February 2024 STAKEHOLDER ENGAGEMENT PLAN FOR TÜRKİYE INDUSTRIAL EMISSION REDUCTION PROJECT DEVELOPMENT AND INVESTMENT BANK OF TÜRKİYE (TKYB) FEBRUARY 2024 1 ABBREVIATIONS & ACRONYMS CE CİTİZEN ENGAGEMENT / COMMUNITY ENGAGEMENT ESF ENVIRONMENTAL AND SOCIAL FRAMEWORK ESS ENVIRONMENTAL SOCIAL STANDARD GRM GRIEVANCE REDRESS MECHANISM IFC INTERNATIONAL FINANCE CORPORATION LMP LABOR MANAGAMENET PROCEDURE PIU PROJECT IMPLEMENTATION UNIT SEP STAKEHOLDER EGAGEMENT PLAN TIERP TÜRKİYE INDUSTRIAL EMISSION REDUCTION PROJECT TKYB DEVELOPMENT AND INVESTMENT BANK OF TÜRKİYE WB WORLD BANK 2 Stakeholder Engagement Plan (SEP) Template for Substantial Risk and High-Risk Projects Türkiye Industrial Emission Reduction Project (TIER Project) 1. Introduction/Project Description Türkiye’s economic growth is strongly correlated with growth in its manufacturing sector. Türkiye’s real Gross Domestic Product (GDP) increased more than sixfold from US$151 billion in 1990 to US$906 billion in 2022, while the poverty rate reduced significantly. However, Türkiye’s economic growth has been accompanied by environmental degradation, including increasing emissions of air pollutants and greenhouse gases. Emissions of both air pollutants and greenhouse gases (GHGs) have adverse impacts on environment, climate, productivity, health, and resilience. GHG emissions, excluding the land use, land-use change, and forestry (LULUCF) sector, increased by 157% from 1990 to 2021 reaching 564 Mt CO2-equivalents. Emissions of key air pollutants have also significantly increased in the last decades, including sulfur dioxide (SO2) by 60%, nitrogen oxides (NOx) by 286%, ammonia (NH3) by 51%, non-methane volatile organic compounds (NMVOC) by 30%, particulate matter (PM10) by 10%, and fine particulate matter (PM2.5) 472% (all trends 1990 to 2021). Air pollution is the largest environmental risk factor for human health and causes 41,524 premature deaths per year in Türkiye (51 deaths per 100,000 population) from PM2.5, with associated welfare costs of 5.8 percent of the Turkish GDP. The industry sector is a major contributor to air pollution and GHGs with emissions having steadily increased over the past two decades along with the growth in heavy industry and manufacturing. GHG emissions from industry alone now represent 28% of the total (excluding LULUCF). Metals (iron and steel), and non-metallic minerals (mainly cement) are the largest GHG emitting sectors through stationary combustion and process emissions. To help decarbonize industrial sectors, the government is planning to implement an emissions trading system (ETS) that will place a price on carbon emissions. The government is also developing a green taxonomy to help channel finance to green investments. As a result of the growing ambition of the policy environment, many industries are starting to investigate emission reduction opportunities at their installations, but support is needed. Türkiye is receiving support from the EU through a project on the Determination of Industrial Emissions Strategy (DIES), which is preparing an action plan to be available by the end of 2023. As per the DIES project, there are approximately 6,000 IED installations in Türkiye and it is estimated that EUR 27 billion of investment is required for alignment with the provisions of the IED. According to the survey conducted by the MoEUCC, the uptake of cleaner production measures (at least one) is low in the industries with relatively large and medium installations, such as metal (40%), cement (59%) and energy (62%), whilst this figure is higher in leather (70%) and textile (75%) industries. This project aims to support Türkiye in achieving its climate and air quality objectives by reducing emissions from the important industrial sectors. With the forthcoming ETS and legislation in line with the IED, industrial emitters will need to start investing in new technologies and processes that will result in substantial emissions reduction. By providing long-term finance, this project will address a key financing gap for implementing emission reduction measures in industry and will support projects that are economically beneficial but not being funded under current financing 3 terms. The project can help demonstrate the business case for such investments and spur market development for clean technologies. This can inform the broader financial market about how to value such projects, inform medium and large industries about the costs and benefits of investing in emissions reductions, help businesses and the financial sector become more familiar with emission reducing investments, and support the flow of finance from the commercial banking sector in the coming years and when macroeconomic conditions settle. The proposed project contributes to achieving several objectives in the World Bank’s Türkiye Country Partnership Framework (CPF, 2018–2021). In particular, the project will contribute to i) Focus Area 1 – Growth, CPF Objective 3: Enhanced competitiveness and employment in selected industries through improving environmental competitiveness of the industrial sector in Türkiye by increasing uptake of cleaner technologies in selected industrial sectors. The project also contributes to Focus Area 3 – Sustainability. Under this Focus Area, the proposed project will contribute to Objective 9 – Strengthened results under climate action agenda given that measures in industries will result in GHG emission reduction. The Project is consistent with the Türkiye’s Nationally Determined Contribution (NDC), the Türkiye Country Climate and Development Report, and the climate Memorandum of Understanding signed between the World Bank, development partners and Türkiye in November 2021. Türkiye’s mitigation policies target GHG emission reduction from the energy, industry, transportation agriculture, building, and waste sectors as well as LULUCF. Particularly, its mitigation policy targeting the industry sector include supporting green transition in industry by prioritizing certification of industrial installations that use “Best Available Techniques” or BAT for clean and green industrial production. Türkiye is also in the process of developing its Long-term strategy (LTS) to set out goals to achieve net zero emissions by their target of 2053. PROPOSED PDO/RESULTS The project development objective is to reduce the emission of air pollutants and GHGs from selected industry sectors of Türkiye. There would be 2 potential key results. First one is projected lifetime net air pollutant emission reduction from selected industries (metric ton), second is projected lifetime net GHG emission reduction from selected industries (metric ton) Intermediate indicators include: (iii) the amount of sub-loans to industry targeting air pollutant and GHG emission reduction (USD); (iv) the number of industries adopting the best available techniques (number); (v) the number of industrial firms that receive IED permit (number). The specific air pollutants to be reduced in the PDO indicator (i) and intermediate indicators including gender and citizen engagement indicators will be further discussed during preparation and included in the results framework of the project appraisal document (PAD). In summary the project development objective is to reduce the emission of air pollutants and GHGs from selected industry sectors of Türkiye. The TIERP Project will contribute to (i) improving air quality and reducing GHG emissions, which are the provision of public goods; (ii) demonstrating the adoption of emission reduction technologies in industries by providing longer- term finance to firms for clean air and decarbonization; (iii) spurring market development for increasing uptake of clean technologies in industries. 4 Türkiye Industrial Emission Reduction Project (TIER Project) is being prepared under the World Bank’s Environment and Social Framework (ESF). In the scope of the Türkiye Industrial Emission Reduction Project (TIER Project), all carbon- intensive sectors and firms are stakeholders. Especially the most carbon-intensive sectors are crucial stakeholders which are Energy industries, Metal production and processing industries, Mineral industries, Chemical industries and Waste industries. These industries are located in whole Türkiye, there is a map of the Organized Industrial Zone below; Figure 1: Map of the Organized Industrial Zone in Türkiye The all OIZs are the potential project components, and they are located almost all over the whole Türkiye. 2. Objective/Description of SEP The overall objective of this SEP is to define a program for stakeholder engagement, including public information disclosure and consultation throughout the entire project cycle. The SEP outlines the ways in which the Development and Investment Bank of Türkiye (TKYB) will communicate with stakeholders and includes a mechanism by which people can raise concerns, provide feedback, or make complaints about the project and any activities related to the project. The SEP specifically emphasizes methods to engage groups considered most vulnerable and that are at risk of being left out of project benefits. Managing stakeholders is a comprehensive process that spans the entire project life cycle. When well-planned and executed, it fosters the development of robust, positive, and responsive relationships crucial for effectively addressing a project's environmental and social risks. This Stakeholder Engagement Plan (SEP) outlines when and how stakeholders will be involved throughout the project's life cycle. The SEP considers the unique characteristics and interests of stakeholders, tailoring the level of engagement and consultation to suit their needs. Additionally, it details the timing and scope of information shared with different stakeholders and outlines the types of information to be gathered from them. Continuous updates to the SEP document will occur throughout the project implementation period. This Stakeholder Engagement Plan consists of a formal management system to establish and maintain a reliable communication with 5 stakeholders of the Project during the lifetime of the Project. It should be updated periodically as stakeholder communication needs change. The objectives of the Stakeholder Engagement Plan (SEP) are as follows: • To establish a systematic approach to stakeholder engagement that will help TKYB to identify all stakeholders and build and maintain a constructive relationship with them. • To assess the level of stakeholder interest and support for the project and to enable stakeholders’ views to be taken into account in project design and environmental and social performance. • To promote and provide means for effective and inclusive engagement with direct stakeholders throughout the project lifecycle on issues that could potentially create an impact. • To ensure that relevant project information on environmental and social risks and impacts is disclosed to stakeholders in a timely, understandable, accessible and appropriate manner and format. • To provide stakeholders with accessible and inclusive means to raise issues and grievances and allow TKYB to respond to and manage such grievances. 3. Stakeholder identification and analysis per project component 3.1 Methodology For the Türkiye Industrial Emission Reduction Project, the following stakeholders have been identified and analyzed per project component. These stakeholders include affected parties (as defined in section 3.2), other interested parties (as defined in section 3.3) and disadvantaged/vulnerable individuals or groups (as defined in section 3.4). 3.2. Affected parties Affected parties include local communities, community members and other parties that may be subject to direct impacts from the Project. Specifically, the following individuals and groups fall within this category: Direct Affected Stakeholders: • Sub-Project Companies: All companies which the qualified companies, which will lend funds from TKYB the scope of the project falls within the direct stakeholders. It is planned that the institutions financing the project will serve as examples in the relevant matter and set an example for other companies. • Workers: All employees who provide and will provide the workforce are considered as one of the main stakeholders of the project. Due to the establishment of a Key Performance Indicator (KPI) for female employees and its monitoring, they will be both beneficiaries and direct stakeholders of the project. • Affected Citizens: All residents living around the projects planned to be funded will be considered direct stakeholders of the project. Due to the project's emission reduction, they are intended to be the individuals who will experience the maximum positive impact, and this matter will be periodically monitored. 6 3.3. Other interested parties The projects’ stakeholders also include parties other than the directly affected communities, including: Indirect Affected Stakeholders: • National authorities involved with the program: The Ministry of Treasury and Finance, Social Security Institution (SGK), The Minister of Environment Urbanization and Climate Change, the Ministry of Industry and Technology (MoIT), Presidency of Republic of Turkey, The Minister of Energy and Natural Resources and related NGOs. • Local authorities in the provinces of Türkiye currently 81 in number; (Adana, Adıyaman, Afyonkarahisar, Ağrı, Aksaray, Amasya, Ankara, Antalya, Ardahan, Artvin, Aydın, Balıkesir, Bartın, Batman, Bayburt, Bilecik, Bingöl, Bitlis, Bolu, Burdur, Bursa, Çanakkale, Çankırı, Çorum, Denizli, Diyarbakır, Düzce, Edirne, Elazığ, Erzincan, Erzurum, Eskişehir, Gaziantep, Giresun, Gümüşhane, Hakkâri, Hatay, Iğdır, Isparta, İstanbul, İzmir, Kahramanmaraş, Karabük, Karaman, Kars, Kastamonu, Kayseri, Kilis, Kırıkkale, Kırklareli, Kırşehir, Kocaeli, Konya, Kütahya, Malatya, Manisa, Mardin, Mersin, Muğla, Muş, Nevşehir, Niğde, Ordu, Osmaniye, Rize, Sakarya, Samsun, Şanlıurfa, Siirt, Sinop, Sivas, Şırnak, Tekirdağ, Tokat, Trabzon, Tunceli, Uşak, Van, Yalova, Yozgat, Zonguldak) 3.4. Disadvantaged / vulnerable individuals or groups1 Within the Project, the vulnerable or disadvantaged groups may include but are not limited to the following: Particular disadvantaged or vulnerable individuals and groups in the context of this project would be women, youth, children, refugees, and disabled, who experience a higher-than- average unemployment or are in informal employment characterized by less pay, and possibly under exploitative conditions and generally have less means and opportunity to express their concerns, or access information to understand their rights or the impact of the project. The disadvantages experiences by these groups are frequently compounded by less awareness of their rights according to the Labor Law, less access to information due to language or reduced mobility, low skills and low relevant job experience, and prevailing social norms inhibit their gainful employment. Vulnerable groups within the communities affected by the project will be further confirmed and consulted through dedicated means, as appropriate. Description of the methods of engagement that will be undertaken by the project is provided in the following sections. 4. Stakeholder Engagement Program 4.1. Summary of stakeholder engagement done during project preparation During project preparation, the following public consultation meetings were conducted below; 7 Table 1: Summary of Previous Meetings with Associations Association / Location Date Participants Key Points of Discussion Feedbacks Minister Within the scope of the DIES Project, the 2nd Related Companies, Ministry of Workshop for the preparation of the "Draft Banks Environment, National Action Plan for Determining Turkey's Conference 30.11.2023 National Organizations - Urbanization and Emission Strategy" was held with the theme of NGOs Climate Change Preparing the National Action Plan for Green Public Instutitions Transformation in Industry. Tunçağ Şen (Secretary General) The project introduction has taken place Yurdem Demir (TKYB- Corporate Marketing The current state of the foundry sector in Turkey Department Manager) The current issues causing the most environmentally and socially Turkish Foundry Cansu Eroğlu (TKYB- Corporate Marketing Expert) difficulties are; Human Resources (a Energy Efficiency and the Practices of Companies Online 11.12.2023 Manufacturers Aydan Çalıcıoğlu (TKYB – Environmental Engineer) significant loss of workers due to EYT). How environmental and occupational safety issues Association Cihan Altınbaş (TYKB – Social Expert) There are deficiencies in automation. are managed and what TÜKOSAD is doing Tuğçem Yılmaz (TKYB Corporate Marketing There is a need for digitization. Points of need in environmental and social matters Department Analyst) and the potential for creating a positive impact. Due to being a member of European The project introduction has taken place Summary Duygu Seymen (Assistant Secretary General -TALSAD) Aluminium and its international of projects carried out within the association Yurdem Demir (TKYB- Corporate Marketing initiatives, emphasis is placed on and Emission reduction as one of the most crucial Turkish Department Manager) developed in various topics. topics, the status of companies in terms of Aluminum Cansu Eroğlu (TKYB- Corporate Marketing Expert) Carbon calculations are being conducted Online 13.12.2023 occupational health and safety and waste Industrialists Aydan Çalıcıoğlu (TKYB – Environmental Engineer) by selecting pilot companies. management Association Cihan Altınbaş (TYKB – Social Expert) It is stated that comments cannot be Whether there will be an impact on local residents, Tuğçem Yılmaz (TKYB Corporate Marketing made on social issues, but the importance employees, and similar issues within the scope of Department Analyst) of the issue may increase with legal the project processes. Most of the companies within their structure are knowledgeable about Kerem Erşen (Economic Evaluations Manager) The project introduction has taken place. carbon reduction. Canan Demiröz (Environment and Climate Change What the industry is doing and its needs regarding Informative training sessions are Turkish Cement Manager) carbon reduction. organized, and despite prejudices, the Industrialists Cansu Eroğlu (TKYB- Corporate Marketing Expert) Online 15.12.2023 Information regarding the awareness level. sector is proactive in addressing these Association Aydan Çalıcıoğlu (TKYB – Environmental Engineer) Activities conducted by the association. issues. Cihan Altınbaş (TYKB – Social Expert) Within the scope of the project, the industry's Many companies publish sustainability Tuğçem Yılmaz (TKYB Corporate Marketing readiness for environmental-social-occupational reports, indicating readiness for the Department Analyst) health and safety issues and sustainability. implementation of environmental-social issues. Betül Küçükay (Association Secretary General) Yurdem Demir (TKYB- Corporate Marketing Department Manager) Cansu Eroğlu (TKYB- Corporate Marketing Expert) Aydan Çalıcıoğlu (TKYB – Environmental Engineer) The association's activities were Tuğçem Yılmaz (TKYB Corporate Marketing The project introduction has been conducted. explained, and there are companies Department Analyst) Activities carried out by the association. within the organization contributing to Galip Tekiner (Oyak Cement) Whether there are efforts and initiatives related to emission reduction. Ömer Benli (Benli Recycling) (Waste separation emission reduction in companies with suppliers in All Waste and There is no such obligation for suppliers, facility) Europe. Environmental but when working with global companies, Online 26.12.2023 Muhammet Sayaç & Savaş Akpolat (İzmit Waste and The current status of companies in terms of Management emission reduction becomes a topic. Waste Treatment Incineration and Evaluation Inc.- emission reduction and their environmental and Association Training sessions and workshops are İzaydaş) social standings. organized on environmental, social, and Bekir Tombul (İSTAÇ, a subsidiary of Istanbul occupational health and safety issues. Metropolitan Municipality) It was mentioned that members comply Sevda Özbaşaran (Eren Holding) with ISO standards and are certified. Mert Koral (INEVA Environmental Technologies) Mert Karaosmanoğlu (Biotrend Energy) Betül Çarkacı (Exitcom- Waste recycling company) Emre Sezgin (Akfensu- Water, wastewater and environmental infrastructure projects for facilities) The photos which were taken on the meetings was added at the end of SEP (Annex 3) 8 4.2. Summary of project stakeholder needs and methods, tools and techniques for stakeholder engagement. The Stakeholder Engagement Plan below outlines the engagement process, methods, including sequencing, topics of consultations and target stakeholders. The World Bank and the Borrower do not tolerate reprisals and retaliation against project stakeholders who share their views about Bank-financed projects. Table 2: SEP Summary Table Topic of Project stage Target stakeholders consultation / Method used Responsibilities Frequency/Timeline message TKYB PIU implementations of Design and Project design and National authorities Office meetings the Project, the risks and 2023 negotiation negotiations effects of the project TKYB PIU to apprise target Written Stakeholder beneficiaries and Design and Beneficiary private information, December 2023- Engagement Plan, communities of project negotiation enterprises electronic January 2024 ESMS documents activities, potential Information environmental and social risks Written TKYB PIU to apprise the information, Industrial Associations Design and Industrial Project design electronic capability to be involved in On-going negotiation Associations documents Information & the TIERP and develop a Consultation methodology to reach out the Meetings final beneficiaries The project explanation, Associations, Design and effectiveness of TKYB PIU collects feedbacks Industrial Online December 2023 negotiation environmental- from the associations Associations social-ohs implementations Non-technical project summary; TKYB PIU to create awareness Design and Beneficiary private press releases, emails and to collect feedback from As needed Implementation enterprises project websites the site and project social media channels Non-technical Written Vulnerable groups project summary; information, (women, youth, TKYB PIU will update TKYB PIU As needed Implementation press releases, electronic children, disabled website for project related Stage project websites Information etc.) potential direct information and project social beneficiaries media channels Written Project information, Semiannual TKYB implementation TKYB PIU to report project Implementation WB electronic office, Video progress with key implementation progress Information, Conferences indicators meetings 9 4.3. Proposed strategy to incorporate the views of vulnerable groups The project will seek the views of women, youth, children, refugees, and disabled through the following methods. The details of strategies adopted to engage and communicate to vulnerable groups effectively will be considered during project implementation. Mechanisms to be considered may include (but not limited to) (i) women: ensure that community engagement teams are gender-balanced and promote women’s leadership within these, design online and in-person surveys and other engagement activities so that women in unpaid care work can participate; consider provisions for childcare, transport, and safety for any in-person community engagement activities; (ii) Pregnant women: develop education materials for pregnant women on basic hygiene practices, infection precautions, and how and where to seek care based on their questions and concerns; (iii) Elderly and people with existing medical conditions: develop information on specific needs and explain why they are at more risk & what measures to take to care for them; tailor messages and make them actionable for particular living conditions (including assisted living facilities), and health status; target family members, health care providers and caregivers; (iii) People with disabilities: provide information in accessible formats, like braille, large print; offer multiple forms of communication, such as text captioning or signed videos, text captioning for hearing impaired, online materials for people who use assistive technology; and (iv) Children: design information and communication materials in a child-friendly manner & provide parents with skills to handle their own anxieties and help manage those in their children. 5. Resources and Responsibilities for implementing stakeholder engagement 5.1. Implementation Arrangements and Resources The TKYB will be in charge of stakeholder engagement activities. The entities responsible for carrying out stakeholder engagement activities will be established within TKYB, with the involvement of full-time dedicated staff from various departments. The overall responsibility for SEP implementation lies with the Project Implementation Unit (PIU) director. The project’s stakeholder engagement implementation arrangements are as follows: Actor/Stakeholder Responsibilities Planning and implementation of the SEP Leading stakeholder engagement activities with development partners, the private sector and coordination on resolution of grievances TKYB PIU Monitoring of and reporting on environmental and social performance to the World Bank Consolidated reporting on SEP activities for the project overall Make available the disclosed ESMS documents The stakeholder engagement activities will be documented through; Depending on level of finance (direct finance by TKYB) the stakeholder engagement activities will be monitored by TKYB PIU. TKYB PIU will track the progress of the SEP as well as the feedback and grievances received. All records related with the SEP activities at Project level will be reported to TKYB regularly with other project progress information. All project engagement records including GRM specific information will be kept by TKYB PIU. 10 6. Grievance Mechanism A Grievance Mechanism is a system that allows not only grievances, but also queries, suggestions, positive feedback, and concerns of project-affected parties related to the environmental and social performance of a project to be submitted and responded to in a timely manner. 6.1. Description of Grievance Mechanism (GM) TKYB has online communication and project GRM in place and approved policy documents to regulate and address grievances for all project stakeholders including its employees. A new procedure called “Grievance Redress Mechanism for IFIs financed projects” has been introduced recently. In line with the requirements of ESS.10 (Stakeholder Engagement and Information Disclosure), the project specific grievance mechanisms will be open to the use of all stakeholders and it can be used to deliver any possible message, complaint and/or suggestion by any stakeholder via TKYB corporate website and other channels defined in the mechanism. In the context of the Project, we are expecting to receive any kind of feedbacks from final beneficiary SMEs, LEs and also Project Affected Parties (PAPs) who may be impacted from the project; and other interested parties who may have an interest in the project (Figure 2). In line with the requirements of ESS.2 (Labor and Working Conditions), TKYB has an internal employee grievance mechanism and procedure for its employees. On the intranet page of TKYB, employees are able to submit their grievances from the notification menu, which may be related to 1. Ethics, 2. Whistle-blowing,3. Suspicious transactions, 4. Complaints and suggestions. Each grievance will be processed according to internal employee grievance procedure, which can be directed to the CEO in case of ethics related grievances; to the Board of Auditors in case of whistle- blowing related grievances; to the Compliance Officer (Head of Internal Control and Compliance department) in case of suspicious transactions related grievances and to human resources department in case of other complaints and suggestions (Figure 3). If there are any non-staff project workers/consultants hired for specifically for this project, they will also be informed about the internal employee grievance mechanism at the time of recruitment and will be provided subject specific e-mail addresses for ethics and whistle-blowing related grievances. They will also be able to use the project GRM for their general complaints and suggestions. The GRM’s steps are explained below; 4 Example of GRM process: Step 1: Submission of grievances Step 2: Recording of grievance Step 3: Investigating the grievance and preparing the draft response Step 4: Complainant Response within 30 days GRM process for project stakeholders: The GRM for all project stakeholders is accessible via TKYB’s official website and aims to collect and address grievances of TKYB’s clients and all other stakeholders. The responsible body 11 governing this grievance process is TKYB’s Internal Control and Compliance Department, which reports directly to the Audit Committee of the Bank. All inquiries/grievances received are directed to the Internal Control and Compliance Department where the relevant inquiry/grievance is reviewed by them and directed to the relevant responsible department to be responded maximum within 30 days unless any other time period is required legally. For the project GRM, all project related grievances that are directed to relevant departments by Internal Control and Compliance department, will also be reported to TKYB PIU for project information and reporting purposes. The GRM Forms are available both in Turkish and English; English link: https://kalkinma.com.tr/en/contact-us/contact-information Turkish link: https://kalkinma.com.tr/tr/bize-ulasin/iletisim-bilgileri As this GRM is a part of the regulatory framework applied by Banking Regulation and Supervision Agency of Turkey (regulation on Internal Processes and Internal Capital Adequacy Assessment Process) all banks in Turkey, are subject to this regulation. Thus, TKYBs PIU is expected to have similar functioning GRMs in place. The project GRM will utilize existing grievance channels of TKYB, but will also be improved through adjustments to collect, manage and monitor project specific grievances. If any of the selected projects is missing some features of this GRM, they will be asked to upgrade and improve their GRM to match the requirements of ESS10 and as specified in the SEP and Project Operational Manual (POM). The project PIU will be the designated department for reporting all project related inquiries that will be directed and shared by Internal Control and Compliance Department and will simultaneously keep the records and reports of all grievances. PIU will be informed in each of these cases: • Submission and recording of project related grievance • Preparation of draft response by relevant department • Approval of legal opinion • Completion of complainant response Internal Control and Compliance Department documents the actions and counter actions taken, and the responses provided to the applicant/complainant, including for project grievances and report to Audit Committee, Board of Internal Auditors and CEO on a monthly basis. These monthly reports related to project grievances will be shared with TKYB PIU for project reporting purposes. Project GRM will be used to submit complaints related to the overall management and implementation of the project, including: violation of project policies, guidelines, or procedures, including those related to child labor, health and safety of workers, work place harassment (mobbing, sexual harassment etc.). The GRM will also allow submission of anonymous grievances. The attached grievance form in Annex 1 will be utilized in the project and allow submission of anonymous grievances. Step 1: Submission of grievances Existing GRM has four different channels to receive grievances: • Complaint form: By filling complaint form 12 (https://kalkinma.com.tr/en/contact-us/contactinformation) • Fax: By sending fax through +90 (216) 6301815-0216 6346145 • E-mail: By sending e-mails to the Bank and staff • Postal mail: By applying to the Bank with a petition In case a compliant would like to submit a grievance via telephone, he/she will be directed to fill in the compliant form on the website. Complainant can also categorize the grievance by project name (When it is applicable as World Bank Türkiye Industrial Emission Reduction Project or others) via a drop-down menu in complainant form. When the grievance form is completed with the subject and other information required, it is delivered to Internal Control and Compliance Department to be recorded, classified and communicated with other relevant departments to be responded. All grievances regardless of the channel received must be delivered to Internal Control and Compliance department and recorded in the same day of receipt. In addition to the project specific TKYB GRM, the national grievance mechanism will be one of the tools that the project GRM will feed from. TKYB may receive formal requests and grievances through the Presidential Communication Center (CIMER) on different types of complaints related to the project. In practice, CIMER (Phone: 150, web: https://www.cimer.gov.tr/) is only available to Turkish citizens. However, project GRM will also utilize a second national level tool namely YIMER (Foreigners Communication Center) to collect grievances from foreigners including refugees. YIMER (Phone: 157, web: http://yimer.gov.tr ) which also serves on a 7 day/24 hours basis, is freely accessible in six languages including, Turkish, Russian, Arabic, Farsi, German, and English. Project related grievances received through CIMER and YIMER will also be recorded by designated staff in TKYB PIU to timely inform the project on taking corrective actions. Both CIMER and YIMER will complement project GRM throughout project life. Project related grievances received through CIMER and YIMER will also be recorded by Internal Control and Compliance department and processed similarly with project GRM. CIMER and YIMER will complement project GRM throughout project life. Step 2: Recording of grievance Once a grievance is received, the Internal Control and Compliance Department is responsible for recording, directing, ensuring and controlling those grievances are replied within required time periods and reporting the analysis of grievances in terms of category and quantity to the Audit Committee and CEO. In the cases of project related grievances, these reports will be shared with TKYB PIU on a monthly basis. Internal Control and Compliance Department will also inform PIU about each recording of project related grievance at the same day of submission. Step 3: Investigating the grievance and preparing the draft response Once the project-specific grievances directed from Internal Control and Compliance Department to the related department and TKYB PIU, the related department is responsible for preparing a draft response letter and inform Internal Control and Compliance Department and PIU. Before preparing the draft response, related department will communicate the initial response informing about the acknowledgement of the submission of the grievance and legal response time. 13 According to TKYB internal regulation for Customer Grievance Management Policy document all responses for customer complaints must be reviewed by the Department of Legal Counselor. The related department prepares the draft response and proceeds to receive legal opinion. Step 4: Complainant response within 30 days The draft response will be reviewed and revised according to legal opinion and all internal approval procedure will be completed before communicating the final response by the related department. The response for the grievance is given from the same channel that the complaint was received. All project-related responses will be answered by related department and PIU will be informed about the response in detail. All grievances should be responded within 30 days provided that the legal period is not exceeded. After all possible redress has been proposed to the complainant, and the complainant is still not satisfied with the proposed resolution, they shall be able to seek the legal recourse by means of judicial system and remedies. Information about the project’s GRM will be publicized as part of the initial feedback consultations in the project and information about the GRM will also be posted online on the TKYB website. Monitoring and Reporting Grievances The TKYB PIU’s GRM focal point, who will also be the Communications and Stakeholder Specialist, will be responsible for all project related grievances: • Analyzing the number, substance and status of complaints and uploading them into the single project • database; • Monitoring outstanding issues and proposing measures to resolve them; • Submitting quarterly reports on GRM mechanisms to the Project Coordinator at the PIU. Semi-annual progress reports to be submitted by the PIU shall include a section related to GRM which provides updated information on the following: • Status of GRM implementation (procedures, training, budgeting etc.), • Qualitative data (gender disaggregated) on number of received grievances / (applications, • suggestions, complaints, requests, positive feedback), • Quantitative data on the type of grievances and responses, issues provided and grievances that • remain unresolved, • Level of satisfaction by the measures (response) taken, • Any correction measures taken. Results will be posted on the TKYB website. 14 Figure 2: Project GRM for Stakeholders (project-affected & other interested parties) in line with ESS.10 Figure 3: GRM Process for Project Workers (employees and non-staff project workers in line with ESS.2) The World Bank Grievance Redress System Communities and individuals who believe that they are adversely affected by a World Bank (WB) supported project may submit complaints to existing project-level grievance redress mechanisms or the WB’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in order to address project-related concerns. Project affected communities and individuals may submit their complaint to the WB’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB non-compliance with its policies and procedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank’s attention, and Bank Management has been given an opportunity to respond. For information on how to submit complaints to the World Bank’s corporate Grievance Redress Service (GRS), please visit http://www.worldbank.org/en/projects-operations/products-and-services/grievance- redressservice. For information on how to submit complaints to the World Bank Inspection Panel, please visit www.inspectionpanel.org. 15 The Sexual Exploitation and Abuse/Sexual Harassment complaints will be safely and ethically received and managed, through the different stages of the GM. This issue is already integrated into TKYB’s HR Policy and it supports by the laws. This topic follows efficiently in general, one of the important topics for TKYB and Republic of Türkiye. 7. Monitoring and Reporting 7.1. Summary of how SEP will be monitored and reported upon (including indicators) The SEP will be monitored based on both qualitative reporting (based on progress reports) and quantitative reporting linked to results indicators on stakeholder engagement and grievance performance. SEP reporting will include the following: (i) Progress reporting on the ESS10-Stakeholder Engagement commitments under the Environmental and Social Commitment Plan (ESCP) (ii) Cumulative qualitative reporting on the feedback received during SEP activities, in particular (a) issues that have been raised that can be addressed through changes in project scope and design, and reflected in the basic documentation such as the Project Appraisal Document, Environmental and Social Assessment, Indigenous Peoples Plan, or SEA/SH Action Plan, if needed; (b) issues that have been raised and can be addressed during project implementation; (c) issues that have been raised that are beyond the scope of the project and are better addressed through alternative projects, programs or initiatives; and (d) issues that cannot be addressed by the project due to technical, jurisdictional or excessive cost-associated reasons. Minutes of meetings summarizing the views of the attendees can also be annexed to the monitoring reports. (iii) Quantitative reporting based on the indicators included in the SEP. An illustrative set of indicators for monitoring and reporting is included in Annex 2. 7.2. Reporting back to stakeholder groups The SEP will be revised and updated as necessary during project implementation. Once in a year summaries and internal reports on public grievances, enquiries, and related incidents, together with the status of implementation of associated corrective/preventative actions will be collated by responsible staff and referred to the project managers. Specific mechanisms to report back to the stakeholders include the following e-mail, phone, face- to-face, and other related ways have been/will be consulted. This reporting back to the stakeholders will be Once in a year of such reporting. 16 ANNEXES Annex 1. Template to capture minutes/records of consultation meetings Annex 2. Sample Table: Monitoring and Reporting on the SEP Annex 3. Photos from the Stakeholder Meetings Annex 4. Sample Grievance Form and Grievance Closeout Form 17 Annex 1: Template to Capture Consultation Minutes Stakeholder Response of Project Summary of Feedback Follow-up Action/Next Steps (Group or Individual) Implementation Team The project will create job The current issues causing the most opportunity, and will made an Turkish Foundry Periodically communication difficulties are; Human Resources (a advertisement of the project. will be conduct about the Manufacturers significant loss of workers due to EYT). The project will be about the situation of Project. Also, the Association There are deficiencies in automation. Emission Reduction, the other feedback will be collected. There is a need for digitization issues can be implement into the project. Due to being a member of European Aluminium and its international initiatives, emphasis is placed on and developed in TIER Project will supply a Periodically communication Turkish Aluminum various topics. national and international will be conduct about the Industrialists Carbon calculations are being conducted by selecting pilot companies. environmental & social situation of Project. Also, the Association It is stated that comments cannot be made on standarts to the Companies. feedback will be collected. social issues, but the importance of the issue may increase with legal processes. Most of the companies within their structure are knowledgeable about carbon reduction. The companies will have an Informative training sessions are organized, opportunity to learn, Turkish Cement Periodically communication and despite prejudices, the sector is experience the international Industrialists will be conduct about the proactive in addressing these issues. standarts. Association Many companies publish sustainability situation of Project. Also, the Also, the project will be an reports, indicating readiness for the feedback will be collected. opportunity as a traning for implementation of environmental-social the companies. issues. The association's activities were explained, and there are companies within the organization contributing to emission The companies will have an reduction. All Waste and opportunity to learn, Periodically communication There is no such obligation for suppliers, but experience the international Environmental when working with global companies, will be conduct about the standarts. Management emission reduction becomes a topic. situation of Project. Also, the The emission reduction will Association Training sessions and workshops are feedback will be collected. be more important topic with organized on environmental, social, and the project. occupational health and safety issues. It was mentioned that members comply with ISO standards and are certified. Within the scope of the DIES Project, the 2nd Workshop for the preparation of the Ministry of "Draft National Action Plan Environment, for Determining Turkey's The feedbacks are collected, Urbanization and Emission Strategy" was held There is no require a action. Climate Change with the theme of Preparing the National Action Plan for Green Transformation in Industry. 18 Annex 2. Sample Table: Monitoring and Reporting on the SEP Key evaluation questions Specific Evaluation questions Potential Indicators Data Collection Methods GRM. To what extent have • Is project affected parties raising • Usage of GM and/or feedback Records from the project-affected parties been issues and grievances? mechanisms implementing agency and provided with accessible and • How quickly/effectively are the • Requests for information from other relevant agencies inclusive means to raise grievances resolved? relevant agencies. issues and grievances? Has • Use of suggestion boxes placed in the implementing agency the villages/project communities. responded to and managed • Number of grievances raised by such grievances? workers, disaggregated by gender of workers and worksite, resolved within a specified time frame. • Number of Sexual Exploitation, and Abuse/Sexual Harassment (SEA/SH) cases reported in the project areas, which were referred for health, social, legal and security support according to the referral process in place. (if applicable) • Number of grievances that have been (i) opened, (ii) opened for more than 30 days, (iii) resolved, (iv) closed, and (v) number of responses that satisfied the complainants, during the reporting period disaggregated by category of grievance, gender, age, and location of complainant. Stakeholder engagement • Was there interest and support for the • Active participation of stakeholders Stakeholder Consultation impact on project design and project? in activities Attendance Sheets/Minutes implementation. • Were there any adjustments made • Number of actions taken in a timely How have engagement during project design and manner in response to feedback Evaluation forms activities made a difference implementation based on the received during consultation in project design and feedback received? sessions with project affected Structured surveys implementation? • Was priority information disclosed to parties. relevant parties throughout the • Number of consultation meetings Social media/traditional project cycle? and public discussions where the media entries on the project feedback and recommendation results received is reflected in project design and implementation. • Number of disaggregated engagement sessions held, focused on at-risk groups in the project. Implementation • Were the activities implemented as • Percentage of SEP activities Communication Strategy effectiveness. Were planned? Why or why not? implemented. (Consultation Schedule) stakeholder engagement • Was the stakeholder engagement • Key barriers to participation activities effective in approach inclusive of disaggregated identified with stakeholder Periodic Focus Group implementation? groups? Why or why not? representatives. Discussions • Number of adjustments made in the stakeholder engagement approach Face-to-face meetings, online to improve projects’ outreach, meetings and/or Focus Group inclusion and effectiveness. discussions with Vulnerable Groups or their representatives 19 Annex 3. Photos from the Stakeholder Meetings 20 21 22 Annex 4. Sample Grievance Form and Grievance Closeout Form 23 24