Base Titanium’s governance policies set out the beliefs and behaviours for the Company and its employees, including the Company’s absolute commitment to conducting its business in a legal, honest and ethical manner. Base Titanium utilises the same policies and standards as its parent Company, Base Resources.


Environment Policy
Published 19/12/2012
Procurement and Supply Policy
Published 22/05/2012
Occupational Health and Safety Policy
Published 07/02/2022
Energy Management Policy
Published 03/12/2014
Security Management Policy
Published 20/10/2011
Integrity Standard
Published 25/02/2022
Communities Policy
Published 23/06/2020
Employment Policy
Published 23/06/2020
Company Values – The Base Way
Published 29/06/2020
Diversity Standard
Published 28/07/2020

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International Standards

The Kwale Operation and the associated Environmental and Social Impact Assessment (ESIA) have been developed in compliance with Kenyan legislation and International Best Practice (IBP) guidelines. Base Titanium adheres to IBP by complying with:

International Finance Corporation Performance Standards

The International Finance Corporation (IFC) Performance Standards are an integral part of their framework for sustainable development. They are an international benchmark for identifying and managing environmental and social risk and have been adopted by Base Titanium as a key component of its environmental and social risk management system.

For more information see IFC Performance Standards.

Equator Principles

The Equator Principles form a credit risk management framework for determining, assessing and managing environmental and social risk in project finance transactions. Projects which fall under the scope of the Equator Principles are evaluated against comprehensive international performance standards on issues such as labour and working conditions, natural resource management, pollution prevention, impacts on indigenous people, community health and safety and cross-cutting themes such as gender and human rights.

For more information see Equator Principles.

Environmental, Health and Safety Guidelines

The Environmental, Health and Safety (EHS) Guidelines are technical reference documents with general and industry‐specific examples of good international industry practice and are referred to in the IFC’s Performance Standards. They contain the performance levels and measures that are normally acceptable to lending institutions and are generally considered to be achievable in new facilities at reasonable costs by existing technology. When host country regulations differ from the levels and measures presented in the EHS Guidelines, projects will be required to achieve whichever is more stringent.

For more information see the IFC EHS Guidelines.

International Labour Organization Standards

The International Labour Organization (ILO) maintains and develops a system of international labour standards aimed at promoting opportunities for both women and men to obtain decent and productive work, in conditions of freedom, equity, security and dignity. The main objectives of the ILO are to promote rights at work, encourage employment opportunities, enhance social protection and strengthen dialogue on work-related issues.

For more information see the ILO Labour Standards.

Voluntary Principles on Security and Human Rights

These comprise a set of voluntary principles to guide companies in the extractive and energy sectors in maintaining the safety and security of their operations within an operating framework that ensures respect for human rights and fundamental freedoms.

For more information see the Voluntary Principles on Security and Human Rights.

The Code of Ethics for Business in Kenya

The Code is an initiative of the business community under the umbrella of the Kenya Private Sector Alliance (KEPSA) directed towards promoting and enhancing ethical business conduct in line with the ten principles of the UN Global Compact in the areas of Human Rights, Labour Standards, Environment and Corruption Prevention. The Code applies to private companies, which in turn expect their business partners to adhere to it.

Statement of Commitment

Base Titanium, through its Letter of Commitment and Engagement, has voluntarily committed to supporting and upholding the Code of Ethics for Business in Kenya.

Ethics Implementation Progress Report for 2020

Following commitment to the Code in 2016, Base Titanium has issued its Report on Progress in Implementing the Code for the period January 2020 to January 2021.


Base Titanium has an absolute commitment to conducting its business in a legal, honest and ethical manner. This commitment flows from the unifying set of beliefs and behavioural expectations of the “Base Way” and is considered critical to achieving Base Titanium’s long-term goals.

Base Titanium’s Supplier Code of Conduct sets out the Company’s key requirements for its suppliers which are directed to ensure they act in a legal, honest and ethical manner, and with integrity and fairness in their business affairs.

Extractive Industries Transparency Initiative

“3.5 billion people live in resource-rich countries. Still, many are not seeing results from extraction of their natural resources. And too often poor governance leaves citizens suffering from conflict and corruption. The EITI was formed to change this.” –

EITI was launched in 2002 at the World Summit for Sustainable Development. It aims to address the misuse of revenues derived from exploitation of natural resources that has plagued many resource-rich developing countries. EITI has put in place a reporting system to encourage transparency and accountability in the receipt and use of revenues from extractive industries. EITI supports good governance through the verification and full publication of payments by companies and use of government revenues derived from oil, gas and mining.

Base Titanium is officially recognised as one of 69 supporting companies globally. Currently 54 countries are implementing EITI. Presently Kenya is neither compliant nor a candidate country.


Statement of Support

Base Titanium adheres strictly to a policy of zero tolerance to all forms of corruption and unethical business practices. Our practices are governed by a series of policies that set the guiding principles in managing the environment, community relationships, occupational health and safety, employment and security. We expressly subscribe to the principles of EITI and its aim to strengthen governance through improving transparency and accountability in the broader extractive industries sector and support and promote its implementation.

Base Titanium supports beneficial ownership transparency. Base Titanium’s parent company, Base Resources Limited, is publicly listed on both the Australian Securities Exchange and London Stock Exchange’s AIM (ASX & AIM: BSE). Base Resources discloses its beneficial owners in accordance with applicable regulations and listing requirements, with Base Resources’ market announcements. Base Resources also maintains and discloses a list of significant shareholders of the company (as defined in the AIM Rules).


FY23 statement of payments to Government and National Entities

For the Financial Year Ended 30 June 2023 and Cumulative to Date ($USD):

Income Tax 19,089,366 86,114,926
Royalties 14,836,454 74,465,823
VAT (Non-refundable) 255,659 2,030,846
Other Payments:
Environmental Deposit Bond 527,267
Pension & Other Contributions 121,564 444,713
Customs Duties 1,157,950 6,403,828
Licenses, Permits & Rates 71,971 1,715,242
Government Services 99,764 627,865
Utility & Service Charges 18,724,210 134,365,903
Totals 54,356,938 306,696,413


Access to Information



Base Titanium Limited provides notice that it has appointed its Public Relations Officer as the company’s Information Access Officer for the purpose of the Access to Information Act, 2016 (the Act).

Requests for information from the company pursuant to the Act should be directed to the Information Access Officer.

Any request received by the Information Access Officer will be assessed in accordance with the Act, and a response provided within the timeframes specified in the Act.

In accordance with the Act, a prescribed fee may be payable to the company before requested information is provided.

The contact details of the company’s Information Access Officer are as follows:

P.O. Box 1214
Ukunda 80400


Raising Integrity Concerns

IntegrityLine is Base’s independent whistleblower service.  It’s a confidential and independently operated service for reporting any integrity concerns related to Base.

Confidentiality is critical to IntegrityLine.  The information you share with IntegrityLine will be received and actioned by a Whistleblower Protection Officer appointed under the Whistleblower System.