TURKISH ELECTRICITY TRANSMISSION CORPORATION DIRECTORATE GENERAL TRANSMISSION SYSTEM TRANSFORMATION PROJECT (TSTP) STAKEHOLDER ENGAGEMENT PLAN (SEP) APRIL 2025 1 Table of Contents GLOSSARY................................................................................................................................................. 5 EXECUTIVE SUMMARY ........................................................................................................................ 6 1. INTRODUCTION............................................................................................................................... 8 2. PROJECT DESCRIPTION ............................................................................................................... 9 2.1. Project Objective .............................................................................................................................. 9 2.2. Project Components......................................................................................................................... 9 2.3. Project Location ............................................................................................................................. 10 3. NATIONAL LEGISLATION AND INTERNATIONAL REQUIREMENTS ............................ 12 3.1. National Legislation on Stakeholder Engagement ...................................................................... 12 3.2. International Legislation on Stakeholder Engagement .............................................................. 14 4. STAKEHOLDER IDENTIFICATION AND ANALYSIS ................................................................ 15 5. STAKEHOLDER ENGAGEMENT PROGRAM .......................................................................... 19 5.1. Stakeholder Engagement Methods ............................................................................................... 20 5.2. Stakeholder Engagement Program .............................................................................................. 23 5.3. Strategy to be Implemented to Incorporate Views of Disadvantaged/Vulnerable Groups ..... 27 5.4. Process of Feedback to Stakeholders ........................................................................................... 29 5.5. Review of Feedback from Stakeholders ....................................................................................... 30 6. ROLES AND RESPONSIBILITIES FOR IMPLEMENTATION OF STAKEHOLDER ENGAGEMENT ....................................................................................................................................... 31 7. GRIEVANCE MECHANISM.......................................................................................................... 32 7.2. Identification of Grievance Mechanism ....................................................................................... 35 7.3. World Bank’s Grievance Redress System ................................................................................... 38 7.4. Workers’ Grievance Mechanism .................................................................................................. 38 7.5. Management of Sexual Exploitation, Abuse/Sexual Harassment .............................................. 39 8. MONITORING AND REPORTING .............................................................................................. 40 ANNEX 1. GRIEVANCE FORM ............................................................................................................ 42 ANNEX 2. GRIEVANCE CLOSE-OUT FORM ................................................................................... 43 ANNEX 3. GRIEVANCE LOG ............................................................................................................... 44 ANNEX 4. DETAILED MANAGEMENT RESPONSIBILITIES OF GRIEVANCE MECHANISM ............................................................................................................................................................ 45 ANNEX 5. RECORDS OF STAKEHOLDER CONSULTATION ACTIVITIES ....... Hata! Yer işareti tanımlanmamış. 2 List of Tables Table 1 Stakeholder Groups Identified for TSTP Project ........................................................................... 17 Table 2 Stakeholder Engagement Methods to be Applied under the Project.............................................. 20 Table 3 Stakeholder Engagement Program ................................................................................................. 25 Table 4 Summary of Disadvantaged/Vulnerable Individuals/Groups and Recommended Stakeholder Engagement Methods.................................................................................................................................. 27 Table 5 Responsibilities of Key Actors/Stakeholders in SEP Implementation .......................................... 31 Table 6 Project-Specific Channels for Rceeiving Grrievances ................................................................... 33 Table 7 CİMER’s Channels to Receive Grievances .................................................................................. 34 Table 8 YİMER’s Channels to Receive Grievances .................................................................................. 35 Table 9 Grievance Mechanism ................................................................................................................... 36 Table 10 Monitoring Indicators .................................................................................................................. 41 List of Figures Figure 1: Potential subproject provinces (highlighted in purple)................................................................ 11 Figure 2: Breakdown of estimated number of subprojects by provinces .................................................... 11 Annexes ANNEX 1. GRIEVANCE FORM ............................................................................................................ 42 ANNEX 2. GRIEVANCE CLOSE-OUT FORM ................................................................................... 43 ANNEX 3. GRIEVANCE LOG ............................................................................................................... 44 ANNEX 4. DETAILED MANAGEMENT RESPONSIBILITIES OF GRIEVANCE MECHANISM .................................................................................................................................................................... 45 ANNEX 5. RECORDS OF STAKEHOLDER CONSULTATION ACTIVITIES ....... Hata! Yer işareti tanımlanmamış. 3 ABBREVIATIONS CİMER The Communication Center of the Presidency E&S Environmental and Social GBV Gender-Based Violence EIA Environmental Impact Assessment ESCP Environmental and Social Commitment Plan ESF World Bank Environmental and Social Framework ESIA Environmental and Social Impact Assessment EMSF Environmental and Social Management Framework ESMP Environmental and Social Management Plan ESS Environmental and Social Standards SEA/SH Sexual Exploitation and Abuse/Sexual Harassment MoEUCC Ministry of Environment, Urbanization and Climate Change WB World Bank VRE Variable Renewable Energy MENR Ministry of Energy and Natural Resources MoYS Ministry of Youth and Sports GRS Grievance Redress Service MoI Ministry of Interior LMP Labor Management Procedures PAP Project-Affected People SEP Stakeholder Engagement Plan POM Project Operations Manual MoH Ministry of Health GM Grievance Mechanism MoT Ministry of Trade GoT Government of Türkiye TEİAŞ Turkish Electricity Transmission Corporation MoAF Ministry of Agriculture and Forestry MoTI Ministry of Transport and Infrastructure YİMER Foreigners Communication Center RF Resettlement Framework RP Resettlement Plan 4 GLOSSARY Disadvantaged/vulnerable groups/individual refers to people /groups who 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. Disadvantaged/vulnerable groups/individuals are also more likely t o be excluded from/unable to participate fully in the mainstream consultation process. These groups/individuals may require specific measures and/or assistance to participate in the stakeholder engagement and consultation processes. Consultation refers to the process which lasts throughout project lifecycle and is intended to share information with stakeholders about the environmental and social risks/impacts of the Project and sub- projects and the measures to mitigate these risks/impacts, and to allow stakeholders to express their opinions, suggestions and criticisms about the project and ask questions about the project. Stakeholder refers to all individuals, groups, entities and organizations who have an interest in a project and are potentially affected by or likely to affect the Project . Individuals or groups who: (a) are affected or likely to be affected by the project (project-affected parties); and (b) may have an interest in the project (other interested parties). Stakeholder Engagement refers to a process of dialogue whereby the persons affected from the decisions and activities of the Project owner (implementing agency) are determined, information is exchanged specifically in relation to the project and feedback is received from stakeholders. Stakeholder Engagement Plan (SEP) is an instrument used to manage communication with all Project stakeholders at the Project and/or subproject level. SEP will define the timing and methods of interaction with stakeholders throughout project lifecycle, as agreed between the Bank and the Borrower. Project refers to the Transmission System Transformation Project in the context of this document. Grievance Mechanism refers to the entirety of comprehensive systems, processes or procedures established, and maintained throughout project lifecycle in a manner that is accessible to all stakeholders, by the Project owner (implementing agency), to receive, record and resolve the requests (complaint, opinion, suggestion, question, etc.) about the environmental and social performance of the Project, in a timely and effective manner. 5 EXECUTIVE SUMMARY This document is a Stakeholder Engagement Plan (SEP) that describes the stakeholder consultation and engagement process that is planned to be executed under the Transmission System Transformation Project (TSTP). The SEP has been prepared within the scope of the World Bank’s ESS10 standard titled “Stakeholder Engagement and Information Disclosure”. Accordingly, TEİAŞ will ensure continuous stakeholder engagement and consultation throughout the project lifecycle while carrying out project work and activities, in order to achieve the project objectives. The proposed project has been structured around three components: (i) Strengthening the transmission grid in order to facilitate VRE (Variable Renewable Energy ) and improve grid reliability and resilience; (ii) Digitalization to strengthen grid management and operation, and support VRE integration; (iii) Technical Assistance to transform TEİAŞ’s operations, governance structure and financing capacity. The subprojects will be implemented in the provinces of İstanbul, Bursa, Çanakkale, Kocaeli, İzmir, Ankara, Aksaray, Samsun, Şanlıurfa, Kahramanmaraş, Gaziantep, Mersin, Hatay, Antalya, Edirne, Tekirdağ, Muğla, Aydın, Kastamonu, Adana, Balıkesir and Sakarya. The right to information implies the right of individuals to access information in the records of public institutions and organizations. National legislation governing the right to information include the following:  Constitution of the Republic of Türkiye  Law on the Right to Information  Law on the Use of Right to Petition  Environmental Impact Assessment Regulation World Bank’s (WB) Environmental ad Social Standard (ESS)-10 titled “Stakeholder Engagement and Information Disclosure” within the WB Environmental and Social Framework (ESF) recognizes that stakeholder engagement is "open and transparent engagement between the Borrower and project stakeholders as an essential element of good international practice”. TEIAS will be responsible for responding, in a timeşly manner, to the suggestions and complaints communicated by project-affected parties regarding the environmental and social performance of the project. To this end, TEIAS will propose and implement a project-specific grievance mechanism (GM) to 6 facilitate the receipt and resolution of suggestions and complaints. The scope, scale, and type of the required GM will be proportionate to the nature and scale of the potential risks and impacts of the project. The GM will include: (i) means to enable submission of grievances and concerns in person, by phone, e-mail and/or website; (ii) a grievance log where grievances are registered in writing and maintained as a database; (iii) publicly advertised procedures setting out the length of time users can expect to wait for acknowledgment, response and resolution of their grievances; (iv) transparency about the grievance procedure, governing structure and decision makers; (v) an appeals process (including the national judiciary) to which unsatisfied grievances may be referred when the resolution of grievance has not been achieved. TEİAŞ will be responsible for implementing the activities and tasks set out in the Stakeholder Engagement Plan, in a timely manner and as specified in the SEP. In order to execute effective stakeholder engagement within the scope of this Stakeholder Engagement Plan, the required applications will be monitored and evaluated by TEİAŞ on a quarterly basis, based on the performance indicators provided in the section “Monitoring and Evaluation”. Documents of stakeholder engagement activities and monitoring reports will be kept in TEİAŞ’s archives. 7 1. INTRODUCTION This document is a Stakeholder Engagement Plan (SEP) that describes the stakeholder consultation and engagement process that is planned to be executed under the Transmission System Transformation Project (TSTP). The SEP has been prepared within the scope of the World Bank’s ESS10 standard titled “Stakeholder Engagement and Information Disclosure”. Accordingly, TEİAŞ will ensure continuous stakeholder engagement and consultation throughout the project lifecycle while carrying out project work and activities, in order to achieve the project objectives. Stakeholder engagement is an inclusive process conducted throughout the project life cycle. When properly designed and implemented, it supports the development of strong, constructive, and responsive relationships that are important for the successful management of the project’s environmental and social risks. Communicating early, often, and clearly with stakeholders helps manage expectations and avoid risks, potential conflict, and project delays. The objectives of the SEP are the identification of the project stakeholders at different stages of development and the establishment of their rules for the management of the exchange of information between TEİAŞ and the stakeholders in line with the national regulatio n and the World Bank (WB) Requirements. The purpose of the SEP is to present how TEİAŞ plans to communicate with stakeholders who may be affected by or will be interested in the TSTP Project throughout the project lifecycle. It also describes a grievance mechanism, which is a process that stakeholders may use to raise any concerns about the Project providing their opinions that may influence the Project implementation and its results. The Stakeholder Engagement Plan is a living document, so it will be reviewed and updated periodically and in line with new activities, changes in the Project, and newly identified stakeholders. The up-to-date version of this SEP will be disclosed before starting the project activities 8 2. PROJECT DESCRIPTION 2.1. Project Objective Project development objective is to expand renewable energy capacity countrywide and enable its integration to electricity transmission grid. The Project consists of three components: Strengthening the transmission grid in order to facilitate the integration of variable renewable energy and improve grid reliability and resilience (Component 1); Digitalization to strengthen grid management and operation and support renewable energy integration (Component 2); Technical Assistance on capacity development to prepare for transition (Component 3). Detailed information on project components is presented in section 2.2. 2.2. Project Components The Project has been structured around three components: Component 1: Strengthening the transmission grid in order to facilitate renewable energy integration and improve grid reliability and resilience; Component 2: Digitalization to strengthen grid management and operation and support renewable energy integration; Component 3: Technical Assistance to transform TEİAŞ’s operations, governance structure and financing capacity. Component 1: Strengthening transmission grid to facilitate VRE scale-up and improve its reliability and resilience This component aims to improve the reliability and resilience of the transmission system by strengthening and modernizing the grid. It will address urgent and local grid constraints that could delay or cause high levels of curtailment in the deployment of VRE projects. Other new and upgraded substations will also enable the transmission of renewable energy and minimize VRE curtailment. These substations will utilize new technologies such as Gas Insulated Switchgear (GIS) and Substation Automation System (SAS). Component 1 will also finance the construction of new 400 and 154 kV underground cables and 154 kV overhead transmission lines. The new underground cables will be equipped with optical fiber cable, which will not only be used by TEİAŞ for fault detection and internal telecommunications purposes, but also potentially for third-party use. These investments are critical to meet the growing demand by delivering clean electricity to residences and industries, through a generation mix with an increased share of renewable energy. 9 Component 2: Digitalization to strengthen grid management and operation and support renewable energy integration. This component aims to digitalize the grid and to facilitate grid management and operations by supporting TEİAŞ through adoption of new digital instruments. This component will include investments such as; i. upgrading the Supervisory Control and Data Acquisition (SCADA)/Energy Management System (EMS) of TEİAŞ; and ii. automatic and remote reactive power management through modernization/installation of Series Capacitor Compensator (SCC) for critical 400kV substations. By upgrading SCADA/EMS, a state-of-the-art digital EMS software will be introduced for TEİAŞ, which will help them manage their power systems with a rapidly growing share of VRE. The proposed SCCs will enable TEİAŞ to deliver more energy from renewable sources to demand centers by increasing transmission capacity and grid stability. The equipment will be fully automated and remotely controlled. Component 3: Technical Assistance on capacity development to prepare for transition This component aims to support Türkiye and TEİAŞ in creating the capacities and processes required to smoothly achieve the Government's energy targets 2.3. Project Location Subprojects will be implemented in the provinces of İstanbul, Bursa, Çanakkale, Kocaeli, İzmir, Ankara, Aksaray, Samsun, Şanlıurfa, Kahramanmaraş, Gaziantep, Mersin, Hatay, Antalya, Edirne, Tekirdağ, Muğla, Aydın, Kastamonu, Adana, Balıkesir and Sakarya, as shown in the map below. 10 Figure 1: Potential subproject provinces (highlighted in purple) 1 1 14 1 1 1 1 2 1 1 5 1 1 3 1 2 2 2 2 1 Figure 2: Breakdown of estimated number of subprojects by provinces 11 3. NATIONAL LEGISLATION AND INTERNATIONAL REQUIREMENTS 3.1. National Legislation on Stakeholder Engagement The right to information is the right of individuals to access the information included in the records of public institutions and agencies. National legislation on the right to information includes the following;  Constitution of the Republic of Türkiye  Law No. 4982 on the Right to Information  Law No. 3071 on Use of the Right to Petition  Regulation on Environmental Impact Assessment Constitution of the 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. According to Article 25 of the Constitution of Republic of Türkiye, which is titled "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 Article titled "Freedom to Explain and Spread Thought (Article 26 of the Constitution of the Republic of Türkiye)"; everyone has the right to express and disseminate his/her thoughts and opinions by speech, in writing or in pictures or through other media, individually or collectively. 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 to Petition" (Article 74 of the Constitution of the Republic of Türkiye). Accordingly, citizens and foreigners residing in Türkiye, on the condition that the principle of reciprocity is observed, have the right to communicate, in writing, their requests and complaints about themselves or the public, to the authorized bodies and Turkish Grand National Assembly. The Presidency Communication Center (CİMER) is an official government tool used to receive requests, complaints, and applications from the public. The communication channels of CİMER are as follows: :  Online applications: https://www.cimer.gov.tr/ ve E-Government website https://giris.turkiye.gov.tr/  Call Center: 150  Address: T.C. Cumhurbaşkanlığı Külliyesi 06560 Beştepe – Ankara  Phone: +90 312 590 2000  Fax: +90 312 473 6494 12 Public institutions and agencies shall provide the requested information within 15 working days. If the requested information or document is to be obtained from another unit within the applied institution and agency or it is necessary to receive the opinion of another institution or if the content of the application pertains to more than one institution; the access shall be provided in 30 working days. In this case, the applicant shall be notified in writing of the extension and its reasons within 15 working days (Article 11). Law No. 4982 on the Right to Information The objective of this law is to regulate the principles and procedures concerning the right to information following the principles of equality, impartiality and openness, which are the requirements of a democratic and transparent government. According to the obligation to provide information (Article 5), 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. Law on Use of the Right to Petition Based on "Article 3 of the Law on the Exercise of the Right to Petition", citizens of the Republic of Türkiye, may submit their complaints to the Grand National Assembly of Türkiye through a written petition (Official Gazette No. 3071 dated 01.11.1984). On the condition of reciprocity and using the Turkish language in their petitions, foreigners residing in Türkiye are also entitled to enjoy this right. Environmental Impact Assessment Regulation The Environment Law No. 2872, which was published in the Turkish Official Gazette No. 18132 dated 11 August 1983 and amended in the Official Gazette dated 29 Mays 2013 (by Law No. 6486), establishes the underlying legal framework of the environmental legislation in Türkiye and is supported by a large number of regulations. Article 10 of the Environment Law lays down the main framework of the Environmental Impact Assessment Regulation (EIA Regulation) published in the Official Gazette No. 31907 dated 29 July 2022. Within the scope of EIA, for the projects included in the Annex-I list, a public engagement meeting (PEM) will be organized by the bodies and organizations authorized by the MoEUCC with the participation of the project owner on the date set by the MoEUCC and at the place and time determined by the Governor's 13 Office before the Committee determines the scope to inform the public about the investment and to hear their opinions and suggestions regarding the project. Furthermore, as specified in Article 9 of the EIA Regulation, for projects included in the Annex-1 list, a Stakeholder Engagement Plan (SEP) is prepared by institutions/organizations authorized by the Ministry in order to inform the public about the project and its effects and to receive the public's opinions and suggestions regarding the project. The SEP prepared is submitted in the attachment of the EIA application file. If deemed necessary, the Ministry may request, from the authorized institutions/organizations, additional activities such as distributing informative brochures, conducting surveys and seminars, or preparing a website relating to the project and sharing information throughout the EIA process in order to inform the public. In addition, if requested by the Ministry, this plan is updated during the EIA process. 3.2. International Legislation on Stakeholder Engagement World Bank Requirements The Environmental and Social Standard (ESS) 10 "Stakeholder Engagement and Information Disclosure" of the World Bank's Environmental and Social Framework (ESF) recognizes, " the importance of open and transparent engagement between the Borrower and project stakeholders as an essential element of good international practice." In more detail, the requirements set out by ESS10 are as follows: 1. 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” 2. “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.” 3. “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.” 4. “The Borrower will maintain and disclose as part of the environmental and social assessment, a 14 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)”. Within the framework of these principles, stakeholder engagement processes will be detailed in the Environmental and Social management Plan (ESMP)/Environmental and Social Impact Assessment (ESIA) documents in line with the principles and process defined in the SEP, taking into account the features of the sub-projects/activities at the implementation stage. In this context, a stakeholder engagement process proportionate to the nature and scale of the project and its potential risks and impacts need to be designed. TEİAŞ will be responsible for responding to concerns and grievances of project -affected parties relating to the environmental and social performance of the project in a timely manner. To this end, TEİAŞ will propose and implement a grievance mechanism (GM) to receive and facilitate the resolution of suggestions and complaints. The scope, scale, and type of the required GM will be proportionate to the nature and scale of the potential risks and impacts of the project. The GM will include: (i) means to enable submission of grievances and concerns in person, by phone, e-mail and/or website; (ii) a grievance log where grievances are registered in writing and maintained as a database; (iii) publicly advertised procedures setting out the length of time users can expect to wait for acknowledgment, response and resolution of their grievances; (iv) transparency about the grievance procedure, governing structure and decision makers; (v) an appeals process (including the national judiciary) to which unsatisfied grievances may be referred when the resolution of grievance has not been achieved. 4. STAKEHOLDER IDENTIFICATION AND ANALYSIS The identification and analysis should be carried out as early as possible in the project cycle by considering dynamics among the stakeholders, risks and opportunities of their inclusion in the Project and should, • categorize stakeholders (individuals, NGOs, government institutions, etc.), • indicate how each stakeholder group will be impacted (directly/indirectly), and • assess their level of interest in and potential influence on the project. 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 openly, free of external manipulation, interference, coercion or intimidation. 15  Informed participation and feedback: information will be provided to and widely distributed among all stakeholders in an appropriate format; opportunities are provided for communicating stakeholders’ feedback, for analyzing and addressing comments and concerns;  Inclusiveness and sensitivity: Stakeholder analysis process will be undertaken throughout Project lifecycle to support better communications and build effective relationships. The participation process for the projects will be inclusive. All stakeholders are encouraged to be involved in the consultation process, to the extent the current circumstances permit. Equal access to information is provided to all stakeholders as an essential principle of Project implementation process. Particular attention will be paid to vulnerable groups who are at risk of being excluded from project benefits and to the cultural sensitivities of diverse ethnic groups.  Flexibility: Where social distance, cultural context or governance factors preclude conventional forms of face-to-face engagement, the Project's stakeholder communication strategy methodology will accommodate alternative forms of participation, including various forms of internet or telephone-based communication. Stakeholder identification is a key step in managing the overall stakeholder engagement process. It reduces the risk that a narrow stakeholder group can dominate the consultation process. The basis of stakeholder identification is their level of interest and interaction with the project. Accordingly, project stakeholders are categorized under the following groups:  Project-Affected Parties refer to persons/groups likely to be affected by the project because of actual impacts or potential risks to their physical environment, health, safety, cultural practices, well-being or livelihoods.  Other Interested Parties refers to individuals, groups or organizations that have an interest in the Project due to the Project location, characteristics, impacts or matters of public good  Disadvantaged/Vulnerable Individuals or Groups refers to persons who may be disproportionately impacted or further disadvantaged by the project(s) as compared with any other groups due to their vulnerable status, and that may require special engagement efforts to ensure their equal representation in the consultation and decision-making process associated with the Project The frequency and the appropriate engagement method(s)/tool(s) for different stakeholder groups are identified by considering the following three criteria;  the extent of the impact of the project on the stakeholder group,  the extent of influence of the stakeholder group on the project, and 16  the culturally acceptable engagement and information dissemination methods. In general, engagement is directly proportional to the level of interest and influence, and as the extent of the impact of a project on a stakeholder group increases, or the extent of influence of a particular stakeholder on a project increases, engagement with that particular stakeholder group should intensify and deepen in terms of the frequency and the intensity of the engagement method used. Table 1 summarizes the potential interests and influence of each of the above-mentioned affected parties. The stakeholder groups presented in the table have been identified by considering the general risks and impacts of the project. For each sub-project, the identification and analysis of the stakeholders specific to the sub-project will be detailed within the scope of the ESMP/ESIA. Table 1 Stakeholder Groups Identified for TSTP Project Stakeholder Group Description  Right holders subject to land acquisition/expropriation [Owners of land or other affected structures, users on land or other affected Stakeholders in this group are structures (tenants, illegal users, common area those who will be affected by users, etc.)] construction activities and/or Project-Affected Parties expropriation requirements in  Residents of the settlements where the project the areas covered by the project. takes place  Businesses, business owners, employees, contractor’s employees in the settlement areas where the project takes place  Ministry of Environment, Urbanization and Climate Change These stakeholder groups were  Provincial Environment, Urbanization and Climate considered under the category of other interested parties as Change Directorates they grant environmental permits within the scope of  Other relevant public institutions construction activities and Other Interested Parties  Governorships/District Governorships and provide opinions about the activities through the district municipalities municipalities and district governorships near the areas of  Neighborhood Headmen construction activities, the  NGOs – Associations at local and national levels relevant units affiliated with these institutions and  Media – National and local levels neighborhood headmen.  Universities Disadvantaged/Vulnerable  Disabled individuals Disadvantaged and vulnerable individuals and groups are at Individuals or Groups  The elderly greater risk of being affected by 17  Pregnant women and/or women with kids project activities and being exposed to greater risks/impacts  Households headed by women than other affected individuals.  Immigrants, refugees and individuals and groups They are also more likely to be excluded from mainstream who do not speak Turkish consultation processes and not be able to participate in these processes. Therefore, special measures may be needed to increase the participation of these individuals and groups. Detailed information on disadvantaged/vulnerable individuals and groups is provided in Section 5.3. 18 5. STAKEHOLDER ENGAGEMENT PROGRAM Stakeholder engagement is an inclusive process conducted throughout the project life cycle. When properly designed and implemented, it supports the development of strong, constructive, and responsive relationships that are important for the successful management of a project’s environmental and social risks. Stakeholder engagement is most effective when initiated at an early stage of the project development process, and forms an integral part of project decisions and the assessment, management, and monitoring of the project’s environmental and social risks and impacts. TSTP views and recognizes the rights of the local communities as key stakeholders in the project. Stakeholder engagement will be free of manipulation, interference, and intimidation, and conducted based on timely, relevant, understandable, and accessible information, in a culturally appropriate format. It involves interactions between identified groups of people and provides stakeholders with an opportunity to raise their concerns and opinions and ensure that this information is taken into consideration when making project decisions. Stakeholder engagement activities will be ongoing through the whole life cycle of the Project, (Project’s preparation, construction, and operation). The nature and frequency of follow-up consultations will be different depending on the sub-projects to be developed. Various consultation techniques will be used to engage and consult with stakeholders, as well as to collect information from and provide information to stakeholders. Stakeholder engagement activities will be conducted using culturally appropriate methods and best practices will be adopted to engage with stakeholder groups. Main principles od communication will be as follows:  Keep the community and key stakeholders informed in advance of project progress.  Encourage community participation.  Listen to feedback, investigate suggestions, and adopt them where possible.  Ensure transparency.  Adapt appropriate communication including gender-sensitive and non-discriminatory language  Apply user-friendly engagement tools.  Use multiple channels for communication.  Ensure safe space, and appropriateness of how communication and engagements are handled, especially when working with vulnerable groups and people who are still recovering from post- disaster trauma. 19 5.1. Stakeholder Engagement Methods Various engagement techniques will be used to engage and consult with stakeholders, as well as to collect information from and provide information to stakeholders. The level of impact, in addition to the needs and concerns of the stakeholders, will determine the basis of the communication tools and methods selected to engage with certain groups. Anticipated engagement methods and instruments for possible stakeholders of the Project are presented in Table 2 below. The language of communication throughout the Project is expected to be Turkish; however, different languages will be also taken into consideration, if need be, to increase the efficiency of the engagement activities and ensure the involvement of all stakeholder groups. The stakeholder engagement activities will be carried out in a culturally appropriate manner and will include the best approaches to interact with stakeholder groups that establish effective relationships for stakeholder engagement. Table 2 Stakeholder Engagement Methods to be Applied under the Project Engagement Application/Objective of the Method Target Stakeholder Method - Information sharing (in particular technical) on project requirements and impacts - Invitations to meetings and key events during Related public authorities and Correspondences project implementation government officials, NGOs, (Letters, Phone, - Arrangements for obtaining permits, licenses, local government, academia, Emails) transfer, and allocation of project land national and local media and - Information and data requests that will be organizations/agencies utilized for project implementation 20 Engagement Application/Objective of the Method Target Stakeholder Method - Information collection on an individual Representatives of relevant basis allows stakeholders to voice their public authorities and concerns/opinions about sensitive issues government officials, NGOs, - Establishing personal connections with key local government, academia, actors organizations/agencies, One-on-one meetings - Collecting baseline data on Project Affected contractors and consultants Persons (PAP) on an individual basis PAPs, project employees - Understanding, monitoring and assessing (including workers hired to work environmental and social impacts and risks of in construction activities, TEİAŞ project activities on an individual basis personnel, contract workers, etc.) - Collective information sharing on project Different national and local requirements and impacts government authorities and - Receiving comments, feedback, views and Formal meetings officials, NGOs, academia, and perception of the project from a group of organizations/agencies, national public institutions and local media - Establishing relations with public institutions - Information sharing (especially non- technical) to a large group of stakeholders, especially communities about the scope and Any stakeholder group identified timeline of the Project and sub-project throughout the project including activities. the affected communities and Consultation - Receiving comments, feedback, views and groups, local NGOs, national and meetings perception of the project from a group of local government stakeholders representatives/authorities, - Collecting grievances and concerns related to businesses, the project organizations/agencies, etc. - Establishing relations with affected communities, and groups - Information sharing on a specific topic to a Stakeholder groups relevant to certain group of people including Focus group the information to be shared and disadvantaged/vulnerable groups discussions discussed during the meeting, - Receiving comments, feedback, views and Disadvantaged/vulnerable groups perception of the project from a certain group 21 Engagement Application/Objective of the Method Target Stakeholder Method - Collecting grievances and concerns related to the project from a certain group - Monitoring project activities’ environmental and social risks and impacts on a certain group of stakeholders - Establishing relations with certain groups - Sharing project-relevant information and update on progress - Disclosing project/subproject related documentation and communication tools: Any stakeholder group identified Environmental and Social Management throughout the project including Framework (ESMF), Stakeholder affected communities and PAPs, Engagement Plan (SEP), Resettlement TEİAŞ website academia, national and local Framework (RF), Labor Management Plan media, NGOs, businesses, and (LMP), Environmental and Social organizations/agencies Management Plan (ESMP), Resettlement Plan (RP), Grievance Mechanism (GRM), presentations, brochures, etc. - Announcements of key events (date/time, venue) Digital communication tools Any stakeholder group identified social media - Non-technical information sharing and throughout the project including (Facebook, Twitter, progress updates project affected communities and Instagram accounts, - Announcements of key events, dates and PAPs, national and local media, WhatsApp groups), published documents related to the Project academia, NGOs, businesses, and national/local organizations/agencies television channels, radio stations, SMS, etc. - Sharing brief project information to Any stakeholder group identified Project information provide regular updates throughout the project including brochures/leaflets - Informing the stakeholders on certain project affected communities and issues such as land acquisition, land entry 22 Engagement Application/Objective of the Method Target Stakeholder Method and exit, project implementation schedule, PAPs, businesses and the scope of project activities and organizations/agencies subprojects, etc. - Disseminating site-specific project information - Information sharing on a specific topic to a group of people including disadvantaged/vulnerable groups - Receiving comments, feedback, views, and perception regarding the project from Any stakeholder group identified Online meeting a certain group throughout the project, including (alternative tool if - Collecting grievances, concerns and project-affected people, needed) feedback related to the project from a disadvantaged/vulnerable groups, group etc. - Monitoring project activities’ environmental and social impacts and risks on a group - Establishing relations with local communities - Receiving and resolving any requests (such as Grievance suggestions, complaints, compliments, Any stakeholder group identified Mechanism (GM) inquiries for information or whistle-blower throughout the project complaints) from project stakeholders 5.2. Stakeholder Engagement Program Stakeholder engagement is an ongoing process that begins before the development of this SEP and will continue throughout Project lifecycle. TEİAŞ will provide all relevant and available information for TSTP to the public through different communication channels (social media, official webpage, announcements, community representatives, local CSOs/NGOs, etc). All project-related documents, and materials will be disclosed and made available throughout the life of the project on the official webpage of the TEİAŞ. 23 All stakeholders, including the public, will be able to use the Grievance Mechanism (GM). The goal of the GM is to strengthen accountability to the people and to provide channels for project stakeholders to provide feedback and/or express their concerns and grievances related to project activities. Detailed information about GM is given in Section 7. TEİAŞ will prepare Project communication materials such as brochures, and posters for informative purposes and these materials will be delivered to the relevant stakeholders. TEİAŞ will be responsible for the disclosure of environmental and social instruments (ESMP/ESIA, SEP, LAP, GM procedure, etc.) before the commencement of the project so that the stakeholders will be informed about the project details and communication channels to raise their requests (suggestions, grievances, questions, etc.) regarding the Project. TEİAŞ will be responsible for the disclosure and consultation of all environmental and social instruments prepared within the scope of the Project for 14 days to ensure the dissemination of sufficient information to all stakeholders about project activities. Details on the communication methods implemented and planned to be implemented throughout the project activities are given in Table 2. 24 Table 3 Stakeholder Engagement Program Project Phase Consultation List of information to be Method to be Used Target Stakeholder Frequency Responsible Subject/Message to be disclosed Party delivered  Inform the  Non-technical summary  Opening meeting  Project Before the stakeholders about of the project, E&S  Public announcements Affected commencement of the scope of and principles and  Non-technical project Parties component requirements for the obligations summaries/presentations  Disadvantaged/ activities Project.  E&S documents (ESMF,  Electronic publications  Vulnerable  Consult the RP, LMP, SEP)  Social media individuals or Throughout the stakeholders about;  Press releases groups project lifecycle o Project  Consultation meetings  Other design, (virtual/face-to-face) interested o Eligibility  Digital communication tools parties criteria,  Grievance Mechanism including Preparation  Poster, brochure, leaflet, etc.  TEİAŞ options in  SMS case of non- eligibility  Engagement with vulnerable o environmental groups will be tailored to and social ensure safety and their risks and inclusion as part of the sub- impacts, project design. o proposed mitigation measures,  ESMF, RPF, SEP, LMP  Inform the  ESMPs  Public announcements  Project Before the start of stakeholders about  RPs  Non-technical project Affected implementation of the project scope  GM procedure summaries/presentations Parties the project, and as and ongoing  Regular updates on  Electronic publications  Disadvantaged/ needed during the activities, including Project development/  Social media  Vulnerable project lifecycle any emerging issues implementation  Press releases individuals or Implementation and/or problems  Consultation meetings groups  TEİAŞ &  E&S documents (virtual/face-to-face)  Other  Contractor Construction (ESMF, ESMPs,  Digital communication tools interested OHSP, etc.)  Grievance Mechanism parties  GMs  Poster, brochure, leaflet, etc.   SMS  Engagement with vulnerable groups will be tailored to 25 Project Phase Consultation List of information to be Method to be Used Target Stakeholder Frequency Responsible Subject/Message to be disclosed Party delivered ensure safety (in case there are grievances) as well as to enable their views to be captured.  GM  Project outputs  Closing Meeting  Project After completion of  Redress of grievances  Consultation meetings Affected sub-project  Disclosure meetings, Parties activities, during  Digital Communication  Disadvantaged/ the one-year Tools/social media  Vulnerable warranty period  Poster, brochure, leaflet, individuals or Operation etc. groups  TEİAŞ  SMS Other interested  As above on parties disadvantaged/vulnerable groups. 26 5.3. Strategy to be Implemented to Incorporate Views of Disadvantaged/Vulnerable Groups It is important to assess the impacts of project activities on vulnerable groups. In order to ensure and strengthen the participation of disadvantaged/vulnerable groups in stakeholder consultation processes, awareness-raising activities and stakeholder engagement activities relating to the project must be implemented by taking into account the difficulties and cultural sensitivities specific to these groups and individuals. Special measures and support are needed to ensure that disadvantaged/vulnerable groups and individuals are aware of the stakeholder engagement process and that their contributions to the process are balanced with those of other stakeholders. Within the scope of this Project, disadvantaged/vulnerable individuals and groups may include the disabled, the elderly, immigrants, refugees and individuals and groups who do not speak Turkish. In the context of sub-projects, disadvantaged/vulnerable groups will be identified during the ESMP/ESIA studies and special measures will be determined to ensure the effective participation of these groups in the consultation processes of the project. In particular, these groups experience some disadvantages in benefiting from public services and these groups are likely to be directly affected by the Project. Table 4 summarizes the preliminary mapping conducted to identify disadvantaged/vulnerable individuals/groups, as well as the proposed stakeholder engagement methods for each disadvantaged/vulnerable individual/group. Stakeholder categories, including disadvantaged/vulnerable individuals/groups, and accordingly this SEP will be updated prior to the commencement of any project activities. Table 4 Summary of Disadvantaged/Vulnerable Individuals/Groups and Recommended Stakeholder Engagement Methods Vulnerable Features/Needs The preferred Additional Resource Individuals/ method for Support Groups information sharing and consultation Funding for training and Audio devices, Special education communication strategy , accessible platforms, coordinators, sign language including development of materials, prepared translators/interpreters communication materials, to using braille alphabet, Disabled individuals assist individuals with a lack of etc. special training accessibility, information and needs special needs Easily accessible meting venues 27 Lack of knowledge and Organizing meetings in inexperience about accessibility, accessible locations, on Transportation support online tools, services and days and times that communication channels will increase their participation Elderly individuals Providing information in accessible language and format Accessibility (Difficulty in Translation of Translation, interpretation accessing information and brochures prepared for support communicating due to language the project into barriers) different languages Individuals who do not speak Turkish Providing interpretation support during the meeting Accessibility, lack of Communication in Transportation support information accessible areas using ccessible methods (determining the Pregnant women meeting venue and and/or women with time in a way that young kids increases women's participation) Separate information meetings for women Accessibility, lack of Determining the Transportation support information meeting venue and time in a way that will Female-headed increase women's households participation Separate information meetings for women To include the views of vulnerable groups;  Engagements will be carried out with regional organizations and NGOs representing the rights of persons with disabilities;  Separate consultations will be conducted for elderly individuals and disabled individuals (or people with additional accessibility needs), immigrant children, refugees and non-Turkish speakers, and other disadvantaged/vulnerable groups who may be identified during the project;  Information on the project will be provided face to face or by any other appropriate method specific to disadvantaged/vulnerable groups/individuals to be specified or already specified (e.g. alphabet for the visually impaired, sign language, etc.);  Consultations will be conducted at locations that provide access to disadvantaged/vulnerable 28 groups/individuals; and  Any written or printed materials related to the project to be distributed at project sites should be accessible to the disadvantaged/vulnerable groups/individuals of the project; the materials will also be prepared in culturally appropriate and easy to understand (non-technical) language. 5.4. Process of Feedback to Stakeholders Draft versions of all environmental and social framework documents prepared for the Project (Environmental and Social Management Framework, Stakeholder Engagement Plan, Resettlement Policy Framework, Labor Management Plan) and specific documents to be prepared for sub-projects (Environmental Social Management Plan, Environmental Social Impact Assessment, Resettlement Plan, etc.) will be disclosed to all relevant stakeholders and consultation meetings will be held following the disclosure process. Information meetings and relevant announcements will be held under the leadership of TEİAŞ environmental and social experts. Necessary services will be procured during the logistics and organization of these meetings. Information meetings will be announced through official correspondence, e-mails, Project website, social media accounts of the project/institution (or various similar means and platforms of communication). Attention will be paid to make sure that TEİAŞ environmental and social experts and representatives of TEİAŞ technical experts participate in the meetings, and during the meeting, a presentation will be made on the content of the documents prepared specifically for the project, the technical summary of the project, the possible environmental and social impacts/risks of the project and the measures by which these impacts/risks will be controlled, the roles and responsibilities of the responsible parties in the project implementation and the Complaint Mechanism. Details about these information meetings will be posted on the official website of TEİAŞ following the completion of the meeting. TEİAŞ’s social expert will be in contact with relevant stakeholder groups throughout project lifecycle. Stakeholders will be informed about the environmental and social performance of the project, the implementation of the stakeholder engagement plan and the Grievance Mechanism, and the overall progress of the project. The methods shown in Table 2 will be applied for feedback. 29 5.5. Review of Feedback from Stakeholders Ongoing feedback and comments received from the stakeholders throughout the project implementation will be reviewed and necessary remediate actions, if needed, will be undertaken by the TEİAŞ to secure smooth implementation of the Project. Additionally, the project GM will be in place during the entire lifetime of the project to receive any concerns from both internal and external stakeholders. 30 6. ROLES AND RESPONSIBILITIES FOR IMPLEMENTATION OF STAKEHOLDER ENGAGEMENT TEİAŞ will be responsible for the overall implementation of TSTP and also this SEP. The existing units implementing different WB financed projects within TEİAŞ have qualified technical staff who have experience in managing design, and construction, and they will work for TSTP Project as well. Table 5 below presents the roles and responsibilities of different parties to be involved in TSTP. Table 5 Responsibilities of Key Actors/Stakeholders in SEP Implementation Responsible Party Responsibilities  Incorporating all stakeholder engagement activities into the environmental and social management systems  Developing an internal system to communicate progress and results of stakeholder engagement to the senior management and staff members  Appropriately implementing and monitoring the processes relating to Grievance Mechanism and stakeholder engagement  Coordinating the parties for proper implementation of processes relating to grievance mechanisms and stakeholder engagement issues  Planning and implementation of the stakeholder engagement activities in line with SEP  Leading stakeholder engagement activities with identified stakeholders Social Expert in TEİAŞ  Coordinating interface and reporting to/from World Bank to implementation of Directorate General SEP  Updating the SEPs periodically and upon major Project changes  Recording and following up on grievances relevant to the Project  Managing and coordinating the resolution of grievances within the Project  Reviewing grievance records to illustrate significant non-compliance issues or recurring problems regarding stakeholder engagement and other Project activities and coming up with actions  Coordinating and monitoring GM contact person at consultant and contractor levels  Consolidating Project related grievances from all different GM levels  Informing the management about the resolution process  Preparing consolidated GM reports of the Project  Monitoring the project's progress Environment Expert in  Ensuring the successful delivery of all defined documentation TEİAŞ Directorate  Consolidated reporting on overall SEP activities and the project progress General  Implementing social and environmental monitoring  Monitoring and reporting to the management whether the social and 31 environmental requirements specified in related documents are implemented throughout the Project's lifecycle  Recording complaints, suggestions and feedback regarding all field activities, informing the relevant units about the complaints and ensuring that the complaints are resolved within 30 days at the latest and providing feedback to the complainant  Recording all kinds of complaints, suggestions and feedback received, using the format provided in Annex-3 GM Focal Point in  Sharing complaints, suggestions and feedback records with the Social Expert in TEİAŞ Directorate TEİAŞ General Directorate on a monthly basis General  Immediately forwarding complaints received on sensitive issues such as sexual harassment, exploitation, sexual abuse to the Social Expert in TEİAŞ General Directorate , and acting in accordance with the actions reported by TEİAŞ General Directorate  Reporting the status of complaints to TEİAŞ General Directorate on a monthly basis  Recording complaints, suggestions and feedback regarding all construction activities on site, informing the relevant units about the complaints and ensuring that the complaints are resolved within 30 days at the latest and providing feedback to the complainant  Recording of all kinds of complaints, suggestions and feedback received, using the format given in Annex-3 Contractor’s  Sharing the records of complaints, suggestions and feedback with TEİAŞ Environmental and Social Regional Directorate GM Focal Point on a weekly basis Expert  Recording complaints, suggestions and feedback received on issues regarding expropriation and other matters that concern TEİAŞ directorates in writing and forwarding them to the relevant regional directorates without wasting time  Forwarding complaints received on sensitive issues such as sexual harassment, exploitation and sexual abuse immediately to the Social Expert in TEİAŞ General Directorate, and acting in accordance with the actions reported by TEİAŞ 7. GRIEVANCE MECHANISM The Grievance Mechanism (GM) is an arrangement that provides any stakeholder with channels to submit their grievances/concerns/suggestions on how the project is planned, constructed, or implemented. To achieve transparency and accountability and meet the related standards of WB, a project-specific Grievance Mechanism (GM) will be established and will be implemented during the project life cycle. 32 The goal of the GM is to strengthen accountability to beneficiaries and to provide channels for project stakeholders to provide feedback and/or express their concerns and grievances related to project activities. The GM is a mechanism that allows also for the identification and resolution of issues affecting the project. By increasing transparency and accountability, the GM aims to reduce the risk of the project inadvertently affecting citizens/beneficiaries and serves as important feedback and learning mechanism that can help improve project impact. The mechanism focuses not only on receiving and recording complaints but also on their resolution process. While feedback should be handled at the level closest to the complaint, all complaints should be registered and follow the basic procedures set out in this chapter. Within the scope of the TSTP, grievances/concerns/suggestions will be handled at multiple levels: (a) TEİAŞ Directorate General, (b) TEİAŞ Regional Directorate, (c) Contractor, and (d) national level through existing GMs of the Republic of Türkiye. TEİAŞ Grievance Mechanism (at the levels of General Directorate and Regional Directorates) Within the scope of the project, TEİAŞ is the main party responsible for collecting, recording and resolving all complaints/concerns/suggestions submitted by stakeholders at the above-mentioned levels. There will be a central grievance log to be kept by TEİAŞ. TEİAŞ is responsible for resolving the complaints/concerns/suggestions within 30 days and informing the owner of complaint/concern/suggestion about the result. TEİAŞ can currently be reached via phone, social media and website. These communication channels are available for all field activities executed by TEİAŞ. TEİAŞ Regional Directorates will also be responsible for ensuring the management of complaints at the level of sub-projects carried out in their regions. The Grievance Mechanism Focal Points to be appointed in Regional Directorates will ensure the operation of the mechanism. The communication channels of TEİAŞ General Directorate and relevant departments are listed in the table below, and the phone numbers and email/mail addresses of all Regional Directorates that will take part in the project will also be given in the table below. Table 6 Project-Specific Channels for Rceeiving Grrievances Website https://www.teias.gov.tr/ Phone Number of TEİAŞ Gneeral Directorate (0312) 203 80 00 - 80 01 Phone Number of Environment Directorate (0312) 203 86 11 Phone Number of Expropriation Directorate (0312) 203 85 67 Phone Number of OHS Directorate (0312) 203 85 55 33 Registered Email (KEP) Address teias@hs01.kep.tr Mail Adresi Nasuh Akar Mah. Türkocağı Cad. No: 12 Balgat, Çankaya/ANKARA Grievance Mechanism at Contractor Level Each contractor appointed to carry out construction works will be responsible for establishing and implementing a Grievance Mechanism within their own organization. Contractors are responsible for receiving, recording and, if possible, resolving concerns and complaints raised by any stakeholders (public building management, building users, visitors, host communities or beneficiaries, project employees, etc.). Contractors are responsible for eliminating any damages and disturbances to the community and the environment resulting from construction work carried out within the scope of the project, taking necessary measures and, in cases where the measures are inadequate, compensating for the damages. TEİAŞ will require contractors to develop a grievance mechanism for their workers, including subcontractors, before starting work, and to hire an Environmental & Social expert responsible for managing complaints. The Environmental & Social Expert to be employed by the contractor will be responsible for recording complaints, following them up, forwarding them to the relevant units, taking necessary actions, resolving the grievances and closing them through mutual agreement. The contractor is responsible for referring the issue to the relevant TEİAŞ Regional Directorate in cases where the contractor cann ot resolve the complaints itself or in cases where the complaints do not fall within their scope of responsibility. Contractors will record all complaints, feedback and suggestions received from external stakeholders and employees in the format provided in Annex-3 and submit these records to the relevant TEİAŞ Regional Directorate every week. Contractors are responsible for announcing the grievance mechanism communication channels to external stakeholders and employees as soon as the construction activities of the subprojects commence. Presidency Communication Center (CİMER) In addition to the communication channels mentioned above, stakeholders can also use the Presidency Communication Center (CİMER) to convey their concerns and complaints regarding the imp lementation of the project. CİMER's communication channels are given below. CİMER provides a centralized complaint system that can be used by Turkish citizens, legal entities and foreigners. CİMER can be used as an alternative and well-known channel for Project stakeholders to convey their complaints and feedback regarding the Project directly to government authorities. Table 7 CİMER’s Channels to Receive Grievances Website www.cimer.gov.tr 34 Call Center 150 Phone Number +90 312 525 55 55 Fax No. +90 312 473 64 94 Mail Address Türkiye Cumhuriyeti İletişim Başkanlığı Individual applications at the community relations desks at governorates, ministries and district governorates Foreigners Communication Center (YİMER) YIMER has been providing a centralized complaint system for foreigners. YIMER will be available to Project stakeholders as an alternative and well-known channel for conveying their Project-related grievances and feedback directly to government authorities. Table 8 YİMER’s Channels to Receive Grievances Website www.yimer.gov.tr Call Center 157 Phone Number +90 312 157 11 22 Fax No. +90 312 920 06 09 Mail Address Türkiye Cumhuriyeti İletişim Başkanlığı Individual applications at the community relations desks at governorates, ministries and district governorates 7.2. Identification of Grievance Mechanism Under the project, the grievance mechanism will operate at the levels of TEİAŞ General Directorate, TEİAŞ Regional Directorates and Contractors. Detailed management responsibilities regarding how complaints will be managed at each level are given in the table in Annex-4. The information in this section should be read in conjunction with the table in Annex-4. Complaints/concerns/suggestions collected through different channels will be recorded by TEİAŞ and will be responded to within 30 days. Comments or concerns will be communicated verbally or in writing (by mail or e-mail) or by filling in the complaint form provided in Annex-1. The Complaint Form for the construction phase of the project will be published on TEİAŞ’s website (https://www.teias.gov.tr/cevre-ve- kamulastirma/cevre-dokumanlari). Printed copies will be available at the premises of relevant buildings/public institutions (when construction activities commence) and at the buildings of local communities located near the project areas. Confidentiality and the right to lodge anonymous complaints will be secured. The complaint registration form shall have all the necessary elements to disaggregate the persons submitting 35 the complaint by gender and type of complaint. Each complaint shall be verified in the grievance log with the following information: a) description of the complaint; b) date the complaint was received and when the acknowledgment of receipt was notified to the complainant; c) description of the measures taken (investigation, remediate measures and preventive measures); d) resolution and closing date and feedback to the complainant. In cases where the suggestion or complaint received is unclear or not clear enough, TEİAŞ will provide advice and help to format/edit the issue/complaint in order to make informed decisions in the best interest of project affected persons. If TEİAŞ is unable to promptly respond to the submitted grievances through remediate action, then long- term remediate action will be identified. The complainant will be informed of the proposed remediate action within 30 calendar days after the complaint has been acknowledged. If TEİAŞ is unable to respond to a specific issue verified through the grievance mechanism or does not require any action, then it will provide a detailed explanation/justification as to why the issue was not addressed. The response will also include an explanation of how the individual/organization reporting the issue or complaint may proceed with the complaint if the result is not satisfactory. As applicable in all cases, complainants may seek other legal remedies, including formal judicial appeal, in accordance with the legal framework of the Republic of Türkiye. Detailed management responsibilities of the Grievance Mechanism are presented in Annex 4. Information on the functioning of the grievance mechanism can be found in Table 9. Table 9 Grievance Mechanism Phase Description of Process Timeline Responsibility Receipt of Complainants can submit their Throughout  TEİAŞ GD Social Expert Grievance grievances to the GM through any Project  TEİAŞ Regional designated communication channel lifecycle Directorate GM Focal using the relevant communication Point channels of the project.  Contractor’s E&S Expert  TEİAŞ Phone No.: (0312) 203 80 00  Website: https://www.teias.gov.tr/iletisi m  E-mail  Compliant boxes 36  During consultation meetings Registration of It is entered to the grievance log (see Within 3 days  TEİAŞ GD Social Expert Grievance Annex-3) and Grievance Form (See after receiving  TEİAŞ Regional Annex-1). grievance Directorate GM Focal Point  Contractor’s E&S Expert Referral of The grievance is forwarded to the Immediately  TEİAŞ GD Social Expert Grievance person/unit responsible for reviewing after  TEİAŞ Regional the grievance within 15 days, at the registration of Directorate GM Focal latest, from the date of receipt of the grievance Point grievance (except for urgent grievances  Contractor’s E&S Expert that must be handled with priority). Evaluation of The grievance received is handled by Within 15 days  TEİAŞ GD Social Expert Grievance the TEİAŞ GM focal point and the after  TEİAŞ Regional relevant person/unit. If it is concluded submission of Directorate GM Focal that it should not be processed, as a grievance Point result of the evaluation, a written  Contractor’s E&S Expert explanation is made to the complainant along with the reason and the complaint is closed. If it is concluded that the complaint should be processed, remediate measures are determined to correct the complaint within 15 days from the date of receipt. A response is then prepared and submitted to the complainant. Providing Necessary measures are taken  TEİAŞ GD Social Expert Feedback regarding the complaint and the  TEİAŞ Regional complainant is informed/responded to Directorate GM Focal using the same communication channel. Point The Grievance Close-Out Form (See  Contractor’s E&S Expert Annex-2) is filled out and detailed information regarding the response is recorded. Conclusion of Result is recorded in the grievance log. Within 30  TEİAŞ GD Social Expert Feedback days after  TEİAŞ Regional receiving Directorate GM Focal grievance Point  Contractor’s E&S Expert Monitoring and Whether the grievance has been Quarterly  TEİAŞ GD Social Expert Evaluation eliminated in line with the solution  TEİAŞ Regional found is monitored Directorate GM Focal Point  Contractor’s E&S Expert 37 7.3. World Bank’s 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 to address project-related concerns. Project-affected communities and individuals may submit their complaints to the WB’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB's 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 allowed 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-redress-service. Project-affected communities or individuals can also raise their grievances to the World Bank Independent Inspection Panel (IIP). This panel determines whether the person or communities that made the complaint were harmed because of the breach of one or more of the WB's performance criteria. The panel can directly convey its concerns about the complaints received to the WB. At this stage, WB would have an opportunity to respond to the complaints. For information on how to submit complaints to the World Bank Inspection Panel, please visit www.inspectionpanel.org. 7.4. Workers’ Grievance Mechanism A separate grievance mechanism will be available for the workers, through which they will be able to report working conditions, financial, child/forced labor, legal issues, and other issues such as gender-based discrimination in the workplace, with special attention to sexual harassment. Specifically building awareness and a GM hotline for gender-based violence (GBV) and abuse in the workplace for female workers (both at the construction site and in the buildings under the project) will be emphasized. There will also be awareness-raising discussions with both men and women regarding appropriate workplace behavior. TEİAŞ will develop and implement a grievance mechanism for their workforce including sub -contractors, before the start of work. The workers’ grievance mechanism will include; (i) a procedure describing the flow of the GM, (ii) timeframes to respond to grievances and to resolve cases, (iii) a register sheet to record and track the timely resolution of grievances; (iv) a focal point responsible for receiving, recording, addressing and tracking resolution of grievances. 38 The workers will be informed about the existence of the grievance mechanism which will be available to all project workers (direct and contracted; including TEİAŞ staff) through notice boards about the availability of “suggestion/complaint boxes” at the site, and other means as needed. In ad dition, the workers’ grievance mechanism will be described during the staff induction trainings, which will be provided to all project workers. The mechanism will be based on the following principles:  The process will be transparent and allow workers to express their concerns and file grievances.  There will be no discrimination against those who express grievances and any grievances will be treated confidentially.  Anonymous grievances will be treated equally as other grievances, whose origin is known Information about the availability of the workers’ grievance mechanism will be available to all project workers (direct, contracted,) through notice boards, the presence of “suggestion/complaint boxes” at, the call center, announcements during training, seminars, meetings, access link on the main page of project website, project printed materials that will be distributed to workers, social media and other means as needed. The Project grievance mechanism will not prevent project workers to use other judicial or administrative remedies available under the law. The project grievance mechanism must be established by Project effectiveness date. TEİAŞ will develop and adapt its current grievance and complaints procedures and mechanisms for the project's necessities. TEİAŞ will be responsible for managing the grievance mechanism and responding to grievances and complaints received in the scope of the Project In addition, the project GM will include a communication channel to receive and address confidential complaints relating to Sexual Exploitation, Abuse/Sexual Harassment, with special measures in place. A detailed Labor Management Procedure (LMP) has been prepared specifically for the Project. Please refer to the LMP for details on the Workers' Grievance Mechanism. 7.5. Management of Sexual Exploitation, Abuse/Sexual Harassment Although the risk from project activities is moderate, the grievance mechanism will include handling Sexual Exploitation and Abuse/Sexual Harassment (SEA/SH) complaints. The GM that will be in place for the 39 project workers will also be used for addressing SEA/SH related issues and will have in place mechanisms for confidential reporting, with safe and ethical documenting of SEA/SH issues. The project GM will include a channel to receive and address confidential complaints related to SEA/SH, with special measures in place. If an employee faces SEA/SH issue s/he can either apply to a higher-level superior or go directly to the police, as stipulated in the national referral system of the country for dealing with such cases. The content and procedures of the project’s GM will also have a reporting line on such cases concerning SEA/SH issues and will be handled under full confidentiality and with the consent of the survivor. If TEİAŞ receives a SEA/SH related grievance, these grievances will be directed to national referral systems immediately and will be recorded. All details of the complainant of the sensitive case will be kept strictly confidential. When the Contractor and TEİAŞ Regional Directorates receive complaints about sensitive issues such as sexual harassment, exploitation, sexual abuse, they are responsible for immediately forwarding the complaint to the TEİAŞ General Directorate’s Social Expert. The forwarded complaint will be handled in line with the actions reported by TEİAŞ. 8. MONITORING AND REPORTING Monitoring and evaluation of the stakeholder engagement process are important to ensure TEİAŞ can respond to identified issues and alter the schedule and nature of engagement activities to make them more effective. It is the responsibility of TEİAŞ to implement the activities and tasks in the Stakeholder Engagement Plan on time and in the specified manner. In order to carry out effective stakeholder engagement within the scope of this Stakeholder Engagement Plan, the specified practices will be monitored and evaluated by TEİAŞ on a quarterly basis based on the performance indicators given in Table 10. Documents and monitoring reports of stakeholder engagement activities will be kept in the archives of TEİAŞ. TEİAŞ will submit reports to the World Bank four times a year, including a section on the GM, containing updated information on the following. The information to be presented in these reports will include the following at minimum:  Stakeholder engagement activities carried out and their breakdown by consultation methods used  Number of participants in stakeholder consultation activities, breakdown of participants by gender  GM implementation status (procedures, training, public awareness campaigns, budget, etc.), 40  Number of complaints received in a reporting period;  Number and percentage of complaints resolved within the prescribed time period;  Number of complaints open for more than 30 days and explanation of reasons;  Types of complaints and responses, qualitative data on issues raised and pending complaints;  Level of satisfaction with remediate actions (response);  Remediate measures taken. Table 10 Monitoring Indicators Monitorin Key Performance Project Responsible Subject Target g Indicators Phase Party Frequency Increase in the number of stakeholder Number of consultation engagement activities activities conducted to conducted inform stakeholder groups Increase in the number Stakeholde of different types of Before r stakeholders Project TEİAŞ Regional Engageme Number of participants in construct Monthly Directorate planned stakeholder Increase in the number nt ion Contractor engagement activities - of activity participants Activities begins category of participating Increase in the number stakeholders of people reached out by different stakeholder engagement activities Number of Complaints Received (disaggregated by gender, province and complaint category) Decrease in the number Number of Open or Closed- of grievances received out Grievances Average Grievance Closing Decrease in the time it Time takes to close out a Through TEİAŞ Regional grievances out Directorate Grievances Types of grievances Monthly Project Number of invalid lifecycle Contractor grievances (Grievance Increase in the rate of forms, other online and grievances closed out offline communication methods, etc.) Average response time to Call Center complaints and calls1 1 The average time between the complaint submission and the response, as specified in the complaint response report. 41 ANNEX 1. GRIEVANCE FORM Reference No Full Name (not mandatory, you can submit anonymously) Please mark how you wish to be contacted (by mail, telephone, or e-mail). Province/District/ Location Date Category of the Grievance 1. Project-affected assets/properties 2. Infrastructure 3. Decrease or complete loss of sources of income 4. Environmental issues (ex. pollution) 5. Employment 6. Traffic, transportation, and other risks 7- Other (if confidential, directly call TEİAŞ): 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? Although giving a name and address is not compulsory, it should be kept in mind that during the feedback process regarding the grievance, some problems may occur due to a lack of information. Signature: Date: 42 ANNEX 2. GRIEVANCE CLOSE-OUT FORM Grievance closeout number: Define immediate action required: Define long-term action required (if necessary): Compensation Required? [ ] YES [ ] NO CONTROL OF THE REMEDIATE ACTION AND THE DECISION Deadline and Responsible Stages of the Remediate Action Institutions 1. 2. 3. 4. 5. ACTIONS TAKEN CLOSE-OUT OF GRIEVANCE This part will be filled and signed by the complainant after s/he receives the compensation fees and/or his/her complaint has been remediated. Notes: Complainant [Name-Surname and Signature] Date: / / Representative of the Responsible Institution/Company [Name-Surname and Signature] 43 and Number Register Grievance Suggestion How Complaint is Received (Grievance Form, Community Meeting, Telephone, Alo 181, etc.) Date of Complaint Received Person Receiving Complaint/Suggestion ANNEX 3. GRIEVANCE LOG Channel Name/Surname and Position Level of Grievance (contractor, TEİAŞ Regional Directorate, TEİAŞ General Details on Grievance/Suggestion In-Take Directorate , Hotline 181, etc.) Name and Surname of the Complainant* Gender of the Complainant Complainant's E-mail* About the Complainant Complainant's Phone Number* Province in which the C/S is Relevant Institution Related to Complaint/Suggestion (Sub-Project) Project Component Related to Complaint/Suggestion Complaint Category (Renovation-related, environmental issues, restriction of access to building entrances, damage, complaints about workers, accidents, working conditions, About the Complaint/Suggestion employee rights, sexual exploitation and abuse, sexual harassment, etc.) Summary of Complaint/Suggestion The date when the complainant is informed that the complaint/suggestion has reached the system and is under evaluation Status of the Complaint Open, Closed, Pending Person/Department to whom Complaint/Suggestion is directed for resolution Action Planned Action Taken Due Date for Addressing the Grievance Closed Date of Grievance Where official letter, etc. Supporting confirmation ion Close-Out Documents for ble: photograph, appropriate/possi Grievance/Suggest etc.) not be to another details If the Please provide Closed/Resolved Complaint could institution/person (referral was made 44 ANNEX 4. DETAILED MANAGEMENT RESPONSIBILITIES OF GRIEVANCE MECHANISM 45 Grievance/ Suggestion Approval Appeal Description Assessing Body Action to be taken for addressing the grievances Closure Action to be taken in case of disagreement Receiving Body Authorities Part Further assessment will be taken by TEİAŞ. If the complaint is verbal, it will be recorded in Grievance/  A site visit would be held to collect more information about the Suggestion forms (this action will be taken for all types of If the complainant is issue/dispute, if appropriate.  CIMER grievances). satisfied with the  A virtual or face-to-face meeting would be conducted with the  Civil Courts of First Instance answers and actions  Administrative Court If an answer/ complainant to propose another remediate action, if possible. taken, the Close-Out remediate action can E&S Expert of E&S Expert of the Contractor will draft a response with Management  The final response will be prepared in line with the additional  Commercial Courts of First Instance Form with remediate be provided the Contractor explanations of remediate actions. of Contractor remediate actions (if any) and submitted to the complainant. actions and  Labor Courts immediately If the agreement is ensured, the proofing documents for the remediate explanations will be  Ombudsman signed by the actions taken will be collected and attached to the Grievance Close-Out Feedback including explanation and remediate necessary actions https://ebasvuru.ombudsman.gov complainant. Form to be signed by the complainant. to be taken will be shared with the complainant. If the complainant is not satisfied with the solution, s/he will be informed about the appeal process. Further-assessment will be made by the management. If the complaint is eligible and there is disagreement, then If the management decides the grievance is relevant to TSTP further assessment will be taken by TEİAŞ. Project activities and is eligible for assessment, the E&S Experts of the Contractor will assess the application and will draft If the complainant is  A site visit would be held to collect more information about the  CIMER a response to the Complainant with explanations and remediate satisfied with the issue/dispute, if appropriate.  Civil Courts of First Instance If it cannot be actions to be taken. answers and actions  Virtual or face-to-face meetings would be conducted with the  Administrative Court taken, the Close-Out complainant in order to propose another remediate action, if possible. ensured whether the Management of Management of  Commercial Courts of First Instance complaint is eligible Contractor Contractor Form with remediate  The final response will be prepared in line with the additional At the Contractor Level Feedback including explanation and remediate necessary actions actions and remediate actions (if any) and submitted to the complainant.  Labor Courts or not to be taken will be shared with the complainant. explanations will be  Ombudsman If the agreement is ensured, the proofing documents for the remediate signed by the https://ebasvuru.ombudsman.gov actions taken will be collected and attached to the Grievance Close-Out If the management decides the complaint is NOT relevant to complainant. Form to be signed by the complainant. TSTP Project activities, the Complainant will be informed; If the complainant is not satisfied with the solution, s/he will be informed accordingly, guidance will be provided to contact the relevant about the appeal process. party(-ies). Once the submitted request is clarified to be assessed under the Project’s GM and if there is still a disagreement with the actions taken, E&S Expert of the Contractor will assist and provide advice in further assessment will be taken by TEİAŞ. If the complainant is  CIMER formulating/ redrafting the submission, to ensure that the  A site visit would be held to collect more information about the grievance is clear enough for assessment in the best interests of satisfied with the  Civil Courts of First Instance issue/dispute, if appropriate. If the submitted answers and actions persons affected by the Project.  Virtual or face-to-face meetings would be conducted with the  Administrative Court grievance or taken, the Close-Out concern is indefinite E&S Expert of Management of Form with remediate complainant in order to propose another remediate action, if possible.  Commercial Courts of First Instance the Contractor Contractor  The final response will be prepared in line with the additional or is not clear After necessary revisions are made to the complaint to ensure actions and  Labor Courts it is detailed enough for assessment and the complaint is remediate actions (if any) and submitted to the complainant. enough explanations will be  Ombudsman assessed; feedback including necessary actions taken will be sent signed by the If the agreement is ensured, the proofing documents for the remediate https://ebasvuru.ombudsman.gov to the complainant. complainant. actions taken will be collected and attached to the Grievance Close-Out Form to be signed by the complainant. If the complainant is not satisfied with the solution, s/he will be informed about the appeal process. Draft assessment will be sent to the GM contact person of TEİAŞ. If the complainant is If the If there is still a disagreement with the actions taken, further assessment will  CIMER satisfied with the be taken by TEİAŞ. issues/disputes are Considering the draft assessment shared by the Contractor, the  Civil Courts of First Instance explanation provided related to the project Management of GM contact person of TEİAŞ Regional Directorate will draft a  A site visit would be held to collect more information about the TEİAŞ and actions taken, the  Administrative Court but cannot be Contractor response with explanations and remediate actions to be taken. issue/dispute, if appropriate. Close-Out Form with  Commercial Courts of First Instance addressed at the The final response will be prepared and shared with the remediate actions and  A virtual or face-to-face meeting would be conducted with the contractor level complainant. complainant in order to propose another remediate action, if possible.  Labor Courts explanations will be 46 Grievance/ Suggestion Approval Appeal Description Assessing Body Action to be taken for addressing the grievances Closure Action to be taken in case of disagreement Receiving Body Authorities Part signed by the  The final response will be prepared in line with the additional  Ombudsman complainant. remediate actions (if any) and submitted to the complainant. https://ebasvuru.ombudsman.gov If the agreement is ensured, the proofing documents for the remediate actions taken will be collected and attached to the Grievance Close-Out Form to be signed by the complainant. If the complainant is not satisfied with the solution, s/he will be informed about the appeal process. The complaint will be referred to the management of the contractor. If the worker is In case of disagreement, the complaint will be directed to TEİAŞ.  CIMER If the grievance can be resolved immediately, the Contractor will satisfied with the  Civil Courts of First Instance identify and take necessary actions. If not, the grievance will be explanation provided  Administrative Court escalated to TEİAŞ for necessary actions to be identified and TEİAŞ will organize a meeting with the worker to further assess potential When a contractor’s and actions taken, the worker issues a E&S Expert of taken. TEİAŞ Close-Out Form with remediate actions that can be taken and additional information to be  Commercial Courts of First Instance the Contractor If the grievance is repetitive, extensive, and high-profile that may provided, as appropriate. complaint remediate actions and  Labor Courts jeopardize the Project or the reputation of the Bank then the explanations will be  Ombudsman grievance will be escalated to TEİAŞ and necessary actions to be signed by the If the worker is still dissatisfied with the recommended additional actions https://ebasvuru.ombudsman.gov taken will be identified. complainant. or explanation, s/he will be informed about the appeal process. The response with the appropriate solution and actions to be taken will be prepared and shared with the complainant. If the complainant is not satisfied with the result, the grievance will be conveyed to TEİAŞ Directorate General for further assessment. If the complainant is TEİAŞ Regional Directorates satisfied with the In case an answer/remediate action can be taken immediately;  A site visit would be held to collect more information about the  CIMER explanation provided the responsible person will take the required remediate action to issue/dispute, if appropriate.  Civil Courts of First Instance resolve the grievance and inform TEİAŞ Directorate General and remediate If the complaint is Regional actions taken, the  A virtual or face-to-face meeting would be conducted with the  Administrative Court Regional about the grievance and the remediate action taken via GM complainant to propose another correction action, if possible. related to the Grievance Log. Directorate Close-Out Form  Commercial Courts of First Instance activities of an Directorate GM GM contact including the  The final response will be prepared in line with the additional contact person remediate actions (if any) and submitted to the complainant.  Labor Courts ongoing sub-project person remediate actions and Feedback including explanation and remediate necessary actions explanations will be  Ombudsman to be taken will be shared with the complainant. signed by the If the agreement is ensured, the proofing documents for the remediate https://ebasvuru.ombudsman.gov complainant. actions taken will be collected and attached to the Grievance Close-Out Form to be signed by the complainant. If the complainant is not satisfied with the solution, s/he will be informed about the appeal process. Further-assessment will be made by TEİAŞ . Feedback including If the complainant is not satisfied with the result, the grievance will be necessary actions conveyed to TEİAŞ for further assessment. If TEİAŞ decides the grievance is relevant to TSTP Project taken will be sent to activities and is eligible for assessment, TEİAŞ focal point  A site visit would be held to collect more information about the  CIMER TEİAŞ General Directorate the complainant. (TEİAŞ General Directorate’s Social Expert) will assess the issue/dispute, if appropriate.  Civil Courts of First Instance application and will draft a response to the Complainant with  A virtual or face-to-face meeting would be conducted with the If it cannot be  Administrative Court explanations and remediate actions to be taken. If the complainant is complainant to propose another correction action, if possible. ensured whether the TEİAŞ TEİAŞ satisfied with the  The final response will be prepared in line with the additional  Commercial Courts of First Instance complaint is eligible answers and actions remediate actions (if any) and submitted to the complainant.  Labor Courts or not Feedback including explanation and remediate necessary actions taken, the Close-Out to be taken will be shared with the complainant. If the agreement is ensured, the proofing documents for the remediate  Ombudsman Form with remediate actions taken will be collected and attached to the Grievance Close-Out https://ebasvuru.ombudsman.gov actions and Form to be signed by the complainant. If TEİAŞ decides the grievance is NOT relevant to TSTP explanations will be If the complainant is not satisfied with the solution, s/he will be informed Project activities and is NOT eligible for assessment, the signed by the about the appeal process. Complainant will be informed; accordingly, guidance will be complainant. provided to contact the relevant party(-ies). 47 Grievance/ Suggestion Approval Appeal Description Assessing Body Action to be taken for addressing the grievances Closure Action to be taken in case of disagreement Receiving Body Authorities Part Once the submitted request is clarified to be assessed under the Project’s GM and if there is still a disagreement with the actions taken, further assessment will be taken by TEİAŞ. If the complainant is The GM Focal Point of TEİAŞ (TEİAŞ General Directorate’s Social Expert) will assist and provide advice in formulating/ satisfied with the  A site visit would be held to collect more information about the  CIMER redrafting the submission, to ensure that the grievance is clear answers and the issue/dispute, if appropriate.  Civil Courts of First Instance When the submitted enough for assessment in the best interests of persons affected by  A virtual or face-to-face meeting would be conducted with the action taken, the complainant to propose another remediate action, if possible.  Administrative Court the Project. grievance or TEİAŞ GM  The final response will be prepared in line with the additional  Commercial Courts of First Instance After necessary revisions are made to the complaint to ensure it TEİAŞ Close-Out Form with concern is indefinite focal point remediate actions (if any) and submitted to the complainant. is detailed enough for assessment and the complaint is assessed; remediate actions and  Labor Courts or not clear enough feedback including necessary actions taken will be sent to the complainant. explanations will be  Ombudsman If the agreement is ensured, the proofing documents for the remediate https://ebasvuru.ombudsman.gov signed by the actions taken will be collected and attached to the Grievance Close-Out complainant. Form to be signed by the complainant. If the complainant is not satisfied with the solution, s/he will be informed about the appeal process. TEİAŞ member submits his complaints to the TEİAŞ Human If the complainant is  CIMER TEİAŞ Human Resources Department and/or Institutional Communication satisfied with the  Civil Courts of First Instance Resources Directorate trough a petition, depending on the subject. answers and the  Administrative Court When member/s of Department This department will select an “Assessor”. Assessor will evaluate action taken, the  If the complainant is not satisfied with the solution, s/he is informed  Commercial Courts of First Instance TEİAŞ issues a and/or the grievance, make necessary inquiries, and reveal a summary TEİAŞ Close-Out Form with about the appeal proses  Labor Courts complaint Institutional report with remediate action(s). remediate actions and Communication explanations will be  Ombudsman Directorate General Manager will make a final decision and the complainer will signed by the https://ebasvuru.ombudsman.gov be informed about the decision. complainant. 48 FLOW CHART OF GRIEVANCE MECHANISM 1.Receive and Register Grievance Verbal (register verbal grievance by forms), Email, Alo 181, Phone, Form, Meeting, other 2. Assessment Acknowledge receipt and outline how grievance will be processed , assess eligibility, and assign organizational responsibility for proposing a response 3.Address Propose Response No Yes 4. Agreement on response? 4.2. Review the response 4.1 Implement agreed response Grievance focal points with upper management consider whether to revise the approach with additional corrective actions or close out Grievance resolved 4.2.1. Revise the approach with successfully. additional corrective and re-propose 4.2.2. Grievance closed out Grievance form is response sıgned by complainant and closed Yes Feedback Right to Appeal Agreement No on response? 49 TEİAŞ GRIEVANCE MECHANISM FLOWCHART 1.Receive and 1. Receive register and Register grievance Grievance Petition Petition Assessing 2.2. Body Assessing Body MoEUCC Institutional Department of Personnel Communication Directorate 3. Assessment 3. Assessment ForwardGrievance torelated to the the Grievance unit within any Department TEİAŞ. within the Ministry Department Selects Unit appoints an Assessor an assessor. 4. Address the grievance 4.Address Assessor prepares Assessor a Summary Prepares a SummaryReport with Report wıth Corrective Corrective Actions Actions Approval Body 5. 5.Approval Body General Manager of EIDGDoGA TEİAŞ General Directorate Yes 6. Cevap üzerinde anlaşma var mı? No Yes 6. Agreement on response? No 6.2 Review the Review 6.2. response the response Grievance Grievance focal points focal with upper points management with upper considerconsider management whether to Implement 6.16.1 agreed Implement agreed response response revise the approach with additional corrective actions or close out whether to revise the approach with additional corrective actions or close out 6.2.1 Revise the approach with additional 6.2.1. Revise the approach with additional Grievance redressed successfully. correction action and re-propose response 6.2.2. 6.2.2 Grievance closed Grievance closed out out corrective and re-propose response Grievance Form is signed Grievance by the resolved complainant and closed. successfully. Grievance form is sıgned Feedback Right by complainant and closed Feedback Right to Appeal to Appeal Yes Yes Agreement on No No Agreement response?on response? 50 ANNEX 5. RECORDS OF STAKEHOLDER CONSULTATION ACTIVITIES An information meeting regarding the said ISDP project and the prepared documents was held on 21.03.2025 at 14:00, both physically at the TEİAŞ General Directorate – Department of Environment and Expropriation, 14th Floor, Meeting Room No. 11, and simultaneously online via the “Microsoft Teams” application (Meeting ID: 935 987 100 551 6 Access code: 9qo9sh), to which internal and external stakeholders were invited. The governorships (being the highest local administrative authorities) of the provinces where the sub- projects are planned (Istanbul, Bursa, Çanakkale, Kocaeli, İzmir, Ankara, Aksaray, Samsun, Şanlıurfa, Kahramanmaraş, Gaziantep, Mersin, Hatay, Antalya, Edirne, Tekirdağ, Muğla, Aydın, Kastamonu, Adana, Balıkesir, Sakarya); the General Directorate of Environmental Impact Assessment, Permit and Inspecti on; the General Directorate of Electricity Generation Corporation (EÜAŞ); the General Directorate of Occupational Health and Safety; the General Directorate of Highways; the General Directorate of Spatial Planning; the General Directorate of National Property; the General Directorate of Forestry (OGM); the General Directorate of Land Registry and Cadastre; the General Directorate of Agricultural Reform; TESAB – Turkish Electricity Industry Association; Turkish Wind Energy Association (TÜREB); and International Solar Energy Society – Turkey Section (GÜNDER) were invited to the meeting via the official letter dated 14.03.2025 and numbered 3001130. The meeting was held simultaneously in both physical and online formats on 21.03.2025. Presentations were delivered to the participants regarding the ISDP components, its objectives and benefits, and the prepared environmental and social documents. As seen in the meeting minutes provided in below, the number of participants attending the physical meeting remained constant, whereas the number of online participants varied. During the meeting, no questions were raised nor feedback provided by the participants. However, the contact information, which participants may access after the meeting as well, was reiterated. 51 T.C. ENERJİ VE TABİİ KAYNAKLAR BAKANLIĞI Türkiye Elektrik İletim Anonim Şirketi Genel Müdürlüğü Çevre ve Kamulaştırma Dairesi Başkanlığı Sayı : E-61576037-611.02-2995575 14.03.2025 Konu : Paydaş Katılım Toplantısı DAĞITIM YERLERİNE Elektrik iletim sistemimizin yenilenmesi, güçlendirilmesi, daha da dijitalleştirilerek, kaliteli ve ekonomik olarak planlanması, tesis edilmesi ve buna bağlı olarak büyük ölçekli yenilenebilir enerji entegrasyonunu kolaylaştırarak Türkiye'nin yenilenebilir enerji üretimini arttırmasına yardımcı olmak amacıyla finansmanı Dünya Bankasından sağlanacak olan Enerji İletim Sisteminin Dönüştürülmesi Projesi (TPTS) kapsamında Dünya Bankası politikaları gereğince hazırlanan "Çevresel ve Sosyal Yönetim Çerçevesi", "Paydaş Katılım Planı", "Yeniden Yerleşim Politikası Çerçevesi", "İşgücü Yönetim Prosedürleri" https://www.teias.gov.tr/duyurular adresinde Türkçe ve İngilizce olarak paylaşılmış olup, görüşlere açılmıştır. Bahse konu TPTS projesi ve hazırlanan dokümanlar ile ilgili 21.03.2025 tarihinde, saat 14:00'da TEİAŞ Genel Müdürlüğü-Çevre ve Kamulaştırma Dairesi Başkanlığı 14. Kat, 11 numaralı toplantı salonunda ve aynı zamanda "Microsoft Teams" uygulaması üzerinden (Toplantı Kimliği:935 987 100 551 6 Geçiş kodu:9qo9sh) linki ile çevrimiçi gerçekleştirilecek bilgilendirme toplantısına katılımınızı arz/rica ederiz. Deniz COŞKUN Orhan KALDIRIM Genel Müdür Yardımcısı Yönetim Kurulu Başkanı Genel Müdür Dağıtım: Çevresel Etki Değerlendirmesi, İzin ve Denetim Genel Müdürlüğü'ne Elektrik Üretim Anonim Şirketi (EÜAŞ) Genel Müdürlüğü'ne İş Sağlığı ve Güvenliği Genel Müdürlüğü'ne Karayolları Genel Müdürlüğü'ne Mekânsal Planlama Genel Müdürlüğü’ne Milli Emlak Genel Müdürlüğü’ne Orman Genel Müdürlüğü (OGM)’ne Tapu ve Kadastro Genel Müdürlüğü'ne Tarım Reformu Genel Müdürlüğü’ne Bu belge, güvenli elektronik imza ile imzalanmıştır. Doğrulama Kodu: 469E569E-DC3B-4535-8027-BBFD2E3C8B35 ................................. Doğrulama ...... .... ........ .................. ........ ...... ........... Adresi: https://www.turkiye.gov.tr/teias-ebys .. ................ ................................... Nasuh Akar Mah. Türk Ocağı Cad. No:12 (06520) Balgat/Çankaya/ANKARA Bilgi için:Firdevs İrem KALE Sermaye: 17.731.798.237,00 TL Vergi D: Ankara Kurumlar ÜNLÜ Vergi No: 879 030 4314 ASO: 5887 ATO: 165458 Mühendis KEP Adresi : teias@hs01.kep.tr Telefon No:(312) 203 86 12 1/2 Adana Valiliği'ne Aksaray Valiliği'ne Ankara Valiliği'ne Antalya Valiliği'ne Aydın Valiliği’ne Balıkesir Valiliği'ne Bursa Valiliği'ne Çanakkale Valiliği'ne Edirne Valiliği'ne Gaziantep Valiliği'ne Hatay Valiliği’ne İstanbul Valiliği'ne İzmir Valiliği'ne Kahramanmaraş Valiliği'ne Kastamonu Valiliği'ne Kocaeli Valiliği'ne Mersin Valiliği’ne Muğla Valiliği’ne Sakarya Valiliği'ne Samsun Valiliği'ne Şanlıurfa Valiliği'ne Tekirdağ Valiliği’ne TESAB-Türkiye Elektrik Sanayi Birliği’ne Mustafa Kemal Mahallesi 2141 Sokak No:15/9 Ankara / TÜRKİYE Türkiye Rüzgâr Enerjisi Birliği (TÜREB)’ne Green Office Kızılırmak Mah. 1443 Cad. No:22/16 Ankara / TÜRKİYE Uluslararası Güneş Enerjisi Topluluğu - Türkiye Bölümü (GÜNDER)ne Via Green İş Merkezi Mustafa Kemal Mah. 2079 Sok. No: 2/B Ofis No: 35 Ankara / TÜRKİYE Bu belge, güvenli elektronik imza ile imzalanmıştır. Doğrulama Kodu: 469E569E-DC3B-4535-8027-BBFD2E3C8B35 ................................. Doğrulama ...... .... ........ .................. ........ ...... ........... Adresi: https://www.turkiye.gov.tr/teias-ebys .. ................ ................................... Nasuh Akar Mah. Türk Ocağı Cad. No:12 (06520) Balgat/Çankaya/ANKARA Bilgi için:Firdevs İrem KALE Sermaye: 17.731.798.237,00 TL Vergi D: Ankara Kurumlar ÜNLÜ Vergi No: 879 030 4314 ASO: 5887 ATO: 165458 Mühendis KEP Adresi : teias@hs01.kep.tr Telefon No:(312) 203 86 12 2/2 T.C. ENERJİ VE TABİİ KAYNAKLAR BAKANLIĞI Türkiye Elektrik İletim Anonim Şirketi Genel Müdürlüğü Çevre ve Kamulaştırma Dairesi Başkanlığı Sayı : E-61576037-611.02-3001130 14.03.2025 Konu : Paydaş Katılım Toplantısı DAĞITIM YERLERİNE İlgi : 14.03.2025 tarihli ve E-61576037-611.02-2995575 sayılı yazımız. İlgi'de kayıtlı yazımız ile Teşekkülümüz paydaşlarına elektrik iletim sistemimizin yenilenmesi, güçlendirilmesi, daha da dijitalleştirilerek, kaliteli ve ekonomik olarak planlanması, tesis edilmesi ve buna bağlı olarak büyük ölçekli yenilenebilir enerji entegrasyonunu kolaylaştırarak Türkiye'nin yenilenebilir enerji üretimini arttırmasına yardımcı olmak amacıyla finansmanı Dünya Bankasından sağlanacak olan Enerji İletim Sisteminin Dönüştürülmesi Projesi (TPTS) kapsamında Dünya Bankası politikaları gereğince hazırlanan "Çevresel ve Sosyal Yönetim Çerçevesi", "Paydaş Katılım Planı", "Yeniden Yerleşim Politikası Çerçevesi", "İşgücü Yönetim Prosedürleri"nin https://www.teias.gov.tr/duyurular adresinde Türkçe ve İngilizce olarak paylaşıldığı, görüşlere açıldığı bildirilmiş, hazırlanan dokümanlar ile ilgili 21.03.2025 tarihinde, saat 14:00'da TEİAŞ Genel Müdürlüğü-Çevre ve Kamulaştırma Dairesi Başkanlığı 14. Kat, 11 numaralı toplantı salonunda ve aynı zamanda "Microsoft Teams" uygulaması üzerinden (Toplantı Kimliği:935 987 100 551 6 Geçiş kodu:9qo9sh) linki ile çevrimiçi gerçekleştirilecek bilgilendirme toplantısına katılım talep edilmişti. Bahse konu paydaş katılım toplantısına Bölge Müdürlüğünüz bünyesindeki Çevre Başmühendisliğinden, Emlak ve Kamulaştırma Başmühendisliğinden ve İSG Biriminden Dünya Bankası kredili projelerin çevresel ve sosyal süreçlerinin yürütülmesinde çalışacak en az birer kişinin çevrimiçi olarak katılım sağlaması hususunda, Gereğini ve bilgilerinizi rica ederim. Gül MISIRLI Daire Başkanı Dağıtım: 1.BÖLGE MÜDÜRLÜĞÜNE (İSTANBUL/DAVUTPAŞA) 2.BÖLGE MÜDÜRLÜĞÜNE (BURSA) 3.BÖLGE MÜDÜRLÜĞÜNE (İZMİR) 4.BÖLGE MÜDÜRLÜĞÜNE (İSTANBUL/ANADOLU) 5.BÖLGE MÜDÜRLÜĞÜNE (SAKARYA) 8.BÖLGE MÜDÜRLÜĞÜNE (ANKARA) Bu belge, güvenli elektronik imza ile imzalanmıştır. Doğrulama Kodu: 1DE5D328-7340-4446-839E-F0BFC23FE34A ................................. Doğrulama ...... .... ........ .................. ........ ...... .......... Adresi: https://www.turkiye.gov.tr/teias-ebys .... ................ .................................. Nasuh Akar Mah. Türk Ocağı Cad. No:12 (06520) Balgat/Çankaya/ANKARA Bilgi için:Firdevs İrem KALE Sermaye: 17.731.798.237,00 TL Vergi D: Ankara Kurumlar ÜNLÜ Vergi No: 879 030 4314 ASO: 5887 ATO: 165458 Mühendis KEP Adresi : teias@hs01.kep.tr Telefon No:(312) 203 86 12 1/2 9.BÖLGE MÜDÜRLÜĞÜNE (KONYA) 10.BÖLGE MÜDÜRLÜĞÜNE (SAMSUN) 12.BÖLGE MÜDÜRLÜĞÜNE (GAZİANTEP) 18.BÖLGE MÜDÜRLÜĞÜNE (ADANA) 19. BÖLGE MÜDÜRLÜĞÜNE (ANTALYA) 20.BÖLGE MÜDÜRLÜĞÜNE (EDİRNE) 21.BÖLGE MÜDÜRLÜĞÜNE (DENİZLİ) 22.BÖLGE MÜDÜRLÜĞÜNE (KASTAMONU) Bu belge, güvenli elektronik imza ile imzalanmıştır. Doğrulama Kodu: 1DE5D328-7340-4446-839E-F0BFC23FE34A ................................. Doğrulama ...... .... ........ .................. ........ ...... .......... Adresi: https://www.turkiye.gov.tr/teias-ebys .... ................ .................................. Nasuh Akar Mah. Türk Ocağı Cad. No:12 (06520) Balgat/Çankaya/ANKARA Bilgi için:Firdevs İrem KALE Sermaye: 17.731.798.237,00 TL Vergi D: Ankara Kurumlar ÜNLÜ Vergi No: 879 030 4314 ASO: 5887 ATO: 165458 Mühendis KEP Adresi : teias@hs01.kep.tr Telefon No:(312) 203 86 12 2/2