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Ulug Enerji

$237.5 million
Environmental and Social Review Summary

Environmental and Social Review Summary 

Ulug Enerji 

This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only. 

Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content. 

MIGA has been requested to cover Actis HoldCo’s (Uludag Power Networks UK Limited) potential equity, and shareholder loan investment to acquire Ulug Enerji that owns UEDAS and UEPSAS in the Uludag region of Turkey from Limak Enerji. UEDAS and UEPSAS together are the Project Enterprises (PEs). UEDAS is an electricity distribution company, while UEPSAS is an energy retail company. Upon acquisition by Actis, Limak Enerji will fully exit the Project and no longer be a shareholder. 

The core activities of the PEs (both distribution and retail) include: (i) distribution network planning and design; (ii) network development, including capital expenditure for network expansion, reinforcement and replacement, safety enhancement, metering, implementation of new technology, support and IT systems and others; (iii) asset operation and maintenance; (iv) general lighting of the distribution region; (v) energy procurement and supply; (vi) meter reading, billing and collection; and (vii) administrative functions (e.g. customer service). The assets operated by UEDAS include medium and low voltage overhead lines, transformers, substations, poles, offices, buildings, warehouses, vehicles, and equipment. All the facilities are currently operating, however, it is likely that new developments (houses and businesses) may require a power connection1. 

Actis was founded in 2004 as a spin-off of the CDC Group plc, a UK development finance institution, and is an existing client of MIGA. Actis has strong experience in the electricity distribution business in several countries around the world including Uganda, Cameroon, and Guatemala.

The Project is categorized as Category B under MIGA’s Policy on Environmental and Social Sustainability (2013) because the potential risks and impacts are limited, few in number, site specific, largely reversible and readily addressed through mitigation measures. The key E&S issues associated with the Project include: (i) environmental, health and safety performance of the current operations; (ii) hazardous and non-hazardous waste management, including Polychlorinated biphenyls (PCBs); and (iii) community health and safety.

While all Performance Standards (PSs) are applicable to this Project, based on our current information, the Project will have impacts which must be managed in a manner consistent with the following PSs: 

  • PS1:  Assessment and Management of Environmental and Social Risks and Impacts 

  • PS2:  Labor and Working Conditions 

  • PS3:  Resource Efficiency and Pollution Prevention  

  • PS4:  Community Health, Safety and Security 

 No vegetation clearance or habitat disturbance or disturbance to cultural assets are anticipated, and therefore, PS 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resource) and PS 8 (Cultural Heritage) are not triggered for this Project. PS7 (Indigenous Peoples) does not apply to the Project as there are no indigenous communities affected by the activities of the PEs.  

In addition, the following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project: 

  • World Bank Group (WBG) General Environmental, Health and Safety (EHS) Guidelines, 2007 

  • WBG EHS Guidelines for Electric Power Transmission and Distribution, 2007 

The following documents were reviewed by MIGA:  

Ulug Enerji 

  • Ulug Enerji Workers Health and Safety Internal Regulation; Feb 01, 2016 

  • Workplace Registration Licenses (dates vary for each facility) 

  • International Organization for Standardization (ISO) Management System certificates; all obtained on Sept 15,2020 

  • OHS Organization Chart 

  • Trainings log 

  • Occupational accidents Lists for 2019 and 2020 

  • First aid training and certification list 2019-2020 

  • Emergency Response Plans for Balikesir, Bursa and Canakkale, released Jan 3, 2016 and revised on Jan 1, 2020 

  • Risk analysis for Covid-19; April 1, 2020 

  • Risk analyses for workplaces; Jan 1, 2020 

  • HR Regulation 

  • MIGA EHS Questionnaire-Ulug 


  • Waste Management Procedure; Oct 20, 2020 

  • Integrated Management system handbook; Oct 5, 2020 

  • Workplace operation licenses; dates vary for each facility, between 2014-2019 

  • OHS training logs; Nov 14-15-21, 2020 

  • Limak Sustainability Goals 2020-30 

  • First aid training participation list; Oct 3, 2020 

  • HR Process Flow documents; released May 15, 2017 and last revised on Oct 20, 2020 

  • OHS Risk Assessment 

  • Human Resources Policy 

  • Risk analysis for Covid-19; Mar 15, 2020 

  • MIGA EHS Questionnaire-UEPSAS 


  • Waste Management Procedure; Aug 21, 2017 

  • Annual Waste Management Plan; released Aug 21, 2018, revised Oct 8, 2020 

  • QEHS Integrated Management system handbook; released Jul 31, 2017, revised Oct 8, 2020 

  • Environmental Impact and Risk Analysis; released Aug 21, 2017, revised Oct 8, 2018 

  • Waste Impact Assessment; released Aug 21, 2017, revised Oct 8, 2018 

  • Official grievances list 

  • Administrative court cases list 

  • Location map and hub addresses 

  • Workplace operation licenses (dates vary for each facility) 

  • Official EIA-Exempt correspondence documents- Nov 4, 2019 (Balikesir), Nov 8, 2019 (Canakkale), Nov 7, 2019 (Yalova) 

  • Forest permit; Sept 3, 2018 

  • Official correspondence on cultural heritage; Feb 19, 2018 

  • Ministry explanation letter for hazardous waste management practices of distribution companies; Feb 9, 2018 

  • OHS training logs -Sept 29, 2020 & Jul 16, 2019 

  • First aid training participation list; Jan31-Feb1, 2019 

  • Management systems training participation list; 14-18 Jun, 2019 

  • Court cases regarding physical damages 

  • Environmental grievances 2020 

  • Burhaniye and MKP Fire Safety Reports; dates Oct23, 2018 and Dec 17, 2012 respectively 

  • Fire precaution and action instructions-one pg; Jul 31, 2017 

  • HR Regulation; released Jul 31, 2017, revised Nov 13, 2020 

  • OHS Risk Assessment; Aug 12, 2020 

  • Occupational Accidents for 2018,19 and 20 

  • Contractor OHS accidents 

  • PCB Test Results 2018 

  • General environmental info including SF6  

  • Expropriation related grievances 

  • Total Land acquisition data 

  • MIGA EHS Questionnaire-UEDAS 

Due to COVID-19 travel restrictions, MIGA was not able to undertake a due diligence site visit. However, with the support of an in-country independent E&S consultant, site visits were conducted to UEDAS and UEPSAS headquarters in Bursa, as well as to sample urban and rural network components and customer service centers in the Uludag region in February 2021. In addition, MIGA also held conference calls with Actis representatives.  

MIGA’s due diligence review considered the E&S management planning process and documentation for the Project and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and in the E&S Action Plan (ESAP) attached to this ESRS. Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards. Key E&S issues associated with the Project business activities are summarized in the paragraphs that follow. 

PS1:  Assessment and Management of Environmental and Social Risks and Impacts 

Environmental and Social Assessment and Management System 

Quality, environment, health and safety issues are managed through an integrated management system developed by the PEs. In addition, UEDAS has the following certifications related to management systems: ISO 9001 (Quality Management), ISO 14001 (Environmental Management Systems), ISO 45001 (Occupational Health and Safety), ISO 10002:2018 (Customer Satisfaction and Complaints Handling), ISO 18295-1:2017 (Customer Contact Centres), ISO 27001:2017 (Information Security Management), and ISO 22301 (Security and Resilience Business Continuity Management Systems). 

Identification of Risks and Impacts  

As per National Environmental Impact Assessment (EIA) Regulations, energy transmission lines that are less than 5 kilometers (km) and/or with a voltage of less 154 kilovolts (kV) do not require an EIA. All of UEDAS’s transmission lines are less than 154kV and therefore out of scope of the Turkish EIA regulations. EIA exempt letters have been obtained for UEDAS’s electrical equipment storage areas and warehouses in Canakkale, Yalova and Balikesir. The application for a waiver in a warehouse in Bursa is still pending and a copy of the waiver will be provided to MIGA by the PEs (ESAP action item #1).  

Management Programs:  

The PEs currently operate a fully integrated management system (IMS) comprising elements of quality, environmental management, health and safety, social management (including customer/stakeholder engagement), security (including data security) and emergency response.  Components of the IMS are spread across various documents and handbooks. In addition, and as mentioned previously, UEDAS has ISO 14001 certification.  

Organizational Capacity and Competency:  

Occupational Health and Safety (OHS) aspects are overseen by a dedicated supervisory unit, in line with national legislation in each PE. The OHS unit organizational structure is relatively well defined, however there is no specific role for senior-level E&S oversight, although UEDAS contracts environmental consulting services from a local E&S consulting firm. As per the ESAP, the Project will therefore appoint a senior E&S specialist in a Managerial (or above) position to coordinate all relevant E&S matters across the PEs (ESAP action item #2).  

OHS, first aid trainings and fire drills are carried out for all personnel. Additional job-specific training includes high voltage facility work permit training, driving and vehicle operations, psychology etc. Copies of training records were reviewed during the site visit carried out by MIGAs consultant. Only trained and certified workers are allowed to install, maintain or repair electrical equipment at UEDAS.  

Emergency Preparedness and Response:  

Fire drills and inspection activities are carried out by the OHS unit in each PE. In addition, equipment is checked annually by a certified company and electrical and mechanical suppression systems were inspected last in August 2020. The 2020 fire drills were postponed for both PEs due to the COVID-19 pandemic.  

Risk assessments have been carried out for both PEs. Emergency Response Plans have also been prepared and implemented, and are regularly reviewed. 

Monitoring and Review:  


A Quality, Environment, Health and Safety Integrated Management System Handbook outlines the processes, procedures and forms related to ISO 9001, ISO 14001 and ISO 45001 standards for UEDAS. According to the Handbook, UEDAS undertakes an internal audit at least once a year, which is usually followed by the internal review of the management systems conducted by management. The PEs will provide MIGA with an Annual Monitoring Report (AMR) that reports on compliance with national legislation and the PSs 



Stakeholder Engagement  

Stakeholder engagement activities are managed by Corporate Communications Department of Limak Enerji, and by on-site operational managers and engineers. During the site visit, UEDAS and UEPSAS representatives stated that consultation activities are regularly conducted with various stakeholders, however systematic records of the engagement activities were not available. However, when there is a grievance, feedback is provided in line with the grievance mechanism.  

After Limak Enerji’s exit and as part of the ESMS, the PEs will develop and implement a Stakeholder Engagement Plan (SEP).  The SEP will: (i) outline the Project’s objectives in terms of stakeholder engagement; (ii) describe the activities to be conducted with the stakeholders; (iii) include procedures for documenting engagement activities; and (iv) include measures to allow the effective participation of those identified as disadvantaged or vulnerable (ESAP action item #3). As part of the SEP, the PEs will ensure a proactive dialogue is maintained with customers and communities within the area of operation. The implications of COVID-19 should be taken fully into account in the SEP and measures to undertake engagement where face-to-face options are not available identified. 

External Communication and Grievance Mechanisms:  

Both PEs have external grievance mechanisms that collect, categorize and respond to grievances raised by individual customers or public/private entities. There is an external grievance register and a total of 3,390 grievances were recorded in 2020 mainly related to technical issues such as lighting, meter readings, power outage and property damage during works. In addition, there is: (i) a call-center service available in Turkish and Arabic, where received grievances are recorded and the necessary departments are informed for their actions; (ii) a private hotline for the use of community headpersons (i.e. muhtars) for swift action in case of a grievance/suggestion/fault reporting.  


PS2:  Labor and Working Conditions 

The number of workers in 2020 are as follows:  

  • UEDAS had a total of 474 direct employees, including 59 of them women, as well as 2,402 employed by contractors (most of these contractors are employed by Ulug Enerji and provide services to UEDAS); and 

  • UEPSAS had a total of 98 employees, including 43 women employees, as well as 171 employed by contractors. 

Working Conditions and Management of Worker Relationship 

The PEs have developed and is implementing a HR Policy and Procedures document that covers the distribution and retail businesses. In addition to the HR policy, this document outlines the hiring process, training, performance management, promotion/duty assignment, grievance procedures, working conditions, employee responsibilities, ethics committee procedures and disciplinary actions, customer relations, employee property use, personal care and attire and OHS. Apart from the grievance procedure (as described below), the HR Procedures are in line with the requirements of PS2.  

The HR Procedures allow workers to form and join worker’s organizations and the unionization rate in UEDAS is approximately 74% (1,300 workers). 

The PEs have an internal grievance redress mechanism (GRM) that allows for anonymous complaints to be raised, is accessible to contractors and is communicated to all employees effectively. The PEs code of conduct explicitly prohibits harassment or violence of any sort towards co-workers or customers, including gender-based violence and sexual harassment, with appropriate disciplinary measures clearly described in the event of any breaches.  

Occupational Health and Safety:  

As mentioned previously, a Quality, Environment, Health and Safety Integrated Management System Handbook outlines the processes, procedures and forms related to ISO 9001, ISO 14001 and ISO 45001 standards for UEDAS.  In addition, the PEs have a comprehensive incident reporting process that includes both incidents and near misses. Root causes, remedial actions and lessons learned are all recorded and communicated to direct and contractor employees.  

Interviews carried out during the site visit indicated that UEDAS employees (distribution station workers, fault intervention workers, maintenance workers, etc.) are all aware of work-related OHS risks, management of these risks, and work-related PPE usage. The PEs have implemented additional OHS measures related to COVID19 (such as PPEs, sanitization, health screens, etc.), and during the site visit, it was observed that COVID-19 measures were taken by both UEDAS and UEPSAS. 

In addition, UEDAS implements an online system for work permits and prior to performing any activity on a work-site, site teams record a video showing their PPE usage, work environment, surroundings, measures taken for public (e.g. safety tapes, traffic diversions, etc.), and send the video to UEDAS’s online management system. An OHS expert examines the video, and if found sufficient, approve team to work.  

As electric utility workers typically have a higher exposure to electric and magnetic fields (EMF), UEDAS has developed and is implementing appropriate safety programs in line with the associated risk to workers. 

Workers Engaged by Third Parties:  

UEDAS includes an OHS and environmental addendum to all contracts with third parties. All contractors are audited periodically and in case of any non-compliance, UEDAS imposes fines as stipulated in the contract. A Third Party OHS Management Procedure has been developed as a guidance document.   

Worker’s engaged though contractors has access to the grievance redress mechanism described implemented through the HR Procedures.  

PS3:  Resource Efficiency and Pollution Prevention 

Resource Efficiency 

The PEs follow the Limak Sustainability Goals for 2020-2030 period, which includes initiatives aiming to decrease resource consumption and increase recycling2. Monitoring of energy and water consumption at the district offices will be carried out and the results included in the AMR provided to MIGA.  

As UEDAS does currently not monitor or report greenhouse gas (GHG) emissions as per national legislation requirements, quantification of GHG emissions will be conducted annually in accordance with PS3 and the results included in the AMR provided to MIGA.  

Water to the warehouses is supplied by the city networks. Only one warehouse facility has a borehole (Balikesir). As water consumption is currently not systematically monitored, the PEs will add a procedure to monitor and report on water consumption (ESAP action item #4). The results of the of the systematic monitoring will be included in the AMR provided to MIGA.  

Pollution Prevention 

Wastewater information is available only for the warehouses. The Yalova warehouse is connected to the municipal sewage system and there are cesspool septic systems in the Canakkale, Balikesir and Panayir warehouses. Industrial wastewater is not generated in the facilities. Domestic wastewater generated from the office buildings and other facilities is discharged to municipality sewers.  

Environmental risk analysis and impact documents are available focusing on waste management and an annual waste management plan has also been developed for all hazardous and non-hazardous waste categories for the PEs. In addition, UEPSAS has a Waste Management Procedure which identifies waste streams, types, and collection and disposal methods. Furthermore, UEDAS has an Industrial Waste Management Plan that is developed in accordance with the stipulations of the national Waste Management Regulation. Hazardous and non-hazardous waste amounts are recorded, and Ministry of Environment and Urbanization is notified accordingly. Observations made during a site visit to a warehouse in Bursa shows an adequate temporary waste storage area that has designated rooms for different types of wastes, lean-to-roof, impermeable ground and a  spill drainage system.   

UEDAS has conducted a study to identify equipment and machinery containing Polychlorinated Biphenyls (PCB). As a result of the study, two transformers, which are approximately 30-40 years old have been identified as containing PCB. Replacement of these transformers is included in the maintenance plans, as well as adequate disposal of the PCB. 


Prior to renovation works planned to be performed at UEDAS’s main warehouse located in Bursa, an asbestos survey was performed. The study showed that there are asbestos containing materials used especially in the roofs. Before renovation works, UEDAS will take necessary measures to manage asbestos containing materials in line with the WBG EHS Guidelines (ESAP action item #5).  

Materials containing Sulfur hexafluoride (SF6) are present on sites. However, SF6 levels are monitored by equipment inspection contractors.  An inventory screening was conducted for equipment in UEDAS warehouse/storage areas, and all were determined to contain less than 3 kilograms (kg) of fluorinated greenhouse gases (as per national regulation, equipment containing 3kg or more f-gas is subject to periodical checks). There was no reported use of wood preservatives such as creosote, pentachlorophenol (PCP), chromated copper arsenate (CCA) to protect wooden utility poles against insect, bacteria, and fungi, and rot. 

PS4:  Community Health, Safety and Security 

Community Health and Safety 

The key risks related to community health and safety include electrocution incidents and traffic. To manage community health and safety risks, the PEs have developed regulations on public safety, which provide a framework to ensure that the activities of the PE do not affect the health and safety of surrounding communities. There have been no major traffic threats or incidents related to community health and safety reported. In addition, a standalone risk assessment has also been developed for COVID-19 and an emergency response plan specific to the pandemic has been developed and includes an assessment of the potential risks to the health and safety of the community.  As mentioned previously, there is: (i) a call-center service available in Turkish and Arabic, where received grievances are recorded and the necessary departments are informed for their actions; (ii) a private hotline for the use of community headpersons for swift action in case of a grievance/suggestion/fault reporting. 

Security Personnel 

There are security personnel provided by licensed security contractors at the headquarters, customer centers, and warehouses. In addition, security plans have been developed and implemented. The security plans include site maps, personnel’s security equipment, defined security risks and procedures as well as communication protocols.  The PEs will therefore review the security contractor’s training program to ensure personnel receive procedural trainings on proper conduct, rules of engagement and ethics/human rights (ESAP action item #6).   

PS5:  Land Acquisition and Involuntary Resettlement  

While no further significant land acquisition or resettlement is anticipated, land acquisition may be unavoidable in order to provide wayleaves for connecting new housing or businesses. UEDAS operates in line with Turkish legislation with regards to any land acquisition and prefers to avoid the acquisition of privately owned land wherever possible. In the event that a network extension is deemed essential and land expropriation is unavoidable, these areas are identified and reported to Turkish Electricity Distribution Corporation, who then undertakes expropriation procedures in line with the Turkish Expropriation Law. Therefore, in line with the ESAP, a Corporate Land Acquisition and Resettlement Framework will be developed outlining principles, procedures and institutional responsibilities for new project developments, in line with national legislation and PS 5 requirements (ESAP action item # 7).  

For additional information on the Project, please contact: 


  • NAME & Title: James Magor (Director, Responsible Investment, Actis) 

Address: 2 More London Riverside, London, SE1 2JT, United Kingdom 


Phone: +44 (0) 2072345114 



MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities. 

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA. 

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm. 

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below: 

Compliance Advisor/Ombudsman 
International Finance Corporation 
2121 Pennsylvania Avenue NW 
Room F11K-232 
Washington, DC 20433 USA 
Tel: 1 202 458 1973 
Fax: 1 202 522 7400