While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security

While all IFC’s Performance Standards (PSs) are applicable to this investment, IFC’s environmental and social due diligence indicates that this investment will have impacts which must be managed in a manner consistent with the following standards

This is a Category B project according to IFC’s Environmental and Social Sustainability Policy (2012), as the project is expected to have limited adverse E&S risks and impacts that are few, generally site-specific, largely reversible, and can be mitigated. Key E&S risks and issues include: (i) the Company’s ESMS and E&S governance capacity; (ii) labor and working conditions including Operational Health and Safety (OHS), grievance mechanisms, and Gender Based Violence and Harassment (GBVH); (iii) supply chain management (iv) resource efficiency (energy/water), wastewater and emissions control, and solid/hazardous waste management; (v) emergency preparedness and life and fire safety; and (vi) stakeholder engagement and grievance management.

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
Environmental and Social Policies. Dogus Cay adopted several corporate-level policies covering product quality and safety, environmental sustainability, OHS, human rights, and ethical practices, which are generally applied across potato and corn chips and tomato paste production facilities. However, the IFC appraisal identified the absence of a single consolidated IFC-aligned corporate E&S Policy applicable across all facilities, projects, contractors, suppliers, logistics operations, and agricultural activities. Facility-level Integrated Management System policies currently address quality, environment, and OHS but will be formally updated to function as IFC-aligned Environmental and Social Policies consistent with PS1. For each project component, Dogus Cay will update facility-level policies to formally designate them as E&S Policies, align with IFC PSs, clarify its role as the framework for E&S risk management and continuous improvement, and ensure communication to workers and availability to relevant stakeholders. The company will then develop a 2026–2030 E&S Policy Implementation Plan for each facility defining a 2026–2030 E&S workplan, including CAPEX/OPEX required for the effective and timely implementation of the E&S policies. Annual verification review of the E&S performance will be carried out, and audit findings and corrective action plans will be reported to senior management for decision (ESAP#1.1).

Identification of Risks and Impacts. The Company has a documented risk assessment procedure consisting of quarterly risk assessments, which provides a structured and effective approach to identifying, prioritizing, and managing workplace hazards. However, broader E&S risks are not addressed while social risks are primarily framed in terms of operational continuity and compliance, rather than stakeholder centric impact assessment. Future risk assessments will be expanded to cover environmental, human rights, agricultural labor conditions, community, and supply-chain-related risks in accordance with PS1. Dogus Cay will enhance its risk assessment process to systematically identify and manage E&S risks and impacts in line with IFC PS 1 through extending the scope to cover road and traffic safety, environmental impacts, social impacts beyond occupational risks, risks to affected communities, and integration with the Environmental and Social Management System (ESMS) (ESAP#1.2).

E&S Assessment and Management System. Dogus Cay has a Quality, Environment, and Occupational Health and Safety Management System (QEOHSMS) in place, with facility level certifications including ISO 9001 (Quality Control), ISO 14001 (Environmental Management), ISO 45001 (OHS), ISO 50001 (Energy Management) and IFS and FSSC 22000-1 (Food Safety) for Pendik and Aksaray facilities while Odemis and Karacabey facilities are in the process of preparation. These systems address environmental and OHS risks, resource efficiency, and pollution prevention. Facility specific Quality, Environment, and OHS Management Systems Handbooks describe EHS, quality, and monitoring and internal audit procedures. HR is managed by facility-based teams and overseen by the centralized team. Management of logistics related OHS risks is functionally separated from facility OHS systems, with traffic accidents tracked by logistics teams rather than integrated into consolidated OHS performance indicators. Dogus Cay will develop ESMSs with facility-level information aligned with PS1 and applicable WBG EHS Guidelines (General, Food & Beverage Production), with implementation progress tracked through management review processes. Dogus Cay will formally designate a Sustainability and E&S Manager with cross-functional authority to coordinate sustainability initiatives; implementation of the ESMS across production facilities; and clarify roles across departments. The company will incorporate the recommendations from the PS1 risk assessment procedure into the ESMS (ref. ESAP#1.2 above) (ESAP#1.3).

Organizational Capacity and Competency. EHS functions are implemented at the site-level under facility management, with environmental and OHS officers reporting to respective facility managers. Environmental Officers are responsible for implementing environmental procedures, conducting regular monitoring and measurements, ensuring compliance with applicable laws and permits, and managing water treatment plants. In certain facilities (Pendik, Karacabey, Odemis, and Afyon), OHS management services are provided by an external contractor (OSGB), while at the Aksaray facility, the OHS Officer is a direct employee of Dogus Cay. Workplace doctors and nurses are present at all facilities. Specialized consultancy firms support the company in environmental management, carbon and water footprint assessments, hazardous materials management, fire safety, and pest control. Facility Managers report directly to the Board of Directors. IFC’s appraisal highlighted the absence of a clearly defined corporate level E&S governance structure, with responsibilities dispersed across quality, HR, and facility management functions. The centralized HR team needs to be trained in grievance management, including handling sensitive grievances such as GBVH. The company will strengthen (i) OHS capacity by hiring an additional OHS Officer through an external contractor at the Karacabey facility, (reflecting the size, operational capacity, and OHS requirements of the facility) and (ii) HR capacity by providing GBVH training to centralized HR team members (ESAP#1.4).

Dogus Cay implements structured training and capacity building programs to ensure that employees, contractors, and subcontractors have the knowledge and competencies required to manage OHS, emergency preparedness, and operational controls. Mandatory induction training, refresher programs, permit-to-work training for high-risk activities, and regular emergency drills are in place across facilities. These measures contribute positively to the Company’s ability to manage workplace risks and maintain compliance during ongoing operations and planned expansions. Currently, there is not training provided to employees on Code of Conduct, HR Policy and GBVH. Supplier farmers are trained on sustainable agricultural practices, but not on HR and working conditions issues, including child labor. In line with planned expansions, Dogus Cay will implement an E&S risk-based training program covering environmental, social, supplier and contractor-related risks in addition to OHS for each facility (ESAP#1.5).


Emergency Preparedness and Response. Emergency Response Plans (ERP) addressing emergency scenarios related to occupational accidents, fires and explosions, natural hazards, chemical spills and pandemics are in place for each facility. The emergency plans identify emergency teams, define communication methods, and document evacuation procedures. Emergency Response Teams are established. Emergency Drills are carried out annually to include all shifts at Aksaray, Pendik and Odemis Facilities. Drill reports provide information on drill scenario and lessons learned. Emergency drills will be implemented at the Karacabey facility from 2026 onward and incorporated into the Company’s regular emergency preparedness program. Dogus Cay will update the existing ERPs to (i) explicitly reference applicable IFC PSs, integrate best-practice elements, and ensure compliance with local regulations; (ii) include new expansions and operational changes due to the Project, provide training to relevant staff, and communicate updates to external stakeholders; (iii) define ERP performance metrics/key performance indicators (KPIs) (e.g., average response time, drill participation rate, incident containment rate) and establish a tracking/reporting system; and (iv) develop and implement a Community Emergency Communication & Engagement Protocol, including regular information sessions, drills involving local stakeholders, and grievance/feedback mechanisms (ESAP#1.6).


Monitoring and Review. Internal audits focusing on safety and environmental performance are carried out at least once a year to ensure Dogus Cay operations compliance with the E&S Policies. Annual Management Review Meetings are held by the Board of Directors annually to review environmental and OHS performance of each facility, make decisions on improvements, and address resource requirements. When necessary, the Board implements facility-level E&S management actions to ensure ongoing compliance with local regulatory requirements and alignment with corporate sustainability objectives. Monthly and annual activity reports are regularly reviewed to monitor overall E&S performance. However, there is a lack of fully standardized formats for E&S reporting across sites. Dogus Cay will (i) develop and implement an integrated E&S monitoring and reporting procedure that consolidates existing quality, environment, OHS monitoring, monitoring of social performance indicators (stakeholder engagement, grievance mechanism statistics, workforce information, community impacts) for the potato and corn chips and tomato paste production plants to align with IFC PS1 requirements; (ii) develop a consolidated quarterly internal E&S performance report combining results from environmental risk assessments, OHS hazard tracking, customer complaints, process performance, social engagement activities, employee grievances, supplier audit results, E&S performance of contractors, emergency drills, corrective actions; and (iii) establish a Compliance Tracking Checklist against IFC PS monitoring/reporting requirements, and conduct annual reviews to ensure all indicators are covered; update monitoring system accordingly (ESAP#1.7).


Supply Chain. Dogus Cay relies on a large and diversified supply chain, including agricultural raw materials (potatoes, corn, tomatoes), food ingredients (including palm oil), and packaging materials.
Total number of suppliers is 89, of which 50% are primary suppliers. Supplier management is mainly based on quality and cost primarily coordinated through the centralized Procurement and Quality Management functions. There are no supplier mapping and analyses conducted from an E&S risk perspective. There is no structured training or capacity building program for suppliers on E&S expectations. Dogus Cay will (i) develop a standalone Supplier Code of Conduct (COC) that is aligned with IFC PS1/PS2 and explicitly includes child labor/forced labor prohibition; (ii) revise supplier contracts aligned with Supplier COC; (iii) implement a risk-based supplier due diligence and monitoring program, including a risk-based mapping/segmentation of agricultural suppliers/farms and any labor intermediaries, and periodic on-site audits of supplier farms/agricultural lands during plantation and harvest seasons to verify compliance with the Supplier COC (ESAP#2).

PS2. Labor and Working Conditions
HR Policies and Procedures. Dogus Cay is in line with Turkish labor law requirements for wages, contracts, working hours, OHS management and benefits. The company commits to formal payroll, social security registration, and working time controls. A consolidated corporate HR policy does not exist currently. HR practices are managed through headquarters guidance and implemented unevenly across facilities. A generic Code of Conduct has recently been developed (December 2025) which needs to be improved to be aligned with IFC PS2 requirements. In addition, at the time of IFC’s appraisal, there were no available records or evidence of Code of Conduct implementation. There are several procedures that cover the company’s commitment to prohibition of discrimination, equal opportunity, prohibition of child labor, non-retaliation, zero tolerance for harassment, and disciplinary sanctions for violations. The company’s HR policies do not explicitly recognize freedom of association and collective bargaining. There is no standalone GBVH policy. GBVH is referenced generically in the procedures but not explicitly framed as GBVH, nor supported by survivor centered procedures. Dogus Cay will develop a HR Policy in line with IFC PS2 and will revise the Code of Conduct and relevant HR procedures accordingly (ESAP#3).
Working Conditions. All employees have employment contracts in line with local law with a clear job description and salary amount. Blue-collar/operational employees mainly work three shifts. There are operational contractors for security, cleaning, logistics, and OHS (in some facilities) services. Overtime exists on occasional basis and is closely monitored and compensated as per the law. IFC observed high exposure to weather conditions and associated safety risks in the raw material storage areas and during the raw material (potatoes) delivery process since these areas are open to air. Under the risk assessment that will be developed as per ESAP#1.2, Cay will identify the areas with high or low temperatures and develop appropriate mitigation measures in consultation with the workers. Accommodation is provided to non-local employees at the Afyon facility. Currently approximately 60 employees are accommodated in the building. The company has been constructing a new 5-storey building for non-local employees on facility land. At the time of IFC’s appraisal, construction was ongoing and planned to be completed by the end of May 2026. Dogus Cay will consider managing the Afyon accommodation and any future accommodation sites in a manner broadly consistent with the IFC’s Guidance on Workers’ Accommodation, as appropriate.. (ESAP#4)
Workers’ Organizations. Turkish law recognizes freedom of association and collective bargaining rights of workers and employees subject to participation thresholds. Employees are not required to disclose their union membership to their employer, and the law also prohibits any retaliatory actions on account of joining and/or participation in union activities. Dogus Cay employees are not unionized. An ongoing court case between two unions inherited from the previous owner was noted, and workers interviewed expressed interest in unionization. The company appointed worker representatives as per the local OHS regulation. However, IFC’s worker interviews revealed that employees are not fully aware of their role. There is no documentation of worker awareness of union rights beyond legal compliance. The company does not prohibit employees from joining unions and respects employee rights to form and join unions of their own choosing. To further strengthen this commitment, Dogus Cay will include a clear statement with respect to workers’ rights to freedom of association and collective bargaining in its HR Policy; will inform employees about their rights of freedom of association and collectively bargaining as well as existing worker representation structures and results of any union court cases (ESAP#3).
Workers Engaged by the Third Parties. Dogus Cay requires its contractors to observe company’s HR and OHS procedures and labor law requirements through contractual documents. The company has established a comprehensive Contractor OHS Management Procedure applicable to all maintenance, construction, installation, cleaning, logistics, and other subcontracted works. The procedure defines clear roles, responsibilities, and approval steps for contractor engagement and on site activities. Contractor performance and practices, including salary payments, social security registration, child labor, forced labor and overtime, are periodically monitored, and non compliances can result in suspension of activities until corrective actions are implemented. The company’s grievance mechanism is accessible to contractor employees. All company trainings are provided to contractor employees as well.
The company produces potatoes and carries out harvesting operations on company-owned land. Plantation teams are direct employees of the company, but seasonal and migrant labor is used both on company-owned land and supplier/farmer lands and engaged primarily for harvesting activities.
In Turkiye, child labor is widely recognized as a high inherent risk in the agricultural sector, particularly during harvest periods and where seasonal/migrant labor and labor intermediaries are used. Accordingly, robust prevention, monitoring, and remediation measures are required across the company’s agricultural supply chains. The company’s farmer supplier base is relatively limited and, as a primary buyer, the company has leverage to support the implementation of supply-chain controls to prevent, identify, and address child labor risks. Labor standards are not addressed in farmer contracts. The company has recently developed a Code of Conduct (December 2025) and a supplier audit check list, covering worker health and safety, social and ethical practices (child labor, working hours, grievance mechanisms). In addition, a Child Labor Policy (December 2025) prohibits child labor by suppliers. However, IFC’s appraisal did not verify Code of Conduct or Child Labor Policy disclosure to suppliers, supplier contract integration and the implementation or results of audit systems as there were no available documented records or reports. There is no standalone Supplier Code of Conduct explicitly aligned with IFC environmental, labor, and human rights standards. Agricultural raw material sourcing (farmers, seasonal labor intermediaries) relies largely on informal or verbal arrangements, with limited documented oversight of labor conditions. Supplier audits are heavily food safety and quality oriented, with limited depth on labor conditions and occupational safety at supplier sites. Building on the Supplier Code of Conduct, contractual provisions, and audit program established under ESAP#2, Dogus Cay will (i)provide on-site training to supplier farmers (and, as relevant, labor intermediaries) on labor rights and working conditions, including child labor/forced labor prevention and OHS; and (ii) ensure the company’s grievance mechanism information is visible on-site to agricultural workers (ESAP#2).
Grievance Mechanism. Grievance channels exist through supervisors, HR departments, and complaint boxes, with grievance oversight assigned to headquarters HR. IFC’s appraisal identified significant gaps in effectiveness, including inconsistent recording of grievances; uneven workers awareness of grievance procedures and escalation routes across facilities; and limited training. Anonymous grievance submission is not explicitly protected as it is allowed only through complaint boxes located in the facilities. Grievance records are not kept, nor reported to the headquarters and monitored. Facility based HR teams will (i) record all direct and contractor employee grievances in a log, including verbal and anonymous grievances; (ii) include the grievance mechanism in induction training; (iii) ensure that HR personnel are trained on handling sensitive (GBVH, etc.) grievances; and (iv) report grievance statistics (grievance category, resolution performance, actions taken, etc.), trends and main grievance issues to the centralized HR team periodically. The HR Headquarters team will monitor the performance of grievance management of all facilities and report to the Board (ESAP#5).
Occupational Health and Safety. Dogus Cay operates an OHS management system aligned with Turkish legislation and ISO 45001, supported by dedicated in-house and external OHS professionals at site-level, all working on a full time basis. Workplace physicians, nurses, infirmaries, and first aiders are available across sites in accordance with legal requirements. OHS performance is monitored through accident frequency and severity indicators, and OHS incidents are recorded and reported through root cause analysis reports. There have been no fatalities in Dogus Cay potato and corn chips and tomato paste production plants in the last three years. Lost Time Injuries Frequency Rate (LTIFR) is 5.74 in 2025, which is below food manufacturing industry norms (7). The company implements a structured and documented OHS training program covering both direct employees and contracted workers. Training is delivered through mandatory induction training prior to job commencement, covering legal obligations, site specific risks, emergency response, personal protective equipment (PPE) use, accident and near miss reporting, and environmental rules, and annual periodic refresher trainings. Training programs are planned annually; attendance is recorded; and effectiveness is monitored through KPIs. IFC’s appraisal identified the need for improvement in implementation of PPE requirements in certain high exposure areas (particularly dusty working areas) and partial separation of logistics and contractor incident tracking from core OHS performance management. Dogus Cay will address logistics-related incident risks in risk assessments that will be developed as per ESAP#1.2; integrate road and traffic safety incidents in OHS statistics; and assess road/traffic incidents by using the existing root cause analysis format (ESAP#6).

PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency. Chips production is energy- and water-intensive. Dogus Cay monitors energy and water consumption through Systems, Applications, and Products (SAP)-based systems and monthly reporting and has established resource efficiency targets and energy efficiency measures at the Aksaray and Pendik facilities, including rooftop solar solar photovoltaic cells supplying approximately 28–32% of the Aksaray facility’s electricity. Dogus Cay will develop and adopt facility-specific energy and water efficiency targets for the Bursa and Odemis facilities, aligned with corporate resource efficiency objectives and IFC PSs. Targets will be informed by baseline assessments of current energy and water consumption and integrated into existing SAP-based monitoring and monthly performance reporting systems (ESAP#7.1). Process water is sourced from groundwater at Aksaray and Odemis, municipal supply at Pendik, and a combination of sources at Karacabey. Reliance on groundwater at certain facilities may increase pressure on local water resources if not effectively managed. To address future water related risks associated with potato and corn chips and tomato paste production processes, including those associated with expansions, Dogus Cay will undertake a Water Sustainability Study and implement water saving measures in line with IFC PSs. The Water Sustainability Study will assess current water use volumes, sources (surface/groundwater), and seasonal availability; identify potential impacts from expanded production and transportation activities, especially in areas with limited water supply or high drought risk. Based on the Water Sustainability Study findings, Dogus Cay will develop a Water Management Plan that includes efficiency measures (e.g., leak detection, reuse/recycling opportunities, water-efficient equipment, etc.), source protection strategies, contingency planning for drought/shortage scenarios, KPIs for water saving, and monitoring and reporting protocols (ESAP#7.2).

Greenhouse gaess. Dogus Cay does not currently quantify or report its annual direct and indirect greenhouse gas (GHG) emissions in accordance with internationally recognized methodologies (e.g., ISO 14064 or the GHG Protocol). GHG emissions are not disclosed through corporate or voluntary reporting mechanisms. After the Project becomes operational, the annual GHG emissions are expected to be [Hold: awaiting input]tons CO2e. The Company will quantify direct emissions from the facilities owned or controlled within the physical Project boundary (Scope 1) as well as indirect emissions associated with the off-site production of energy used by the Project (Scope 2), if applicable. Quantification of GHG emissions will be conducted annually, using internationally recognized methodologies.

Pollution Prevention. The main environmental risks associated with chips and tomato paste production are related to air emissions, odor, wastewater generation and solid waste.

Air emissions and noise. Air emissions from chips production are generally due to processes involved in cooking and frying. Dogus Cay has identified air emission sources at each chip production plant and periodic emission monitoring is carried out by an accredited laboratory every other year in line with local regulatory requirements. Dogus Cay will commission air emissions monitoring 6-12 months of full operation following expansion and benchmark results against local legislation and relevant WBG EHS Guideline values, and implement corrective actions if results exceed the most stringent guideline value (ESAP#8.1). While facilities are exempt from regulatory environmental noise monitoring, occupational noise levels are monitored annually and managed through engineering controls and PPE.


Wastewater Management. Process wastewater at each facility is treated on-site prior to discharging into the municipality or industrial area sewerage system. Discharge permits are in place and valid for Aksaray and Pendik facilities while Karacabey and Odemis facilities are in the process of obtaining updated permits. Wastewater treatment plants utlize physical, chemical and biological processes. In addition to periodic analysis carried out by an accredited laboratory on behalf of Dogus Cay, the relevant municipality also conducts random sampling at the discharge channel. Continuous monitoring of onsite treatment is carried out by Dogus Cay`s in-house laboratory to ensure compliance with the regulatory limit values. No exceedances were identified in the last three years at the Aksaray and Pendik facilities. The project consists of capacity increase of wastewater treatment plants at these locations.

Solid/hazardous waste management. Dogus Cay implements facility level waste management procedures covering hazardous and non-hazardous wastes, including segregation, storage, tracking, and disposal through licensed contractors, with domestic waste collected by municipalities. Dogus Cay will upgrade its facility-level Waste Management Procedures in line with IFC PS3. The upgraded Waste Management Procedures will define waste-related KPIs and targets aligned with PS3; explicitly link waste risks to the site-specific E&S risk register covering both existing and expansion units; formalize waste-related training requirements and frequency; and integrate waste spill response into emergency preparedness procedures (ESAP#8.2). The Cold Warehouses and the new Potato Pellet Production Facility are within the Afyon site, where waste storage areas and certain waste management practices are shared. As a result, waste management arrangements are not fully segregated by activity, and waste-related risks associated with shared infrastructure are not yet fully managed in line with IFC Performance Standard requirements. Dogus Cay will design and construct dedicated waste storage areas for the Cold Warehouses and Potato Pellet Production facility, including separate and clearly marked areas for hazardous and non-hazardous wastes, in line with IFC PS3 and Good International Industry Practice (GIIP) requirements within the Afyon facility premises (ESAP#8.3).

Pest Control. Dogus Cay obtains regular (four times a month) pest control services from licensed service providers at each facility. There are not any pesticides stored on-site.

PS4: Community Health, Safety and Security

Road Safety. Dogus Cay’s logistics activities cover inbound transport of raw materials, internal storage movements, and distribution of finished products, managed centrally by the Procurement team based in the Pendik facility. Finished products are transported by Dogus Cay’s logistics company (44%) and third-party companies, while raw materials are transported by third-parties. Dogus Cay’s logistics company has 132 trucks currently and will purchase 25 additional vehicles through the IFC investment. All facilities are in industrial or semi-industrial areas, except the Pendik facility, which poses limited road safety risks to communities.

Food/Product Safety Management. Internationally recognized food safety certification systems are currently implemented at the Aksaray and Pendik facilities, with certification planned for the Karacabey and Odemis facilities. These systems establish requirements for hygiene, hazard analysis, traceability, product quality control, and corrective actions. The company maintains documented procedures for monitoring product safety performance, addressing non-conformities, and implementing corrective and preventive actions. Regular management reviews and external audits provide assurance that food safety risks are identified and effectively controlled in accordance with GIIP. No food safety-related community grievances, product recalls, or legal cases have been reported in recent years.

Emergency Preparedness and Response. Potential off site impacts of emergencies (e.g., fire, explosion, chemical spills, flooding) are considered in emergency planning. Each facility maintains active coordination mechanisms with fire brigades, emergency medical services, law enforcement, disaster and civil protection authorities (e.g., Disaster and Emergency Management Authority (AFAD)), local municipalities and hospitals. Emergency contact lists are maintained and regularly updated. Communication protocols for interaction with external stakeholders, including families of workers and media representatives, are clearly defined.

Security. Closed-circuit Television (CCTV) systems have been installed at Dogus Cay facilities and are included in entrance/exit protocols. Security services at production facilities are provided through a combination of in-house and licensed third-party security providers. Security personnel are unarmed at the Aksaray, Pendik, Karacabey and Odemis facilities, and armed at the Afyon facility. Security personnel receive training through their respective employers. Security risk assessments are conducted by external specialists, and no community security-related grievances have been reported.

PS6: Biodiversity conservation and sustainable Management of Living Natural Resources

The Company processes locally sourced potatoes and corn, with biodiversity risks primarily associated with upstream agricultural supply chains and water use rather than direct operations. These risks are managed through the ISO 14001 certified Environmental Management System (EMS) using a risk-based approach. No habitat loss or natural habitat conversion has occurred in the past five years, all facilities are located in designated industrial or agricultural areas, and sourcing is limited to cultivated land. Biodiversity risks are considered limited and manageable and broadly aligned with IFC PS6 and GIIP. The Company will adopt a Biodiversity and Sustainable Sourcing Policy covering agricultural supply chains and water use, including commitments to legal land sourcing, no habitat conversion, sustainable practices, and integration into the existing ESMS (ESAP#9).

The company does not have a stakeholder engagement plan at the corporate or project level. Stakeholders are defined broadly across documents. An External Communication Procedure is in place covering engagement with regulators, customers and suppliers, as well as emergency and media communications, with responsibility assigned to the Management Systems Manager and Facility Managers. There is no documented disclosure of E&S risks to communities near Company operations. A well structured grievance mechanism is in place for customers and consumers. External grievance channels include the company website (https://www.Doguscay.com.tr/iletisim), corporate social media accounts, dedicated email addresses, the consumer hotline (444 97 53) and customer satisfaction surveys. No visible branded or publicly communicated grievance channel exists for neighbors/communities. While no recent external E&S grievances have been recorded, historical complaints from neighboring landowners in Karacabey related to land access and domestic waste were identified during the IFC appraisal. In addition to the ongoing tracking of customer grievances, Dogus Cay will (i) differentiate its engagement methods by information disclosure, consultation and ongoing engagement for each stakeholder group, (ii) disclose grievance channels to neighboring communities, and (iii) record all external stakeholder and community grievances and ensure the complainant is provided feedback through the process (ESAP#10).

Contact Person: Alpaslan Karakan
Company Name: Dogus Cay ve Gida Maddeleri Uretim Pazarlama Ithalat Ihracat A.S.
Address: Altintepe Mah. Cihadiye Cad. No:94 Maltepe/Istanbul
Email: akarakan@doguscay.com.tr
Phone: +902165875300
Website: https://www.doguscay.com.tr

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	(i)(ii) Dogus Cay will update facility-level policies to formally designate them as E&S Policies, align with IFC PSs, clarify their role as the framework for E&S risk management and continuous improvement, and ensure communication to workers and availability to relevant stakeholders.	07/31/2026
2	ESAP#1.1(iii) The company will develop a 2026–2030 E&S Policy Implementation Plan for each facility defining a 2026–2030 E&S workplan, including CAPEX/OPEX required for the effective and timely implementation of the E&S policies. Annual verification review of the E&S performance will be carried out, and audit findings and corrective action plans will be reported to senior management for decision	10/29/2026
3	ESAP#1.2 Dogus Cay will enhance its risk assessment process to systematically identify and manage environmental and social risks and impacts in line with IFC PS1 by expanding the scope to cover: (i) environmental aspects and impacts; (ii) labor and working conditions and OHS risks (including identification of areas with high or low temperatures and definition of appropriate mitigation measures); and (iii) community risks, including road and traffic safety and other risks to affected communities. The enhanced risk assessment process will be integrated with the Environmental and Social Management System (ESMS).	10/29/2026
4	ESAP#1.3 (i) Dogus Cay will develop ESMSs with facility-level information aligned with PS1 and applicable WBG EHS Guidelines (General, Food & Beverage Production), with implementation progress tracked through management review processes.	10/29/2026
5	ESAP#1.3(ii) Dogus Cay will formally designate a Sustainability and E&S Manager with cross-functional authority to coordinate sustainability initiatives.	09/29/2026
6	ESAP#1.4 Dogus Cay will strengthen (i) occupational health and safety (OHS) capacity by hiring an additional OHS Officer through an external contractor at the Karacabey facility, (reflecting the size, operational capacity, and OHS requirements of the facility) and (ii) HR capacity by providing GBVH training to centralized HR team members.	12/31/2026
7	ESAP#1.4(ii) Dogus Cay will strengthen HR capacity by providing GBVH training to centralized HR team members.	10/29/2026
8	ESAP#1.5 Dogus Cay will implement an E&S risk-based training program covering environmental, social, supplier and contractor-related risks in addition to OHS for each facility.	12/31/2026
9	ESAP#1.6 Dogus Cay will update the existing ERPs to (i) explicitly reference applicable IFC PSs, integrate best-practice elements, and ensure compliance with local regulations; (ii) include new expansions and operational changes due to the Project, provide training to relevant staff, and communicate updates to external stakeholders; (iii) define ERP performance metrics/key performance indicators (KPIs) (e.g., average response time, drill participation rate, incident containment rate) and establish a tracking/reporting system; (iv) Develop and implement a Community Emergency Communication & Engagement Protocol, including regular information sessions, drills involving local stakeholders, and grievance/feedback mechanisms	12/31/2026
10	ESAP#1.7 Dogus Cay will (i) develop and implement an Integrated E&S Monitoring and Reporting Procedure that consolidates existing quality, environment, OHS, social performance indicators (stakeholder engagement, grievance mechanism statistics, workforce information, community impacts) for the chips and tomato paste production plants to align with IFC PS1 requirements; (ii) develop a Consolidated Quarterly Internal E&S Performance Report combining results from environmental risk assessments, OHS hazard tracking, customer complaints, process performance, social engagement activities, employee grievances, supplier audit results, E&S performance of contractors, emergency drills, corrective actions; and (iii) establish a Compliance Tracking Checklist against IFC PS monitoring/reporting requirements, and conduct annual reviews to ensure all indicators are covered; update monitoring system accordingly.	03/31/2027
11	ESAP#2 Dogus Cay will (i) develop a standalone Supplier Code of Conduct (COC) that is aligned with IFC PS1/PS2 and explicitly includes child labor/forced labor prohibition; (ii) revise supplier contracts aligned with Supplier COC; (iii) implement a risk-based supplier due diligence and monitoring program, including a risk-based mapping/segmentation of agricultural suppliers/farms and any labor intermediaries, and periodic on-site audits of supplier farms/agricultural lands during plantation and harvest seasons to verify compliance with the Supplier COC; (iv) provide on-site training to supplier farmers (and, as relevant, labor intermediaries) on labor rights and working conditions, including child labor/forced labor prevention and OHS; and (v) ensure the company’s grievance mechanism information is visible on-site to agricultural workers.	07/31/2026
12	ESAP#2(ii) Dogus Cay will revise supplier contracts aligned with Supplier COC.	07/31/2026
13	ESAP#2(iii) Dogus Cay will implement a risk-based supplier due diligence and monitoring program, including a risk-based mapping/segmentation of agricultural suppliers/farms and any labor intermediaries, and periodic on-site audits of supplier farms/agricultural lands during plantation and harvest seasons to verify compliance with the Supplier COC.	09/29/2026
14	ESAP#2(iv)(v) Dogus Cay will (iv) provide on-site training to supplier farmers (and, as relevant, labor intermediaries) on labor rights and working conditions, including child labor/forced labor prevention and OHS; and (v) ensure the company’s grievance mechanism information is visible on-site to agricultural workers.	12/28/2026
15	ESAP#3 Dogus Cay will develop (i) an HR Policy in line with IFC PS2 and will revise the COC and (ii) relevant HR procedures accordingly. The HR Policy/COC/HR procedures will address, at a minimum: terms and conditions of employment and non-discrimination/equal opportunity; worker organization, including freedom of association and collective bargaining, and information to workers on existing representation structures and the status/results of any union-related legal proceedings (as applicable); prohibition of child labor and forced labor for direct workers; OHS responsibilities and worker obligations; workers’ grievance mechanism; and worker communication and training requirements.	07/31/2026
16	Dogus Cay will develop (i) an HR Policy in line with IFC PS2 and will revise the COC and (ii) relevant HR procedures accordingly. The HR Policy/COC/HR procedures will address, at a minimum: terms and conditions of employment and non-discrimination/equal opportunity; worker organization, including freedom of association and collective bargaining, and information to workers on existing representation structures and the status/results of any union-related legal proceedings (as applicable); prohibition of child labor and forced labor for direct workers; OHS responsibilities and worker obligations; workers’ grievance mechanism; and worker communication and training requirements.	07/01/2027
17	ESAP#4 Dogus Cay will consider managing the Afyon accommodation and any future accommodation sites in a manner broadly consistent with the IFC’s Guidance on Workers’ Accommodation, as appropriate.	11/30/2026
18	ESAP#5 Facility based HR teams will (i) record all direct and contractor employee grievances in a log, including verbal and anonymous grievances; (ii) include the grievance mechanism in induction training; (iii) ensure that HR personnel are trained on handling sensitive (GBVH, etc.) grievances; and (iv) report grievance statistics (grievance category, resolution performance, actions taken, etc.), trends and main grievance issues to the centralized HR team periodically. The HR Headquarters team will monitor the performance of grievance management of all facilities and report to the Board.	07/01/2027
19	ESAP#6 Dogus Cay will address Road and traffic-related incidents within the Company’s existing OHS incident reporting and root cause analysis process.	07/01/2027
20	ESAP#7.1 Dogus Cay will develop and adopt facility-specific energy and water efficiency targets for the Bursa and Odemis facilities, aligned with corporate resource efficiency objectives and IFC PSs. Targets will be informed by baseline assessments of current energy and water consumption and integrated into existing SAP-based monitoring and monthly performance reporting systems.	12/31/2026
21	ESAP#7.2 Dogus Cay will undertake a Water Sustainability Study and implement water saving measures in line with IFC PSs. The Water Sustainability Study will assess current water use volumes, sources (surface/groundwater), and seasonal availability; identify potential impacts from expanded production and transportation activities, especially in areas with limited water supply or high drought risk. Based on the Water Sustainability Study findings, Dogus Cay will develop a Water Management Plan that includes efficiency measures (e.g., leak detection, reuse/recycling opportunities, water-efficient equipment, etc.), source protection strategies, contingency planning for drought/shortage scenarios, KPIs for water saving, and monitoring and reporting protocols.	12/28/2026
22	ESAP#8.1 Dogus Cay will commission an air emissions monitoring 6-12 months of full operation following expansion and benchmark results against local legislation and relevant WBG EHS Guideline values and implement corrective measures if results exceed the most stringent guideline value.	08/31/2027
23	ESAP#8.2 Dogus Cay will upgrade its facility-level Waste Management Procedures in line with IFC PS3. The upgraded Waste Management Procedures will define waste-related KPIs and targets aligned with PS3; explicitly link waste risks to the site-specific E&S risk register covering both existing and expansion units; formalize waste-related training requirements and frequency; and integrate waste spill response into emergency preparedness procedures.	12/31/2026
24	ESAP#8.3 Dogus Cay will design and construct dedicated waste storage areas for the Cold Warehouses and Potato Pellet Production facility, including separate and clearly marked areas for hazardous and non-hazardous wastes, in line with IFC PS3 and Good International Industry Practice (GIIP) requirements within the Afyon facility premises.	11/30/2026
25	ESAP#9 Dogus Cay will adopt a Biodiversity and Sustainable Sourcing Policy covering agricultural supply chains and water use, including commitments to legal land sourcing, no habitat conversion, sustainable practices, and integration into the existing ESMS.	03/31/2027
26	ESAP#10 Dogus Cay will (i) differentiate its engagement methods by information disclosure, consultation and ongoing engagement for each stakeholder group; (ii) disclose grievance channels to neighboring communities; and (iii) record all external stakeholder and community grievances and ensure the complainant is provided feedback through the process.	03/31/2027