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Supplementary
Disclosures for BIST

We prepared this section in line with TCCC standards and all the policies are relevant to CCI operations in order to provide additional qualitative and quantitative information required by the Sustainability Index on environment (including biodiversity and climate change), governance (including board practice), bribery and corruption, human rights, and stakeholder issues (including health & safety, covering the parts of each topic which fall outside the scope of this sustainability report.
Environment
Environmental Policy and Reporting
CCI’s environmental policy, the results of key performance indicators and targets of our three main focus areas;
• Energy Management and Climate Protection
• Water Management
• Sustainable Packaging
are provided in the Environmental Footprint
Section 2 – Sustainability in Review of this report.

All CCI environmental data is provided under Environmental
Footprint topic under
Section 3 – Performance Indicators of this report.
In addition to the above-mentioned topics, we also monitor and manage our atmospheric emissions in line with national regulations as well as with TCCC standards in all our operations. All CCI plants (except water treatment plants) are in the scope of “Emission Permission” according to Air Pollution Control Regulation.
Sulphur oxides (SOx), nitrogen oxides (NOx), dust, and carbon monoxide (CO) parameters are measured in every two years and an air emission reports prepared. The materiality assessment we conducted showed that air emissions from our factories, both quantitatively and qualitatively, are insignificant. Nevertheless, we also included atmospheric and wastewater data in this section.
Environmental Management
For CCI environmental management structure, please refer to Sustainability Organization topic of this report.

For CCI environmental management systems, please refer to the Environmental Footprint and Management Systems Standards and Principles topics of this report.
Environmental Management System (EMS)
CCI’s environmental management system has been established in compliance with KORE, which is the Environmental Management System of Coca-Cola Company and TSE ISO 14001, which covers the basic principles and practices of these systems.

This system is built on five basic principles:

1-Our commitment to be the leader in environmental protection

For an effective environmental management program, and in terms of our commitment to environmental protection, the full participation of all employees of CCI’s operations is required. All employees should completely understand and practice the daily activities which should be complied with in terms of environment.

2-Compliance with environmental matters and going beyond compliance

Our commitment to environmental protection extends beyond the legal requirements and regulations relating to the environment.

3-Minimizing the effect and determining the opportunities

According to the results of various research conducted around the world, the negative effects on environment should be reduced by using new technologies and implementing recommendations of successful studies on the environment. Pollution prevention and control implementations should be practiced in a responsible manner, thereby minimizing our waste as well as costs related to waste management.

4-Auditing environmental activities

For continuous development, every activity we performed, and every written document produced with respect to the environment should be audited pursuant to the quality system and environmental management system. If there are findings as a result of the audits conducted by auditors or government agencies or the auditors of TCCC, then the necessary corrective and preventive actions should be taken.

5-Social responsibility

As being a part of the society, we use all kinds of information and combine our energies with public, private, and non-governmental organizations in a manner to create positive improvements and fulfill our social responsibilities to the environment.
Target Setting & Planning
At the beginning of each year, under the leadership of the Operations Manager and with the participation of the Environmental team, the objectives and targets of our plant environmental management system is defined for the new year according to the local legislation and company requirements as well as environmental policies in order to minimize the environmental impacts or to keep them under control. While determining the targets for the new year, the factors like the results of the previous years, company targets, legal requirements, measurability, traceability and applicability of the objectives are considered in accordance with our continuous development principle.
Major environmental performance indicators and targets determined by the plants are incorporated in CCI’s business plan.

Plant environmental performance indicators are shared with all employees and the Business Unit (BU). Performance indicators are constantly followed throughout the year and the compliance with the objectives is kept under control. Performance indicators are reported monthly to the BU, plant management and senior management.
EMS Audits
The environmental management system is assessed once a year. The nonconformities in matters regarding environment management system that are found both in internal and external assessments and in daily practice are processed according to the relevant procedures. The Environmental Coordinator is responsible for the assessment of the environment management system and for the follow-up of the corrective/preventive activities. The Environmental Management System is assessed every quarter during operation meetings and in annual management review meetings. The existing regions are also audited in terms of Environmental Management System during monthly environmental checks.
Those responsible for executing and coordinating CCI’s environmental management activities in our plants do so in line with the legislation, conduct and internal audit according to the provisions of the relevant legislation at least once a year and issue a report at the end of the internal audit. Non-conformities are followed, preventive and corrective actions are taken according to the relevant procedure.

CCI plants ensure that the obligations defined in the relevant legislation are fulfilled by monitoring the operations performed in regular intervals.The assessment of environmental management system performance at CCI locations is necessary to understand the effectiveness of the program. The final summary of the environmental performance is the monthly assessment of the factory environmental performance measurement report.
The basic performance indicators reported are as follows;
Water Usage Ratio (L / L)
Energy Usage Ratio (MJ / L)
Wastewater Generation Ratio (L / L)
Solid Waste Generation Ratio (g/L)
Solid Waste Recycling Ratio (%)
CO2 Emission Ratio (g/ L)
Additionally, every plant has to comply with local legal requirements and TCCC limits in air emissions and wastewater discharge.
All CCI plants are also audited regarding environment management system requirements and TCCC’s standards by TCCC audit department regularly (at least every 2 years).

ISO 14064-1 GHG verification and ISO 50001 Management System Certification Audits are conducted in CCI Turkey plants every year. Additionally, selected environmental KPIs are verified by third party auditing companies every year. Verification statements are available in this report.
EMS Review
Management Review Meeting is held in line with CCI’s Environment Management System requirements at least once a year. Environmental key performance indicators are reviewed during Business Plan Meetings.
The Environmental board meetings and the annual management review meeting involves the following topics.
a - Discussing the decisions made in the previous meeting,
b - Discussing the environmental management system performance indicators,
c - Revisions and improvements in environmental management system indicators,
d - Internal and external audit findings and environmental accidents, feedbacks and complaints regarding environment management system,
e - Corrective and preventive activities regarding the environmental management system,
f - Improvement recommendation regarding environmental management system,
g - Amendments in law and company requirements,
h - Assessment of supplier and subcontractor activities and, if any, the nonconformities in environmental practices,
i - Reviewing the environment policy and its fitness to the needs,
j - Environmental Risk Assessment
k -
Technological, managerial, design, etc. changes which may affect the environment performance and objectives
EMS Procedures
The Environmental Coordinator is responsible for ensuring all associated operations are in compliance with all relevant laws and regulations regarding environment. He/she should find the method for applying these laws and regulations to work. He/she should follow all updated laws related to environment and evaluate compliance.

As well as laws and regulations, he/she should follow the Coca-Cola KORE system and ISO 14001 standards and adapt them to factory’s environmental management system and ensure its continuity.

The Environmental Coordinator also works in coordination with BU in environmental matters and completely fulfills the requests of The Coca-Cola Company within this respect.

There are several procedures that CCI follows and all these procedures are standard in all plants;
Environmental Management Procedure
Waste Management Procedure
Hazardous Materials Management Procedure
Wastewater Management Procedure
Storm Water Management Procedure
Fleet Management Procedure
Ozone Protection Procedure
Air Pollution Control Procedure
Water Management Procedure
Energy Management Procedure (ISO 50001)
ISO 14064-1 GHG Manual (CCI Turkey)
Environmental Operations Management Designs in Compliance with Environment

While designing new packaging, products, processes, factories or offices, their full compliance with environmental laws should be checked. In new designs, systems which are recently invented, and which will further protect the environment should be used.

Forklifts using LPG should be used when possible in the factory while electric forklifts should be used indoors. Maintenance of forklifts is performed regularly. Waste from forklift maintenance is disposed of in a manner that is compliant with legislation.

Waste Management

The type of waste generated at CCI locations, recyclable solid wastes, where and how to collect them, the amount of waste and whether to remove them from the collection area are determined. The hazardous waste of the factory is determined by the Environmental Coordinator by considering the provisions of relevant regulations, and the storage and removal methods are appointed according to the same regulations. Recyclable waste, hazardous waste, and medical waste are stored separately in the factory. Wastes which may not be recycled are collected and disposed of separately from recyclable waste.

Rainwater Pollution Prevention

Rainwater drainage channels are marked on a project plan showing all infrastructure drainage channels at CCI locations. The contamination of rainwater with substances hazardous to the environment through chemical diffusion or contamination of wastewater generated from the processes via channels in the factory is brought under control. Operators are trained on preventing the contamination of rainwater.
Wastewater Management

All process and domestic wastewater at CCI locations are processed (local treatment facility, neutralization, central treatment facility, etc.) as required in order to discharge them to the receiving environment in compliance with discharging standards without harming the environment. The operation and analysis methods and the principles of local treatment facility are described in the relevant procedures/guidelines. The required intervention in case of nonconformities in the quality of the treated water from the wastewater facility is made by the Treatment Facility Operator under the supervision of the Quality Assurance Chief. The central treatment facilities are periodically visited, and discharge water analysis results are taken. In case of nonconformity, a Corrective/Preventive action is taken.

Environmental Risk Assessment and Generating Control Plans

The environmental aspects which constitute a potential risk to the environmental pollution and ecological balance at CCI locations are determined. The environmental risk is scored on this list and the control measures for important environmental risks are determined. An action plan (Environmental Program) is prepared for medium and high risks, and it is updated in case of environmental accident, process amendment, new line installation, or legislation amendment is reviewed once every year.

Noise Control

To determine the effects of the noise on environment and employees at CCI locations, necessary assessments are conducted regularly. If the noise level exceeds the standards in the assessment, then necessary improvements are performed. The purpose is to reduce noise at its source.
Biodiversity
CCI’s highest impacts on biodiversity occurs as a result of the water we use during production. We reuse and recycle water, treat it via wastewater treatment facilities, and replenish it via our community projects. At the local level, since 2012, we conduct source vulnerability assessments (SVA) to develop source water protection plan (SWPP) to protect water catchment basins in the regions where our plants are located and to mitigate water-related risks to our system and to the communities we serve.

We fully support TCCC’s ultimate goal of “replenishing every drop of water used.”

In 2019, we have submitted our fifth detailed report to Carbon Disclosure Project (CDP) Water program on our water strategy and data.

For detailed disclosures on water efficiency performance of CCI, please refer to the Water Management topic under Environmental Footprint part of this report.
Biodiversity Impacts of Water
Stewardship Projects  
Among the water stewardship projects ‘Agriculture of the Future Project’, which is a part of “Life Plus Environment” Program, bears the highest impacts on biodiversity.

This Project has two objectives:

1) to improve the water holding capacity of soil, ensuring the efficient use of land and water, and

2) to increase the capacity to use the ecosystem services in agriculture. In order to do this, the project implements direct seeding and windbreaks. Direct seeding machines were provided to farmers in four districts in the Konya basin. The project was conducted in partnership with the Coca-Cola Life Plus Foundation, Turkey’s Ministry of Food, Agriculture and Livestock, and the Nature Conservation Center.  

For detailed information on water replenishment projects of CCI, please refer to the Water Stewardship topic under Community Investments part of this report.
Biodiversity Conservation Aspect of the Agriculture of the Future Project

Conventional nature conservation activities focus on conservation of certain species or their ecosystems. The new approaches, such as ecosystem and biodiversity conservation, take into account the multi-sector nature of conservation practices and aim at sustainable use and conservation of natural resources. The Agriculture of the Future Project aims at promoting the “ecosystem services” approach in agricultural practices in order to conserve agricultural ecosystems and biodiversity without reducing the prosperity of the communities. The project’s ecosystem services, and biodiversity monitoring activities are summarized below.
Ecosystem Services Approach in the Project

Natural ecosystems provide various benefits, which are called ecosystem services, for human welfare directly or indirectly. Agriculture is a dominant human activity and agricultural land covers nearly 40% of the terrestrial surface. The ecosystem services used by agricultural production can be provisioning (freshwater, genetic biodiversity etc.), supporting (soil structure and fertility), or regulating services (climate regulation, pollination, biological control etc.).

In the Agriculture of the Future Project, the aim is to integrate the ecosystem approach (a strategy for sustainable management of land, water and living resources) into agricultural activities. The ecosystem approach provides tools to minimize the conflicts between nature conservation and economic activities, and thus enhances sustainability of the socio-ecological systems. The project is the first of its kind in terms of having such a comprehensive approach to handling socio-economic activities and environmental values together.
The project includes conservation agriculture activities such as implementing direct seeding and wind breakers. These activities are important tools for protecting soil and water resources which are important components of ecosystems. In order to increase the integration level of the ecosystem approach into the project, the following activities are being carried out:
Mapping of agricultural ecosystems
Determining the benefits of ecosystem services to agricultural practices
Developing, in collaboration with Yale University School of Forestry and Environmental Studies, a methodology for mappin these services
Mapping ecosystem services through advanced scientific approaches and incorporating local knowledge through a participatory approach
Analyzing the vulnerability of agricultural ecosystems
Modeling climate parameters related to agriculture
Determining to what extent ecosystems are vulnerable to climatic changes and human activities.
Developing recommendations for protection of the vulnerable ecosystem services
Below are ecosystem services maps produced for the Cihanbeyli District of Konya.
Biodiversity Monitoring Activities in the
Project
The conservation agriculture activities in the project protect soil and water, both significant resources for biodiversity elements in the region. In order to monitor the interaction of the project activities with the biodiversity of the area, we developed a continuous monitoring program which includes:  
Determination of the species groups to be affected from agricultural activities
Determination of rare/endangered/endemic/
sensitive species in Konya
Determination of the monitoring and inventory methodology
Continuous monitoring of selected species groups, especially those that are rare/ endangered/endemic/sensitive.
As a part of the biodiversity monitoring activities in the project, 43 bird species, 18 plant species, 15 butterfly species, and 10 small mammal species has been observed in the direct seeding areas, wind break zones and control areas. The project also develops environment-friendly solutions to the problems of agricultural production, such as rodent management. As a part of biological pest control scheme, owl and kestrel boxes are placed in farming areas as an alternative to chemical pesticides used to exterminate the rodents in the fields.  
Wastewater Management and Reclamation
For detailed disclosures on wastewater management performance of CCI, please refer to the Water Management topic under Environmental Footprint part of this report.
All CCI plants must comply with TCCC’s Water Discharge Limits as outlined in KORE procedure, “Wastewater Quality Requirements”.
Results of CCI plants’ water discharge analysis for 2019 are in following tables.
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SC*** Discharge concentration at or below sea concentration
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Climate Change
For detailed disclosures on climate protection performance of CCI, please refer to the Energy Management and Climate Protection topic under Environmental Footprint part of this report.
For detailed data on climate protection performance of CCI, please refer to the Environmental Footprint topic under Section 3 – Performance Indicators of this report.
Emissions to Air
CCI manages all of its environmental impacts including emission to air. Our targets for atmospheric emissions are to improve our efficiency values and to remain 100% legally compliant. 2019 stack gas emission analysis results of CCI pants are given in the following tables.
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Governance
Board Practice
For detailed information on board structure and practices please refer to CCI 2019 Annual Report pages 96-105.
For detailed information on board structure and practices please refer to CCI 2019 Annual Report pages 96-105.
Bribery and Corruption
Countering Bribery Policy and Reporting
CCI’s anti-bribery policy is a part of Code of Ethics and CCI Board of Directors is committed to support the implementation of Code of Ethics. For detailed information on Code of Ethics and reporting please refer to Ethics Management topic under Sustainability Governance part of this report.
Countering Bribery System
Ethics Line is managed by a completely independent third-party company where our employees may ask questions and share their concerns about corporate business principles, code of ethics, discrimination, superiors - subordinates, mobbing, conflict of interest and etc. Employees can access Ethic line by a dedicated e-mail address, an assigned telephone number or by the web site www.cciethicsline.com where the message may be sent anonymously via a free text area. This hotline gives service in Turkish, English, Russia, Arabic and Georgia. CCI has system and policy in place to ensure that the numeration of the independent company is appropriate, and the service received is legitimate.

All calls and e-mails received by ethics line are shared with Ethics and Compliance Manager and the Ethics and Compliance Manager records all the notifications on an Ethics Program where the notification is sent timely to the Ethics Committee.
Recording system for all ethics notifications  is launched in 2016 where CCI keeps all the details on non-compliance and breaches of Code of Ethics (including the anti-bribery policy) and the issues consulted to the Ethics and Compliance Managers. he system provides details of its performance and progresses in relation to bribery and other violations of Ethics Code and gives quantitative data on its whistle-blowing system in relation to bribery and all type of violations. Violations to Code of Ethics are audited by CCI Internal Audit department and reported to Audit Committee on regular basis.

Code of Ethics training is provided to most of the CCI employees through classroom trainings or as a part of orientation program and also of contract.

The number of participants and total training hours for certain countries are shown in the table below. In 2018, total hours of 624 human-hours of training is delivered in Turkey, Jordan, Kazakhstan, Azerbaijan, Pakistan and Kyrgyzstan.
Companies’ policies on business conduct, anti-bribery/anti-corruption and copies of any notice, correspondence or memoranda to or from any governmental authority in connection with any possible violation of any statute, rule, regulation or other legal requirement by the Company or a description of any such possible violation where no such notice or correspondence exists are evaluated during due diligence process before establishing any joint ventures.

Code of Ethics is communicated to supplier and contractors as an appendix of contract. A newly based supplier evaluation process is alive on system and it is available both for pre and post evaluation. Suppliers are evaluated by engineering service, procurement, legal and finance and required to pass each evaluation successfully to give service to CCI. “Business Management Code of Ethics” and “Basic Principles for Suppliers” are also added to CCI contracts for Bribery, Child Labor, Abuse etc.

Political donations are prohibited by the company, consequently, no donations have been made in 2019 at CCI operations. Also, facilitation payments are strictly prohibited at CCI. Bribery is assessed as critical risk for Azerbaijan, Tajikistan, Kyrgyzstan operations and considered as one the top priority risks of the company in Azerbaijan.
Human Rights
Human Rights Policy
For detailed information on Human Rights Policy (HRP) and related
performance results please refer to Human Rights Along the
Value Chain topic under Human Rights part of this report.
SGP Audits for CCI Plants conducted by TCCC

If any CCI operation is deemed noncompliant with Supplier Guiding Principles, a corrective action plan is implemented immediately. Upon completion of the action plan, an independent auditing company audits it to evaluate of the corrective actions taken. In addition to our Human Rights Policy implementation efforts, independent audits for SGP compliance audits take place in all CCI countries periodically since 2014.

After passing audit, CCI operation is given a score that is linked to a color rating. A color rating determines follow-up requirements as below:
Green (0 points)- No action required. Facility will be assessed in 1-3 years.
Yellow (1-7 points)- Correct minor findings to achieve Green status. Company will receive a new summary report with a zero score and Green rating after completing a desk review, after audit team receives letter within the time frame specified in assessment summary report along with any required evidence that corrective action has occurred. After desk review, company will be re-assessed in 1-3 years.
Orange (8-27)- Company fills out Facility Action Plan form and sends to audit team. Audit team will notify if the plan meets SGP requirements; if not, they will provide any necessary guidance. Company corrects findings as outlined on the approved Facility Action Plan. Follow-up assessment to occur within 6 months of the initial assessment. In certain instances, a Desk Review Assessment is acceptable in lieu of an in-person visit. Process continues until the facility becomes Green.
Red (28+ points)- Company fills out Facility Action Plan form and sends to the audit team. Audit team will notify if the plan meets SGP requirements; if not, they will provide any necessary guidance. Company corrects findings as outlined on the approved Facility Action Plan. Follow-up assessment to occur within 6 months of the initial assessment. Process continues until the facility becomes Green or is deauthorized.
Human Rights Reporting
Violations and non-compliance related to Human Rights Policy (HRP) are governed by Code of Ethics Handbook. Ethics and Compliance Manager manages all HRP reports and notifications regarding possible violations of human rights in co-operation with the CCI Group Employee Relations department. The procedures below are implemented generally in order to lend additional integrity to the processes: Group HR Operations, Employee Relations and Human Rights department was established under CCI Group HR Department to lead the HRP implementations. Role of Ethic and HR Departments in the Human Rights Policy management process:
Investigating HRP related complaints and submitting report to Ethics and Compliance Manager
Relations Specialist, depending on the location.
Maintains privacy and also enables others (managers) to do so.
Submits a written summary/report of the problems and corrective action, if any, to the Employee Relations.
The investigation should be completed in a timely fashion. A copy of the report should not be shared with any of the people related with the event in the report or accused. The report should only be shared on a “should be known” basis. It makes sure that management is aware of the Company policy against retaliation.

During this process, managers should do the following:
Take all complaints into account
Maintain integrity of the process
If Ethics Committee decides that corrective and preventive action is required, perform this action immediately
Consult Human Resources Manager if there are questions
Corrective Action and
Disciplinary Action
Managers are held responsible for breaches of policy. Appropriate corrective actions are taken if a reported breach is proven, to ensure compliance to with CCI’s Human Rights Policy (HRP), as well as Code of Ethics. In some cases, disciplinary actions are taken for individuals who are found in breach of HRP, which are determined incompliance with the disciplinary procedures.
All disciplinary actions are documented. Country Ethics Managers maintain record of all disciplinary actions and implementation of any corrective measures. Employee having questions have the liberty to ask their manager, HR or CCI Legal Department.
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Stakeholder Issues
Employee Issues
Health and Safety
For detailed disclosures on health and safety organization, management, implementations, training and performance results please refer to Health and Safety topic under Human Rights part of this report.
Performance Indicators
Content Indices