OVERVIEW OF IFC'S SCOPE OF REVIEW IFC's review included:Site visits to Sanko Holding headquarters, the Superfilm plant, and the following Sanko Textile facilities: Baspinar cotton and viscose fiber knitting and spinning mills), Organized Industrial Zone (OIZ) (composed of various kinds of textile, food processing, chemicals and plastics production plants.) and Central Waste Water Treatment Plant in Gaziantep, Adiyaman cotton knitting and spinning mills, Isko Denim Fabric mill in Inegol and the cotton knitting, fabric dyeing and finishing mill in CorluMeetings were held with the Supply Chain Director, Plant Production Managers, Operation Managers, Quality Managers, Technical Managers, Human Resources (HR) Managers, Occupational Health and Safety (OHS) Consultants, Environmental Consultants, and Technicians, Plant Managers, Quality Engineers, and the Gaziantep OIZ Treatment Plant ManagerReview of available corporate environmental and social documents, including; completed Environmental & Social (E&S) questionnaires for each plant, risk assessment studies, training plans and programs, Emergency Response Plans and Fire Safety Procedures, emission and discharge permits, ambient noise level permits, drinking and waste water analyses, emission measurements, maintenance programs, groundwater usage permissions, fire safety reports, ISO 9001 management system certificates, work permission forms, human resources (HR) policy and procedures PROJECT DESCRIPTION The "Project" is related to the investment programs of Sanko Holding's two subsidiaries. Superfilm is a manufacturer of packaging film, while Sanko Tekstil is a vertically-integrated textile operation. The Project includes proposed investment by Superfilm in new production lines which will increase capacity and expand its product mix, and by Sanko Tekstil which will increase the production capacity in Gaziantep and Corlu facilities.Project cost is composed of Superfilm and Sanko Tekstil's investments and associated working capital needs. The project cost is estimated to be US$156 million. IFC will provide an A loan up to US$70 million to finance the project. IDENTIFIED APPLICABLE PERFORMANCE STANDARDS PS1: Social and Environmental Assessment and Management SystemPS2: Labor and Working ConditionsPS3: Pollution Prevention and AbatementPS4: Community Health, Safety and SecurityWhile 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 above Performance Standards:Project site is readily located in an industrial zone. PS5 does not apply as the project involves no land acquisitions or involuntary resettlement; there is no biodiversity conservation or significant natural resource management issues in relation to PS6; PS7 and PS8 do not apply as there are no indigenous peoples or cultural heritage sites in the area of influence of the project ENVIRONMENTAL AND SOCIAL CATEGORIZATION AND RATIONALE Key environmental and social issues for this proposed project include:EHS management systems and capability; air emissions control (including VOC-Volatile Organic Compounds) and monitoring; highly polluted wastewater/ sludge treatment and disposal for the textile business; water and energy use reduction programs, occupational health and safety (OHS); and fire safety measures.The Project has limited potential adverse environmental and social impacts, and those that do exist are site-specific and can be resolved through the effective implementation of the action items in the ESAP, which integrate IFC's Performance Standards requirements and good international industry practices as defined in World Bank Group (WBG)'s general and applicable sector-specific (Metal, Plastic, Rubber Products Manufacturing & Textiles Manufacturing) Environmental, Health and Safety requirements. This corporate-level investment is therefore a Category B project according to IFC's Environmental and Social Review Procedures.The information about how these potential impacts are and will be addressed is summarized in the following sections of this Environmental and Social Review Summary (ESRS) and in the attached Action Plan (ESAP) agreed upon with the Company. KEY ENVIRONMENTAL AND SOCIAL ISSUES AND MITIGATION PS1: Social and Environmental Assessment and Management SystemSanko Textile: Sanko Textile facilities are located in Gaziantep and Adiyaman provinces. In Gaziantep, there are three plants, two of which produces cotton and fiber yarn and the other one produces towel. There are also 2 cotton yarn production units in Adiyaman located in the industrial zone and city center.Management Systems and Assessment:The development of an Environmental Impact Assessment (EIA) study for Superfilm and Sanko Textile has not been requested by the local authorities. Nevertheless, both of the companies have acquired operational licenses and environmental permits for their existing facilities from the regulatory authorities.Both Superfilm and majority of Sanko Textile facilities have quality assurance management systems certified compliant with ISO 9001 Turkish Standards Institution (TSE). The companies do have informal environmental and social policies and procedures in place. However, in order to systematically manage and mitigate the environmental and social risks of its business operations, Superfilm and Sanko Textile will establish integrated Environmental and Occupational Health and Safety Management systems capable of certification of compliance with internationally recognized standards, (e.g. ISO14001 and OHSAS18001 respectively) as per the attached Environmental and Social Action Plan (ESAP). The Company will integrate Environment and OHS policies into its existing quality policy.Superfilm: The company undergoes customer audits on a regular basis and has had BRC (British Retail Consortium) certification for the production of food packaging film since 2008. The company aims to initiate OHSAS 18001 and ISO 14001 certification processes of its occupational health and safety and environmental management systems in 2012. The production and distribution processes have been systematically reviewed in regards to GMP as defined by the framework regulation (EC 1935/2004) and GMP regulation EC 2023/2006 as amended.Sanko Textile: Corlu facility has obtained Oeko-tex Class 1, GOTS (Global Organic Textile Standard) standardization and Ecolabel Certificates and has applied to qualify for bluesign standard (this standard aims to put a reliable and proactive tool at the disposal of the entire textile production chain - from raw material and component suppliers who manufacture e.g. yarns, dyes and additives, to textile manufacturers, to retailer and brand companies, to consumers.)ISKO Denim Production facility has also Oeko Tex and OEP certificates as well as ISO 9001 management system certificate. The company targets ISO 14001 and OHSAS 18001 certifications by the end of 2012. Sanko Iplik Gaziantep and Adiyaman facilities have ISO 9001 certification.Organization:Superfilm: The company has a Quality Management Directorate including three persons who are responsible for pest control, quality systems and quality management. Superfilm has an agreement with an environmental consulting company; Envoy whose representatives work in cooperation with the quality engineer of the plant. Envoy provides consultancy on wastewater treatment plant operations and guidance on environmental requirements and monitoring of legal compliances.Sanko Textile: An environmental engineer and a part-time OHS specialist with is employed at Corlu facility and reports to both the Technical Manager and General Manager of the company.At ISKO, The project manager oversees environmental responsibilities. An environmental specialist and an OHS expert are employed in line with the regulations, however not on a full-time basis.At Gaziantep facilities, a person responsible for OHS is available and coordinates with the OHS expert employed in the Sanko holding headquarters. The environmental consulting company; Envoy oversees the reporting of environmental liabilities.Neither Sanko nor Superfilm has an established organizational structure for the management of environmental and social responsibilities. The Company will hire a Corporate Environment, Health and Safety (EHS) Manager/Coordinator who will oversee the environment, health and safety issues associated with its operations at all facilities and will define roles and responsibilities at each facility.Training:Superfilm and Sanko Textile have established training programs to provide necessary induction and periodic trainings EHS issues for all of their direct and contractor employees. These include but are not limited to PPE (Personal Protective Equipment) usage and specific job trainings, etc. The Companies record and report all training activities and trainees.Training plans are revised according to the specific needs of the departments and according to the outcomes of the training evaluation mechanism.Monitoring:Both Superfilm and Sanko Textile regularly monitors effluent discharge, air emissions, solid waste generation, energy and water consumption, lost time accidents, customer complaints, and suppliers' performances for the various operations at all plants, in compliance with Turkish regulatory requirements. The companies will set and follow key performance indicators for EHS as continuous improvement targets.Sanko Textile undergoes social accountability and occupational health and safety audits from internationally-known branded customers.Reporting:Reporting of EHS key performance indicators is done internally as per the requirements of the corporate EHS management system and externally to the national regulatory agencies requiring EHS monitoring. Both Superfilm and Sanko Textile undergoes regular audits within the context of Environmental License and fulfill the reporting requirements to the relevant authorities under Ministry of Environment and Urban Planning and Ministry of Forestry and Water Works on the hazardous and non-hazardous waste, wastewater quality, air emissions, hazardous chemicals and labor working conditions. The Company will regularly submit to IFC an Annual Monitoring Report on Environmental and Social Performance prepared in accordance with the IFC's Performance Standards and guidelines.PS2: Labor and Working ConditionsHuman Resources Policy and Management:There is a Human Resources policy at Sanko Group level and each company has its own Human resources policy and procedures in place.Superfilm and Sanko Textile both operate in accordance with The Turkish Labor Code that covers workers' conditions, worker and employer rights, retrenchment, leave, minimum wages, discipline, the relationships between workers, companies and unions, and other labor issues.Superfilm currently employs approximately 535 workers including administrative, technical and support staff with an annual turnover of around 10%. Total workforce consists of 30% white collar employees; and employees between the ages of 21-40 represents 87% of the total workforce. The company contracts cleaning, security and catering services.Superfilm employees work in 12 hours-shifts and overtime work is paid in accordance with the Working Conditions regulation and the collective agreement. For all workers Superfilm guarantees minimum wages, however supports all employees with a comprehensive benefits package including family and child allowances, annual leave, religious holiday packages.Sanko Textile: At Corlu plant, 413 white and blue collar employees work in three 8-hours shifts and when overtime work is needed occasionally, workers are compensated for such work with additional payment, pursuant to the provisions of the labour contract and the labour law that govern overtime and shift work. Sanko Corlu guarantees the minimum salary to be slightly above the national minimum wage, and supports all employees with a comprehensive benefits package including a half-salary bonus offered three times a year, family and child allowances, half salary bonus on regional holidays and maximum half salary payment to be awarded for outstanding performance.At Isko plant, 2200 people are employed and work in three 8-hours shifts. ISKO guarantees the minimum salary to be slightly above the national minimum wage, and supports all employees with a comprehensive benefits package including a healthy life support, family and child allowances, 21 annual leave days after the first year of employment and bonus on regional holidays.Sanko Textile Gaziantep and Adiyaman facilities employ 1500 and 1030 people respectively including administrative staff.IFC's review found no evidence of forced or child labor. The minimum age of employment is 18 at all plants.Workers' Organization:Sanko Textile management has stated that each employee is free to join a worker organization and confirmed the existence of the union at ISKO, Gaziantep and Adiyaman plants. Each plant has union representatives and the collective bargaining agreement is renewed every two years.Although there is no union at Superfilm or the Corlu textile facility, these companies work in line with the holding company which adopts in principle the provisions in the textile sector collective agreement.Non-Discrimination and Equal Opportunity:Both Superfilm and Sanko Textile are equal opportunity employers, and neither makes employment decisions on the basis of personal characteristics unrelated to inherent job requirements. The companies also comply with the national labor law requirements for non-discrimination and employ a certain number of disabled people as required by the law.Grievance Mechanism:The Companies adopt an open door policy and as reported; employees can directly communicate their concerns to chiefs and managers. The Companies have placed a number of suggestion boxes at locations throughout the facilities, to allow employees to submit suggestions or complaints. Superfilm also requests all employees to complete a survey to collect data about employee satisfaction.As well as these internal grievance mechanisms, external worker protection mechanisms are ensured by the national labor laws and union activities where relevant.Retrenchment:There are no current plans for retrenchment in either Superfilm or Sanko Textile, however if it becomes unavoidable, the company will implement retrenchment plan in accordance with PS2 and if applicable, in consultation with the union active at Sanko Textile facilities.Occupational Health and Safety:Both of the companies operate in accordance with several requirements of an accredited occupational health and safety management system such as ISO OHSAS 18001 including risk assessment studies, accident root cause analysis and reporting. The Companies are also obliged to comply with the Law on OHS which establishes the general principles relating to the prevention of occupational risks, protection of workers at the workplace, elimination of risk factors and occupational accidents, training of workers and their representatives, and general guidelines for the enforcement of these principles. All Superfilm and Sanko Textile staff is provided with general health and safety trainings prior to commencement of work activities and OHS trainings is conducted once a year.At Superfilm, monthly OHS meetings are held with the participation of the general manager to identify risks and to continuously improve workplace health and safety conditions. A monthly OHS and hygiene control system is available. A workplace physician works each day of the week in the Superfilm facility in line with the national Occupational Health and Safety legislation (No: 25311, dated December 9, 2003). A medical examination is required for all workers upon the employment. Staff also undergoes medical examination annually, including lung screenings and audiometric tests.The company keeps detailed records of incidents and near-misses in their accident log system including the relevant corrective actions. Risk analysis studies had also been initiated and a draft risk analysis document is available, however it will be revised to account for more accurate weighting and reporting of each risks identified. A Permit to Work system is in place for hot work and working at height and will be extended to electrical works and confined spaces working. The company will post danger signs or implement other effective means, to inform employees of areas defined as confined spaces.Superfilm facilities have detailed maintenance programs for lines and equipment, such as forklifts, pressurized vessels, boilers, etc and the maintenance activities are regularly tracked on the Data Stream system. MSDS cards are being prepared for the workshop.The company has its own fire department and a fire safety plan has been established according to national legislation. Well trained fire fighting teams are accessible at every shift. Smoke detectors and fire extinguishers are in place, a hydrant system is available for the thermal oil heater. Emergency exits are specified in the site including emergency meeting areas. Fire drills are performed once a year.The company uses toluene to dissolve a silicone containing material during the production of adhesive tapes. In that production area, automated fire extinguishing system is available and all relevant equipment is protected with safeguards against explosion. Additional measurement of workplace solvent concentrations will be carried out in adhesive tape production area. The company will also improve cooling in this production area by adding or upgrading air conditioning equipment.Superfilm will also ensure full implementation of an occupational health and safety and environmental management system for the construction of new PET line construction including daily visual inspections and review of the contractor agreement in terms of OHS practicesSanko Textile: At Corlu, Risk analysis studies are revised every year under the guidance of the OHS committee and the most significant risks are assessed as fire risk and machine guarding. The company has a thorough emergency response plan and fire drills are performed once a year as part of this plan. Fire extinguishing equipment is inspected every 3 months by a fire safety contractor. An emergency action plan has been developed for fabric storage rooms however there is no fire detection system in these rooms: these will be installed by the company. Emergency exit routes within the facility are clearly labeled and unobstructed.All chemicals are labeled and stored appropriately with relevant MSDSs. All the chemicals and dyes are fed in to the process through a closed fully automated system, additionally lock out/tag out procedures have been drafted and implemented. PPEs are provided to all workers and extra stocks are available. Technical periodical maintenance programs for equipment, such as forklifts, pressurized vessels, boilers, etc are available. A workplace doctor works 2 hours a day and a full-time nurse is available on site. Corlu plant employs approximately 40 trained first aiders as required by the law and ensures that a first aider is available at each shift Staff also undergoes medical examination annually, including lung screenings and audiometric tests. The company keeps detailed records of incidents and near-misses in their accident log system including the relevant corrective actions.The majority of the accidents were caused by rotating equipment; the company had taken necessary precautions to minimize those accidents mainly by installing machine guarding systems. The company will implement a Permit to Work system specifically for hot work and working at height. The company will improve machine guarding at certain lines such as unpacking and will make alterations in the warehouse and coal storage area to improve housekeeping and occupational safety.Risk analysis studies have been carried out at ISKO plant and the company is in the process of implementing lock out/tag out procedures for its production lines and maintenance works. The company will improve machine guarding at certain locations and housekeeping around the boilers. The company has drafted an emergency response plan and fire drills are performed in accordance with the fire safety procedures. The company keeps detailed records of incidents and near-misses in their accident log system including the relevant corrective actions. Medical examination of staff is done annually, including lung screenings and audiometric tests. ISKO ensures that all workers are supplied with PPE at the areas where cotton dust level is higher than limits and use of this PPE was observed during site visits. ISKO will continue to the efforts to decrease cotton dust amount at workplaces.Risk assessment studies have been completed at Gaziantep facilities and OHS procedures have been drafted in accordance with the Sanko Group. The major risk is determined as cotton dust. Inhalation of the dust generated where cotton fibre is converted into yarn and fabric, is an important occupational health concern and requires appropriate engineering controls in processing areas along with work practices, medical surveillance and PPE usage. Sanko Textile facilities use air conditioning and vacuum systems and wet floor cleaning to minimize or eliminate cotton dust exposure. The company will extend dust elimination measures to all facilities and will make necessary equipment upgrades.A workplace doctor and nurse visit Gaziantep and Adiyaman facilities as required by the law. Staff also undergoes medical examination annually, including lung screenings and audiometric tests. An OHS engineer is employed for Gaziantep facilities and Adiyaman facility is in the process of on- boarding an OHS specialist. The OHS expert of the Sanko Group supervises both of the facilities twice a month and attends monthly OHS meetings. Gaziantep facility keeps detailed records of lost time accidents and reports to the management.Documentation of the preventive maintenance programs is available and annual technical inspections are carried out by authorized institutionsNoise levels are problematic in some yarn manufacturing processes, the company will ensure that hearing protection equipments are used by all employees at these locations where noise levels cannot be engineered below required limits.Sanko Textile will improve fire detection and alarm systems and will install fire extinguishing equipments in compliance with best available international practices at the cotton warehouses.Total recordable accident per employee rates for Gaziantep, ISKO Denim Production Facility and Corlu facilities are 0.055, 0.0703, 0.058 respectively, which are ten times higher than the rate (586.3 all reported injuries/100,000 employees) by textile industry in the U.K as indicated in HSE (Health and Safety Executive) Statistics. Facilities will continuously improve accident-free environment in line with OHSAS18001.Adiyaman facility will systematize the accident reporting and provide the information to IFC as required in the Annual Monitoring Report (AMR).Supply ChainSuperfilm: The company relies solely on industrial suppliers for the main raw materials; BOPP (Biaxially-Oriented Polypropylene) and BOPET (Biaxially-oriented Polyethylene Terephthalate) film granules and has a list of approved suppliers for the raw materials and consumables. Approval process involves quality assessment of materials and sustainability of the supply. Superfilm is an AB category member of SEDEX (a non- profit membership organization dedicated to driving improvements in ethical and responsible business practices in global supply chains) and implementing their standards in the company.Sanko Textile obtains around 90% of the seed cotton used in its processes from Izmir, Adana, Gaziantep and Urfa provinces in Turkey and sources supplies the remainder from the USA. UNICEF has reported that "while the economic exploitation of children is not as widespread in Turkey as in some developing countries, unacceptable forms of child labor persist."Sanko Textile: Sanko Textile is an approved member of the BCI (Better Cotton Initiative) which promotes measurable improvements in the key environmental and social impacts of cotton cultivation to make it more economically, environmentally, and socially sustainable. Sanko Textile engages in some other sustainability practices such as use of recycled cotton waste and denim fabric in yarn production process, minimizing water usage in dying process utilizing more efficient technologies.Going forward, Sanko Textile will extend its supply chain management system and procedures in terms of environmental and social aspects and ensure compliance of suppliers with IFC PS2 he company will also promote safe agricultural practices and raise awareness among farmers regarding harmful child labor. In case a supplying country or a region has high risk of harmful child labor and/or forced labor; the company will where practicable work with suppliers to avoid child labor in harvesting and where this is not possible will search for new suppliers in lower risk regions.PS3: Pollution Prevention and AbatementResource Conservation and Energy Efficiency:Superfilm: The company circulates an average of 300 ton/day water in the production system and Reverse Osmosis method is used to treat the process wastewater for reuse. There is a recirculation rate of approximately 75%. Following the production process, waste water is pumped to the wastewater collection pool and after the adjustment of conductivity and pH, it is used again in production process and the remaining 25% discharge water is used for cleaning ash pool.A solvent recovery system is in place to recover toluene in the adhesive tape manufacturing process and solvent contaminated wastewater is sent to the Gaziantep OIZ WWTP. Superfilm operations consume 6.9MJ/kg thermal energy and 0.84 kWh/kg electrical energy which are within industry benchmark limit values.Sanko Textile:Sanko Textile facilities have metering to facilitate benchmarking of energy and water use. The average amount of water used for one kg of product at Sanko is around 100 -110 L which is the industry benchmark. The site-specific water consumption figures for Corlu, Isko Denim Facility and Gaziantep Facility are, 100-150 L/kg (depending on the product and the process), 140-150 L/kg and 28L/kg respectively. The electrical energy consumption figures for Gaziantep Spinning and Knitting mill, Adiyaman Knitting mill, Corlu Knitting mill and ISKO Denim facility are 3.5, 0.56, 3.77, 0.7 and 2.18 kWh/kg respectively, which are within the industry benchmark range.Sanko Textile will make further investments in VORTEX spinning technology- an energy saving design- that will contribute to a more user friendly production system as well as lower power consumption.Sanko Corlu plant management will establish a cleaner production plan for the facility within the framework of the Integrated Pollution Prevention and Control in the Textile Industry Notification. ISKO Denim plant will also conduct a Cleaner Production audit to identify opportunities to save energy and water in its production processesThe plant is located within the Ergene Basin, an ecologically sensitive area and wastewaters discharged from Cerkezkoy and Corlu districts in the north of the province are alarmingly polluting the Cerkezkoy and Corlu rivers at the Ergene Basin intersection. For this reason, governorships of Tekirdag, Kirklareli and Edirne have started studies to prevent pollution in the Basin and the preliminary measures for the selection of industrial installment locations, planning, disposal and treatment of wastewater are studied by the relevant regulatory authorities. In this respect, a project has been initiated to establish Rehabilitated Organized Industrial Area (ISLAH OSB) in Velimese district under the amendment of the Organized Industrial Areas Law #4562. Sanko Corlu is a founding member of this initiative which includes construction of an advanced wastewater treatment facility.Air EmissionsSuperfilm: Superfilm operates one natural gas and one coal fired combustion system both with 7 mln kcal/h capacities, for the film production and heating purposes. The thermal oil heater with the fluidized bed combustion system utilizes 0-10 mm fine coal and circulates 90 tons of thermal oil at 250 C in a closed system. The company sends the residual combustion ash to Cimko Cement Plant in Narli.To control particulate matter emissions, the company uses wet filter system checked every month.The company has obtained B-class emission permission from relevant government authorities and emission measurements are performed by accredited laboratories. Review of the available data indicates compliance with the local regulations and WBG guideline values.Sanko Textile:Sanko Corlu facility operates natural gas and coal fired combustion systems. The fluidized bed coal combustion system has 30000kg/h steam production capacity and utilizes 0-8mm lignite. There is an online emission monitoring system connected to the coal boiler stack as required in the Industrial Air Pollution Control Regulation for tracking temperature, CO and SO2 parameters. There are 5 combustion and 28 process stacks in the facility with a total heat capacity of approximately 63 MW. Emissions from all stacks except coal boiler stack are measured by an accredited laboratory every three years. Review of the available data indicates compliance with the local regulations and WBG guideline values. Air emission standards are maintained using wet scrubbers in the fluidized bed combustion system which significantly reduces the SO2 and dust emissions. Residual ash is sent to Edirne Cimentas Cement Production Plant.ISKO facility also uses natural gas and lignite to produce steam for the production purposes. Two 24.5 MW capacity fluidized bed coal boilers are available and online emission monitoring system has also been installed at this facility connected to the relevant unit of the Ministry. Emission measurements conducted by an accredited institution indicates that emission levels are in compliance with relevant regulatory requirements as well as WBG guideline values. Residual ash is sent to Bursa Cement Production Plant.Sanko Gaziantep and Adiyaman facilities use electricity for production and heating purposes.Water and Waste Water Management:Superfilm: Water used in the process is obtained from wells within the facility perimeter and depending on the weather conditions; additional water is supplied from the wells located in the Organized Industrial Zone. Monthly drinking water analysis is performed by the District Public Health Laboratory.Domestic wastewater and filter cleaning water produced on site is sent to the Wastewater Treatment Plant of the Gaziantep Organized Industrial Zone in a closed pipe network system. The company has acquired the sewage connection authorization to discharge its effluent to the WWTP of the OIZ.Gaziantep Organized Industrial Zone Wastewater Treatment Plant includes a combination of physical, chemical and biological treatment components. Waste sludge has been analyzed and is not considered as hazardous waste. The WWTP is designed to accommodate a load of 90000 m3/day and current treatment volume is 45000 m3/day.Sanko Textile: Water used at Corlu plant for production purposes and other operations is sourced from wells and water samples are sent to an accredited lab periodically for assessment. The wastewater treatment facility at Corlu plant is comprised of physical, chemical and biological (Sequencing Batch Reactor system) unit and the effluent is discharged to Corlu River. Review of the measurement data indicates compliance with the local regulations and WBG guideline values. Wastewaters generated at ISKO facility is discharged directly to the Inegol Organized Industrial Zone WWTP and the company has the required sewage connection authorization and complies with the acceptance requirements of the WWTP.Sanko Gaziantep facilities discharge their domestic and process wastewaters to the Wastewater Treatment Plant of the Gaziantep Organized Industrial Zone in a closed pipe network system. The company has acquired the sewage connection authorization to discharge its effluent to the WWTP of the OIZ.The production processes in Adiyaman yarn production facilities are water-free. Domestic wastewater is discharged directly to the municipal sewage system.Solid and Hazardous Waste Management:Solid non-hazardous waste and hazardous waste management at all Superfilm and Sanko Textile plants visited is in general adequate, involving waste segregation and reduction. Non-recyclable waste produced on sites are temporarily stored by type, capacity and physical state in the appropriate containers or barrels and treated in accordance with the provisions of the regulations on the disposal of waste from the production processes.Hazardous waste is stored separately from non-hazardous waste in special labeled containers and disposed to licensed companies authorized by regulatory agencies.Superfilm sends its radioactive waste; PM-147 isotope, which is used to measure film thickness, to Turkish Atomic Energy Authority for safe storage and management.Superfilm uses HFC-134A at its air conditioning systems and the total volume used is around 4 tones.Pesticide Use and Management:Sanko Corlu plant sends sample fabrics to an accredited laboratory for pesticide detection. Sanko Textile also undergoes regular pesticide audits by independent audit firms.PS4: Community Health, Safety and SecurityThere are no immediate households or neighbors in the vicinity of both Superfilm and Sanko Textile facilities as they are constructed on industrial zones.The Company employs licensed and armed security personnel at all sites contracted from a private Sanko Group company and they are regularly trained and certified as per the local regulatory requirements.Sanko Textile aims to minimize and eliminate harmful inputs to reduce the level of chemical residues left on the textile. Thus the company adapts organic cotton treatment and processing standards. The company uses 110000 tons of cotton annually and 5% of this amount is organic cotton and other natural fibers. Sanko has also produced a high performance cotton fabric under the brand name "Zeugma" which, compared to normal cotton, requires 30% less energy in the manufacturing process. No harmful chemicals or enzymes are used in the production of Zeugma.

ACCOUNTABILITY MECHANISM OF IFC The Compliance Advisor Ombudsman (CAO) is the independent complaint mechanism and fact-finding body for people who believe they are likely to be, or have been, adversely affected by an IFC or MIGA- financed project. If you submit a complaint to the CAO, they may assist you in resolving a dispute with the company and/or investigate to assess whether the IFC is following its own policies and procedures for preventing harm to people or the environment. If you want to submit a complaint electronically, you can email the CAO at CAO@worldbankgroup.org. You can learn more about the CAO and how to file a complaint at http://www.cao-ombudsman.org/