Sustainability

As Mersin Highway Investment and Operation Inc. (MOİ), we commit to adopting sustainability principles throughout the construction and operation processes of the Çeşmeli – Kızkalesi Highway Project (CKH), managing environmental, social, and economic impacts in a balanced manner. In this regard:

• Ensuring full compliance with relevant local and international regulations during the construction and operation of the project, acting in accordance with ethical business principles and corporate governance principles,
• Planning and implementing our activities in line with the United Nations Sustainable Development Goals,
• Effectively manage the direct environmental impacts arising from the construction and operation of the Project, take measures to protect biodiversity and natural resources,
• Implementing applications that reduce carbon footprint, developing long-term sustainability strategies by taking into account the risks posed by climate change,
• Ensuring safe, healthy, and decent working conditions, implementing occupational health and safety practices to the highest standards, communicating our approach to human rights to our supply chain and stakeholders,
• Within the scope of the project, adopting energy-efficient technologies and applications, promoting renewable energy sources and smart transportation systems,
• To develop sustainable and environmentally friendly highway solutions, we pursue an R&D and innovation-focused business development approach,
• Supporting local communities along the project route, prioritizing projects that will contribute to regional development,
• To provide transparent communication by taking our stakeholders’ expectations into account and to develop long-term partnerships,
• To increase social benefit by developing social responsibility projects in the regions where the CKH Project is located, and to support sustainable projects in the fields of education, culture, environmental protection, and social development,
• To base our procurement processes on sustainability principles and establish responsible purchasing processes in line with our supply chain policy,
• Support sectoral sustainability practices in line with the partnerships and initiatives joined.

As MOİ, we will continue to implement practices that support sustainable development within the scope of the Project and update our policy with a continuous improvement approach.

Mersin Otoyolu Yatırım ve İşletme A.Ş. (MOİ) publishes this policy in order to reflect its sustainability approach to its suppliers and subcontractors and to adopt a responsible supply chain approach in this direction. Within the scope of the construction and operation activities of the Çeşmeli – Kızkalesi Motorway Project (CKH), MOİ adopts sustainability principles in all business processes carried out with suppliers and subcontractors.

In line with this policy, MOİ expects its suppliers, subcontractors and service providers to comply with the following issues:

• To act in compliance with MOİ’s general sustainability and corporate social responsibility policies,
• Comply with all relevant legal regulations, act in accordance with the labour legislation in force in the country where they are located in terms of working hours, permits, wages and benefits,
• Monitor and manage their environmental impacts by fully complying with environmental legislation,
• Observe occupational health and safety rules in the field, construction site and production facilities, and take necessary measures to prevent accidents during the motorway construction process,
• Not to employ forced and child labour, to observe human rights regarding the labour force, to operate with business principles that are worthy of human beings and human dignity by observing human rights,
• Respect employees’ right to unionise and their decision to join a trade union, and support their right to organise and bargain collectively in accordance with the law,
• Not discriminate on the grounds of race, ethnic origin, age, position, gender, gender identity, colour, religion, country of birth, marital status, pregnancy, dependants, disability, social class, trade union membership or political opinion,
• Adopt energy and resource efficiency orientated practices within the scope of the project,
• Use appropriate technologies to minimise environmental impacts by increasing their awareness of emissions and carbon footprint,
• Observe quality standards in the materials and services used and prioritise occupational safety.

By adopting a sustainability approach within the value chain, MOİ evaluates and encourages the development of suppliers in this area in line with the responsible supply chain approach. At every stage of the CKH project, it carries out the necessary controls to ensure that suppliers and subcontractors meet environmental, social and economic sustainability requirements.

This policy is periodically reviewed and updated in line with the requirements. MOİ Sustainability Committee is responsible for updating the policy.

Mersin Otoyolu Yatırım ve İşletme A.Ş. (MOİ) is committed to adopting an environmentally sensitive approach throughout the construction and operation of the Çeşmeli – Kızkalesi Motorway Project (CKH). With this policy;

• To fully comply with all local, national and international environmental laws and regulations specific to the project in which we operate, and to fulfil all environmental obligations within this framework,
• Raising environmental awareness among the local community, neighbouring regions, our employees, subcontractors and other stakeholders with whom we interact directly and indirectly within the scope of the project, emphasising their environmental responsibilities by organising trainings, preferring systems based on the effective use of the environment and natural resources and ensuring their continuity,
• To minimise the direct and indirect negative impacts on the environment during the construction of the project by using the best technologies; to minimise environmental impacts, especially by controlling factors such as air, water, soil pollution and noise,
• To ensure that the wastes that will be generated during the construction processes and motorway operation within the scope of the Project are reduced at source, recycled and their environmental impacts are minimised,
• Increasing energy efficiency, reducing the use of natural resources and providing the necessary manpower, technology, infrastructure and financial resources in this direction; taking measures and ensuring sustainable development by setting targets every year,
• To prepare and implement emergency plans in order to minimise the effects of environmental accidents that may occur during the construction and operation of the Project; to provide support to the local community and the environment after accidents,
• To develop projects for long-term environmental goals such as combating climate change and protecting biodiversity and to implement practices to support sustainable development,
• To provide training on environmental policy to our employees, subcontractors and project stakeholders and to raise environmental awareness,
• To continuously raise environmental standards by cooperating with national and local official institutions, other industrial organisations and suppliers,
• To establish an Environmental Management System that provides access to all kinds of data on environmental management and is continuously improved, to ensure sustainable development by increasing our environmental performance.

As MOİ, we are committed to taking all necessary measures within the framework of this policy by giving the highest priority to our environmental protection commitments throughout all processes of the CKH Project.

Mersin Otoyolu Yatırım ve İşletme A.Ş. (MOİ), as an organisation that cares about reflecting its sustainability approach to its employees and the communities in the regions where it operates, considers human rights as a priority issue. Accordingly, MOİ will adopt respect for human rights as a fundamental principle throughout the construction and operation of the Çeşmeli – Kızkalesi Motorway Project (CKH). With this policy, MOİ;

• To fully comply with the local legislation on working conditions in force in the countries in which it operates,
• To act in accordance with the International Labour Organization (ILO) and the United Nations Convention on Human Rights, to which Turkey is a party, in all processes of the Project,
• Ensure full compliance with relevant local laws and international agreements on forced labour and child labour,
• Adopt a zero-tolerance policy against discrimination and respect the rights of employees to organise and bargain collectively,
• Not to discriminate against employees on the basis of language, religion, gender, ethnic origin, marital status, age, etc. during recruitment processes and throughout their careers in matters such as promotion, remuneration, fringe benefits, paid and unpaid leave,
• Observe a zero tolerance policy for physical, sexual, psychological and/or emotional harassment in all work areas, Project construction sites and operational facilities,
• To observe human rights and to provide a safe, healthy and decent work environment for all employees, and to implement occupational health and safety measures at the highest standards in this direction,
• To provide training and development opportunities to support the career and personal development of employees,
• To respect the rights of local communities in the regions where it operates and to develop projects that favour their welfare,
• To give importance to stakeholder participation by taking into account the expectations of stakeholders and to establish long-term collaborations with stakeholders,
• It aims to expect subcontractors, suppliers and service providers involved in the project construction and operation processes to act in accordance with human rights and to apply the necessary sanctions in case of any violation.

This policy is periodically reviewed in line with the requirements and updated if deemed necessary. The Holding Sustainability Committee is responsible for updating the policy.

Mersin Otoyolu Yatırım ve İşletme A.Ş. (MOİ) was established by Koloğlu Holding for the implementation of the Çeşmeli – Kızkalesi Motorway Project (CKH Project) and MOİ will follow the same Zero Tolerance Policy applied among the companies affiliated to Koloğlu Holding.

MOİ aims to provide a respectful, equal, inclusive, and safe working environment for its employees and stakeholders through its zero-tolerance policy and procedures against violence and harassment. The company is aware that combating violence should be a priority in all aspects of life, and with this understanding, MOİ is committed to implementing the policy created to fight violence and harassment.

Through this policy document, MOİ adheres to the following principles:

• Violence-Free and Safe Working Environment: A work environment based on respect for human rights, equality, and safety will be provided, and zero tolerance will be maintained towards all forms of violence. A safe working environment will be created where employees who are victims of violence or harassment can seek help without hesitation.
• Non-Discrimination: No individual will be discriminated against based on race, gender, ethnic origin, language, religion, age, disability, sexual orientation, gender identity, family status, or any other characteristic. Discrimination in any form will not be tolerated.
• Gender Equality: A zero-tolerance attitude towards all forms of violence and harassment, including domestic violence, will be adopted and promoted in a gender-sensitive manner.
• Training and Awareness: Training programs will be organized to increase awareness and understanding of violence and harassment for all employees and managers at all levels.
• Recruitment and Employment Policy: Discrimination, violence, and harassment will be prevented during recruitment, employment, and termination processes.
• Confidentiality and Privacy: The confidentiality and privacy of employees who are victims of violence will be protected, and a safe process for reporting incidents will be ensured.
• Support Mechanisms: Accessible mechanisms for employees who have experienced violence or harassment, including domestic violence, will be provided to offer support.
• Social Dialogue and Collaboration: Necessary measures to combat violence and harassment will be developed and implemented through social dialogue and collaboration with stakeholders.
• Occupational Health and Safety: Violence and harassment will be recognized as an occupational health and safety issue, and risk assessments, including domestic violence, will be carried out with employee participation.
• Domestic Violence Support: Support mechanisms will be established for employees who are victims of domestic violence, and assistance will be provided within a structured process to empower these individuals.
• Effective Complaint Mechanisms: Effective complaint, investigation, referral, support, and remedy mechanisms will be put in place, ensuring confidentiality, impartiality, reliability, and protection against retaliation for employees.
• Use of Non-Violent Language: The use of inclusive, equal, and non-violent language in the workplace will be encouraged, and employees will be educated to raise awareness in this area.
• Performance Support: Employees who have been victims of violence will receive necessary support to ensure they do not experience performance-related stress in the workplace.
• External Support Organizations: Contact information for external support organizations related to violence and harassment will be shared with employees, and necessary referrals will be made with careful attention to confidentiality.
• Supply Chain Awareness: A zero-tolerance approach to violence will be promoted in the supply chain, and efforts will be made to raise awareness and encourage action in this regard.
• Right to Information: Employees will be empowered to exercise their right to obtain information and consult on issues related to violence and harassment effectively.
• Identification of Issues and Needs: Regular surveys and similar initiatives will be conducted to identify employee concerns and needs regarding discrimination, violence, and harassment, and the results will be reflected in relevant policies and procedures.
• Corporate Culture: The principles of this policy will be integrated into the corporate culture, and a holistic approach will be adopted to combat violence and harassment.
• Partnerships: Comprehensive, inclusive, and constructive partnerships will be established with public institutions, civil society organizations, and/or employer and employee organizations to promote a violence-free working life.
• Policy Dissemination: The policy will be widely communicated to all relevant parties, and it will be regularly supported and updated with updated procedures.
• Information and Training: Necessary strategies and conditions will be developed to inform and train all employees about the content of the zero-tolerance policy on violence and harassment.

As Mersin Otoyolu Yatırım ve İşletme A.Ş. (MOİ), we are committed to adopting a sustainability approach and integrating our corporate social responsibility principles into our activities throughout the construction and operation of the Çeşmeli – Kızkalesi Motorway Project (CKH). This policy covers our employees, subcontractors, suppliers and local communities in the region where we operate.

By adopting an environmental, economic and social responsibility approach, MOİ aims to ensure that CKH contributes to local and national development, protects the environment and supports social development. Within this framework, we manage the social impacts of our operations with an understanding of accountability.

MOİ’s Social Responsibility Implementation Principles:

• Not tolerating any discrimination based on language, race, gender, belief, age or disability among employees and providing equal opportunities to all our employees, creating a positive working environment,
• To minimise the impacts on local communities throughout the Project and to build strong, healthy relationships with these communities, and to develop activities by taking into account the needs of local people,
• Manage all environmental impacts that may arise from the Project, minimise adverse environmental impacts and develop solutions to ensure continuous improvement, and build strong relationships with local communities and individuals affected by its operations,
• Supporting social projects aimed at ensuring access to health, education, and cultural opportunities for vulnerable groups such as women, children, youth, and people with disabilities,
• To support projects in this field by investing in quality education and training opportunities for young people and future generations through Koloğlu Holding Education Foundation (KOLEV),
• To develop social responsibility projects to increase social benefit, to protect the cultural heritage and to improve the ecosystem,
• To develop innovative projects that support social development and the environment in co-operation with public institutions and local governments, and to actively participate in social responsibility platforms,
• To receive feedback from the local community, our employees and other stakeholders throughout all processes of the Project and to establish open and accessible channels to evaluate their complaints and suggestions.

This policy undertakes to comply with and apply the laws, regulations and principles in force.

This policy is regularly reviewed and updated as necessary to ensure its validity and effectiveness.

As Mersin Otoyolu Yatırım ve İşletme A.Ş. (MOİ), occupational health and safety (OHS) is one of our top priorities. Throughout the construction and operation processes of the Çeşmeli – Kızkalesi Highway Project (CKH), we are committed to providing a healthy, safe, and clean environment for our employees, subcontractors, suppliers, road users, and the entire community affected by our activities.

Our ultimate goal is to achieve zero workplace accidents and occupational illnesses, and to create and maintain a healthy and safe working environment by eliminating hazards in all our activities. At MOİ, our managers and employees will take all necessary measures to prevent loss of life, injury, and health problems that may arise due to working conditions and workplace accidents, and will continuously improve OHS management and performance.

In this context:

• We will conduct regular information, training, and awareness activities to ensure that our employees, contractors, and subcontractors are aware of their individual OHS responsibilities.
• We will act in accordance with all applicable national and international legislation and contractual requirements regarding occupational health and safety.
• During the construction of the project, we will conduct detailed risk analyses and implement preventive measures for high-risk activities such as the use of construction machinery, heavy haulage, excavation work, and working at heights.
• We will promote and monitor the use of appropriate personal protective equipment in our work areas and impose sanctions where necessary.
• By continuously reviewing emergency management plans, we will be prepared for fires, accidents, natural disasters, and hazardous material spills.
• We will create safe passage areas for workers and road users by implementing traffic management plans in construction sites to ensure road safety.
• We will maintain safety standards on the highway and at its facilities to ensure the safety of road users, maintenance personnel, and visitors.
• We will implement work procedures that comply with occupational health and safety regulations in maintenance and repair activities.
• We will ensure the safety of our employees and road users by adopting high safety standards in roadside works, tunnel and bridge maintenance processes.
• We will encourage highway users to travel safely by organizing awareness campaigns on road safety.

As MOİ, we will take into account the opinions and suggestions of our employees and employee representatives in all OHS processes, acting with a mindset of open communication and continuous improvement.

This policy will be shared with all employees and relevant parties, continuously reviewed, and will provide a framework for achieving our occupational health and safety goals.

Mersin Otoyolu Yatırım ve İşletme A.Ş. (MOİ) acts in accordance with the Human Resources Policy of its affiliate Koloğlu Holding and develops additional practices that encourage regional employment and increase diversity within the scope of the construction and operation of the Çeşmeli – Kızkalesi Motorway Project (CKH).

Basic Principles of our Human Resources Policy:

• MOİ is committed to prioritise local labour force in recruitment processes within the scope of the project. By setting targets to increase the local employment rate, the employment of local people will be encouraged throughout the project.
• Support mechanisms will be established to increase the ratio of female employees. Vocational training programmes, positive discrimination in recruitment and safe working conditions will be provided to ensure greater participation of women in employment.
• MOİ adopts the principle of "placing the right person in the right position at the right time" in recruitment processes. In order to make more effective use of the local labour force, it will prioritise cooperation with professional chambers, labour force development centres and non-governmental organisations in the region.
• MOİ will organise various training programmes to support the professional and personal development of its employees. Technical and occupational health and safety trainings specific to Project construction and operation processes will be made accessible to local employees. Efficiency of trainings will be monitored and continuous improvement will be ensured.
• MOİ is committed to providing equal opportunities to all employees and preventing any form of discrimination. Fair and transparent evaluation processes will be applied in recruitment, promotion and other human resources processes, and diversity will be increased.
• Full compliance with occupational health and safety standards will be ensured and necessary measures will be taken for all employees to work in a safe environment. Workers’ rights will be respected, and legal legislation will be complied with regarding trade union rights and working conditions.
• MOİ will implement regular surveys and feedback mechanisms to increase employee satisfaction. Human resources policies and working conditions will be continuously improved in line with the opinions of employees.
• Considering the social impacts that will occur throughout all processes of the CKH Project, employment opportunities will be created in cooperation with the local community. An active role will be taken in working with local suppliers and contributing to social development.

As MOİ, we are committed to taking all necessary steps within the framework of this policy by giving the highest priority to our principles of contributing to national and regional development and sustainable employment.