TURKEY

NATIONAL DISASTER RISK MANAGEMENT PROJECT (P157683)

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK

FINAL DOCUMENT

[WILL BE APPLIED AS THE LOAN AGREEMENT BECOMES EFFECTIVE]

MARCH 2019

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ABBREVIATIONS

AFAD Disaster and Emergency Management Presidency

Bank World Bank

BP Bank Procedure

CRED Construction and Real Estate Department

EIA Environmental Impact Assessment

E&S Environmental and Social

ESMF Environmental and Social Management Framework

ESMP Environmental and Social Management Plan

FM Financial Management

GRM Grievance Redress Mechanism

LA Loan Agreement

M&E Monitoring and Evaluation

MoNE Ministry of National Education

NDRMP National Disaster Risk Management Project

OP Operational Policy

PIU Project Implementation Unit

POM Project Operational Manual

RT Republic of Turkey

SuTP Syrians Under Temporary Protection

SC Scientific Committee

WB World Bank

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Table of Contents

1. INTRODUCTION ................................................................................................ 4

2. COMPLIANCE WITH WORLD BANK SAFEGUARDS POLICIES ................. 7

3. GUIDELINES FOR PREPARATION OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT PLANS (ESMP) ............................................................. 13

4. SITE ALTERNATIVES ...................................................................................... 15

5. ENVIRONMENTAL AND SOCIAL MONITORING AND GRIEVANCE REDRESS MECHANISM ......................................................................................... 16

6. INSTITUTIONAL IMPLEMENTATION AND RESPONSIBILITIES .............. 18

7. SCHEDULE ........................................................................................................ 21

8. PUBLIC CONSULTATION ............................................................................... 22

List of Tables Table 1: Roles and Responsibilities ................................................................................................. 19

List of Figures Figure 1: Organigram of Construction and Real Estate Department .............................................. 18

Annexes ANNEX 1: LAND ACQUISITION CHECKLIST .......................................................................... 23 ANNEX 2: ESMP CHECKLISTS ................................................................................................... 24 ANNEX 3: SAMPLE OF GRIEVANCE FORM............................................................................. 30 ANNEX 4: SAMPLE OF GRIEVANCE CLOSEOUT FORM ....................................................... 31 ANNEX 5: CONSULTATION MEETING PARTICIPANT LIST ................................................. 32

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1. INTRODUCTION Building disaster and climate resilience into the physical infrastructures contributes to achieving the World Bank’s twin goals of decreasing poverty and promoting shared prosperity. The proposed project also contributes to achieving the goals and objectives of the National Policy Documents specified below:

- The ongoing World Bank Country Partnership Framework for Turkey (2017-2021) which builds on three pillars; (i) growth, (ii) inclusion, and (iii) sustainability: Country Partnership Framework (CPF) Objective 8, i.e. improving sustainability and resilience of cities, embodies the safer school agenda targeting increased resilience of cities through increased number of disaster-resilient public buildings and improved preparedness against disasters.

- 10th Development Plan (2014–2018): The Plan calls for mainstreaming disaster risk considerations into macroeconomic, sectorial, and spatial planning processes; raising awareness and resilience to disasters, and building disaster-resilient and safe settlements.

- Disaster and Emergency Management Authority’s (AFAD) Strategic Plan

- Ministry of National Education (MoNE) Strategic Plan

National Disaster and Risk Management Project (NDRMP) will be implemented by the Construction and Real Estate Department (CRED) of the Ministry of National Education (MoNE). The Project Implementation Unit (PIU) established under CRED, which currently is responsible for management of the ‘Education Infrastructure for Resilience Project (EIRP) (P162004), will also be responsible for the overall implementation, management and coordination of the proposed Project.

The overall objective is to increase the safety of students, teachers and staff who benefit from / serve in schools which are located in high-risk seismic zones: The NDRM Project will enable retrofitting and reconstruction of approximately 400 schools reaching out to more than 320,000 students and staff per annum.

The proposed Project will be implemented through three components: (i) improving seismic resilience of schools; (ii) enhancing institutional and technical capacity for safer schools; and (iii) project management.

Component 1: Improving Seismic Resilience of Schools (US $ 292.25 million)

The objective of Component 1 is to support ensuring disaster resilience of existing school. The component will support;

i. preparation of a package of prioritised investments as a means of supporting risk reduction in existing school buildings across the country through retrofitting and reconstruction,

ii. retrofitting or reconstruction of those prioritised schools, and

iii. conducting additional assessments of schools against seismic risk.

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Structural improvements will include the retrofitting works to ensure the performance of the buildings meet the levels as described in the “Turkey Building Earthquake Regulation”. In addition to seismic strengthening of existing schools, retrofitting/reconstruction measures will be complemented with the implementations concerning energy efficiency. The measures will include savings in natural gas, electricity and water consumption, asbestos abatement and removal, and modernization. The focus of the functional improvements will be on creating an enhanced learning environment that meets the requirements of current standards.

Design reviews, soil surveys, or other analysis for ground conditions and civil works supervision will also be covered by this component. Schools to be intervened will satisfy all applicable Turkish regulations and codes for seismic safety, land use planning, energy efficiency, shelter, fire, safety at workplace, access for people with disabilities and so on as well as all standards related with the materials to be used.

Lastly, this component will also support communication and awareness-raising activities to ensure that the school communities are well-informed. Organization of workshops, trainings, and other informative meetings will be supported under this component. These services will focus on delivering:

(i) informative meetings about long-term benefits of the retrofitting and reconstruction which target students, teachers, parents and school-administrations,

(ii) development of in-school awareness programs, and

(iii)public awareness campaigns by means of various communication tools, including billboards, posters, brochures, and social media.

Component 2: Enhancing Institutional and Technical Capacity for Safer Schools (US $ 3.0 million)

The objective of Component 2 is to enhance CRED’s engineering and research capacity. The source allocated for this component will cover the studies summarised below:

- Adding modules or layers to the Geographic Information System involving hazard information and risk assessment to help support prioritization process for investment planning: MoNE will use this system as a tool to manage and maintain its inventory in medium-to-long-term, to take risk- informed investment decisions and to track improvements regarding overall resilience of schools in Turkey.

- Conducting structural performance analysis of MoNE’s typical school designs before and after retrofitting to demonstrate the economic and social benefits of planned interventions.

- Conducting cost-benefit analysis on retrofitting and reconstruction for various school types and analysis on alternative retrofitting methods for specific school designs.

- Damage and loss estimation and development of typical recovery and repair designs based on selected scenarios for various school types.

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- Improving minimum design criteria for school buildings, developing standards and regulation to prevent non-structural damages.

- Conducting research on innovative technologies (such as use of seismic isolators for school, modular construction, etc.) to improve efficiency for new construction and retrofitting.

The Component will also finance consulting services to develop an investment strategy based on risk assessment.

Component 3: Project Management (US $ 4.0 million)

The project management will be conducted by CRED. The component will include strengthening the department’s staff capacity by hiring experts in the fields of procurement, financial management (FM), disbursement, monitoring and evaluation (M&E), community engagement and environmental and social safeguards.

M&E will be given special emphasis. M&E includes all activities related to data collection, assessment of disbursement performance and evaluations ensuring to meet targeted schedule and financial plans. Activities related to the consultancy services for capacity building, procurement of hardware and software for project implementation, monitoring and assessment of results, trainings and other processes will be supported under this component.

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2. COMPLIANCE WITH WORLD BANK SAFEGUARDS POLICIES The World Bank’s environmental and social safeguards policies require that the Borrower country perform an Environmental Assessment Study, integrated with Environmental Impact Assessment (EIA) Regulation and World Bank’s relevant Operational Policies.

The Environment Law No. 2872 is Turkey’s primary framework for environmental legislation. Article 10 of the Environment Law sets the framework for the Regulation on EIA. However, seismic retrofitting, demolition and reconstruction of the public buildings (including schools) are not included in the EIA Regulation. Due to this reason the scope of the project is exempted from the EIA process. The exact lists and locations of the schools to be retrofitted or reconstructed will not be readily available in the preparation phase of the project. Therefore, this document (ESMF) has been prepared to fulfil the requirements of the national Environment Law, and WB Operational Policies.

The main objective of this document is to assist the project management team in screening all sub-projects with respect to their potential social and environmental impacts, identifying Environmental and Social (E&S) management requirements and prioritizing investments.

- Within the scope of the project, the design and supervision consultants to be hired by MoNE will prepare a full Environmental and Social Management Plan (ESMP) for each school project they will be implementing. The locations of the schools which are planned to be reconstructed or retrofitted within the scope of the project are in the areas whose settlements are complete and which provide various advantages (no need for any additional access road or electricity transmission line, able to include the waste water discharge into the current sewage system). Considering such features of the project sites, very critical environmental impacts due to the project activities are not expected to emerge.

o During the ESMP preparation, ESMP Check List which has been detailed in Section 3 will be utilised.

o ESMP to be prepared will be an integral part of the work contract which will be signed for each school.

- The projects which have the potential of falling into Category A1 due to their significant environmental and social impacts (i.e. projects with wide footprint areas and/or which are close to environmentally sensitive areas) will be left out of the investment package as they will not be in compliance with the project evaluation criteria.

- The envisaged projects which are on critical habitats or which may have significant impacts on natural habitats will also be ineligible.

1 If the proposed project may have significant environmental impacts (based on the project type, location, sensitivity, scale, structure of the potential environmental impacts and dimension) it is classified as Category A. These impacts are generally at large scale, irreversible, sensitive, variable, cumulative, establish a precedent and may have impact on a wider area than the financed location and facility within the project.

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- Therefore, projects which will be conducted in the areas that are already in use, and/or already impacted by human-sourced (anthropogenic) activities and which are allocated/designated to MoNE for educational facilities will be considered eligible.

- The Operational Policies that are triggered within this project are given below. Any activity that could potentially impact the non-triggered OPs will not be eligible for financing.

OP 4.01 Environmental Assessment:

The planned project is classified as Category-B for its potentially temporary and uncritical environmental and social impacts. Within the scope of WB Operational Policies (OP)/Bank Procedures (BP), OP 4.01 will be triggered due to the environmental and social impacts which will mostly be of a temporary nature and which will be effective within close proximity of project area. Implementing OP 4.01 requires developing general environmental and social management tools along with construction site management tools. This ESMF includes templates for ESMP which is to be prepared for each project to be carried out under NDRMP.

It is likely that some schools which will be included in the Project are to be registered as cultural asset. Thus, for each school, the relevant governmental correspondences and procedures will be conducted and the process will be evaluated.

Infrastructure projects are composed of different stages (project design, works and operation phases) and thus are subject to different legislative arrangements. As part of European Union (EU) accession process, substantial institutional and legislative reforms have been made in Turkey. Thanks to these reforms, environmental legislations and instruments for environmental protection are aligned with international standards. Those that pertain to construction works for the environmental protection include (but not limited to) the following:

• Waste Management Regulation, Waste Oil Control Regulation, Vegetable Waste Oil Control Regulation, Packaging Waste Control Regulation, Waste Batteries and Accumulators Control Regulation, Medical Waste Control Regulation, Excavation, Construction and Demolition Waste Control Regulation, Waste Tires Control Regulation, Landfill Regulation, Communique on Recovery of Some Non-Hazardous Wastes, Regulation on Control of Electrical and Electronic Equipment, Regulation on Soil Pollution Control and Contaminated Sites by Point Source, Water Pollution Control Regulation, Regulation on Monitoring of Surface Water and Groundwater, Regulation on Protection of Groundwater against Pollution and Deterioration, Regulation on Control of Pollution Caused by Hazardous Substances in the Aquatic Environment and Its Surroundings, Regulation on Water Intended for Human Consumption, Regulation on Urban Wastewater Treatment, Regulation on Assessment and Management of Air Quality, Regulation in relation to Ozone-Depleting Substances, Regulation on Assessment and Management of

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Environmental Noise, Regulation with respect to Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres.

• The Project will comply with the 6331 numbered Law on Occupational Health and Safety, Official Gazette No.28339, dated June 30, 2012 and its regulations.

In addition to the Environmental Law and its associated regulations, there are several other laws and regulations that directly or indirectly include environmental and social impact assessment, and thus, are applicable to the Project. These can be listed as follows:

• Highways Traffic Law, Regulation on Highway Traffic, Regulation on Work Place Establishment and Operating Licenses, Turkey Building Earthquake Regulation, Regulation on the Transportation of Hazardous Substances by Road, Labor Law, By-Law on Principles and Procedures Production, Importing, Transportation, Storage, Stocking, Selling, Usage, Assessment of Explosive Materials which are Monopolized

Within this project, the schools which will be identified to bear the highest risk as a result of assessments to be conducted by MoNE will be funded: A list of technical, social and economic criteria which include, among others, seismic hazard level, school-specific structural specifications, functions of schools, and role of the school in emergency management systems is jointly developed by the CRED and the Bank. As per these criteria, a methodology determining the risk level faced by schools has been developed. Schools which face highest level of risks will be determined using this methodology. The list of schools to be included in the project will be determined drawing on the results of prioritization assessment. MoNE will conduct the school selection process.

The prioritization methodology is independent from income and social level of households in districts where schools are located enables eliminating/preventing the potential risk of exclusion or elite capture, and the associated social tension. Therefore, investments will include schools that bear highest exposure to seismic risk.

World Bank Group Environmental, Health and Safety Guidelines:

The activities to be conducted during the lifespan of the project will comply with both Turkey’s Occupational Health and Safety Law and relevant regulations, and World Bank’s Operational Policies.

Thus, MoNE and the contractor and consulting firms under the project are obliged to provide safe and healthy work environment to the workers. The workers shall be informed about job descriptions, responsibilities and risks about occupational health and safety. The workers will be provided with necessary personal protective equipment and with information on works and occupational safety requirements through regular trainings. Before the construction works start, a Risk Assessment Report will be prepared for all works to be carried out and necessary measures will be taken to avoid related risks. "Emergency Response Plans" will be

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prepared for possible accidents and emergency situations, and emergency teams will be established and drills and training will be carried out in line with the emergency scenarios.

OP 4.11, Physical Cultural Resources (PCR):

Any proposed school building for retrofitting/reconstruction may be identified as a cultural asset that requires special protection. Such circumstances will be handled in compliance with the Turkish laws, notably Law No. 2863 on the Protection of Cultural and Natural Assets, and World Bank requirements. The Law; gives a definition for the movable and immovable cultural and natural assets that are regarded as Cultural Heritage, describes procedures and regulations regarding the preservation of these assets, and identifies the conservation principles and roles and responsibilities of institutions that will be in charge of implementation decisions.

World Bank is highly sensitive in preserving cultural resources and takes great care to ensure that Cultural Heritage assets will not be adversely affected by Bank-financed projects. The policy of WB regarding Cultural Heritage is clearly indicated under OP 4.11. In regard with this policy, the Bank requires certain measures to be taken during the preparation and implementation of Bank-financed projects. OP 4.11 will be triggered in case of following situations:

(i) if the nature of retrofitting work for a certain school building depends on historical/cultural value of that school;

(ii) if retrofitting/reconstruction work is conducted in close proximity to such historical/cultural properties;

(iii) where new plots may be required and the land has historical/cultural value.

As per this policy, for the projects financed by itself, WB stipulates to take the required measures during the preparation and implementation phases of the project regarding cultural heritage.

The proposed project has to address impacts on cultural resources as an integral part of the Environmental Assessment (EA) process and all details should be provided in the ESMP. The findings and recommendations of the EA including the Cultural Heritage Impact will determine whether the project provides adequate basis for processing the project for Bank financing. The cultural resources may not be known or visible, the local inventorying may be inadequate, or the cultural resources may not be listed, registered or declared as ’Protected Heritage' by the laws. Thus, the determination of the cultural resources will not be limited by the registered sources but also additional works will be conducted when necessary. The proposed project’s potential impacts on 'all' cultural resources are considered at the earliest possible stages of project processing (regardless of being registered or protected by the local current legislation).

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MoNE is responsible to avoid or mitigate impacts on physical or cultural resources of the financed projects. Therefore, MoNE will not receive project funding until all requirements of the Turkish legislation and WB requirements are met in the impacted areas.

A “Chance Find Procedure”, in line with the requirements of the OP 4.11, will be prepared for the possible case of finding cultural or historical asset during the lifespan of the Project. The Procedure, for the relevant plot, will include necessary information for the consulting firms and contractors on the steps to be followed in case of a find, including responsibilities for managing accidently discovered or chance find cultural artefacts.

In line with the requirements, a detailed evaluation report on archaeological or cultural assets will be included in the ESMPs. All such reports and relevant official letters pertaining to correspondences with the relevant public institutions will be annexed to the ESMPs.

Relevant mitigation and monitoring measures related to conservation of cultural heritage will be integrated into the ESMP document.

OP 4.04, Natural Habitats:

OP 4.04 is not triggered for this project as all retrofitting and reconstruction works will be conducted in areas which do not qualify as “natural habitats” since schools are built (and will be built) close to residential areas. However, projects which may have impacts on any Natural Habitats will be defined as ineligible within the project.

OP 4.12, Involuntary Resettlement:

Further land acquisition or expropriation is not covered within the Project. However, even minimal, there might be cases where schools are to be re-built. The first option will be to reconstruct on the same plot, but sometimes due to seismic or other natural disaster risks, schools may necessarily need to be rebuilt on a new plot. For such cases, MoNE will ensure the following: (i) the plots selected will require no land take under the project activities (ii) there are no squatters/formal or informal users on the subject public land; (iii) there are no other issues (pending court cases, legacy issues etc.) that may trigger OP 4.12 on the lands acquired previously which is then used for this project. To ensure these are valid, World Bank will request that MoNE fills out a land acquisition checklist (please see ANNEX 1). Any land (designated for building schools) that involves involuntary resettlement that will trigger OP 4.12 will not be eligible for financing.

The objective of this checklist, which is to be prepared for each parcel, is to confirm that OP 4.12 will not be triggered in any parcel and all lands have been allocated to MoNE. Lands which have been allocated for school construction, but which also trigger the implementation of OP 4.12 will be ineligible and will not be assessed within the Project. During the implementation phase, borrower will have confirmed (i) no land acquisition is required and (ii) selection of lands that are not occupied or being used.

Any land that causes involuntary resettlement will not be eligible within the scope of the Project. In such circumstances, construction works will be conducted on an alternative land

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that does not have issues triggering OP 4.12. In the event of a need for more land, lands allocated for MoNE will be utilised.

Existing schools that need to be reconstructed would need to transport the active students of the existing schools to nearby schools. The issue of ‘host communities’ is likely to emerge in such cases. For this transition MoNE will prepare a set of communication tools to inform affected schools and try to carry out construction activities during the off-semester season to the extent possible. The existing schools will eventually be affected by the Project’s construction activities that will coincide with the academic calendar. In such cases support from the existing parent-teacher associations can be sought during the transition period of schools.

MoNE will establish a Grievance Redress Mechanism to resolve and administer the grievances that could be encountered during reconstruction/retrofitting of school buildings. This mechanism will be used for addressing any project induced grievances that may result from either environmental and/or social impacts including ones pertaining to transfer of students and relocation once the schools are operational. The mechanism will allow for worker related grievances to be registered as well as overall project affected people and school communities to express their concerns and requests. Grievances will be addressed at multiple levels: (i) local level through the contractors; (ii) provincial level through MoNE’s provincial administrations; and (iii) national level through MoNE-PIU. Implementation details about the grievance mechanism will be specified in Project Operational Manual (POM).

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3. GUIDELINES FOR PREPARATION OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT PLANS (ESMP)

This ESMF is prepared to describe the implementation arrangements for safeguarding full compliance of the project with WB environment and social safeguards requirements and national laws and regulations. The ESMF will be disclosed by MoNE and WB on their websites both in Turkish and English.

This ESMF includes guidance to contractors and consultants who will be responsible for preparing ESMPs before any construction/retrofitting works begin. The ESMPs will make use of the ESMP Checklist (please see ANNEX 2).

The ESMP checklist, which will be a section of the ESMPs, has 3 (three) parts:

_ Part 1 includes a descriptive part that characterizes the project and specifies it in terms of the institutional and legislative aspects, the technical content of the project, the potential need for a capacity building program and description of the public consultation process. This section can be up to two pages long. Attachments for additional information can be supplemented when needed.

_ Part 2 includes an environmental and social screening checklist, where activities and potential environmental issues can be checked in a simple Yes/No format. If any given activity/issue is triggered by checking “yes”, a reference is made to the appropriate section in the table in Section 3, which contains clearly formulated management and mitigation measures.

_ Part 3 represents the monitoring plan for activities during project construction and implementation. It retains the same format required for ESMP proposed under normal Bank requirements for Category B projects. It is the intent of this check-list that Part 2 and Part 3 be included into the bidding documents for contractors, priced during the bidding process and diligent supervision be implemented during work.

The checklist-type format has been developed to ensure that basic good practice measures are recognized and implemented, while designed to be both user friendly and compatible with the World Bank’s safeguards requirements. The intention of this checklist is that it offers practical, concrete and implementable guidance to contractors and supervising engineers for their civil works contracts. It should be finalised during the final design phase and should be included among the bidding documents along with other documentation required by national law. The list is binding for the works contracts.

The ESMP attempts to cover typical core mitigation approaches for civil works contracts with small, localized impacts. It is accepted that this format provides the key elements of the ESMP to meet World Bank’s operational policies. A sample ESMP will be prepared by MoNE and World Bank in order to be used as an example for the ESMPs to be prepared for each school site and to be included in the construction bidding documents.

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The scope of the ESMPs will also cover social impacts and safeguards as the project may have a land acquisition process for the schools to be reconstructed. Regarding the social impacts CRED will make sure that District Directorates of MoNE make necessary arrangements and apply a set of communication tools to avoid conflicts between host communities and transferred students during reconstruction of the schools. CRED will provide the construction supervisor with detailed school designs that consider gender-friendly, safe bathrooms with sanitary facilities, that allocate spaces for social activities and that consider the special needs of disabled. Additionally, during the reinforcement works, the CRED and consulting firms will ensure that contractors take required health and safety measures.

Prior to the bidding process of the civil works for each subproject, CRED will fill out a land acquisition checklist including all relevant complementary documents. The due diligence studies will be concluded once all designated schools/plots are approved by the Bank ensuring that there are no social safeguard issues left out. The details regarding the land acquisition process and social due diligence studies will be provided in the Operational Manual of NDRM Project.

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4. SITE ALTERNATIVES The schools which will be included in the project to be intervened (i.e. priority schools) will be identified by MoNE. The prioritization methodology developed jointly by the MoNE and the Bank will be utilised during identifying the priority schools.

The due-diligence work on the selected schools and school plots which will be conducted during the preparation and implementation phases of the Project, the WB will ensure that there are no incompliance issues with WB’s safeguard policies. In case any incompliance is determined during the due diligence work, MoNE will be responsible to find alternative schools/plots in full compliance2 with WB policies.

2 Alternative lands (i) should not have issues triggering OP 4.12 and (ii) should not have squatters/users on public lands.

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5. ENVIRONMENTAL AND SOCIAL MONITORING AND GRIEVANCE REDRESS MECHANISM

Environmental and Social Monitoring

As part of project supervision the Environmental and Social Monitoring System will help WB and MoNE to evaluate the success of mitigation measures, and to interfere in the process when needed. The environmental and social issues covered by the mitigation measures will be monitored and supervised by the appointed specialists through MoNE. By the monitoring system,

_ technical assistance and supervision will be provided when needed,

_ situations for which mitigation measures are to be applied will be detected ex ante,

_ mitigation measures will be monitored,

_ information regarding the progress of the project will be provided.

CRED will regularly collect data regarding performance indicators from the field through Provincial Directorates of MoNE and routine site visits. CRED will be responsible for the quality of data collected, and evaluating the achieved outputs/outcomes within the scope of Project’s Results Framework.

Grievance Redress Mechanism (GRM)

The Grievance Redress Mechanism (GRM) is a process that enables any stakeholder to submit a complaint, concern or a suggestion on the way the project is being planned, constructed or implemented.

MoNE will establish a transparent and comprehensive GRM before Project implementation phase in order to resolve and administer the grievances that could be encountered during reconstruction/retrofitting of school buildings. In addition, GRM will be used for monitoring of both environmental and social issues induced by the Project. School communities may have concerns regarding the actual benefits of reconstruction and retrofitting. To cope with that, the mechanism will also allow overall school communities to express their concerns and requests. The Project GRM will additionally serve to register and address worker related grievances. Grievances will be addressed at multiple levels:

a. Contractor Level: Each contractor appointed for conducting the civil works will have a designated person to receive, record and resolve grievances lodged by host community or project beneficiaries;

b. Provincial Level: Grievances and concerns that cannot be resolved at the contractor level will be dealt with by the provincial directorates of MoNE in each province. Within the project, the contact information at local level which will be used for raising the grievances will also be provided in ESMP during the implementation.

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c. National Level: Grievances of higher importance will be escalated to the national level to be resolved by CRED. When necessary additional assistance will be provided from other service providers. CRED will be reached via landline numbered ……………..and via ……………email address 3

To avoid any negative feedback from or misunderstanding by the school communities, it is important to have a comprehensive set of communication tools in place. These communication tools will target students, teachers, school administrations and parents. As a good practice, CRED can provide information flow by using various means of information dissemination such as brochures, notice boards, official website of MoNE, etc. to inform the communities about the new schools.

Although there is no obligation, a Sample Grievance Form has been prepared. All the received complaints, concerns and suggestions should be archived and solved within 30 days and feedback should be provided for the complainants. A database for all kind of received grievances will be logged and kept. The statistics of the grievances should be reported to the WB regularly. Example grievance form and grievance closeout form (to be prepared by the CRED) are provided respectively in ANNEX 3 and ANNEX 4.

3 Telephone number and e-mail address will be published on the CRED official website following to the start of the Project.

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6. INSTITUTIONAL IMPLEMENTATION AND RESPONSIBILITIES The project will be implemented by MoNE through The Project Implementation Unit (PIU). CRED currently has well-qualified technical staff who have significant experience in conducting seismic risk assessments and managing design, construction, and retrofitting contracts (see Figure 1).

Figure 1: Organigram of Construction and Real Estate Department

PIU is led by the head of CRED with its current staff who are supported by external consultants. Within the scope of the Project, PIU staffing may call for additional short- and long-term consultants.

Table 1 also includes responsibility distribution of all parties involved in the Project.

The awarded contractors will be responsible for the preparation of the site-specific ESMPs and setting up and ensuring the sustainability of a contractor level Grievance Mechanism. It is also assumed that the relevant costs are covered in the bid proposals.

PIU will make site specific evaluation for each of the proposed projects in accordance with national legislation as well as WB Safeguard Policies and will integrate them into the ESMPs. Moreover, PIU will guide the construction contractors as well as the consultants for the preparation of ESMPs and assist them during the implementation of the roles and responsibilities listed in Table 1.

MoNE will be responsible for the review and the quality of all documents and site-specific ESMPs. MoNE will submit the site-specific ESMPs to WB for prior review. When the WB is confident that MoNE has demonstrated that the process is accurate, WB will transfer this prior review to post review.

The details of the tasks to be implemented will be given in the Operational Manual of the National Disaster Risk Management Project.

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Table 1: Roles and Responsibilities

Responsible Party Responsibilities World Bank • To review and provide no objections to the ESMPs

• To review and provide clearance to all environmental and social checklists (including land acquisition checklist) as well to approving each site proposed by MoNE

• To conduct implementation support missions in order to ensure that the project is in compliance with WB OPs

• To disclose the ESMF on WB’s official website

• To disclose the financial audit reports (excluding the management letter) publicly, in a manner acceptable by the World Bank

Contractors • To implement ESMPs on site, and to revise the ESMP together with the construction supervision consultant if required

• To welcome and apply the relevant laws and regulations that are included in the tender documents and/or noted by MoNE, in consultation with WB

• To make ESMPs public before any civil works begin

• To develop “Chance Find Procedure”, if required

• To ensure that construction related grievances are received and addressed

• To ensure the sustainability of the grievance mechanism

• To monitor site activities on regular (daily, weekly monthly etc.) basis as defined in ESMPs

• To report any significant environmental or social incident (e.g. lost time incidents, fatalities, environmental spills etc.) to MoNE immediately

• To prepare the progress reports regarding ESMPs for the review of MoNE

Construction Supervision Consultants • To conduct the initial assessment of the project site

• To develop the ESMPs

• To monitor/assess the contractor’s activities in compliance with the ESMP and to include ESMP issues in the monthly progress reports

• To provide feedback and give notice to the MoNE

Communication Specialist (hired by the PIU)

• To prepare all communication and visibility tools (i.e brochures, leaflets, banners, posters, meeting announcements, etc.)

• Oversee the process for the translation, printing and dissemination of the communication/visibility tools as well as planning and organization of public events and

consultation meetings with project beneficiaries

• To prepare periodic reports on all communication and visibility activities realized under the project to the PIU to be submitted to the WB as a part of the monitoring

process

• To support District Directorates of MoNE during site-specific information of the project and other stakeholder engagement activities.

Financial Management (FM) Specialist • To review all financial management reports and audits and take necessary follow-up actions according to World Bank procedures

• To advice the task team on all financial management issues

Monitoring Specialist (appointed by the MoNE)

• To monitor and supervise both the environmental and social issues covered within the mitigation measures

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Responsible Party Responsibilities MoNE/CRED/PIU • To implement the Project and manage the funds

• To ensure that funds are used to finance eligible expenditures in accordance with the applicable policies and procedures stipulated in the loan agreement.

• To collect data regarding Project outcomes from the field through its M&E unit (by outsourcing if needed), to assess the quality of data collected and evaluate

results.

• To monitor the progress of the project and report to the government and WB management as to progress, results, potential issues, and proposed solutions

• To realise and conduct the required correspondences with governmental authorities

• To tailor the financial management system according to the novelties introduced by the project at hand.

• To maintain at least one financial management and Environmental and Social staff member throughout the implementation and payment period of the project.

• To review and verify the data and evaluate results before including these results in reports to be sent to the World Bank

• To identify the first set of priority schools to be intervened

• To maintain a separate accounting system to follow up the fund flows on a cash basis

• To produce data necessary to prepare regular project reports requested by the stakeholders

• To handle the hiring activities through PIU

• To develop a project operational manual in consultation with the WB

• Confirming that the schools/plots do not have issues that may trigger OP 4.12

• To establish the grievance redress mechanism and resolve the complaints and concerns both at provincial and national level.

• Awarding the construction contractors

• To prepare and disclose the ESMF both in Turkish and English

• To disclose the financial audit reports (excluding the management letter) publicly and in a manner acceptable to the World Bank

• To report to the WB on compliance with the triggered security measures applied directly within the project

• To notify the World Bank about any significant incident (accidents, spills, fatalities, etc.) in 5 business days, and send an incident investigation report together with

the corrective action plan in 30 business days to the World Bank.

• To draw up the monitoring report semi-annually before the site visits of the WB and share it with the WB Treasury Controllers • To audit the project financial statements for their compliance with respect to international standards and for their being acceptable by the World Bank

• To communicate the audits to the World Bank

20

7. SCHEDULE The preparation of the site-specific ESMPs (in checklist format) would require an estimated time period of about 1 month for each site. This period also includes MoNE’s review (and WB’s review and approval for the projects subject to prior approval) and disclosure. All ESMPs should be developed, completed and disclosed by MoNE on their website, before any civil works begin.

21

8. PUBLIC CONSULTATION This draft ESMF was presented and discussed with public and private sector institutions in an information-sharing meeting. MoNE organized the consultation meeting on May 3rd, 2018 in Antalya with the participation of 130 participants (participant list attached as Annex 5) from MoNE’s central units in Ankara, representatives from 25 provincial directorates of MoNE, consultants and contactors awarded by MoNE, local administrators and school principals. No questions or issues related to ESMF’s content were raised by the participants during the meeting.

The ESMF will be disclosed as final version to the public via MoNE’s and WB’s websites. Besides, each of the ESMPs will be made publicly available on MoNE’s website and the physical copies will be accessible by the public at the offices in the construction yard during the construction activities. In this manner, all stakeholders will have full access to the ESMPs which provides information regarding the potential environmental and social impact and the details of the mitigation measures to be taken.

During the lifespan of the project, various stakeholder engagement activities at different levels and with different scopes will be conducted. The scope of these events will include varied visuals (brochures, social media, videography, etc.) and event-oriented stakeholder engagement tools (parent-teacher meetings, meetings organized with the Provincial Directorates of National Education etc.). Within the scope of the engagement activities both the parents and the students will be informed about the project objectives, characteristics of the schools to be retrofitted/reconstructed and the targeted social impacts of the project.

The stakeholder engagement activities and the scope of them will be described in detail in the Communication Strategy Document to be drawn up for the Project.

22

ANNEX 1: LAND ACQUISITION CHECKLIST PART 1 – GENERAL INFORMATION

Location of the Subject Plot

Province

District

Quarter

Plot/Parcel

Number

Ownership Status

A. State Treasury B. Other Public C. State Treasury

and Other Public

D. Private

Ownership

� � � �

Other Information

Type of land (indicated on master plan)

Any formal/informal users of the land � Yes � No

Any pending court cases or legacy issues � Yes � No

Already in use for educational purposes

If yes;

Active school facility � Yes � No

Number of classrooms

Number of students

Project number if it is MoNE Type Project

Construction year

Any decision for demolishing existing

building/education facilities? � Yes � No

School to be built in a different (new) plot? � Yes � No

ATTACHMENTS/ANNEXES

1. Copy of title deed 2. Satellite image (if any) 3. Photo of plot and surroundings 4. Other documents (if there is any demolishing decision for existing education facilities)

ANNEX 2: ESMP CHECKLISTS4 (to be used while preparing ESMPs)

PART 1: GENERAL PROJECT AND SITE INFORMATION

INSTITUTIONAL & ADMINISTRATIVE

Country Turkey

Project title

Scope of project and activity

OP Criteria

Environmental Assessment OP/BP 4.01 [ ] Triggered [ ] Not Triggered [ ]Eligible [ ] Ineligible

Natural Habitats OP/BP 4.04 [ ] Triggered [ ] Not Triggered [ ]Eligible [ ] Ineligible

Pest Management OP 4.09 [ ] Triggered [ ] Not Triggered [ ]Eligible [ ] Ineligible

Physical Cultural Resources OP/BP 4.11 [ ] Triggered [ ] Not Triggered [ ]Eligible [ ] Ineligible

Indigenous Peoples OP/BP 4.10 [ ] Triggered [ ] Not Triggered [ ]Eligible [ ] Ineligible

Involuntary Resettlement OP/BP 4.12 [ ] Triggered [ ] Not Triggered [ ]Eligible [ ] Ineligible

Forests OP/BP 4.36 [ ] Triggered [ ] Not Triggered [ ]Eligible [ ] Ineligible

Safety of Dams OP/BP 4.37 [ ] Triggered [ ] Not Triggered [ ]Eligible [ ] Ineligible

Projects on International Waterways OP/BP 7.50 [ ] Triggered [ ] Not Triggered [ ]Eligible [ ] Ineligible

Projects in Disputed Areas OP/BP 7.60 [ ] Triggered [ ] Not Triggered [ ]Eligible [ ] Ineligible

SITE DESCRIPTION

Name of site

Describe site location Attachment 1: Site Map [ ]Y [ ] N

Who owns the land?

Description of land use trend (if applicable)

Description of geographic, physical, biological, geological, hydrographic and socio-economic context

Locations and distance to nearest sensitive receptors such as hospitals, health care units, schools, houses?

Locations and distance for material sourcing, especially aggregates, water, stones?

4 The checklists contained in this annex point out main impacts and mitigation measures, but are not meant to be exhaustive in their coverage. Impact assessment and mitigation planning must be tailored to each individual subproject.

LEGISLATION

Identify the infrastructures used by the project such as sewer system, electricity, water network etc.

Identify national & local legislation & permits that apply to project activity (i.e. 1/1000 or 1/5000 scaled master plan

arrangements, construction permit building permit etc.)

PUBLIC CONSULTATION

Identify when / where the public consultation process took place

Brief summary of the issues and concerns raised by the stakeholders

INSTITUTIONAL CAPACITY BUILDING

Will there be any capacity building? [ ] YES

[ ] NO

25

PART 2: SAFEGUARDS INFORMATION

ENVIRONMENTAL /SOCIAL SCREENING

Will the site activity include/involve any of the following?

Activity Status Triggered Actions

A. Building rehabilitation and minor new construction [ ] Yes [ ] No See Section A below

B. Individual wastewater treatment system [ ] Yes [ ] No See Section C below

C. Historic building(s) and districts [ ] Yes [ ] No See Section D below

D. Acquisition of land5 [ ] Yes [ ] No See Section E below

E. Hazardous or toxic materials6 [ ] Yes [ ] No See Section F below

F. Impacts on natural habitats, forests and/or protected areas7

[ ] Yes [ ] No See Section G below

G. Collection/ management of medical waste [ ] Yes [ ] No See Section H below

H. Traffic and Pedestrian Safety [ ] Yes [ ] No See Section I below

5 Land acquisitions includes displacement of people, change of livelihood and encroachment on private property. This is applicable to land that is purchased/transferred and affects people and/or squatters who are living and/or businesses (kiosks) operating on land that is being acquired. 6 Toxic / hazardous material includes but is not limited to asbestos, toxic paints, noxious solvents, removal of lead paint, etc. 7 Any project which may have significant impact on natural habitats, forests, critical habitats, areas within the borders of nationally or internationally protected areas will NOT be eligible for financing.

26

PART 3: MITIGATION MEASURES

ACTIVITY PARAMETER MITIGATION MEASURES CHECKLIST

A. General Conditions Notification and Worker

Safety

(a) The local construction and environment inspectorates and communities have been notified of upcoming activities (b) The public has been notified of the works through appropriate notification in the media and/or at publicly accessible sites (including the site of the works) (c) All legally required permits have been acquired for construction and/or rehabilitation (d) All activities will be implemented in line with the both Law on Occupational Health and Safety

(Official Gazette No.28339, dated June 30, 2012) and its relevant regulations and also with the World Bank Group EHS Guidelines.

(e) The Contractor formally agrees that all work will be carried out in a safe and disciplined manner and is designed to minimize the risks on neighboring residents and environment. (f) The Contractor will ensure a safe working environment for the workers and supply appropriate personal protective equipment (PPE) in line with international best practice and Turkish Legislation (always hardhats, as needed masks and safety glasses, harnesses and safety boots, etc.) (g) The Contractor will assign personnel with relevant certification and experience in charge of occupational health and safety (h) Before the construction works start, a Risk Assessment study will be implemented for all works to be carried out. Relevant procedures and plans (including "Emergency Plans") will be put in place. (i) Appropriate signposting of the sites will be provided and then workers will be informed of key rules and regulations to follow. (j) Occupational Health and Safety (OHS) trainings and toolbox talks will be provided to the employees indicating the possible risks regarding the work site and works to be carried out. (k) Both trainings and incidents (fatalities, lost time incidents, any significant events including spills, fire, etc.) will be recorded. (l) The contractor notifies MoNE immediately in case of any significant event occurs. MoNE will notify the World Bank about any significant incident (accidents, spills, fatalities, etc.) in 5 business days, and will send an incident investigation report together with the corrective action plan in 30 business days to the World Bank.

B. General Rehabilitation and /or Construction Activities

Air Quality

(a) In case demolition, debris-chutes shall be used above the first floor (b) Demolition debris shall be kept in controlled area and sprayed with water mist to reduce debris dust (c) In case pneumatic drilling during excavation dust shall be suppressed by ongoing water spraying and/or installing dust screen enclosures at site (d) The surrounding environment (sidewalks, roads) shall be kept free of debris to minimize dust (e) There will be no open burning of construction / waste material at the site (f) There will be no excessive idling of construction vehicles at sites

Noise (a) Noise during demolishing and construction will be limited to restricted times agreed to in the permit (b) During operations, the engine covers of generators, air compressors and other powered mechanical equipment shall be closed, and equipment placed as far away from residential areas as possible

Water Quality (a) The site will establish appropriate erosion and sediment control measures such as e.g. hay bales and / or

silt fences to prevent sediment from moving off site and causing excessive turbidity in nearby streams and rivers.

Waste management

(a) Waste collection and disposal pathways and sites will be identified for all major waste types expected from demolition and construction activities. (b) Mineral construction wastes will be separated from general refuse, organic, liquid and chemical wastes by on-site sorting and stored in appropriate containers. (c) Construction waste will be collected and disposed properly by licensed collectors (d) The records of waste disposal will be maintained as proof for proper management as designed. (e) Whenever feasible the contractor will reuse and recycle appropriate and viable materials (except asbestos)

C. Individual wastewater treatment system

Water Quality

(a) The approach to handling sanitary wastes and wastewater from building sites (installation or reconstruction) must be approved by the local authorities (b) Before being discharged into receiving waters, effluents from individual wastewater systems must be treated in order to meet the minimal quality criteria set out by national guidelines on effluent quality and wastewater treatment (c) Monitoring of new wastewater systems (before/after) will be carried out (d) Construction vehicles and machinery will be washed only in designated areas where runoff will not pollute natural surface water bodies.

D. Historic building(s) Cultural Heritage

(a) If the building is a designated historic structure, very close to such a structure, or located in a designated historic district, notification shall be made and approvals/permits be obtained from local authorities and all construction activities planned and carried out in line with local and national legislation. (b) It shall be ensured that provisions are put in place so that artefacts or other possible “chance finds” encountered in excavation or construction are noted and registered, responsible officials contacted, and works activities delayed or modified to account for such finds.

E. Acquisition of Land Land take, expropriation (a) Within the scope of this project, any land acquisition, expropriation will be avoided. ANNEX 1: LAND ACQUISITION CHECKLIST will be used to evaluate the land status of the proposed site.

F. Toxic Materials Asbestos management

(a) If asbestos is located on the project site, it shall be marked clearly as hazardous material (b) When possible the asbestos will be appropriately contained and sealed to minimize exposure (c) The asbestos prior to removal (if removal is necessary) will be treated with a wetting agent to minimize asbestos dust (d) Asbestos will be handled and disposed by skilled & experienced professionals (e) If asbestos material is being stored temporarily, the wastes should be securely enclosed inside closed containments and marked appropriately. Security measures will be taken against unauthorized removal from the site. (f) The removed asbestos will not be reused

Toxic / hazardous waste

management

(a) Temporarily storage on site of all hazardous or toxic substances will be in safe containers labelled with details of composition, properties and handling information (b) The containers of hazardous substances shall be placed in a leak-proof container to prevent spillage and leaching (c) The wastes shall be transported by specially licensed carriers and disposed in a licensed facility. (d) Paints with toxic ingredients or solvents or lead-based paints will not be used

27

G. Impacts on natural habitats, forests and/or protected areas

Habitats

(a) All protected areas at national and international level, natural habitats and critical natural habitats, and wetlands will be avoided during site selection. (b) A survey and an inventory shall be made of large trees near the construction activity, large trees shall be marked and cordoned off with fencing, their root system protected, and any damage to the trees avoided (c) Adjacent wetlands and streams shall be protected from construction site run-off with appropriate erosion and sediment control feature to include by not limited to hay bales and silt fences (d) All borrow pits to be used should be licensed pits and these pits should not be located in any site which can be classified as a natural habitat.

H. Disposal of medical waste

Infrastructure for medical waste management

(a) In compliance with national regulations the contractor will insure that health care facilities include sufficient infrastructure for medical waste handling and disposal; this includes and not limited to:

• Special facilities for segregated healthcare waste (including soiled instruments “sharps”, and human tissue or fluids) from another waste disposal; and

• Appropriate storage facilities for medical waste are in place; and • If the activity includes facility-based treatment, appropriate disposal options are in place and

operational

İ. Traffic and Pedestrian Safety

Direct or indirect hazards to public traffic and

pedestrians by construction

activities

(a) In compliance with national regulations the contractor will insure that the construction site is properly secured and construction related traffic regulated. This includes but is not limited to

• Signposting, warning signs, barriers and traffic diversions: site will be clearly visible and the public warned of all potential hazards

• Traffic management system and staff training, especially for site access and near-site heavy traffic. Provision of safe passages and crossings for pedestrians where construction traffic interferes.

• Adjustment of working hours to local traffic patterns, e.g. avoiding major transport activities during rush hours or times of livestock movement

• Active traffic management by trained and visible staff at the site, if required for safe and convenient passage for the public.

28

PART 4: Monitoring Plan

Phase

What

is the parameter to

be monitored?

Where

is the parameter

to be monitored?

How

is the parameter to

be monitored?

When

define the frequency / or continuous?

Why

is the parameter

being monitored?

Cost

if not included in

project budget

Who

is

responsible for monitoring?

During activity preparation (pre-construction)

During activity implementation (construction)

29

ANNEX 3: SAMPLE OF GRIEVANCE FORM Reference No

Full Name

Please mark how you wish

to be contacted (mail,

telephone, e-mail).

Province/Town/Settlement

Date

Category of the Grievance

1. On abandonment (public housing)

2. On assets/properties impacted by the project

3. On infrastructure

4. On decrease or complete loss of sources of income

5. On environmental issues (ex. pollution)

6. On employment

7. On traffic, transportation and other risks

8.Other (Please specify):

Description of the Grievance What happened? 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 name and address is not compulsory, it should be kept in mind that during the feedback process regarding the grievance some problems may be encountered due to lack of

information. Signature: Date:

30

ANNEX 4: SAMPLE OF GRIEVANCE CLOSEOUT 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

Stages of the Remediate Action Deadline and Responsible

Institutions

1.

2.

3.

4.

5.

6.

7.

8.

COMPENSATION AND FINAL STAGES

This part will be filled and signed by the complainant after s/he receives the compensation fees and his/her complaint has been remediated.

Notes:

[Name-Surname and Signature]

Date: ___ / ___ / _____

Of the Complainant:

Representative of the Responsible Institution/Company [Title-Name-Surname and Signature]

31

ANNEX 5: CONSULTATION MEETING PARTICIPANT LIST

Order No

Name and Surname Title Province

1. AHMET IŞIKLI BRANCH MANAGER ADANA

2. AHMET OFLAZ BRANCH MANAGER ADANA

3. MUSTAFA YAYLACI DEPUTY DIRECTOR ADANA

4. HAKAN CEYLAN TECHNICIAN ADANA

5. ABUZER KADİR ÖZKİN PROGRAMMER ADIYAMAN

6. HALİT BİLGİÇ GEOLOGICAL ENGINEER ADIYAMAN

7. MEHMET ALTINDAL DEPUTY DIRECTOR ADIYAMAN

8. METE KIZILKAYA PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

ADIYAMAN

9. YILMAZ KARAKUŞ TECHNICIAN ADIYAMAN

10. VEFA BARDAKÇI PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

ANKARA

11. ADEM KOÇ EVENT MANAGER ANKARA

12. İSMAİL ÇETİNKAYA DEPUTY DIRECTOR ANKARA

13. YALÇIN ZEDALİ BRANCH MANAGER ANKARA

14. MÜBERRA ÖZYILMAZ BRANCH MANAGER ANKARA

32

15. LEYLA ERTUĞRUL OFLAZ ENGINEER ANKARA

16. NECDET SEZER DEPUTY DIRECTOR BURSA

17. ÖZGÜR PAZARLI CHIEF BURSA

18. SABAHATTİN DÜLGER PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

BURSA

19. ADNAN HURATA

PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

DİYARBAKIR

20. İSMAİL TEMEL BRANCH MANAGER DİYARBAKIR

21. MUHAMMED VEYSEL ASLAN SURVEY ENGINEER DİYARBAKIR

22. SÜLEYMAN İLGE DEPUTY DIRECTOR DİYARBAKIR

23. M.METİN KILIÇPARLAR DEPUTY DIRECTOR GAZİANTEP

24. ALİ LEBA BRANCH MANAGER HATAY

25. CENGİZ TUNCAY DATA PREPARATION AND CONTROL OPERATOR

HATAY

26. HALİL SANLI DEPUTY DIRECTOR HATAY

27. DİNÇER TUNA BRANCH MANAGER İSTANBUL

28. HARUN TÜYSÜZ DEPUTY DIRECTOR İSTANBUL

29. İBRAHİM POLAT BRANCH MANAGER İSTANBUL

30. ÖMER FARUK YELKENCİ PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

İSTANBUL

33

31. ŞEHMUS SEVEN ENGINEER İSTANBUL

32. ABDULLAH KOTAY BRANCH MANAGER İZMİR

33. EMİNE GEZGİN CHIEF İZMİR

34. NURAY EMEKSİZ CHIEF İZMİR

35. ÖMER YAHŞİ PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

İZMİR

36. FATİH KORKMAZ CHIEF KAHRAMANMARAŞ

37. HAKAN İĞCİ TECHNICIAN KAHRAMANMARAŞ

38. MEHMET EMİN AKKURT PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

KAHRAMANMARAŞ

39. MUSTAFA DAL TECHNICIAN KAYSERİ

40. REFİK BALCI CHIEF KAYSERİ

41. OSMAN ELMALI PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

KAYSERİ

42. OSMAN ALAN TECHNICIAN KİLİS

43. AHMET YILDIRIM CHIEF KİLİS

44. COŞKUN ZENCİRCİ BRANCH MANAGER KİLİS

45. FEHMİ RASİM ÇELİK PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

KOCAELİ

46. MUKADDER GÜRSOY PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

KONYA

34

47. MUSTAFA YILMAZ DEPUTY DIRECTOR KONYA

48. HALİM YILDIZ BRANCH MANAGER KONYA

49. VAHİT ÇETİN SURVEY ENGINEER KONYA

50. ALİ TATLI PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

MALATYA

51. GÖKHAN YILDIRIM ELECT. ENGINEER MALATYA

52. H.FATİH TOPALOĞLU ARCHITECT MALATYA

53. YAKUP SARI PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

MARDİN

54. ŞEHMUS GÜLER DEPUTY DIRECTOR MARDİN

55. NİHAT ERGİNOĞLU YERSEL CHIEF MARDİN

56. MAHMUT MİRZEOĞLU CONSTRUCTION TECHNICIAN MARDİN

57. ADEM KOCA PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

MARDİN

58. ALİ UZUN BRANCH MANAGER MERSİN

59. EBUBEKİR KILIÇ EMPLOYEE MERSİN

60. OZAN SAĞLAM V.H.K.İ. MERSİN

61. YUSUF DUMAN DEPUTY DIRECTOR MERSİN

62. ABDULLAH TEKDEMİR TEACHER OSMANİYE

35

63. AYTEKİN KÜÇÜK ENGINEER OSMANİYE

64. RAMAZAN ÇELİK PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

OSMANİYE

65. ŞABAN PEKER ŞABAN PEKER İNŞ. ŞANLIURFA

66. ŞERAFETTİN TURAN PROVINCIAL DIRECTOR OF NATIONAL EDUCATION

ŞANLIURFA

67. FEHMİ GÖV BRANCH MANAGER ŞANLIURFA

68. ABDURRAHMAN BİRCAN BRANCH MANAGER ŞANLIURFA

69. BURHAN DAĞTEKİN BRANCH MANAGER ŞANLIURFA

70. AHMET DUMANOĞLU MONE CRED - PROJECT COORDINATOR CENTER

71. BURHANETTİN BÜYÜKAKKAŞLAR MONE CRED CENTER

72. BÜLENT UZUN MONE CRED CENTER

73. CEMAL DEMİR MONE CRED CENTER

74. CİHAN NALBANT MONE CRED CENTER

75. DURMUŞ DEMİR MONE CRED CENTER

76. EMRE DUMAN MONE CRED CENTER

77. EROL BOZKURT MONE CRED - DEPARTMENT OF MONİTORING AND ASSESSMENT

CENTER

78. FATİH MEHMET ORUÇ MONE CRED - CONSTUCTION WORKS DEPARTMENT

CENTER

36

79. GÖKHAN DİNÇ MONE CRED CENTER

80. HACI MEHMET KULOĞLU MONE CRED CENTER

81. İLKER KESKİN MONE CRED CENTER

82. MUSTAFA DERİCİ MONE EVENT MANAGEMENT CENTER

83. MUSTAFA DOĞAN MONE CRED CENTER

84. OSMAN KOÇAK MONE CRED CENTER

85. ÖZCAN DUMAN MONE CRED - CONSTRUCTION AND REAL ESTATE DEPARTMENT

CENTER

86. ÖZGÜR ARAS MONE PRESS AND PUBLIC RELATIONS CENTER

87. RECEP DEMİRCİ MONE CRED CENTER

88. SERDAR AKÇİL MONE CRED CENTER

89. YUSUF M. ÖZYAŞAR MONE CRED CENTER

90. SÜLEYMAN SARIKAYA MONE CRED CENTER

91. TURAN AKPINAR MONE CRED - DEPUTY UNDERDECRETARY

CENTER

92. EKREM KURUM ARTI MİM. MÜH. MÜŞ. TAAH. TİC. LTD. ŞTİ.

ANKARA

93. MEHMET ŞAHİN ARTI MİM. MÜH. MÜŞ. TAAH. TİC. LTD. ŞTİ.

ANKARA

94. OKTAY BOZKURT ARTI MİM. MÜH. MÜŞ. TAAH. TİC. LTD. ŞTİ.

ANKARA

37

95. BAYRAM ATAŞLAR ATAŞLAR - BARAN İNŞ. DİYARBAKIR

96. MUSTAFA DEMİR EMEK - TCK İNŞAAT TRABZON

97. SERDAR GÖYLÜ EYLÜL - ÖMÜR GROUP JOINT VENTURE DİYARBAKIR

98. GÜLİZ CANSABUNCU F.G.C. İNŞAAT İZMİR

99. FEHİM CANSABUNCU F.G.C. İNŞAAT İZMİR

100. ÖMER NESUHİ GÜLEÇ GÜLEÇ DEKORASYON YAPI İNŞAAT NAKL.TAAH.LTD. ŞTİ.

GAZİANTEP

101. BURAK DALGIÇ HİDROTEK MÜŞAVİRLİK A.Ş. ANKARA

102. DOĞAN ÇETİN HİDROTEK MÜŞAVİRLİK A.Ş. ANKARA

103. GİZEM BEKEM HİDROTEK MÜŞAVİRLİK A.Ş. ANKARA

104. İRFAN ÖNER HİDROTEK MÜŞAVİRLİK A.Ş. ANKARA

105. YALÇIN İĞNEBEKÇİLİ HİDROTEK MÜŞAVİRLİK A.Ş. ANKARA

106. ABDULKADİR TANRIAŞIKI İKİZLER İNŞAAT JOINT VENTURE KİLİS

107. CENGİZ TUNCER MAKSİMUM İNŞ. KAYSERİ

108. YUSUF AKSOY MAKSİMUM İNŞ. KAYSERİ

109. İDRİS BOĞRUL MAKSİMUM İNŞ. KAYSERİ

110. MÜSLİM POLAT MAKSİMUM İNŞ. KAYSERİ

38

111. ŞAHİN ÖZKAN MEHMET ÖZKAN İNŞ. HATAY

112. HAYRİYE ÇALIŞKAN MEHMET ÖZKAN İNŞ. HATAY

113. ÜMİT ÇALIŞKAN MEHMET ÖZKAN İNŞ. HATAY

114. SEZAİ ÖZUSAN NAMDAR İNŞ. MÜH. MİMARLIK HİZ. İTH.İHR. SAN TİC. LTD.ŞTİ.

ŞANLIURFA

115. CUMA KOÇAK NOKTA YATIRIM İNŞAAT GIDA TEKSTİL PETSAN. TİC. LTD. ŞTİ.

GAZİANTEP

116. ALP AYDIN PROPLAN PROJE YÖNETİMİ VE DANIŞMANLIK TİC. AŞ.

İSTANBUL

117. ATAKAN PAYSA PREFABRİK İNŞAAT TURİZM VE ENDÜSTRİ LTD. ŞTİ

ANKARA

118. EMİN YILDIZ ÖZKAN KARDEŞLER İNŞAAT SAN VE TİC. LTD. ŞTİ.

HATAY

119. MEHMET ÖZKAN ÖZKAN KARDEŞLER İNŞAAT SAN VE TİC. LTD. ŞTİ.

HATAY

120. MEHMET TEVFİK ARSLAN ÖZGE DİLCE İNŞ. BATMAN

121. CEMAL POLAT TRANSMAN TRANSİT TRANSPORTATION ERZURUM

122. ÖNDER SEYİS TÜMAŞ TÜRK MÜH. MÜŞ. VE MÜT. A.Ş. ANKARA

123. RAZİNHAN ER TÜMAŞ TÜRK MÜH. MÜŞ. VE MÜT. A.Ş. ANKARA

124. SEMİH SERDAR ASLANHAN TÜMAŞ TÜRK MÜH. MÜŞ. VE MÜT. A.Ş. ANKARA

125. YASEMİN KAYA OPTİMAL PROJE YÖNETİMİ VE İNŞ. SAN. TİC. LTD. ŞETİ.

ANKARA

126. ZEYNEP ARSLAN ÖZGE DİCLE İNŞ. BATMAN

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127. AYTEN CAN ELECT. ENGINEER KOCAELİ

128. ŞÜKRAN YILMAZ SURVEY ENGINEER KOCAELİ

129. MURAT DOĞAN DEPUTY DIRECTOR MARDİN

130. MEHMET ÖZKAN MEHMETE ÖZKAN İNŞ. HATAY

131. SERAP AYDOĞAN PROPLAN PROJE ANKARA

132. ERDİNÇ BOZKURT DEPUTY DIRECTOR KOCAELİ

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