Environmental and Social Risk Management in Emerging Economies: An Analysis of Turkish Financial Institution Practices

Abstract

Turkish Financial Institutions (FIs) have come to recently realise that nonfinancial factors can materially affect an institution’s long-term performance. Environmental and social issues (i.e. pollution, resource depletion, wastes, biodiversity, land acquisition and resettlement, labour and working conditions, occupational/community health and safety, cultural heritage) have been recognised to pose risks to the Turkish FIs through their project finance operations. This awareness developed in parallel to the concept of sustainability being embraced by Turkey’s corporate sector. Several large Turkish lending institutions have developed environmental and social (ES) management systems for evaluation of the projects considered for financing. Although the majority of these are based on international standards that include ES performance criteria of the International Finance Corporation (IFC), European Bank for Reconstruction and Development (EBRD) and European Investment Bank (EIB), they do not yet fully encompass the requirements of the international standards in the actual implementation process. The projects considered for financing are typically subject to the Turkish Environmental Impact Assessment (EIA) Regulations that set the commitments for the project owner for environmental protection based on the Turkish regulatory framework. Compared to the international standards, there are gaps in the Turkish EIA studies that include a lack of a structured impact assessment, insufficient baseline studies and limited community engagement programmes. These gaps may eventually pose legal risks to the project during development and operations and also to the lending institution in terms of financial and reputational risks. Although several institutions have developed ES management systems internally, experience shows that these systems initially focus on following the Turkish EIA process without fully assessing issues such as biodiversity, cultural heritage and social impact assessments including expropriation and resettlement issues. This chapter will provide an overview of ES procedures of large lending institutions in Turkey and discuss generic data gaps between Turkish EIA studies and international requirements as well as the evaluations of ES risk management systems in place. Discussions include main risks and opportunities in applying international standards in investment finance in Turkey as well as identifying future trends.