS standards;
Working Conditions and Terms of Employment: GRT corporate policy commits to non-discrimination and equal opportunity. Employment conditions, compensation, attendance, leave, insurance, overtime, performance evaluation, and promotions are all managed in accordance with corporate HR policies. For Türkiye project, a labour management plan has been prepared by qualified consultant outlined local labour requirement for direct and contracted workers. GRT will require the EPC contractor to implement the labour management plan during construction stage. Employment contracts will be established to formally outline the working conditions and terms of employment for operational staff. The terms and conditions will include minimum wage, working schedule, overtime, leave, and benefits (such as social security provisions), all referenced to Türkiye labour laws. GRT corporate level has an overtime management procedure and maintained records of staff working hours. GRT's sample payslips show China staff received overtime pay in line with national law. For the Türkiye project, overtime management should comply with Türkiye labor law, specified in the staff manual as per (ESAP#6).
Worker's Organization: GRT fully respects freedom of association and right to collective bargaining power with established corporate policy in place. The corporate HR policy respects freedom of expression and association without any direct or indirect impediment or negative consequences for any employees. Ninety percent of GRT workers joined the labour union. For Türkiye project, freedom of association should be specific outlined in HR policy as per (ESAP#6).
Grievance Mechanism: GRT has established an internal corporate policy that outlines the rights to raise grievances. This right is applicable to all employees, providing a platform for voicing concerns. At each facility, employees can raise grievance through oral communication or submit a formal compliant, grivance can also be submited on anoymous basis. Grivance will be handled by direct manager with escalation process to GRM committee with the member include General Manager, HR manager, workers’ representatives. GRT has provided 3 GRM cases which indicate the machanism is functioning. For Türkiye project, direct workers grievance mechanism is already been prepared as part of labor management plan. GRT will extend its corporate GRM to third party workers as per (ESAP #6).
Prevention of Sexual Harassment and Protecting the Workforce: GRT corporate HR policy has specific provision regarding to child labor and force labor align with National Law and ILO requirement. IFC’s review did not identify any signs of the use of child or forced labor. The company publish policy to prevent any kind of sexual harassment, as part of company’s code of conduct. Workers can use existing GRM to file any case of sexual harassment. No cases have been reported in China through the existing channel. The Türkiye project will implement GRT’s corporate policy and extend the GBVH procedure to all workers, including EPC contract workers. All contractors and subcontractors must complete GBVH training. (ESAP#6).
Occupational Health and Safety (OHS): GRT’s corporate OHS management system is defined in detail in its OHS policy and SOPs. Key OHS elements and practices include: (i) identifying hazards and classifying them by severity, implementing mitigations, and enforcing preventive measures; (ii) investigating and reporting incidents; (iii) monitoring workplace conditions like air quality, using personal protective equipment, and providing annual health checkups; (iv) assigning trained OHS officers for regular inspections; (v) developing an Emergency Preparedness and Response plan; (vi) following work permit procedures for high-risk operations; (vii) conducting job hazard analyses and regular health tests. OHS KPIs include zero incident, incident timely report,occupational disease rate, improvement action plan completion rate, training taken etc. Incident records only show incidents of direct staff, and only record incident that lead to lost time injury. The Türkiye facility will implement the GRT corporate Occupational Health and Safety (OHS) management system per ESAP#2. This will include improved incident reporting and monitoring for minor injuries and near misses, as well as the extension of incident reporting to cover third-party workers in line with as per ESAP#7.
Supply Chain Management: GRT procures from both local and international suppliers across the regions including China, Japan, and Korea. The Türkiye project will purchase TPU/PET film, solvent from Türkiye. Some of the coating materials and glue from China at early stage and gradually shift to Türkiye local suppliers. GRT Suppliers sign a code of conduct where child labor and force labor are prohibited. The supplier code of conduct also provides provision for other OHS requirements and labor protection. GRT need to establish supply chain management system for Türkiye facility operations as per ESAP#8.
Management of Third-Party Workers: GRT has implemented a corporate contractor management program that includes pre-qualification reviews of EHS track records, standard OHS covenants, and adherence to applicable corporate SOPs. The SOPs cover contractor OHS safety training, pre-construction OHS inspections, work permit management (such as hot work and work from height) and daily monitoring contractor implementation of ESMP. For the Türkiye greenfield project construction, the EPC contractor will retain OHS personnel to implement the construction stage ESMP per National Law requirement. GRT Türkiye will also retain an EHS manager to monitor the OHS performance of the contractors and subcontractors as per ESAP#5.
PS 3 – Resource Efficiency and Pollution Prevention
Resource Efficiency: Major sources of electricity consumption for the Türkiye facility operations are the grid and natural gas (for waste treatment). Water supply will be provided by OIZ. The facility will establish a water efficiency program to achieve 80% of cooling water will be recycled. The facility will use state-of-the-art equipment and annual GHG emission is estimated as 11,789 tCO2e.
Pollution Abatement: GRT’s film production will generate VOCs during the coating and drying process. In China operating facilities, these are collected and treated using highly efficient Regenerative Thermal Oxidizers (RTOs). Monitoring results of Sample records of stack air emission monitoring reviewed at the Jianyin site visit indicated compliance with the regulatory requirements as well as WBG EHS Guidelines air emission levels. The GRT Türkiye facility will follow the same air pollutant treatment technique which is compliant with the national law.
The water quality near the Türkiye facility indicating moderate contamination by recently increasing industry activity and agriculture runoff in the area. OIZ is in the process of constructing a Wastewater Treatment Plant (WWTP), which is anticipated to become operational by the end of 2026. Before that, OIZ contracted third-party companies to collect wastewater generated by GRT Türkiye facility. The project will manage the construction stage wastewater and minimize impact to the river per ESMP. The Türkiye facility will separate rainwater from sewage and clean water from contaminated water. Wastewater during operations will be limited to domestic wastewater which will be treated by septic tank before discharged to OIZ’s WWTP.
Noise control will be integrated into project design per Türkiye national law. The machine and equipment used for GRT’s production are designed to generate minimal noise.
Solid and hazardous waste: Wastes generated from the GRT facility operations typically include domestic waste, non-hazardous industry waste such as packing material, scrap films and membranes, hazardous waste such as machine oil, chemical residues, spent catalyst, etc. Non-hazardous waste will be collected and disposed of by licensed third party. Hazardous waste will be stored at designated locations and disposed of through licensed contractors.
Hazardous Material Management: GRT uses ethyl acetate, toluene, and methyl ethyl ketone in the coating material preparation process of the existing facilities in China. Details of chemicals to be used by the Türkiye facility is yet to be finalized. GRT maintains a chemical management plan in all operating facilities. Workers handling Hazmat are regularly trained for safe handling, the content of the Material Safety Data Sheets (MSDS) and emergency procedures. Storage areas are kept unobstructed, well lit, ventilated, dry and at an appropriate temperature. Access is restricted, emergency equipment and Safety Data Sheets are easily accessible. Hazmat is stored in approved labelled containers with secondary containment (for liquids) and are segregated based on their compatibility. Integrity of containers is checked routinely.
GRT Türkiye will prepare a chemical management plan for the safe storage, use, and disposal of chemicals on-site during operations phases as per ESAP#2. All chemicals will be stored in secure, labelled containers, in designated, impermeable areas away from sensitive ecological zones. Chemical storage facilities will be designed with secondary containment.
PS 4 – Community Health, Safety and Security
The Türkiye project is located within the OIZ, with limited direct exposure to local communities given that such parks are typically set up to be at reasonable distances from local residences. Given the setback, the project’s daily operation is not expected to disturb residents. GRT Türkiye facility will be secured by unarmed security personnel. Security personnel will be trained to properly use force (only for preventive and defensive purposes).
Life & Fire Safety (L&FS): GRT's China facility meets L&FS regulations, with required hardware like smoke detectors and automatic warning systems installed. The local fire department has issued L&FS certificate and conducted regular audits to confirm that the facility has maintained a good L&FS function. The Occupational Health and Safety (OHS) team routinely conducts inspections of life and fire safety equipment. Fire drills and other emergency response simulations are conducted annually. Follow the medical procedures, evacuation procedures, and communication protocols as outlined in the company’s Emergency Preparedness and Response Plan (EPRP).
The design and construction of the Türkiye facility will be in line with the local law. An EPRP will be prepared as per ESAP#2 and #4.
Traffic Impacts and Transportation Safety: There are a few roads leading to the OIZ where there are sporadic residential areas. While it’s not densely populated, and structures are not within immediate vicinity of road, a traffic management plan during construction phase as per ESAP #4 would still be necessary to avoid and minimize impact to communities, pedestrians and ensure public safety.
