Republic of Turkey Turkey Organized Industrial Zones Project ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) (Draft) December 18, 2020 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Republic of Turkey, through its Ministry of Industry and Technology (MoIT), shall implement the Turkey Organized Industrial Zones Project (the Project). The International Bank for Reconstruction and Development (hereinafter the Bank) has agreed to provide financing for the Project. 2. The MoIT shall implement material measures and actions so that the Project is implemented in accordance with the Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, any specific documents or plans, as well as the timing for each of these. 3. The MoIT shall also comply with the provisions of any other environmental and social (E&S) documents required under the ESF and referred to in this ESCP, such as Environmental and Social Management Framework (ESMF), Environmental and Social Impact Assessments (ESIAs), Environmental and Social Management Plans (ESMPs), Resettlement Framework (RF), Resettlement Action Plans (RAPs), Labor Management Procedures (LMP), and a Stakeholder Engagement Plan (SEP), and other specific mitigation plans as per the timelines specified in those E&S documents. 4. The MoIT is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the by the parties involved in the project. 5. Implementation of the material measures and actions set out in this ESCP shall be monitored and reported to the Bank by the MoIT as required by the ESCP and the conditions of the legal agreement, and the Bank shall monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Bank and the Republic of Turkey, through MoIT, this ESCP may be revised from time to time during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, the Government of Turkey shall agree to the changes with the Bank and shall update the ESCP to reflect such changes. Agreement on changes to the ESCP shall be documented through the exchange of letters signed between the Bank and the MoIT. The MoIT shall disclose the updated ESCP in the shortest possible time. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, MoIT shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts, which may include environmental, land acquisition/resettlement related or labor risks. 2|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING MoIT Prepare and submit regular monitoring reports on environmental, Starting ninety (90) days after the Effective Date of the Loan social, health and safety (ESHS) performance of the Project, including and then quarterly (every three (3) months) throughout but not limited to the implementation of the ESCP, status of preparation Project implementation. and implementation of Environmental and Social (E&S) documents required under the ESCP, stakeholder engagement activities, functioning of the grievance mechanism(s). No later than the Effective Date of the Project. Ensure frequency and content of monitoring reports is detailed in the Project Operations Manual and implemented accordingly. B INCIDENTS AND ACCIDENTS Promptly notify the Bank of any incident or accident related to the MoIT shall obligate the Organized Industrial Zones (OIZ) MoIT Project which has, or is likely to have, a significant adverse effect on the concerned to report to the MoIT the details of any significant environment, the affected communities, the public and workers such as environmental or social incidents (e.g., fatalities, lost time Occupational Health and Safety (OHS) accidents or that result in incidents, environmental spills, etc.) within 48 hours after the threatening community health and safety. occurrence of the incident or accident, and MoIT shall immediately notify the Bank upon receipt of such notification. Provide sufficient detail regarding the incident or accident, findings of MoIT shall obligate the OIZ concerned to submit to MoIT an the Root Cause Analysis (RCA), indicating immediate measures taken or incident report, including root cause analysis, precautions and that are planned to be taken to address it, compensation paid, and any compensation measures taken within 30 business days of the information provided by any contractor and supervising incident. MoIT shall forward the incident report to the Bank entity/consultant, as appropriate. Ensure the incident report is in line immediately upon receipt from the OIZ. with the Bank’s Environment and Social Incidence Response Toolkit (ESIRT). Subsequently, as per the Bank’s request, prepare a report on the incident or accident and propose any measures to prevent its recurrence. Include in bidding documents of contractors that prompt notification of accident and incidents remain inclusive under contractor’s Environmental and Social Management Plan (ESMP). Ensure and monitor that an incident register at all construction sites are kept by the contractors throughout the Project life. 3|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY C CONTRACTORS QUARTERLY REPORTS Obligate OIZs to produce monthly progress reports for all sub-project Starting thirty (30) days after the receiving withdrawal of the MoIT sites and monitor quality of reporting throughout the duration of works. Loan financing and then monthly throughout the Project Include reporting requirements in bidding documents of contractors. implementation. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Ensure that a Project Implementation Unit (PIU) is established and Strengthen the capacity of the PIU, by hiring one (1) MoIT staffed with qualified staff to support management and monitoring of environmental, one (1) social, one (1) OHS and one (1) E&S risks by appointing one social, one environmental, one OHS stakeholder engagement specialist by the Effective Date of specialist and one stakeholder engagement (SE) specialist, who are the Loan. responsible for full compliance with the ESF and relevant instruments. All designated PIU staff positions for the Project shall be Maintain the structure of the complete PIU throughout Project retained for the duration of the Project. implementation. Obligate OIZs to assign E&S, OHS and SE/GRM focal points for Throughout project implementation management of sub-projects’ E&S risks. Obligate contractors to assign E&S, OHS and SE/GRM focal points for sub-projects’ E&S risk management by including this requirement in the bidding documents for works. 4|Page 1.2 MANAGEMENT TOOLS AND INSTRUMENTS Finalize and implement the existing Environmental and Social An ESMF, in form and substance acceptable to the Bank, shall MoIT Management Framework (ESMF) for the Project, in a manner be publicly consulted on, finalized, adopted and publicly acceptable to the Bank. disclosed before January 20, 2021 (i.e., five (5) days before the expected date for consideration of the Project by the Prior to the approval of any OIZ investments or subprojects under this Bank’s Board of Executive Directors (Board)); in the event that Project, MoIT shall carry out environmental and social screenings of the the said Board date is changed, the said consultation, related OIZs. Based on the results of the screening for the OIZ finalization and disclosure of the ESMF shall be no later than concerned, and where required by the Bank, the MoIT shall undertake five (5) days before such revised date for Board consideration . Environmental and Social Due Diligence for the respective investment or subproject.1 The Environmental and Social Due Diligence shall include a systematic review and assessment of the respective OIZ’s performance MoIT shall (a) submit to the Bank the review or assessment in addressing environmental and social risks and impacts, and ensure undertaken by the Environmental and Social Due Diligence that any issues that may negatively affect the natural environment, process for the Bank’s prior review, and (b) approve of the MoIT habitats, communities within the scope of the investment or subproject related investment or subproject only after receiving the are avoided, minimized or remedied/mitigated through appropriate Bank’s no-objection. actions. Where significant residual impacts remain, the MoIT shall compensate for or offset them where technically and financially feasible. Following the screening and Environmental and Social Due Diligence, ESIAs, ESMPs and RAPs – to be prepared and disclosed prior MoIT (as appropriate, and in accordance with the ESMF prepared for the Project, prepare, to tendering of works for each sub-project and thereafter shall cause OIZs to disclose, consult upon, adopt and implement the sub-project specific implemented in a manner acceptable to the Bank. carry out in accordance Environmental and Social Impact Assessments (ESIAs), ESMPs and with the ESMF) Resettlement Action Plans (RAPs) as per the guidelines/requirement accordance with ESMF and Resettlement Framework (RF), disclose and consult in form and substance acceptable to the Bank. Include provisions for E&S tasks and instruments in tender documents Sixty (60) days from the date of receipt of the full package of MoIT (as appropriate, and contract requirements so that detailed design tasks reflect phasing the draft detailed engineering/technical design of OIZ shall cause OIZs to for activities such as the ESMPs and RAPs. subproject investments under the Project, and prior to the carry out in accordance finalization of respective tender documents of subprojects. with the ESMF) Prepare, disclose, consult and adopt ESF documents for any associated After the finalization of the detailed engineering/technical facilities (electricity transmission lines, water purification), as confirmed design, and before the start of the construction. MoIT (as appropriate, by the final detailed design. shall cause OIZs to carry out in accordance with the ESMF) 5|Page Ensure that the requirements of the ESF are integrated into the terms of ToRs shall be approved by the Bank prior to tendering of MoIT reference (ToRs) to be prepared for each feasibility study. feasibility studies. 1.4 MANAGEMENT OF CONTRACTORS Incorporate the relevant aspects of the ESCP, including the requirement After finalization of the detailed/technical engineering design MoIT (as appropriate, to comply with ESIAs, ESMPs, RAPs, and Labor Management Procedures for the investments and financing, prior to the finalization of shall cause OIZs to (LMPs), into the ESHS requirements of the procurement documents to the respective tender documentation. carry out in accordance ensure that the requirement to produce Contractor’ s ESMP (based on with the ESMF) ESIAs and ESMPs produced as per the ESMF), RAP, Labor Grievance Mechanism (GM) for Contractor’s personnel, and ESHS Code of Conduct Supervise contractors throughout the Project implementation. MoIT (as appropriate, are included into bidding documents for civil works contracts. shall cause OIZs to Thereafter, ensure that the contractors comply with the ESHS carry out in accordance requirements of their respective contracts. with the ESMF) ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES . Finalize and implement Labor Management Procedures (LMP) and LMP, in form and substance acceptable to the Bank, shall be MoIT (as appropriate, ensure that Project workers are informed of and have access to these publicly consulted on, finalized, adopted and publicly shall cause OIZs to procedures. Update LMP, as needed. disclosed before January 20, 2021 (i.e., five (5) days before carry out in accordance the expected date for consideration of the Project by the with the LMP and Bank’s Board); in the event that the said Board date is ESMF) changed, the said consultation, finalization and disclosure of the ESMF shall be no later than five (5) days before such revised date for Board consideration. The LMP shall be maintained and implemented throughout Project Obligate the Contractors to adopt and implement contractors’ labor implementation. Before the start of the civil works and management procedures, inluding OHS measures as detailed in the LMP throughout Project implementation. and ESMPs. MoIT (as appropriate, shall cause OIZs to carry out in accordance with the LMP and ESMF) 1 “Environmental and Social Due Diligence� means (a) the systematic identification, quantification and assessment or evaluation of environmental and social risks and impacts associated with a proposed transaction, and (b) the proposed measures for remedying and/or mitigating the identified risks and impacts, or compensating and/or offsetting those risks where feasible in accordance with the requirements of the Bank’s Environmental and Social Framework. 6|Page 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish, maintain, and operate grievance mechanisms (GM) for direct Grievance mechanism established not later than 30 days after MoIT (as appropriate, workers and obligate contractors to provide GM for contracted workers , the Effective Date of the Project, prior to the recruitment of shall cause OIZs to including a mechanism to address sexual exploitation and abuse (SEA) any Project workers, and thereafter maintained throughout carry out in accordance and sexual harassment (SH) grievances. Project implementation. with the LMP and ESMF) Monitor implementation of the Project workers’ GM, maintain a GM log, MoIT (as appropriate, and report on Project workers’ grievances Report on Project workers’ GM implementation activities in shall cause OIZs to regular quarterly reports as required in Section A of this ESCP. carry out in accordance with the LMP and ESMF) 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Where assessed as necessary, implement measures of protection at Throughout Project implementation. MoIT MoIT (as work and safety for jobs with increased risk of injury and damage to appropriate, shall health, as well as organization of training for workers in such jobs. cause OIZs to carry out in accordance with the ESMF and LMP) Ensure all Contractors adopt and implement OHS measures as detailed in Throughout project implementation MoIT (as appropriate, LMPs and ESMPs. shall cause OIZs to carry out in accordance with the LMP and ESMF) ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT: Include measures to prevent and/or minimize environmental pollution Prepare and disclose sub-project specific ESA documents MoIT (as appropriate, during construction and operation into Contractors’ individual ESMPs (ESIAs and ESMPs) prior to tendering of works for each sub- shall cause OIZs to (including development of necessary management plans, as project and implement thereafter. carry out in accordance appropriate) following guiding principles of the ESS 3, sub-project with the ESMF) specific ESIAs and ESMPs to be prepared under action 1.2 above, and Apply mitigation measures throughout Project the WBG EHS Guidelines, and duly applied. implementation. MoIT (as appropriate, shall cause OIZs to carry out in accordance with the ESMF) 7|Page ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: Adopt and implement measures and actions to assess and manage Prepare and disclose, ESIAs and ESMPs, in a form and MoIT (as appropriate, traffic and road safety risks through Traffic Management Plans as substance acceptable to the Bank, prior to tendering of works shall cause OIZs to required in the sub-project specific ESIAs and ESMPs to be developed for each sub-project. carry out in accordance under action 1.2. with the ESMF) Ensure these measures are included into Contractors’ ESMPs following Ensure adherence to ESIAs and ESMPs throughout the Project guiding principles of the ESMF duly applied. MoIT (as appropriate, shall cause OIZs to carry out in accordance with the ESMF) 4.2 COMMUNITY HEALTH AND SAFETY: Adopt, and implement measures and actions to assess and manage Prior to commencement of civil works and throughout the MoIT (as appropriate, specific risks and impacts to the community arising from Project Project implementation shall cause OIZs to activities and ensure these measures are included in Contractor’s sub carry out in accordance management plans, in line with sub project specific ESMPs and in form with the ESMF) and substance acceptable to the Bank. 4.3 Detailed design and Contractor’s individual ESMPs shall assess / analyse After finalization of technical designs of investments and MoIT (as appropriate, emergencies risks and outline mitigation measures to address these financing, prior to the preparation of procurement shall cause OIZs to risks. documents. carry out in accordance with the ESMF) Ensure that design of new public access buildings and facilities consider life & fire safety design requirements as specified by the WBG General EHS guidelines. Ensure that design and construction of investments that require new buildings and facilities consider universal access concept. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 8|Page 5.1 RESETTLEMENT PLANS: Finalize, consult upon, disclose, adopt, and implement Resettlement RF, in form and substance acceptable to the Bank, shall be MoIT Framework (RF) in a manner acceptable to the Bank. publicly consulted on, finalized, adopted and publicly disclosed before January 20, 2021 (i.e., five (5) days before Prepare sub-project specific Resettlement Plans (RPs)/Ex Post Social the expected date for consideration of the Project by the Assessment (if necessary) as per the RF, disclose, consult with Bank’s Board); in the event that the said Board date is stakeholders, and implement in a manner acceptable to the Bank. changed, the said consultation, finalization and disclosure of the ESMF shall be no later than five (5) days before such revised date for Board consideration. Establish, adopt and implement the RP with arrangements, that allows for the compensation of certain entitlements currently not covered After finalization of detailed designs of investments, and prior MoIT (as appropriate, through national legislation. to commencement of civil works. shall cause OIZs to carry out in accordance with the ESMF and RF) Prepare, adopt, implement RPs (if necessary), for OIZ sub-projects in a manner acceptable to the Bank. Prior to commencement of any land acquisition activity. MoIT (as appropriate, shall cause OIZs to carry out in accordance with the ESMF and RF) Prior to commencement of civil works of sub-projects. MoIT (as appropriate, shall cause OIZs to carry out in accordance with the ESMF and RF) ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES Identify, describe and design mitigation measures for biodiversity risks Prepare and disclose ESIAs and ESMPs, in form and substance MoIT (as appropriate, and impacts in the sub-project specific ESIAs and ESMPs to be prepared acceptable to the Bank, prior to tendering of works for each shall cause OIZs to under action 1.2 above. sub-project. carry out in accordance with the ESMF) ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Currently not relevant to the project 9|Page ESS 8: CULTURAL HERITAGE 8.1 Prepare, adopt, and implement the chance finds procedure described in Implement chance find procedures included in the ESIAs and MoIT (as appropriate, the sub-project specific ESIAs and ESMPs developed for the Project ESMPs, in each instance of when a chance find occurs, shall cause OIZs to under action 1.2 above. throughout the implementation of the Project. carry out in accordance with the ESMF) Chance Finds Procedure is included into all civil works contracts and contractors are obligate to adhere. Ministry of Culture and Tourism. ESS 9: FINANCIAL INTERMEDIARIES Not relevant to the project ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE: Consult upon, finalize, disclose, maintain and implement a Stakeholder The SEP, in form and substance acceptable to the Bank, shall MoIT (as appropriate, Engagement Plan (SEP) in a manner acceptable to the Bank. be publicly consulted on, finalized, adopted and publicly shall cause OIZs to disclosed before January 20, 2021 (i.e., five (5) days before carry out in accordance the expected date for consideration of the Project by the with the ESMF and SEP) Bank’s Board); in the event that the said Board date is Implement SEPs; report on the implementation of all activities in the changed, the said consultation, finalization and disclosure of SEPs. the ESMF shall be no later than five (5) days before such revised date for Board consideration. Implement SEPs starting with the Effective Date of the Loan and throughout Project implementation. Report on SEP implementation activities in regular quarterly reports as required in Section A of this ESCP. MoIT (as appropriate, shall cause OIZs to carry out in accordance with the ESMF and SEP) 10 | P a g e 10.2 Establish, maintain and operate grievance mechanism (GM) in a Grievance mechanism to be established not later than 30 days MoIT (as appropriate, manner acceptable to the Bank. after the Effective Date and maintained throughout Project shall cause OIZs to implementation. carry out in accordance with the ESMF and SEP) Manage, respond to and monitor project grievances. Reporting on received grievances – Quarterly in progress MoIT (as appropriate, reports throughout the Project implementation. shall cause OIZs to carry out in accordance with the ESMF and SEP) 11 | P a g e CAPACITY SUPPORT (TRAINING) CS1 Training shall be required for staff and stakeholders on: Within the first year of the Project implementation, before MoIT (as appropriate,  the World Bank Environmental and Social Framework start of the Project activities, and followed by a minimum one shall cause OIZs to  preparation of site-specific E&S Instruments annual refresher training carry out) with the  stakeholder mapping and engagement support of the Bank  specific aspects of environmental and social assessment  land acquisition, restrictions on land use and involuntary resettlement  international requirements for tender procedures  SEA /SH and GBV and COVID 19 prevention measures 12 | P a g e