ADDITIONAL REMARKS ON THE BIST

This section provides additional qualitative and quantitative information on topics of environment (including biological diversity and climate change), governance (including board activities), bribery and corruption, human rights and stakeholder issues (including health and security which comprise the aspects of each topic that are not covered by this sustainability report) as required by the Sustainability Index in line with TCCC standards and all policies related to CCI’s operations.

CCI’s environmental policy, results of key performance indicators and all environmental data regarding the following three key focus areas:

In addition to the topics mentioned above, we monitor and manage our atmospheric emissions across all activities in accordance with national regulations and TCCC standards in all our operations. All CCI plants (excluding water treatment facilities) are subject to “Emission Permit” in accordance with the Air Pollution Control Regulations. Sulfur oxide (SOx), nitrogen oxide (NOx), dust and carbon monoxide (CO) parameters are measured every two years and an air emissions report is prepared. Our significance assessment has shown air emissions from our factories to be both quantitatively and qualitatively insignificant. Nonetheless, atmospheric and wastewater data is also included in this section.

Please refer to RESPONSIBLE SUPPLY & PRODUCTION topic in this report for CCI’s environmental management structure.

CCI’s Environmental Management System was established in accordance with The Coca-Cola Company’s Environmental Management System (KORE) and TSE ISO 14001,which includes basic principles and practices associated with these systems.

This system is built on five basic principles:

At the beginning of each year, Environmental Management System goals and targets are identified for the upcoming year by the Quality and Environment Leader with the participation of other relevant parties and stakeholders to minimize or control our environmental impact in line with local legislations, company requirements and environmental policies. When setting targets, a number of factors are taken into account such as the results from the previous years, long, medium and short term company strategies, legal requirements, mensurableness, traceability and feasibility inaccordance with our principle of continuous progress. Key environmental performance indicators and targets identified are included in CCI’s business plan. Targets are communicated to all employees and TCCC EME OU. Performance indicators for targets are continuously monitored throughout the year, and target compliance is kept under control. Performance indicators are reported to OU, plant management and senior management each month.

An audit is performed on the Environmental Management System once a year as apart of our internal audit process. Necessary actions are taken according to relevant procedures regarding any non-conformities identified during internal and external audits on Environmental Management System as well as daily practices. Environmental Coordinator is responsible for evaluating the Environmental Management System and following up with any corrective/preventive actions. The Environmental Management System is evaluated every three months during operational meetings in addition to the annual management review meetings. Current regions are also inspected in terms of the Environmental Management System during monthly environmental inspections.

These inspections are performed by the staff responsible for executing and coordinating CCI’s environmental management activities in our facilities in accordance with the legislation, and an internal audit is performed at least once a year in accordance with the provisions of the relevant legislation, after which a report is prepared. Any non-conformities are monitored and preventive/corrective actions are taken in accordance with the relevant procedure.
‍
CCI plants monitor the activities at regular intervals and ensure that the obligations defined in relevant legislations are fulfilled. In order to comprehend the effectiveness of the program, it is necessary to evaluate the Environmental Management System’s performance at CCI locations.

Management Review Meetings are held at least once a year in accordance with the requirements of CCI’s Environmental Management System. Key environmental performance indicators are reviewed during Business Plan Meetings.
‍
Environmental board meetings and annual management review meetings focus on the following topics:

Environment Coordinator is responsible for ensuring that all relevant activities comply with all applicable laws and regulations regarding on environment. Coordinator must find a way to implement these laws and regulations at the workplace. Coordinator must also follow all current laws regarding the environment and assess the compliance status.

In addition to laws and regulations, Coordinator must follow Coca-Cola’s KORE system as well as ISO 14001 standards, and adapt them to the Environmental Management System employed at the plant and ensure continuity. Environmental Coordinator also works in coordination with OU on environmental issues and implements any requests from The Coca-Cola Company in this regard.
‍
CCI employs several procedures which are standard across all plants;

Rainwater drainage channels are marked on project plans which demonstrate all drainage channels in the infrastructure at CCI locations. Contamination of rainwater with environmentally hazardous substances through chemical diffusion or blending of wastewater from processing into plant channels is kept under control. All employees are trained in prevention of rainwater contamination.

All process-related wastewater and domestic wastewater at CCI locations are processed (local treatment facilities, neutralization, central treatment facilities, etc.) as necessary to be discharged to the receiving body in accordance with the associated standards. In case of non-conformities in the quality of treated water from the wastewater treatment facility under a plant’s own management, necessary intervention is implemented by the Treatment Facility Operator under Environmental Coordinator’s supervision. In plants using wastewater treatment facilities managed by third parties,the relevant central treatment facility is inspected periodically and the discharge water is analyzed. In case of non-conformities, Corrective/Preventive actions are taken.
Central treatment facilities are inspected periodically and the discharge water is analyzed. In case of non-conformities, Corrective/Preventive actions are taken.

CCI’s biggest impact on biological diversity originates from the water used during production. Since 2012, we have been performing source water vulnerability assessments (SVA) at the local level to build a source water protection plan (SWPP) to protect catchment basins in regions where our plants are located and to mitigate water-related risks to our system and communities we serve. We reuse and recycle water, treat it in wastewater treatment facilities and renew it through community projects.
‍
We fully support TCCC’s ultimate goal of “replenishing every drop of water we use”.In 2020, we published our fifth detailed report on our water strategy and data as a part of the Carbon Disclosure Project (CDP) Water program.

A part of the “Life Plus Environment Program”, the “Agriculture of the Future Project” has the greatest impact on biological diversity among water management projects.
‍
Traditional nature conservation approaches focus on protecting certain species or their ecosystems. New approaches such as ecosystem and biological diversity protection consider the multi-sectoral nature of conservation practices and aim for sustainable use and conservation of natural resources. The Agriculture of the Future Project intends to support the ecosystem service approach in agriculture to protect agricultural ecosystems and biological diversity without damaging communal well-being.

The project involves two objectives: 1) ensuring efficient use of land and water by improving water retention capacity in the soil, and 2) increasing the usage capacity of ecosystem services in agriculture. To achieve these, the project employs direct drilling methodology and living windbreaks. Direct drilling machines were made available for farmer use in six towns in Konya basin. The project was implemented as a collaboration between The Coca-Cola Life Plus Foundation, Turkish Ministry of Agriculture & Forestry and Nature Conservation Center.
‍
The project also cultivates eco-friendly solutions to agricultural problems such as biological rodent control. As a part of the biological control plan, owl and kestrel nests were planted in farming areas as an alternative to chemical pesticides used to destroy rodents at croplands.

CCI manages all environmental impacts, including air emissions. Our goals for atmospheric emissions include increasing our efficiency values and complying with the laws on a 100% basis. Charts below show the results of CCI’s 2021 flue gas emission analysis.

CCI’s anti-bribery policy is an integral part of our Code of Ethics. CCI Board of Directors is committed to supporting the adoption of our Code of Ethics. For detailed information on Code of Ethics and reporting, please see the Business Ethics Management topic in the Sustainability Management section of this report.

The Ethics Line, which is used for reporting ethical issues, is managed by a completely independent third party company. Employees can use this line to raise queries about corporate business principles, code of business ethics, discrimination, relationships between junior-senior levels, mobbing at the workplace, conflict of interest, etc. Employees can submit their concerns anonymously using the dedicated e-mail address or the dedicated phone number,or they can type their notifications in the free text field provided on the website at HYPERLINK "http://www.CCIethicsline.com" www.CCIethicsline.com. The helpline is available in Turkish, English, Russian and Arabic.

Each call and e-mail received through the Ethics Line is shared with the Ethics and Compliance Manager,who records each notification in the company-specific ethical management system to automatically notify the Ethics Committee members through the system.
‍
The system used for managing notifications on ethical issues was commissioned in 2016. CCI stores information on non-conformities and violations of the Code of Ethics (including anti-bribery policy) as well as issues consulted with Ethics Managers in this system. The system provides information on system performance and progress regarding all issues constituting aviolation of the Code of Ethics, including bribery and corruption issues. It provides quantitative data on notifications made on ethical issues such as bribery and all types of violations.

Code of Ethics violations are generally reviewed by CCI Internal Audit Department and regularly reported to the Audit Committee. Code of Ethics trainings offered to all CCI employees as a part of the orientation program, through classroom trainings and also as online trainings. In case of any acquisition or joint venture by CCI, the relevant company’s code of ethics and anti-bribery & anti-corruption policies are evaluated during the due diligence process prior to any joint venture with such company along with copies of notices, correspondences or statements sent to or received from any governmental bodies regarding the company’s possible violation of any laws, codes, regulations or other legal requirements if such documents exist, or an explanation of such possible violation if such documents do not exist.
‍
The basic principles contained in our Code of Ethics are communicated to suppliers and contractors as an attachment to the service or supply contracts. A new supplier evaluation system is currently being implemented in the system, which is ready for use in pre-assessment and post-assessment steps. Suppliers are assessed in terms of engineering services, procurement as well as legal and financial requirements and they must successfully pass all assessments to provide services to CCI. Topics such as bribery, child labor and abuse are also incorporated into any contracts to be made with 3rd parties in accordance with the “Basic Principles and Business Ethics for Suppliers”. Since political donations are prohibited by the Company, no political donations have been made as a part of CCI operations.Facilitation payments are also strictly prohibited at CCI.

In case it is deemed that any CCI operation does not comply with the Supplier Guiding Principles, a corrective action plan is immediately adopted. Upon completion of the action plan, an audit process is performed by an independent audit firm to evaluate any corrective action taken. In addition to adoption of our Human Rights Policy, periodical independent audits are being performed in all CCI countries since 2014 regarding SGP compliance audits. After successfully completing the audit, the relevant CCI operation is assigned as core using a color-coded rating system. Monitoring requirements are indicated by the following color codes:

Violations and non-conformities related to Human Rights Policy (HRP) are governed by our Code of Ethics. All Human Rights Policy reports and notifications regarding possible human rights violations are handled by the Ethics and Compliance Manager with the support from CCI Group’s Employee Relations Department. To support the integrity of the processes, the following procedures are applied in general: Group HR Operations, Employee Relations and Human Rights sub-departments were established under CCI Group HR Department to manage activities related to Human Rights Policy.

All employees are liable for violations of the policy. In case a reported violation is proven to be true, appropriate corrective actions are taken to ensure compliance with the Code of Ethics and CCI Human Rights Policy (HRP). In certain cases, individuals who violate the HRP or who are do not comply with disciplinary procedures may be subject to disciplinary action. All disciplinary procedures are documented. Country Ethics Managers keep a record of all disciplinary actions and corrective measures implemented. Employees can raise queries with their managers, HR Department or CCI Legal Department at any time.