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
Cimko has in place an Integrated Quality, Environment, Health and Safety (QEHS) Management System which is aligned with the objectives of IFC Performance Standard 1 and commensurate with the scale and E&S impacts of their respective operations. Like all cement plants of Cimko, Cimko Adiyaman is also certified to ISO 9001 (quality), ISO 14001 (environmental), ISO 45001 (occupational health and safety), ISO 50001 (energy) and ISO 27001 (information security) management standards. The EHS compliance team conducts regular internal audits to review effectiveness of the QEHS programs and procedures and make necessary enhancements based on monitoring. In addition, annual third-party audits are carried out to ensure compliance with ISO requirements.
Following its acquisition in late 2024, Cimko is in process of integrating its corporate QEHS management system into Adana Port. The port has its E&S Management System (ESMS) compliant with national regulatory requirements and certified to ISO 9001. As per ESAP #1, Cimko will integrate its corporate ESMS into Adana Port operations. This will include, but not limited to, the provisions for i) Environmental, Health and Safety (EHS) and HR Policies aligned with IFC Performance Standards; ii) risks assessment and management procedure for environment, OHS, and labor risks and impacts; iii) emergency preparedness and response; and iv) monitoring and reporting of EHS performance.
Cimko cement facilities as well as their associated quarries, Waste Heat Recovery (WHR) units, and Refuse-Derived Fuel (RDF) preparation facilities, have obtained the necessary approvals from the Ministry of Environment, Urbanization and Climate Change (MoE) of Türkiye. Adana Port and its ship waste reception facility have been granted necessary environmental permits.
Sanko Group established their Sustainable Finance Department in 2023 and Sustainability Department in 2024 to strengthen its sustainability governance. Sustainability Committee established by Cimko systematically monitors and integrates sustainability initiatives across the company’s operations. The committee oversees key sustainability areas, including OHS, Biodiversity, Climate and Environmental Protection, Sustainable Cities and Construction, Stakeholder Engagement, and Supply Chain Management.
Cimko has an Environmental Management Unit in accordance with national regulatory requirements. At the corporate level, an environmental manager serves as the coordinator, overseeing environmental compliance and sustainability efforts across all operations. Each cement plant has a dedicated environmental engineer who reports directly to the plant manager, ensuring site-specific environmental management practices are effectively implemented. The corporate OHS manager, responsible for cement facilities and supports Adana Port operations, holds an A-class Occupational Safety Specialist Certificate from the Ministry of Labor and Social Security. At Adana Port, there is an OHS expert with A-class Occupational Safety Specialist Certificate and EHS responsibilities are managed through an accredited environmental consultancy company, which provides compliance support, reporting and advisory services. Cimko will assign a qualified EHS officer for Adana Port to oversee and manage E&S risks and impacts of port operations (ESAP #2).
The cement production facilities and Adana Port have documented emergency preparedness and response plan (EPRP) that address potential risks specific to its operation. The roles and responsibilities of employees for evacuation, rescue, and firefighting are defined and displayed at various locations across the facilities. Evacuation route maps, assembly point signs, and hose reels have been placed at appropriate locations. Annual drills including contractors are conducted to ensure the implementation of fire safety measures. Spill response is also part of emergency plans and spill kits are readily available on sites. As per the Regulation on the Implementation of the Law on Emergency Response and Compensation for Damages in Cases of Pollution of the Marine Environment by Oils and Other Harmful Substances, Adana Port engaged with an accredited marine emergency response service provider consultant company to develop and oversee the implementation of the port’s risk assessment and emergency response plan. This plan details emergency response protocols, coordination mechanisms with regulatory authorities, deployment of response teams, and the necessary equipment for incident containment. Additionally, Adana Port fully complies with national regulations by maintaining an operational emergency management framework, including specific procedures for ship waste management and environmental risk mitigation.
According to climate projections, the location of Adana Port highlights high exposure to extreme heat which may lead to heat-related illnesses among workers, physical injuries, waterborne diseases, and respiratory issues due to mold growth while location of Cimko Adiyaman does not present significative exposure to climate risks for E&S elements. Cimko, as per ESAP #3, will conduct a comprehensive climate risk assessment for its cement plants and the port and will update its EHRPs and OHS procedures to explicitly address the identified climate related risks.
As part of the QEHS, cement production facilities have established EHS monitoring programs. Key Performance Indicators (KPIs) comprise energy (electricity, natural gas, and coal) and water consumption per ton product, workplace safety including Lost Time Incident Frequency Rate (LTIFR) and near misses reported. Performance data is evaluated through monthly departmental meetings and an annual management review, where monitoring results are analysed, and corrective actions are implemented as needed. Adana Port is expected to adopt a similar monitoring and evaluation system as part of its ESMS to ensure compliance and continuous improvement.
PS 2 – Labor and Working Conditions
Overall, Cimko, has a total of 1,774 direct employees of which 94 (5.3 percent) are female, while Cimko Adiyaman and Adana Port have 189 and 114 direct employees, respectively. The contracted workforce of Cimko Adiyaman is 126 while contractors of Adana Port have 267 workers.
Cimko has a HR policy and code of conduct consistent with the requirements of Performance Standard 2 and national law. As reflected in the code of conduct, the company does not discriminate the employees based on their language, race, color, gender, political opinion, belief, religion, sect, age, physical disability, and they offer them equal opportunities. As per ESAP #4, Cimko will update its HR policy and procedures to ensure their applicability to Adana Port employees. This update will include acknowledgment of Adana Port employees’ rights to unionization and freedom of association, as well as a commitment to gender equality and addressing GBVH and will enhance its grievance mechanism to provide a dedicated procedure and anonymous reporting for GBVH cases for employees and contractors.
Cimko is not hiring migrant or seasonal workers, all workers are provided with an indefinite term employment contract. Workers at Adana Port work in a one shift, while cement plants operate in three shifts. Workers work 45 hours per week in one shift and overtime work is paid in accordance with the national regulation. For all workers, the company guarantees minimum wages supported with a comprehensive benefits package including family and child allowances, annual leave, and religious holiday packages. The minimum wage in all Cimko operations is higher than the official minimum wage in the country.
Workers of Cimko cement plants are covered by the collective bargaining agreements between the Türkiye Cement, Ceramic, Sand and Glass Industries’ Workers (CIMSE-IS). Each plant has union representatives and the collective bargaining agreements which are renewed every two years.
Cimko has a documented grievance mechanism and adopts an open-door policy and, as reported, employees can directly communicate their concerns to management. All cement plants and Adana Port have placed a number of suggestion boxes at locations throughout the facilities to allow employees to submit anonymous suggestions or complaints. An ethics hotline and an ethics violation reporting mechanism via email are available for all employees.
Cimko cement plants operate in accordance with ISO 45001 which includes risk assessments, accident root cause analysis, corrective and preventive action plans, reporting, and management review. To enhance workplace safety and streamline data management, Cimko has implemented the OHS 360 Occupational Safety Management System, which ensures real-time access, reporting, and secure storage of OHS data.
While the average LTIFR of cement operations of Cimko was 10, which is slightly higher than the industry benchmark for non-metallic mineral product manufacturing (nine - US Data), in 2022, it reduced up to 2.4 in 2024. The LTIFR of Cimko Adiyaman is reported as 1.6 in 2024 which is well below the industry benchmark and as 13.5 for Adana Port operations including contractor workforce. The latter is also below the industry benchmark for transportation and warehousing (18.5 - US Data). No fatalities have been reported for Adana Port and Cimko Adiyaman in the last three years.
In compliance with local regulations, workplace hygiene measurements, including noise monitoring, are conducted annually at Cimko Adiyaman. Similarly, at Adana Port, noise levels were assessed through workplace hygiene monitoring, with measurements conducted by an accredited environmental laboratory in February 2025. The review of the results concluded that all measured noise levels at Cimko Adiyaman and Adana Port are within the applicable regulatory limits.
At all facilities, some 20 percent of the staff has been trained in first aid and available at each shift. Staff also undergoes medical examinations twice a year, including lung screenings and audiometric tests.
All third-party workers including quarry site operators are required by contracts to respect and follow the labour and OHS standards as those followed by the full-time workers. All contractor workers are required to abide by OHS rules of Cimko and show proof of their social security registration as required by their contracts. The contractor workforce also has access to the workers committee meetings and Cimko’s grievance mechanism. Any accidents or incidents associated with third-party employees are also recorded and monitored.
Cimko has in place a supply chain management system including policy, risk screening and mitigation procedures and supplier code of conduct addressing the harmful use of child labor and forced labor and OHS requirements and conducts due diligence on its suppliers.
PS 3 – Resource Efficiency and Pollution Prevention
Resource Efficiency
Cimko has implemented various resource efficiency measures at Cimko Adiyaman to enhance energy efficiency and reduce environmental impact. Electricity consumption at the plant significantly decreased from 84,507,041 kWh in 2021 to 54,713,912 kWh in 2023, demonstrating a commitment to energy optimization. The facility also integrates RDF from textile, pulp, and wastewater treatment sludge as an alternative to coal, supporting Cimko’s broader sustainability goals.
The electricity consumption per ton of cement produced (including all units) in Cimko Adiyaman is 105.25 kWh/ton, which is at the upper end of the 80–105 kWh/ton range recommended by the WBG EHS Guidelines. Electricity use for clinker grinding was reported at 40.63 kWh/ton of cement, which is within the industry benchmark values (28-45 kWh/t cement) of the WBG EHS Guidelines. The reported thermal energy consumption for clinker production is 3.25 GJ per ton of clinker (equivalent to 777 kcal/kg), which falls within the IFC’s industry benchmark range of 2.9–3.3 GJ/t clinker for preheater/precalciner (PHP) kilns.
The Alternative Fuel Feeding System at Cimko Adiyaman enables the use of alternative fuels, resulting in an annual reduction of 23,626 tons of CO2. The new Vertical Raw Mill contributes to energy efficiency with a saving of 12 kWh/ton of clinker, corresponding to an annual reduction of 3,738 tons of CO2. Additionally, the Cement Mechanical Transport System provides a 1 kWh/ton of cement saving, leading to a further 445 tons of CO2 reduction per year. In total, these measures achieve an estimated 27,809 tons of CO2 savings annually.
At Adana Port, electricity is supplied from the national grid with total consumption recorded at 2,339,127 kWh in 2024. Cimko is investing in electrification and operational optimization at the port to enhance energy efficiency and reduce carbon emissions including mobile harbour cranes, electric rubber tyred gantry (RTG) cranes, low emission terminal trucks and eco-efficient reach stachers.
Cimko actively monitors its water footprint, implements water recycling measures, and in 2023, successfully recovered and reused 27 percent of the water used across its cement and ready-mix concrete plants, reinforcing its commitment to sustainable water management.
Greenhouse Gas (GHG) Emissions
In 2023, Cimko’s three cement plants recorded total GHG emissions of 3,879,043 tons CO2 equivalents, and the carbon footprint of the Cimko Adiyaman was 867 kg CO2 per ton of clinker, which corresponds to approximately 786 kg CO2 per ton of cement based on the 2023 clinker-to-cement ratio of 90.6 percent. This value exceeds the range of 550–700 kg CO2 per ton of cement recommended by the WBG EHS Guidelines for Cement and Limestone Manufacturing. By 2026, the plant targets a clinker emission intensity of 800 kg CO2 per ton of clinker and a clinker-to-cement ratio of 80 percent, which would reduce the carbon intensity to 672 kg CO2 per ton of cement, aligning with the mentioned WBG EHS Guidelines recommended range.
In line with Türkiye’s Nationally Determined Contributions (NDCs) and the global decarbonization roadmap, Cimko is implementing energy efficiency improvements at Cimko Adiyaman. These measures, funded in part by IFC, are expected to reduce GHG emissions by 27,809 tons CO2 equivalents per year, contributing to Türkiye’s 29.8 percent sectoral emission reduction target by 2040.
Cimko quantifies and reports its GHG emissions annually, with verification conducted by accredited organizations, and submits a greenhouse gas reduction plan to the relevant authorities. The company will continue monitoring direct GHG emissions in line with internationally recognized methodologies and, where necessary, expand the scope to include indirect emissions. The monitoring will include GHG emissions of Adana Port and verified reports and the annual carbon footprint of project facilities will be submitted to IFC as part of the Annual Monitoring Report (AMR).
Air Emissions
Cimko monitors and optimizes air emissions, including NO?, SO2, dust, and total organic carbon (TOC). A continuous air emissions monitoring system (CEMS) was installed at the main rotary kiln stack at Cimko Adiyaman, ensuring compliance with national regulatory requirements and international best practices. Based on the 2024 data from the CEMS at Cimko Adiyaman, the average concentrations of NO? and SO2 were recorded at 293.08 mg/Nm³ and 322 mg/Nm³ respectively. These values are below the WBG EHS Guidelines thresholds for cement and limestone manufacturing, which are 600 mg/Nm³ for NO? and 400 mg/Nm³ for SO2. Additionally, periodic waste incineration emissions from Cimko Adiyaman are measured in accordance with national Waste Incineration and Industrial Air Pollution Control regulations. Emission levels for heavy metals, TOC, dioxins, furans, and polycyclic aromatic hydrocarbons (PAHs) are all below regulatory thresholds.
In addition to continuous monitoring, Cimko conducted ambient air quality measurements for NO2 and settleable dust, with results indicating that both parameters were below the applicable national threshold values.
Water and Wastewater
Water for Cimko Adiyaman is sourced from groundwater wells within the facility premises, with total annual consumption recorded at 168,183 m³, including 21,352 m³ for household use, 91,637 m³ for process operations, and 55,194 m³ for irrigation in 2024. In 2024, water consumption per ton of cement produced at the plant was recorded at 0.15 m³/ton.
Wastewater generated at the plant is treated via biological treatment in three package treatment units before being discharged into the receiving environment. Wastewater analyses are conducted every four months by an accredited laboratory to ensure compliance with discharge standards. Sewage sludge from the treatment process is disposed of through incineration.
At Adana Port, water is supplied from the municipal water network, with total annual consumption recorded at 39,704 m³ in 2023 and 53,722 m³ in 2024.
Solid and Hazardous Waste
Cimko has implemented a waste management system at Cimko Adiyaman, ensuring compliance with applicable national regulations and IFC Performance Standard 3. The facility follows a structured approach to hazardous and non-hazardous waste management, incorporating segregation, handling, storage, and disposal practices in accordance with its Waste Management Plan, which is updated every three years.
Hazardous waste, including waste oils and process-related hazardous materials, is stored in designated, labelled containers within a dedicated temporary storage area that meets containment requirements. These wastes are collected by licensed waste management companies authorized by regulatory agencies. Non-hazardous waste, such as metal, glass, plastic, and packaging materials, is properly segregated and sent to recycling facilities to minimize landfill disposal.
In alignment with Cimko’s Zero Waste Certification and circular economy principles, the Adiyaman Plant integrates RDF preparation and alternative fuel use to reduce reliance on traditional raw materials. Additionally, awareness-raising activities on waste reduction and recycling are conducted for employees, promoting sustainable waste management practices.
At Adana Port, waste generated within the facility is segregated by type and temporarily stored in a designated waste storage area. The stored waste is then transferred at regular intervals to the municipal landfill for proper disposal. Wastewater generated at the port is collected in a septic tank and later transferred to the municipal wastewater treatment plant for treatment and disposal. Additionally, approximately 50 tonnes/year bilge water was received, and all ship waste is recorded in the official website of MoE.
Cimko develops and implements a quarry site EHS management plan including a quarry site closure and rehabilitation action plan for each quarry site as per the recovery of nature and rehabilitation requirement of Mining Regulation No 32040. Cimko will develop a Quarry Sites Management Procedure to ensure that quarry site opening, closure, and rehabilitation plans comply with WBG EHS guidelines for Construction Materials Extraction and GIIP to meet objectives related to social, physical, chemical, ecosystem services and ecological habitat integrity. The procedure will clearly identify E&S and biodiversity screening processes to be undertaken to identify and implement necessary mitigation measures to be taken during quarry site opening and closure phases with clear roles and responsibilities (ESAP item #5).
PS 4 – Community Health, Safety and Security
The closest human settlement to Cimko Adiyaman is Borkenek village located approximately 1.9 km to the east of the site. The distances between the quarry sites and nearest community settlements vary between 1 km and 3.5 km. No risks or impacts are envisaged to these communities due to any unforeseen catastrophic incident or accident (e.g., fire, explosion, hazardous leaks).
Cimko have traffic management plan, transportation safety procedures in place for prevention of road accidents and providing safe transportation of its employees, products, raw materials and wastes. Cimko Adiyaman has an outsourced transportation fleet. The plant has a direct connection to the main road so that the route used for the transportation from and to the cement plant does not pass through any community settlements. The transportation companies are contractually asked to follow the transportation safety procedures of Cimko including vehicle safety checks, speed limits, safe driving practices and the drivers were provided with relevant trainings about the procedures.
One of the access roads to Adana Port is used as a parking area for the hundreds of trucks waiting for loading. The width of the road is only enough to accomodate two lane traffic movement. The trucks queue along the road, extending kilometers and occupying the one lane of the road which poses a risk for traffic accidents for the other vehicles using this road. As per ESAP #6, Cimko will conduct a Traffic and Road Safety Assessment for the access road to the port and identify necessary mitigation measures including clear signage, scheduling loading activities with the respective transportation companies to reduce waiting duration of the trucks in this area and rehabilitation of the road in coordination with the local authorities to provide safer parking areas for the trucks that have to wait for loading and safe traffic movement for the other vehicles using the road.
Cimko outsources the security services from Sanko Private Security Company, another subsidiary of the Sanko Group. Cimko deploys armed security in Cimko Adiyaman and Adana Port. Cimko has a clearly defined written protocol as to the use of armed force and the armed security personnel are licensed and regularly trained and certified as per the local regulatory requirements.
PS6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
Cimko’s existing integrated concrete plant and existing/planned quarries in Adiyaman are located in Eastern Anatolian deciduous forests ecoregion of temperate broadleaf and mixed forests biome. The terrestrial part of Adana Port is in Eastern Mediterranean conifer-broadleaf forests ecoregion of the Mediterranean forests, woodlands and scrub biome, while the marine section of the port is in the Mediterranean bioregion (Resolve, 2017).
Two of the seven existing quarries are in the Southern Euphrates and Birecik Plains Key Biodiversity Area (KBA)/Important Bird and Biodiversity Area (IBA), and the quarries have been in operation for several decades, while for some of the other existing quarries Natural Habitat conversion has taken place more recently over the last five years. Impacts of quarries on Natural Habitat values has not been assessed as part of the national environmental permitting processes. Expansion of existing quarries and establishment of new quarries for the extraction of raw materials will affect Natural Habitat and associated priority biodiversity values, including threatened plants, birds and mammals.
For the operations of its existing and planned quarries, and other future assets, Cimko will develop and implement a Biodiversity Management Plan (BMP), which will include a Biodiversity Screening Procedure and a Habitat Restoration Program (ESAP #7). The Biodiversity Screening Procedure will be developed in line with IFC Performance Standard 6 requirements to identify/map habitats and priority biodiversity values, define risks and impacts, and design a mitigation strategy commensurate to the risks and impacts of quarry expansion/operations, as well as activities related to any other future assets. The Habitat Restoration Program will, at the minimum, include (i) recommendations for restoration measures and opportunities to maintain biodiversity on-site; (ii) a clear demonstration of how No Net Loss will be achieved for Natural Habitat values; and (iii) requirements to monitor progress towards restoration targets. A qualified expert or a team of experts will be contracted to develop and implement the BMP.
The existing Adana Port is in the Sugozu-Akkum KBA, designated for two threatened sea turtles; Green Turtle (IUCN Red List EN) and Loggerhead Turtle (IUCN Red List VU). The port itself and related activities do not overlap with sea turtle habitats, specifically the breeding beaches of either of the species. Therefore, impacts on these priority biodiversity values due to project activities are not anticipated.
Per ESAP #8, Cimko will engage and consult with stakeholders (e.g. authorities, conservation organizations, research institutions, etc.) to understand any concerns related to priority biodiversity values associated with the Southern Euphrates and Birecik Plains KBA/IBA and the Sugozu-Akkum KBA that might be impacted by its activities. In line with Performance Standard 6 requirements, Cimko will seek opportunities of collaborating with relevant stakeholders to support development and/or implementation of conservation programs in line with conservation objectives of the Southern Euphrates and Birecik Plains KBA/IBA and the Sugozu-Akkum KBA.
