THE REPUBLIC OF TÜRKIYE TSKB STAKEHOLDER ENGAGEMENT PLAN FOR A GREEN FINANCE PROJECT Draft 12.06.2023 1 Table of Content 1. Introduction............................................................................................................................................... 4 1.1. Context ............................................................................................................................................... 4 1.2. Project Description ............................................................................................................................. 5 1.2.1. About TSKB .................................................................................................................................. 7 1.2.2 About Maxis Private Equity Portfolio Management A.Ş. ............................................................. 9 1.2.3. About Fund Management ........................................................................................................... 9 2. Regulations and Requirements ............................................................................................................... 12 2.1. National Legislation .......................................................................................................................... 12 2.1.1 Constitution of Republic of Türkiye ............................................................................................ 12 2.1.2 Law No. 4982 - Law on the Right to Information, Official Gazette No. 25269 (24.10.2003) ..... 12 2.1.3 The Law on Use of the Right to Petition ..................................................................................... 13 2.1.4 The Environmental Impact Assessment Regulation, Official Gazette No. 31907 (29.07.2022) . 13 2.1.5 Participatory Planning Approach in Türkiye ............................................................................... 13 2.2 International Legislation for Stakeholder Engagement .................................................................... 14 2.2.1 Human Rights ............................................................................................................................. 14 2.2.2 World Bank Requirements ......................................................................................................... 14 3. Brief Summary of Previous Stakeholder Engagement Activities ............................................................. 15 3.1 Key Stakeholder Meetings and Consultations................................................................................... 15 4. Stakeholder Identification and Analysis .................................................................................................. 16 5. Stakeholder Engagement Program ......................................................................................................... 18 5.1. Stakeholder Engagement Methodologies ........................................................................................ 18 5.2. Future Phases of Stakeholder Engagement ..................................................................................... 20 6. Grievance Redress Mechanism ............................................................................................................... 24 7. Management, Monitoring and Reporting ............................................................................................... 27 2 List of Tables Table 1 Previous stakeholder Engagement Activities ................................................................................ 15 Table 2 Identification of Stakeholders ........................................................................................................ 16 Table 3 Level of Interest .............................................................................................................................. 17 Table 4 Stakeholder Engagement Methods ................................................................................................ 19 Table 5 Stakeholder Engagement Program ................................................................................................. 21 Table 6 Budget for Operational Expenses of SEP…………………………………………………………………………………….24 List of Figures Figure 1 Indicative Fund Structure ................................................................................................................ 5 3 1. Introduction The primary project development objective is to support the greening of firms through equity financing and mobilized private capital which will be achieved by providing accessible and affordable long-term financing fund. Türkiye Green Fund (hereinafter referred to as “TGF� and “Project�) is capitalized by the collaboration of IBRD and TSKB. The initial size of Project is estimated at US$300 million in the first phase, with the IBRD contribution at most half of that. One of the mandatory documents to be prepared for Project is the Stakeholder Engagement Plan (SEP) which has been prepared in accordance with the relevant national legislation, the Environmental and Social Standard (ESS) 1 and 10 of the World Bank Environmental and Social Framework (ESF) and the relevant Good International Industry Practice (GIIP). 1.1. Context TGF’s objective is to support investments in innovative greening firms, i.e., firms that are already green or genuinely decarbonizing, and promote greening of the private equity industry through establishing a demonstration green fund in Türkiye. The Fund will have a double bottom line mandate, with non- concessional returns and sustainable impact maximization. Support for the establishment of TGF should be considered as a pilot project aimed at (i) proving commercial viability and crowding in private capital for green private equity investments, (ii) scaling up the private equity industry and therewith contributing to lowering high corporate leverage and diversifying the financial sector, and (iii) ultimately creating a market for the private sector to take over eventually. As such, TGF lends itself to explore opportunities for collaboration with IFC and other IFIs and DFIs, in addition to institutional and private investors, who may be interested in partly supporting capitalization of such a fund or in making co-investment with the fund at deal level or sub-fund level. The Project aims to support (i) firms’ decarbonization and investments in green technologies, (ii) development of the Private Equity (PE) industry through a demonstration green fund, (iii) financial sector diversification and development of firms’ access to diversified sources of long-term finance, (iv) lowering high corporate leverage, and (v) accelerate financing for the green transition and enhanced climate action. The idea is to pioneer green private equity investments and encourage local corporate green debt market development, therewith enhancing local green and climate investment capacity and creating markets for private players so that the private sector can take over eventually. By doing so, the project will ultimately support the transition to a low-carbon and climate-resilient economy, contribute to financial sector diversification and support the development of domestic sources of long-term finance and capital markets. TSKB will be the borrower and implementing entity for IBRD funds, with a sovereign guarantee, and will use those funds to inject capital into TGF (Figure 1). The reason for choosing TSKB as the implementing entity for TGF is that the sponsor (founder) of TGF needs to have strong credibility in the market. A direct government investment would be suboptimal as the PE (Private Equity) Fund would be perceived as government controlled. TSKB has the highest credibility in the market and the strongest implementation capacity out of all potential options. 4 Sovereign MoTF guarantee IBRD [USD] loan On balance sheet TSKB Fund investment Fund (USD) investments Turkish or Manages (USD) Türkiye Green Fund international Investment Fund Manager investors Equity investments (minority stakes, TRY) Equity co- investments (TRY) Other PE funds, corporates Firms/ Sub- or/and equity injections of the funds existing shareholders Figure 1 Indicative Fund Structure 1.2. Project Description Türkiye Green Fund proposes to finance and support green and/or greening firms through equity financing and mobilized private capital. Companies that are adopted systematic green investment strategies to align with the basis of Turkish Green Taxonomy expected to be entered into force in the upcoming years will be considered eligible as investee enterprise. More specifically Green and Greening Firms can be defined as follows; Green (Greentech) firms refer to any enterprise or project based SPVs established to develop or invest in activities that contribute to low energy intensity production, reduction in GHG emissions by developing renewable energy PPs or decreasing utilization of non-renewable sources, circular economy practices to reduce their or their stakeholders’ natural resource utilization, reduction in air, soil and water pollution and more efficient and sustainable use of natural resources. 5 Green firms’ activities can be listed as follows; ▪ Generation of renewable energy sources, including onshore and offshore wind power plants, utility-scale and decentralized solar photovoltaic (PV) plants, hybrid solutions (e.g., floating solar, combined solar and wind), biogas or biomass, and associated technology solutions such as battery energy storage systems (BESS), ▪ Climate Industries, manufacturing activities that contribute to the supply of goods and services that align with the country’s CM and CA goals. Eligible industries may include, among other, e- mobility (e.g., electric vehicle charging infrastructure and manufacturing), RES technology (e.g., solar panel, inverters, trackers, wind turbines, BESS), grid technologies (e.g., smart meters, smart grids), clean hydrogen, low carbon technologies, low-carbon footprint food producers (e.g., products with lower footprints that can be substitutional to the high carbon footprint foods.etc. ▪ Circular economy adopted companies, applying production technologies and processes to substantially contribute to the elimination of waste and pollution and facilitate recirculation of products and materials at their highest value and producing eco-efficient products to substantially contribute to the regeneration of nature, including companies reusing their own waste and/or other sector company wastes, water-efficient fixture manufacturers, high energy electric motors producers, etc. ▪ Green Service Companies, Consulting services, Project operation management, Project evaluation, audit, and verification, Monitoring and testing services, Technical product certification and promotion including ESCOs, RESCOs, waste management companies, etc. Green-tech companies reducing the emissions by giving services along with the digital platforms including shared vehicle companies, sharing economy companies etc., Greening firms refer to any company in any sector which have/plan to have concrete decarbonization plans, environmentally and socially sustainable practices to increase their competitiveness and maintain their growth potential. These firms can either be high GHG emitters or adopters of industrial good practices in order to compete and extend their market. These companies’ policies and investments will support them to decarbonize their activities, mitigate and adapt to climate change impacts, implement circular economy practices and address environmental issues. Furthermore, through this approach, they can cope with physical and transitional risks easily. Greening firms may include but not limited to: ▪ Energy efficiency at facility level, that shall be demonstrated by the comparison of product specific energy consumption values with the national and/or international sector values. National and/or internationally known green building certifications for the construction and tourism sector companies. ▪ Industrial companies which already measure emissions in compliance with ISO 14064 and/or have solid plans to set targets such as utilizing renewable energy sources to reduce scope 2 emissions, developing decarbonization plans to decrease scope-1 emissions. ▪ Companies having high water-intensity processes that assess water footprint through ISO 14046 or relevant standards and intend to promote resource efficiency and adaptation of circular economy principles. ▪ Enterprises producing environmental benefits, decreasing environmental costs, improving management capacity through establishment of ISO-based management system, and reducing environmental risks for the purpose of improving corporate environmental performance. 6 ▪ Companies with ambitious targets to label their products with green product labels such as Environmental Product Declaration (EPD), The Product Environmental Footprint (PEF), EU Ecolabel, the Blue Angel, etc. 1.2.1. About TSKB TSKB is Türkiye’s privately-owned investment and development bank, with a strong focus on sustainable development objectives. The bank was established in 1950 with the support of the World Bank and the Central Bank of Türkiye and commercial banks. TSKB supports Türkiye’s sustainable growth with a broad array of corporate banking, investment banking, and advisory services provided to the customers as first- and second-tier lender. TSKB focuses on creating value for the inclusive and sustainable development of Türkiye through its financing and consultancy solutions. TSKB started its sustainability journey in 1980s with environmental factors being integrated in loan evaluation processes. In the 1990s, the first environmental loan was offered to the industry and in the 2000s, TSKB started project financing in the field of renewable energy. In the environment and renewable energy sectors, the bank ranks as number one in terms of number of projects financed in Türkiye. It is also the leading bank in Türkiye in promoting new initiatives for scaling up green finance as well as in establishing governance arrangements and developing methodologies for climate-related and environmental risks. TSKB is majority-owned by Isbank Group. TSKB is 51.4 percent owned by Turkiye Is Bankasi A.S. Group, 8.4 percent by Turkiye Vakiflar Bankasi T.A.O, with the remainder owned by other institutions and individuals quoted in Borsa Istanbul. TSKB is the 12th largest bank and the largest development bank by shareholders equity in Türkiye as of 2022Q3. The loans-to-assets ratio stood at 69.7 percent at 2020Q3. Total assets grew by 29 percent in the first 9 months of 2022 from TL 84.1 billion to TL 108.3 billion (USD 5.9 billion), with loan growth at 18 percent (8.9 percent decline in FX-adjusted terms). TSKB only lends to private companies. The loan portfolio distribution by leading sector includes electricity generation (42.7 percent – of which 93 percent renewable), financial institutions (8.2 percent), energy distribution (5.6 percent), tourism (5.5 percent), metal and machinery (7 percent). As a privately-owned development and investment bank, TSKB has a unique status in Türkiye’s financial system. TSKB is fully wholesale funded and does not have a deposit-taking license. TSKB funds its operations through IFIs funding, external loans, and capital market transactions. TSKB has been providing investment loans and funding projects in areas of strategic importance to the authorities, although the bank has been diversifying its operations. Most of its borrowings are in foreign currency, matching its loan book, and borrowings are predominantly long-term. TSKB’s rating was downgraded to B- from B by Fitch Ratings in July 2022. Fitch downgraded the ratings of 25 banks simultaneously, following the downgrade of the sovereign rating to B with a negative outlook. The downgrade reflects heightened operating environment risks, including exchange rate volatility, high inflation, and weak monetary policy credibility. In 2021, 100 percent of international borrowing was ESG-focused. In addition, TSKB is listed on Borsa Istanbul, with a market value reaching US$756 million on 16 December 2022. TSKB is a market leader for green/ sustainable finance in Türkiye, with the share of SDG-linked loans close to 93 percent of total loans. TSKB adopted a Sustainability Policy in 2012 (updated in 2022), a Climate Change Mitigation and Adaptation Policy in 2021, and integrated climate-related and environmental considerations into its governance arrangements. Under the policies, TSKB committed to consider mitigation and adaptation to climate change in all its activities and internal operations. TSKB aims to have more than 90 percent share of SDG-linked loans and a 60 percent share of climate and environment- 7 focused SDG-linked loans in the total portfolio by 2025. For its direct impact, TSKB aims to reduce its scope 1 emissions by 42 percent by 2030, and by 63 percent by 2035. On the governance side, TSKB's organizational structure for sustainability involves the Board of Directors and the Executive Committee and comprises of all employees. The Board of Directors guides the Bank's operations in line with the adopted sustainability strategy. All sustainability work, including coordination of the activities and business plans, is conducted by two main pillars. First, the Sustainability Committee, established in 2014, consists of four Board Members as well as the CEO and three Executive Vice Presidents. The second pillar is the Sustainability Management Committee, chaired by the CEO and led by three Executive Vice Presidents with the head of working groups from various departments that are responsible for rolling out sustainability activities throughout the bank. TSKB also plays an active role in national and international initiatives in the field of sustainability (e.g., UNEP FI, UN Global Compact, Global Reporting Initiative, International Development Finance Club, Konya Climate Council, etc.). TSKB monitors its green portfolio and provides disclosures in line with TCFD. TSKB’s sustainability reporting practice started in 2009 and evolved into integrated reporting in 2016. Since 2018, TSKB illustrates its strategy, targets, performance, value creation scheme and impacts driven by its operations via its Integrated Annual Reports. Given that a national taxonomy is not in place yet, TSKB uses its own taxonomy, with 11 sectors identified for the purpose of loan-tagging and reporting. TSKB identifies impacts and manages risks from own operations via the ISO 14001 Environmental Management System certification. Environmental and social impacts from its lending operations are managed using 'TSKB Environmental and Social Risk Evaluation Tool' (ERET). ERET is an evaluation model that rates projects on the basis of five criteria under 35 separate headings, including evaluation of physical and transition risks that are to be further developed by end-2023. The greenhouse gas emissions and energy and resource efficiency dimensions of the financed projects are also taken into consideration. The results of such evaluations are taken into account in the project assessment, financing, and investment monitoring processes. Customers then take measures to prevent or mitigate environmental and social impacts considered to be negative and draft an Environmental and Social Action Plan when necessary. TSKB is among the Best Banks in the Global Arena with an ESG Risk Rating of “Negligible Level�. Continuing to raise the bar with its Environmental, Social and Governance (ESG) performance every year, TSKB improved its ESG risk rating from 13.6 to 7.9 in 2022. With this rating, TSKB ranked 12th among global development banks, 15th in the global banking sector, and 60th among approximately 15 thousand institutions evaluated by Sustainalytics. TSKB also publicly discloses information on climate-related risks. In 2021, TSKB issued the first TCFD- compliant climate risk report. TSKB broke new ground in Türkiye with its Responsible Sustainability Communication Policy published just before COP27. Within the scope of COP27, the Bank actively participated in panels on climate-related risks and the role of the financial sector in Türkiye, low-carbon economy, gender equality and sustainable infrastructure investments, and shared important information closely related to Türkiye’s sustainability agenda after the summit. TSKB has raised the score of its Climate Change Report, which it has been publishing since 2010 within the framework of the Carbon Disclosure Project (CDP), to leadership level.1 In 2013 and 2015, the Bank was granted the Climate Change Leadership Award by CDP Türkiye, and since 2016 it has maintained its “B� score. The Bank has achieved significant progress with its ambitious targets and decisive steps regarding carbon emissions as of 2022, raising its score to “A-�. TSKB now ranks at the top 21 percent in the world, and among the top Turkish banks. TSKB’s latest CDP report can be found here: https://www.tskb.com.tr/uploads/file/tskb-cdp-climate-change-report- 2022.pdf 8 The first green/sustainable bond in Türkiye was issued by TSKB in 2016. TSKB issued three green/sustainable bonds for the total amount of US$1.05 billion. The first green/sustainable bond issuance was in 2016 for US$300 million, followed by a sustainable subordinated bond issuance in 2017 and another sustainable bond issuance in 2021. Funds obtained through bonds are used to finance green and social projects in line with the Sustainable Finance Framework. TSKB submits an Allocation and Impact Reporting to its investors annually to provide them with an insight into the impacts of the projects financed through the funds from the bond issuances. In addition, TSKB funding includes syndicated loans tied to ESG rating and sustainability performance criteria. In 2022, the syndicated loan was linked to 3 ambitious sustainable KPIs in line with the bank’s medium to long-term targets. TSKB also has a market-leading subsidiary, Escarus, in sustainability assessment area. Escarus is providing services to almost all WB clients in establishing sustainability frameworks and the only domestic independent verifier in this area. 1.2.2 About Maxis Private Equity Portfolio Management A.Ş. Maxis Private Equity Portfolio Management A.Ş. (“Maxis�) was established in 2017 under the Capital Board of Türkiye (“CMB�), has become a leading venture capital and private equity investment firm with its investment team with more than 130 years of combined experience. Assets under Management (“AuM�) of Maxis has reached US$450 million with 8 funds from US$19 million in 2018. In virtue of the experience gained by Isbank Group’s private equity activities, Maxis team has an outstanding reputation and close relations in the Turkish business community and amongst DFIs operating in Türkiye. Maxis team had joint equity investments and credit facility arrangements with IFC, EBRD and FMO. Besides, TSKB has been in a reliable collaboration with the experienced and coherent investment team of Maxis. Considering Maxis’s experience regarding private equity activities and diversified investment areas (green, women entrepreneurs, technology, RE etc.) which are in line with the TGF’s mission and target areas, Maxis has awarded as fund manager partner of TGF Project together with TSKB. 1.2.3. About Fund Management Turkish Green Fund will be the first Green Private Equity Fund in Türkiye. It will be also a customized Private Equity Fund through its unique scope and targeted impact. IBRD will be counting on TSKB for the establishment and origination of TGF and also for the repayment of the associated loan, therefore TSKB has to also undertake the role of General Partner (GP) of the Fund and have a control on the selection and management of the investee enterprises. Maxis will lead legal process of establishment of the Fund and support TSKB in management of the Fund. As a result, an Investment Committee, where duties have been defined for members who will work proactively from TSKB and Maxis will be established to manage the Fund. TSKB and Maxis will have the following responsibilities with the mentioned scopes for these stages stated. • Origination: Mainly TSKB will create the pipeline and assess the target companies with the support of Maxis. • Execution: Mainly Maxis will perform investment and shareholder negotiations, due diligence studies, shareholder agreements, competition authority applications, closing and other related activities with the support of TSKB. • Management: Mainly TSKB, holding a board membership, will monitor and support portfolio companies and conduct other related management activities with the support of Maxis. 9 • Exit: Mainly Maxis will screen exit opportunities, perform exit negotiations and execute exit procedures with the support of TSKB. 1.2.3.1. Purpose and Scope of SEP The overall purpose of this SEP is to ensure that a consistent, comprehensive and coordinated approach is taken to stakeholder engagement and information disclosure throughout the Project. It is further intended to demonstrate the commitment of the TSKB and Maxis, as main implementing parties of TGF, to an ‘international best practice’ approach to engagement. In line with current international best practice, this SEP aims to ensure that stakeholder engagement is conducted on the basis of timely, accurate, and accessible information. In this way, the SEP seeks to ensure that honest relationship is built between the Fund and investors and green and greening companies are supported by the introduction in green markets. The main objectives of the development and implementation of the SEP for the Project are outlined below: • Identify relevant stakeholders and categorize individuals or organizations that may affect and also be affected by the Project. • Defining the engagement responsibilities of TSKB, Maxis and investee enterprises at different stages. • Distribute accurate Project information in an open and transparent manner. Information should allow affected parties to develop an understanding of potential impacts, risks and benefits of the Fund. The point of effective engagement is not simply to relay information to affected stakeholders, but engage them in a communication process that will identify their interests, expectations, concerns and fears. • Develop relationships of trust between the Fund and stakeholders to contribute to proactive interactions and avoid where possible, unnecessary conflicts based on rumor and misinformation. • Record and address received concerns, issues and suggestions to allow the rationale for investment decisions to be traced and understood. • Identify the most effective tools, methods, timing and structures through which to share project information, and to ensure regular, accessible, transparent and appropriate consultation. • Define reporting and monitoring measures to ensure the effectiveness of the SEP and periodical reviews of the SEP based on findings. Since TGF is at the development stage, this SEP has been prepared only for the Fund management. Stakeholder engagement activities for investee enterprises and their subprojects will be defined in the TGF’s Environmental and Social Management System (ESMS), which will be developed after approval of the Project. Mentioned sub-projects’ SEPs shall be clear and concise and focus on describing the sub-project and identifying its stakeholders. It is key to identify what information will be in the public domain, in what languages, and where it will be located. It should explain the opportunities for public consultation, provide a deadline for comments, and explain how people will be notified of new information or opportunities for comment. It should explain how comments will be assessed and taken into account. The SEP also needs to take into account special provisions for any disadvantaged and vulnerable groups. It should also describe 10 the sub-project’s grievance mechanism and how to access this mechanism. The SEP should also commit to releasing routine information on the sub-project’s environmental and social performance, including opportunities for consultation and how grievances will be managed. Key SEP objectives and activities expected from sub-project SEP is given below: SEP Objectives: • Identify relevant stakeholders, • Familiarize the stakeholders with the Project, • Fulfil national and international requirements for consultation, • Record and address stakeholder concerns, issues and suggestions. SEP Activities: • Develop and implement and regularly update SEP, • Maintain regular engagement with stakeholders, • Develop, disseminate and implement grievance management procedure, • Maintaining ongoing relationship with Project workers and NGOs, • Regular reporting to stakeholders. This SEP is a “living� document that will be regularly reviewed with the results of stakeholder engagement activities carried out by the Project. Similarly, as new stakeholders are identified, the list of stakeholders will also be updated by TSKB. The Stakeholder Engagement Program will be adapted to the Project evolution and will reflect any significant change in the Project design or execution. When (i) more details become available on stakeholder preferred means of engagement; (ii) more resources are needed for implementing this SEP; (iii) responsibilities for implementation of this SEP change or are delegate; and (iv) new stakeholders are identified for the Project, this SEP needs to be updated. This SEP is intended to cover the broad range of engagement activities required for the TGF and is going to be supported by the following documents: - Environmental and Social Commitment Plan - Environmental and Social Management System 11 2. Regulations and Requirements 2.1. National Legislation 2.1.1 Constitution of Republic of Türkiye Stakeholder engagement is secured by the Constitution of the Republic of Türkiye. The Constitution contains provisions that ensure that people can freely express their views. Article 10 of the Constitution of the Republic of Türkiye is the article “Equality before the law". According to this article, “Everyone is equal before the law regardless of distinction as to language, race, color, sex, political opinion, philosophical belief, religion or any similar reasons. Men and women have equal rights which are the obligation to be ensured exist in practice by the government. Measures taken for this purpose shall not be interpreted as contrary to the principle of equality.� Article 25 of the Constitution of the Republic of Türkiye is the article "Freedom of thought and opinion". According to this article, “Everyone has the freedom of thought and opinion. No one shall be compelled to reveal his/her thoughts and opinions for any reason or purpose; nor shall anyone be blamed or accused because of his/her thoughts and opinions.� As emphasized by the "Freedom to Explain and Spread Thought (Article 26 of the Constitution of the Republic of Türkiye)"; everyone has the right to express and disseminate their thoughts and opinions individually or collectively by word, text, picture or other means. This article also covers the freedom to receive or impart information or ideas without the intervention of the official authorities. At the same time, everyone has the "Right of petition, Right to Information and Appeal to the Ombudsperson� (Article 74 of the Constitution of the Republic of Türkiye). Accordingly, ““Citizens and foreigners resident in Türkiye, with the condition of observing the principle of reciprocity, have the right to apply in writing to the competent authorities and to the Grand National Assembly of Türkiye with regard to the requests and complaints concerning themselves or the public. The result of the application concerning himself/herself shall be made known to the petitioner in writing without delay. Everyone has the right to obtain information and appeal to the Ombudsperson. The Institution of the Ombudsperson established under the Grand National Assembly of Türkiye examines complaints on the functioning of the administration1.� 2.1.2 Law No. 4982 - Law on the Right to Information, Official Gazette No. 25269 (24.10.2003) Law on the Right to Information No.4982 (Official Gazette dated 24.10.2003 and numbered 25269) defines the process concerning the right to information. The purpose of this law is to regulate the procedure and basis of the right to information in accordance with the principles of equality, impartiality and openness, which are the requirements of a democratic and transparent government. According to the obligation to provide information (Article5), institutions and organizations are required to take necessary administrative and technical measures for all kinds of information and documents, considering the exceptions set out in this law, to provide information to applicants; and to evaluate and decide on applications promptly, effectively and correctly. 12 2.1.3 The Law on Use of the Right to Petition Citizens of the Turkish Republic are entitled to apply Turkish Grand National Assembly and the public authorities by written petition, in respect to their requests and complaints, in accordance with the Article 3 of the Law on Use of the Right to Petition (Official Gazette dated 01.11.1984 and numbered 3071). On the condition of reciprocity and using Turkish language in their petitions, foreigners residing in Türkiye are entitled to enjoy this right. 2.1.4 The Environmental Impact Assessment Regulation, Official Gazette No. 31907 (29.07.2022) Article 9 - Public consultation and participation meeting: “1) In order to inform the investing public, to get their opinions and suggestions regarding the project; Public Participation Meeting will be accomplished on the date given by Ministry and Ministry qualification given institution / organization and project owners as well as the participants of the project affected community will be expected to attend in a central location determined by the Governor. a) The competency issued institutions / organizations by the Ministry will publish the meeting date, time and place through widely published newspaper at least ten (10) calendar days before the determined date for the PPM. b) Public Participation meeting will be held under the Director of Environment or through Urbanization or authorized chairman. The meeting will inform the public regarding the project, receive views, questions and suggestions. The Director may seek written opinions from the participants. Minutes of meeting will be sent to Ministry, with one copy kept for the Governorship records. 2) Governorship will announce the schedule and contact information regarding for the public opinion and suggestions. Comments received from the public will be submitted to Commission as per the schedule. 3) Members of Commission may review the Project implementation area before the scoping process, also may attend to public participation meeting on the date announced. 4) The competency issued institutions / organizations by the Ministry could provide studies as brochures, surveys and seminars or through internet in order to inform the public before the Public Participation Meeting.� 2.1.5 Participatory Planning Approach in Türkiye Within the context of the Public Financial Management and Control Law No. 5018, under the heading of “Strategic planning and performance-based budgeting� it is stated that: “Article 9- Public administrations; They prepare a strategic plan with participatory methods in order to create their future missions and visions within the framework of development plans, programs, relevant legislation and the basic principles they adopt, to determine strategic goals and measurable targets, to measure their performance in line with the predetermined indicators, and to monitor and evaluate this process.� Moreover, Strategy and Budget Department of the Presidency prepares and shares manuals on guidelines for the strategic planning process that public administrations have to implement. One of these guides is about the principles of participation. The principles of participation document are a best practice guide for those who design, implement and manage participatory work. The Ministry of Industry and Technology 13 acts under the guidance of these guides in large-scale projects and works that require corporate strategic planning and participation. 2.2 International Legislation for Stakeholder Engagement 2.2.1 Human Rights The Universal Declaration of Human Rights is a declaration in which the fundamental rights and freedoms of women, men and children are determined and guaranteed. The declaration also provides general definitions of economic, social and cultural rights as well as civil and political rights. The first Article of the Declaration is "All human beings are born free and equal in dignity and rights. They are endowed with reason and conscience, they should treat each other with a sense of brotherhood." and all Articles address fundamental, cultural, economic, political and social rights of people all over the world. The Declaration, along with the International Covenant of Economic, Social and Cultural Rights, International Covenant on Civil and Political Rights and Optional Protocols constitute the International Human Rights Law. 2.2.2 World Bank Requirements The World Bank’s Environmental and Social Framework (ESF)’s Environmental and Social Standard (ESS) 10, “Stakeholder Engagement and Information Disclosure�, recognizes “the importance of open and transparent engagement between the Borrower and project stakeholders as an essential element of good international practice� (World Bank, 2017: 97). Specifically, the requirements set out by ESS10 are the following: Borrowers will engage with stakeholders throughout the project life cycle, commencing such engagement as early as possible in the project development process and in a timeframe that enables meaningful consultations with stakeholders on project design. The nature, scope and frequency of stakeholder engagement will be proportionate to the nature and scale of the project and its potential risks and impacts. Borrowers will engage in meaningful consultations with all stakeholders. Borrowers will provide stakeholders with timely, relevant, understandable and accessible information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. The process of stakeholder engagement will involve the following, as set out in further detail in this ESS: (i) stakeholder identification and analysis; (ii) planning how the engagement with stakeholders will take place; (iii) disclosure of information; (iv) consultation with stakeholders; (v) addressing and responding to grievances; and (vi) reporting to stakeholders. The Borrower will maintain and disclose as part of the environmental and social assessment, a documented record of stakeholder engagement, including a description of the stakeholders consulted, a summary of the feedback received and a brief explanation of how the feedback was taken into account, or the reasons why it was not.� (World Bank, 2017: 98). 14 3. Brief Summary of Previous Stakeholder Engagement Activities 3.1 Key Stakeholder Meetings and Consultations As result of TGF is in development stage, some engagement activities carried out by TSKB. For the scope of the SEP studies, the previous stakeholder engagement activities conducted are given in Table 1 below. Table 1 Previous stakeholder Engagement Activities Location Event Date Participants Key Points of Discussion *Notifying the capital investments decision to SME companies in developing countries. *Limiting the scope of investments within the framework of Green and Greening Firms. Online/ In Regarding this, aiming to increase environmental person Nov-22, and social tendencies. meetings IBRD TGF Feb-23, *Providing private mobilization in addition to (TSKB HQ) Proposal May-23 IBRD, TSKB the resources provided by IBRD. *Discussion on the compatibility of the Fund's theme with TSKB's vision and mission. *Determining TSKB's financial return expectations regarding the Fund. *Sampling the sectors in which the Fund will TSKB (DFI, invest Corporate *Obtaining the approval of TSKB top In person Adoption of Finance, management meetings the Fund idea Nov-22 - Engineering *Providing information about IBRD E&S (TSKB HQ) by TSKB May-23 ) Teams standards to TSKB teams *Providing information on the CMB obligations regarding the establishment of the Fund TSKB, *Submitting the Fund's cost/expense criteria and Fund Jan-23, Maxis, offers to TSKB. Online Manager Feb-23, Other Fund *Discussion on the Fund's competencies related Meetings Selection Apr-23 Managers to E&S matters Telephone Engagement Ministry of *Introduction of the idea establishment of a calls, online with Treasury green fund meetings governmental May-22 – and Finance *Informing the relevant governmental body bodies May-23 (MTF) about the scope of the Fund 15 4. Stakeholder Identification and Analysis Affected parties refer to individuals or groups who are affected or likely to be affected by the project because of actual impacts or potential risks to their physical environment, health, security, cultural practices, well-being, or livelihoods. These stakeholders may include individuals or groups who are impacted or likely to be impacted directly or indirectly (actually or potentially), positively or adversely, by the Project and/or have been identified as most susceptible to change associated with the project, and who need to be closely engaged in identifying impacts and their significance, as well as in decision-making on mitigation and management measures. Other interested parties (OIPs) refer to individuals or groups who may have an interest in the project because of the project location, its characteristics, its impacts, or matters related to public interest. For example, these parties may include regulators, government officials, the private sector, the scientific community, academics, unions, women’s organizations, other civil society organizations, and cultural groups. These stakeholders may not experience direct impacts from the project, but consider or perceive their interests as being affected by the project and/or who could affect the project and the process of its implementation in some way. Vulnerable/Disadvantaged Individuals/Groups refer to individuals or groups who because of their circumstances may be more likely to be adversely affected by the project impacts and/or more limited than others in their ability to take advantage of a project’s benefits. Table 2 Identification of Stakeholders Stakeholders Affected Parties/ Main Influence on or Significance Level Other Interested Interest in the Project Parties/ Disadvantaged & Vulnerable Individuals or Groups Interest Influence Investee Enterprises Affected Parties Directly benefitting High High from the Project Capacity building in E&S management Investee Enterprises’ Affected Parties Potential impacts from High High Workers the project working conditions and OHS impacts Citizens and Affected Parties Successful Low Moderate communities settled in implementation of the the investee Project with visible and enterprises operation measurable results area Could be impacted by the business activities of beneficiary enterprises 16 Capital Markets Board Other Interested Successful High Moderate of Türkiye (CMBT) Parties implementation of the Project with visible and measurable results Key Other Interested Successful Moderate Moderate government Parties implementation of the authorities Project with visible and measurable results Other investors of the Other Interested Successful High Moderate Fund Parties implementation of the Project with visible and measurable results Significance Level (Interest and Influence) provides information about the level of participation, how to establish a relationship with the stakeholders, how they will be informed, and the continuity and level of the established communication, in line with the needs of the stakeholders, depending on their sensitivity related to their impact-interest level. According to Significance Level of the identified stakeholders, the conditions will be considered as follows: Table 3 Level of Interest Level of Interest Low Moderate High High Involve/Engage Involve/Engage Partner (Work Together) Level of Influence Moderate Inform Consult Consult Low Inform Inform Consult Any stakeholders that are not identified at this stage of the Project may directly contact TSKB to make themselves and their needs known to facilitate the effective implementation of the SEP. Sub-project level stakeholder analysis, including identification of stakeholders will carry out for each sub- project independently. Investment Committee, where TSKB will be holding the leading role is going to be the responsible body to ensure that analysis is performed in line with national regulations, World Bank ESF and GIIPs. 17 5. Stakeholder Engagement Program A variety of engagement techniques can be utilized to engage and consult with stakeholders, as well as to gather information from and deliver information to stakeholders. 5.1. Stakeholder Engagement Methodologies In order to meet best practice approaches, the project will apply the following principles for stakeholder engagement: • Openness and life-cycle approach: Public consultations for the project(s) will be arranged during the whole life cycle, carried out in an open manner, free of external manipulation, interference, coercion, or intimidation. • Informed participation and feedback: Information will be provided to and widely distributed among all stakeholders in an appropriate format; opportunities are provided for communicating stakeholder feedback, and for analyzing and addressing comments and concerns. • Inclusiveness and sensitivity: Stakeholder identification is undertaken to support better communications and build effective relationships. The participation process for the projects is inclusive. All stakeholders at all times are encouraged to be involved in the consultation process. Equal access to information is provided to all stakeholders. Sensitivity to stakeholders’ needs is the key principle underlying the selection of engagement methods. Special attention is given to vulnerable groups that may be at risk of being left out of project benefits, particularly women, the elderly, persons with disabilities, displaced persons, and migrant workers and communities, and the cultural sensitivities of diverse ethnic groups. • Flexibility: If social distancing, cultural context (for example, particular gender dynamics), or governance factors (for example, high risk of retaliation) inhibits traditional forms of face-to-face engagement, the methodology should adapt to other forms of engagement, including various forms of internet- or phone- based communication. The level of impact, in addition to the needs and concerns of the stakeholders will found the basis of the tools and methods selected to engage with certain groups. Anticipated engagement methods and means of application for possible stakeholders of the Fund are presented in Table below. These methods and tools are generic and need to be revised accordingly once the project specific SEPs are prepared. 18 Table 4 Stakeholder Engagement Methods Engagement Application of the Method Possible Stakeholder Method Potential and actual Investee Enterprises, Potential and actual - Information collection on an individual basis allowing One-on-one investors of the Fund, to speak freely about sensitive issues meetings Representatives of relevant state - Establishing connections with key actors authorities and government officials, NGOs, IBRD, Potential and actual Investee - Information sharing (in particular technical) on Fund Enterprises, Potential and actual structural and scope investors of the Fund, Relevant Correspondences - Invitations to meetings and key events during Fund state authorities and (Letters, Phone, management government officials, NGOs, Emails) - Information and data requests that will be utilized for academia, national and local Fund and sub-project implementation media and organizations/agencies, IBRD -Collective information sharing on project Potential and actual Investee requirements and impacts Enterprises, Potential and actual -Receiving comments, feedback, views and perception investors of the Fund, Formal meetings of project from a group of high-level stakeholders Representatives of relevant state -Gathering information about the sub-projects from authorities and government investee enterprises officials, NGOs, IBRD, - Baseline data collection on an individual basis with impacted Affected Parties Face to face Project affected parties, Investee - Monitoring of sub-projects’ environmental and social interviews Enterprises’ workers impacts and activities on an individual basis - - Information sharing on a specific topic to a certain group of people including vulnerable groups - Receiving comments, feedback, views and perception of project from a certain group Certain target groups, vulnerable Focus group - Collecting grievances and concerns related to the groups, Project affected parties, discussions project from a certain group Investee Enterprises’ workers - Monitoring of project environmental and social impacts and activities on a certain group - Establishing relations with certain groups - Information sharing and progress updates Affected Parties, national, -Disclosure of SEP, Exclusion List and other relevant TSKB & Maxis international and local media, Fund documentation website academia, NGOs, businesses and - Announcements of key events, dates and published organizations/agencies documents 19 5.2. Future Phases of Stakeholder Engagement Stakeholders will be kept informed as the project develops, including implementation of the Stakeholder Engagement Plan, the grievance mechanism, etc. TSKB and Maxis will update their official website regularly with key project updates and reports on the Fund’s environmental and social performance. The websites will also provide information about the grievance mechanism for the Fund. In addition, TGF will have an ESMS which sets principles regarding information disclosure, implementation of stakeholder engagement plan stakeholder consultation and grievance redress activities, etc. for investee enterprises and their sub-projects in order to ensure that stakeholder engagement is implemented in the whole Fund lifecycle. 20 Table 5 Stakeholder Engagement Program Stage Main Purpose Time Event/Location Scope Stakeholders Establishment CMBT Establishment of 2-3 Visit, Video Call, *Establishment of TGF of TGF the Fund and its months TSKB *Preparation of documents such as Fund by decision organs Headquarters etc. laws, Fund issuance certificate with CMBT *Establishment of Investment Committee and other necessary committees *Analyzing and presenting E&S capacity of Maxis *Establishment of the ESMS for the Fund Origination Potential Introduction of 1 month Site visit, Video *Meetings with PIE in order to introduce the Investee Project Overview call etc. Fund, including its environmental and social Enterprises (E&S) requirements. (PIE), * Receiving feed backs about structure and applicability of the Fund Potential Introduction of the 1 month *Innovate4Climate *2-3 TSKB representatives will be investors of Fund conference and participating in Innovate4Climate conference the Fund, other green in Bilbao which will take place on May 23-25, Potential finance 2023 to consult the Fund Investee conferences etc. *Sharing information, including the Fund Enterprises structure, opportunities and risks, primary (PIE), Key objectives, eligibility criteria, E&S government requirements, etc. authorities *Receiving feed backs about structure and applicability of the Fund MTF Development and 16 Regular reports, * Reporting Fund management units implementation of months telepone calls, * Providing information about the Project online meetings implementation of the Fund 21 *Consultation in order to increase effectiveness of the Fund Due Diligence Potential Investigating 3 months Site visit, Video *Assigning all relevant due diligence (DD) Investee project's financial, call, Expert advisors (financial, tax, legal etc.) Enterprises environmental, meetings etc. *Coordination of DD process with all advisors (PIE) legal risks and and Target management *Site visits, management meetings, expert sessions *Analyze the DD results and reflect the red flags into the PIE’s analysis including E&Sissues *Negotiations of terms (inc. E&S related ones) with the PIE’s shareholder *Securing approvals from Investment Committee to submit NBD* Portfolio Investee Directing and 5 years Site visit, Video *TSKB to hold board membership on each IE, management Enterprises supervising IE's call etc. providing strategic direction and oversight to (IE), Potential risks and E&S the company's management team Investee impacts *Development of an ESMS to be prepared to Enterprises’ close the gaps defined during DD stage. Workers, *Green and financial monitoring and Citizens and supporting portfolio companies and conduct communities other related management activities settled in the investee enterprises operation area 22 Investee Implementation of 5 years Site visit, Face-to- *Investee Enterprise will manage its sub- Enterprises the ESMS face meetings, projects in line with the ESMS developed (IE), Investee developed by IE etc. according to DD findings. Stakeholder Enterprises’ engagement and disclose requirements will Workers, be defined in the ESMS that will be Citizens and established for the Fund. communities *Monitoring E&S performance of the IE, settled in the including SEP activities such as grievance investee redness mechanism, disclosure activities, etc. enterprises operation area Exit Investee 6 months *Maxis will screen exit opportunities (such as Enterprises share buy back etc.) (IE) *Perform exit negotiations and execute exit procedures *Non-Binding Offer 23 6. Resources and Responsibilities TSKB is responsible for development and management of the Fund. A dedicated Committee consisting of TSKB and Maxis has been assigned for Fund management duties, including stakeholder engagement activities. The Investment Committee is supported by 2 environmental and 1 social specialists from TSKB Engineering Department in order to fulfill E&S requirements of the Fund. These specialists have strong experience in national and international medium and high E&S risk projects financed through IDF loans. Conducting E&S due diligences, planning, conducting, and analyzing stakeholder interviews and focus groups are selected practices performed by the team. Besides, the team has experience in development and management of ESMS for financial institutions. However, the team may need to strengthen its capacity and skills through additional consultants, trainings or advisors. The stakeholder engagement activities will be documented by the team right after of the project-related public engagement activities have been carried out. Sub-project level stakeholder engagement activities will carry out by independent consultants, who will be selected with regards to qualifications to be demonstrated by previous accomplishment, etc. Investment Committee and investee enterprises should have sufficient budget to manage stakeholder engagement process effectively. For the proposed engagement methods, including consultation meetings, formal meetings, face to face and focus group discussions Investment Committee and investee enterprises are required to spend time and effort causing event organization and designated staff expenses. In addition to that the stakeholder identification process or social based analyses to be developed sub- project level will be carried out by an independent consultant to find out meaningful information about the community and region. E&S specialists shall accompany consultants during consultation meetings to ensure stakeholder engagement activities are conducted properly. Apart from all those expenses, it also should be noted that to create and manage a web-site and to hand out brochures for disclosure of information will cause expenses that should be considered by Investment Committee. Table 6 Budget for Operational Expenses of SEP Estimated Budget Category Total Costs Remarks/ Resources (USD) 1. Estimated staff salaries* and related expenses Environmental engineers and social specialist salary in order to Fund Establishment Phase 25,000 develop TGF Expenses of E&S consultants who will assess E&S activities of investee Investee Funding Phase 30,000 enterprises 2. Events and communication campaigns TSKB & Maxis will attend Green Finance Conferences, have meetings Green Finance Conferences, etc. 12,500 with stakeholders to introduce TFG to the market TSKB will lead the Fund web site, hand out brochures, proceed social Communication Tools 2,500 media campaign, etc. Consultation Organizations, Investee enterprises will organize consultation organizations about 7,500 (organization of focus groups, etc.) their investments, disclose E&S performances, etc. 24 3. Beneficiary surveys Project Perception Surveys 7,500 TSKB will manage the survey with the support of Maxis 4.Grievance Mechanism, Trainings, others Advisory services for Investee Investee enterprises will establish GRM, have trainings to build enterprises 25,000 capacity, etc. TOTAL STAKEHOLDER ENGAGEMENT BUDGET: 110,000 7.. Grievance Redress Mechanism As Investment Committee members, TSKB and Maxis will have separate and inclusive Grievance Redress Mechanisms in place to receive complaints from stakeholders of the Fund via website, the Fund specific e-mail or phone call. Those communication channels are defined separately in the table below. TSKB Communication channel Web site http://www.tskb.com.tr/en/about-us/tskb-contact-form http://www.tskb.com.tr/tr/hakkimizda/tskb-iletisim-formu E-mail address tgf@tskb.com.tr Phone number +90 0 212 334 50 50 Maxis Communication channel Web site https://www.maxisgs.com/iletisim.html Phone number +90 0 (212) 283 51 13 An online contact form is utilized for the complaint management of TSKB. The form has a customized area for complaints to inform relevant departments within the BankWhen the complaint is received, "Customer Complaints Statement" is issued to record the subject within the Bank system within 2 days after the receipt of the complaint Simultaneously, the system informs the related department head in order to take necessary actions. After the necessary investigations are made, the final result is reached as soon as possible, the Evaluation and Conclusion Section of the Statement is filled in by the authorized employees and the reply is given within 30 days after the application is made. During the process, all steps are followed up by Board of Internal Auditors and Internal Control Department. Internal Control Department is responsible for monitoring and assisting relevant departments in implementation of the process where Board of Internal Auditors is responsible for ensuring that compliant management has been proceeded effectively. For the complaints received by the phone, same procedure is implemented via filling out the online contact form by TSKB staff. It should be noted that the mentioned system has the capacity to compile information about number of the complaints, reply periods, etc. in order to measure performance of TSKB in this regard. TSKB Workers’ Grievance Mechanism: Employees have the right to submit suggestions, express concerns and grievances related to the workplace, and to file complaints and lawsuits due to the administrative actions and procedures applied to them by their managers or the workplace. In that sense, TSKB has an internal grievance mechanism for its own employees which can also be reached anonymously and transparently. All necessary information about the communication channels which allows the employees to convey their grievances/suggestions about the TSKB and the working conditions are placed on TSKB’s 25 web-site. The grievances/suggestions are received, evaluated and closed by Human Resources Department in 30 days after the application is made and employees are informed about the taken action. Maxis Workers’ Grievance Mechanism: On Maxis side, a similar procedure is in place. There is a Grievance Committee consisting of General Director, Deputy Director General and Coordinator to manage the procedure. The Committee duties also cover to hear, investigate, and resolve any complaint, grievance, or conflict raised by employees. However, Maxis is required to inform TSKB as soon as receives a grievance regarding the TGF since TSKB is leader of the Investment Committee. Then TSKB will implement its grievance procedure to solve any complaint raised. National Grievance Mechanism: In Turkiye, CIMER (Presidency’s Communication Center) which is a public relations application that is implemented on receiving and responding to the problems, wishes, demands and complaints of citizens in a fast way is available to be used by community. According to Directorate of Communications of Presidency of the Republic of Türkiye, if the subject of the application to CIMER contains a specific request, complaint or notice, the related institutions has to give a definite positive or negative answer within 30 days. TSKB will follow its Grievance Redress Mechanisms in case of any concern is received from this channel. In line with the sub-project specific SEP and the requirements of other E&S documents, a Grievance Redress Mechanism (GRM) will be developed by the investee enterprises for potential use by both external and internal stakeholders (workers etc.). The fundamental aim of the GRM will be to timely resolve any project related grievance that may result in the complainant being worse off due to project activities. TSKB will ensure that investee enterprises have various communication channels established within their system in order to allow all stakeholders to submit their concerns. The World Bank and the Borrower do not tolerate reprisals and retaliation against project stakeholders who share their views about Bank-financed projects. 26 8. Management, Monitoring and Reporting Monitoring and evaluation of the stakeholder engagement process defined in this SEP is of utmost importance to ensure timely and effective decision making for Project implementation. The responsibility of monitoring and evaluation of stakeholder engagement processes belongs to TSKB, which is leading body of the Investment Committee. Monitoring reports will involve: - Updates of the stakeholder list; - Minutes of all meetings and attendance registers (sex disaggregated); - Records of all consultation events; - Records of all received and closed and recurrent grievances; - Status of grievances (open/closed); and The stakeholder engagement for each investee enterprises and sub-projects will be conducted in the whole process of the investment cycle as well. During the project implementation, monitoring and reporting for the stakeholder engagement will be implemented primarily in the level of investee enterprises and sub-projects, together with the E&S monitoring and reporting for investee enterprises and subprojects. Each investee enterprise or subproject will establish its internal monitoring mechanism. For substantial-risk and medium-risk investee enterprises and subprojects, the Fund shall require the investee enterprises/subprojects to engage third-party professionals with tracked experience to monitor and evaluate the implementation of the E&S documents, including stakeholder engagement. For low risk investee enterprises and subprojects, TSKB may require the investee enterprises to report their E&S performances or to engage third-party professionals in order to ensure stakeholder engagement process is proceeded properly. 27 Annex 1: Sample Grievance Form and Grievance Close Out Form GRIEVANCE FORM If you wish to submit an anonymous complaint, you are kindly requested to fill out the (*) denotes required fields. Date * Reference Number Way of Receiving Grievance Phone □ Meetings □ Application to Office □ Mail/email □ Field visit □ Compliant Full Name (optional and can be left blank) Compliant ID Number: (optional and can be left blank) Address - Compliant Village: * Contact Postal Code: Information (optional and can Phone: be left blank) Email: Content of Grievance or Complaint * • On abandonment (public housing) • On assets/properties impacted by the project • On infrastructure • On decrease or complete loss of sources of income • On environmental issues (ex. pollution) • On employment • On traffic, transportation and other risks • Other (Please specify): Description of the Grievance * What did happen? When did it happen? Where did it happen? What is the result of the problem? What would you like to see happen to resolve the problem? * Consent to disclose the grievance information to 3rd parties 28 Signature of complainant Full Name Received by Signature GRIEVANCE CLOSE OUT FORM Grievance closeout number: Define immediate action required: Define long term action required (if necessary): Yes Compensation Required? No CONTROL OF THE REMEDIATE ACTION AND THE DECISION Stages of the Remediate Action Deadline and Responsible Institutions 1. 2. 3. 4. 5. 6. 7. 8. COMPENSATION AND FINAL STAGES This part will be filled and signed by the complainant after s/he receives the compensation fees and his/her complaint has been remediated. Notes Complainant Name & Surname 29 Signature Date Title: Representative of the Name & Surname Responsible Institution / Signature Company Date 30