Environmental Management Policy

Agacan Tarım Gıda Turizm Ltd. Şti., operating as ACG Industrial & Infrastructure Solutions (ACG IIS), is committed to identifying, managing, and minimising the environmental impacts of all its operations. This commitment extends across every phase of project delivery — from engineering specification and procurement through construction, commissioning, and handover — and applies equally to ACG IIS's own offices, supply chain, and logistics operations.

ACG IIS recognises that infrastructure and development projects in East Africa and the Middle East operate in ecologically sensitive and resource-constrained environments. The communities served by these projects depend directly on clean water, healthy land, and functioning ecosystems. Protecting these resources is not only a regulatory obligation — it is a fundamental responsibility to the communities in which ACG IIS operates and a prerequisite for the sustainable development outcomes that our project work is intended to create.

• All ACG IIS project sites in all countries of operation
• All procurement and supply chain activities managed by ACG IIS
• All logistics operations conducted by or on behalf of ACG IIS
• All subcontractors and suppliers engaged by ACG IIS on any project or assignment
• ACG IIS office environments in Uganda, Turkey, Scotland, and all other locations
• All personnel — permanent, contracted, and seconded

Framework	Application
IFC Performance Standard 1	Assessment and Management of Environmental and Social Risks — all donor-funded projects
IFC Performance Standard 3	Resource Efficiency and Pollution Prevention — energy, water, waste, GHG emissions
IFC Performance Standard 4	Community Health, Safety and Security — impacts on surrounding communities
IFC Performance Standard 6	Biodiversity Conservation — protection of habitats and species within and adjacent to project areas
ISO 14001:2015	Environmental Management System framework — applied on relevant projects as reference standard
Uganda National Environment Act 2019	All project activities with potential environmental impact in Uganda
Uganda EIA Regulations (SI 13/1998)	Environmental Impact Assessment requirements for prescribed projects in Uganda
Kenya Environmental Management Act 2015	Projects with environmental impact in Kenya
EU EIA Directive 2011/92/EU	Reference standard for ESIA methodology on EU-funded projects

4.1 Environmental and Social Impact Assessment (ESIA)

ACG IIS conducts an environmental screening at the outset of all project activities to determine the level of environmental review required. For projects funded by multilateral donors, subject to national environmental regulations, or assessed as carrying significant environmental risk, a formal ESIA is commissioned and implemented in accordance with the applicable framework.

4.2 Environmental Management Plan (EMP)

For all projects assessed as having moderate to significant environmental impact, ACG IIS prepares a site-specific Environmental Management Plan prior to commencement. The EMP identifies all significant environmental aspects, sets control measures and mitigation actions, assigns responsibilities, and establishes monitoring requirements.

4.3 Waste Management

All project activities are conducted under a Waste Management Plan. ACG IIS applies the waste hierarchy — Reduce, Reuse, Recycle, Recover, Dispose — to all waste streams generated on project sites.

Waste Category	Management Requirement
General construction waste	Segregated at source; inert waste to approved landfill; recyclables directed to licensed facilities
Hazardous waste	Documented chain of custody from generation to final disposal; licensed contractor; manifest system
E-waste / electrical equipment	Directed to certified e-waste recycler; no uncontrolled disposal
Wastewater / effluent	No untreated discharge to watercourses or ground; temporary sanitation facilities on all sites
Packaging / procurement waste	Packaging minimisation requirements communicated to suppliers; single-use plastic avoided where alternatives exist

5.1 Water Resources

• No untreated effluent, construction runoff, or contaminated water discharged to surface water, groundwater, or wetlands
• Erosion and sediment control measures implemented on all earthworks and construction sites
• Drill cuttings and drilling fluids managed in accordance with applicable regulations on borehole projects

5.2 Air Quality

• Dust suppression measures applied on all earth-moving and demolition activities
• Diesel generator and vehicle emissions minimised through equipment maintenance programmes and fuel quality standards
• Open burning of waste is prohibited on all ACG IIS project sites

5.3 Hazardous Materials

• All hazardous materials stored in secondary containment with spill prevention and response equipment
• A Material Safety Data Sheet (MSDS/SDS) register maintained for all hazardous substances on site
• Fuel storage complies with applicable national regulations and IFC EHS Guidelines

5.4 Noise and Vibration

• Construction activities generating significant noise or vibration scheduled to minimise impact on surrounding communities
• Noise impact assessments conducted on projects in sensitive locations

ACG IIS commits to no net loss of biodiversity on all projects. For projects in or adjacent to protected areas, critical habitats, or areas of recognised ecological sensitivity, a Biodiversity Management Plan is prepared and implemented in accordance with IFC Performance Standard 6.

Land acquisition and resettlement activities, where required, are conducted in compliance with IFC Performance Standard 5 (Land Acquisition and Involuntary Resettlement) and applicable national law, with particular attention to the rights of affected communities and vulnerable groups.

• Preference for energy-efficient equipment in all procurement recommendations
• Promotion of renewable energy solutions where technically and commercially feasible
• Fuel consumption monitoring and reporting on projects where transport and generation are significant emission sources
• Assessment of climate resilience risks on infrastructure projects in climate-vulnerable regions

ACG IIS recognises that environmental impacts do not stop at the project boundary. Community health, water supply, and livelihoods may be affected by project activities. ACG IIS implements a community engagement process on all projects with potential off-site environmental impacts, including a Grievance Redress Mechanism accessible to all affected community members.

All ACG IIS project personnel responsible for activities with environmental impact receive environmental awareness training at induction. Personnel responsible for managing environmental aspects receive role-specific training appropriate to their responsibilities.

Environmental performance is monitored through site inspections, internal audits, incident tracking, and review of waste and resource consumption data. Environmental performance is reported to project clients and donors in the format and at the frequency required by contract and grant documentation. This policy is reviewed annually.