Lobbying for Wild Animals






On the 22nd of September 2021−World Rhino Day−the acting head of South African National Parks, Dr Luthando Dziba, said that there may be fewer than 3000 rhinoceroses left in the Kruger National Park. Dziba also confirmed that South Africa’s rhino population had declined by nearly two-thirds in just ten years.

The primary threat to rhinos is human demand for their horns which are sold on the black markets of Southeast Asia as aphrodisiacs, so-called traditional medicine or as a status symbol.

Only a decade ago South Africa was home to the world’s largest population of White Rhino (Ceratotherium simum) and Black Rhino (Diceros bicornis), this equated to approximately 90% of the global population of southern white rhino and 36% of the world’s black rhino population.

Since 2008 there has been a cataclysmic increase in the number of rhinos killed for their horn. The reported number of rhinos killed for their horn in South Africa since 2008 is 9067.

The number of white rhinos living in South Africa’s flagship national park, the Kruger National Park declined by 60.42% in just a six-year period, from an estimated 8,968 in 2013 to an estimated 3,549 in 2019, while the black rhino population fell by 57.25% in a 10-year period, from an estimated 627 in 2009 to an estimated 268 in 2019.1

The data contained in the first chapter of this report illustrates the confusing and in concise figures regarding the official rhino population figures that have been reported and repeated over the past twenty years.

What happened to the Biodiversity Management Plan (BMP) for white rhino−a draft of which was gazetted for comment in March 2015? The announced target was aligned to the escalating poaching statistics. The world was informed by the South African government that a realistic achievable goal of a meta-population of at least 20 400 white rhinos in South Africa was entirely achievable for the year 2020, this bearing in mind that 1349 rhino were poached in 2015.

Where Have All the Rhino Gone, is a compilation of, and expansion on, the work previously carried out by researchers and investigative journalists over the past two decades. The Information contained in this retrospective report sets out to illustrate the questionable decisions that have been made over the past two decades regarding the protection and conservation of South Africa’s rhino.

The content of this report is limited to the past two decades, the time period that will forever be marked by a magnitude of government corruption and the capture and destruction of the South African justice system. It would be foolish to believe that South Africa’s environmental sector and the conservation and protection of wildlife that resides within it, has remained unscathed.

South Africa is meant to be responsible for the protection and conservation of the majority of the world’s remaining rhinos. In order to establish just what the ‘majority’ means in a reliable numerical format we would need to obtain absolute accurate data from all the African rhino range states and South Africa as a matter of priority.

The scientific advisory organisations should be urged to recommend to the United Nations that there should be a global moratorium on the trade and hunting of all rhinos until it can be established, unequivocally, how many rhinos exist in Africa today.

There can no longer be any debate−the next decade is critical for the survival of the species, and this needs to take place within a revised policy framework which foregrounds protection, welfare, well-being and a one health approach.


The EMS Foundation is a South African based social justice NGO established in November 2016. Our key purpose is to alleviate and end suffering, raise public awareness and lobby and empower, provide dignity and promote the rights and interests of vulnerable groups, particularly children, the elderly and wild animals.

The EMS Foundation is committed to contributing to the improvement of wildlife governance. With an area of nearly two million hectares, the Kruger National Park situated in the north of South Africa is one of the continents largest game reserves. The South African government is responsible for the care and protection of the world’s largest remaining white and black rhino populations. The current estimated numbers of black and white rhinos in South Africa’s flagship national park are extremely concerning.

This report has highlighted the fact that hundreds of rhinos were knowingly exported from the Kruger National Park to trophy hunters, some of whom ignited the rhino horn trade in Vietnam. Rhinos were also exported to zoos whilst at the same time thousands of rhinos were being illegally killed in the Kruger National Park.

Close examinations of the agreements made with hunters, by investigators, has revealed that anomalies were overlooked in order to facilitate the acquisition of the rhinos.

Furthermore, in 2019 the National Union of Public Service and Allied Workers accused the Kruger National Park of perpetuating nepotism, corruption and maladministration. It was alleged that the outsourcing of services at SANParks was organised to enrich a few individuals.

This report has highlighted and expanded upon, what investigative journalists highlighted many years ago about State Capture and the Kruger National Park. They ask, as do we, what policies and procedures does SANParks have in place to avoid real or perceived conflicts of interests specifically involving holders of high political office in its spending?

We all argue that SANParks has a duty to avoid repeating the same mistakes, although an organ of government, SANParks is reliant on revenue generated from consumers. We are disheartened to learn of the large financial contribution being withdrawn because of maladministration.

On the 2nd May 2021, when Minister Creecy released the High Level Panel Report −which reviewed policies, legislation and practises related to the management, breeding, hunting, trade and handling of elephant, lion, leopard and rhinoceros− she made the 2nd of May 2021, Minister Creecy released the Report of the High-Level Panel of Experts, the Minister made the following statement:

“Despite South Africa’s reputation as a global leader in conservation, there are still reported incidents and perceptions of irresponsible, unethical and unsustainable conservation practices in the management, breeding, hunting, trade and handling of elephant, lion, leopard and rhinoceros, especially in terms of animal welfare and well-being, that negatively affect the country’s conservation reputation and do not bode well for the country’s international standing and development objectives.”

Notwithstanding the alarming figures that have been released of the vastly diminished rhino populations in South Africa, on the 8th of October 2021 the Department of Forestry, Fisheries and Environment released a government gazette notice on the proposed hunting and or export of elephant, black rhinoceros and leopard hunting trophies for the 2021 calendar year.

Hindsight is a wonderful thing. Queen Elizabeth II once said:

“To all those who have suffered as a consequence of our troubled past, I extend my sincere thoughts and deep sympathy. With the benefit of historical hindsight we can all see things which we would wish had been done differently, or not at all.

©The EMS Foundation 2021. All Rights Reserved.No part of this publication may be reproduced or transmitted in any form or by any means without permission from the EMS Foundation in writing.

Legal Disclaimer: The mention of any individual, company, organisation or other entity in this research report does not imply the violation of any law or international agreement, and should not be construed as such. Refer to the full disclaimer in the Report.






South Africa is the 12th worst emitter of greenhouse gases in the world. A large South Africa delegation attended the Climate Change COP26 Conference held between the 31st October and 12th November 2021in Glasgow in the United Kingdom.  South Africa’s substantial agenda was to access international finance for investments that are needed in order for the country to transition from its  reliance on fossil fuels.

Scientists have proved that in order to keep global warming below 1.5C, to mitigate the current global climate crisis, we have to leave the vast majority of fossil fuels untouched.   

In steep contradiction to the mandate of the legally binding international treaty on climate change, the Paris Agreement, which was adopted by 196 Parties at COP21 on the 12th December 2015, South Africa has granted permission to Royal Dutch Shell to conduct deep-water seismic oil and gas surveyance of two massive offshore areas which stretch all the way from the Eastern Cape to the Mozambique maritime border. 

Climate change activists have recently won a big legal victory against oil giant Shell, who has a result been forced to reduce its greenhouse gas emissions by 45% by 2030 based on 2019 levels.  Friends of the Earth International stated: “Our hope is that this verdict will trigger a wave of climate litigation against big polluters, to force them to stop extracting and burning fossil fuels.”

The administrators of South African Presidential Climate Commission and the authors of the Climate Change Bill have not, according to our research, objected to the deep-water seismic oil surveyance of two massive offshore areas which stretch all the way from the Eastern Cape to the Mozambique maritime border.

Why did the South African government choose to ignore a coalition of eight civil society groups who asked that ties be severed with Myanmar because of their continued human rights abuses? This plea, is in light of the controversial deal with the Silver Wave Energy Company, which is linked to the Myanmar regime.  A deal controversially concluded during the Zuma regime.

Diplomatic information published on WikiLeaks shows that the Silver Wave Energy Company, though registered in Singapore, has close ties to the Burmese regime. 

Questions were raised in the media in 2011 about this aforementioned deal when it was uncovered that Burma’s ambassador to South Africa provided top officials with gifts, these officials apparently included Jacob Zuma and Kgalema Motlanthe.  

Jacob Zuma, South Africa’s former President, has been charged with corruption linked to a 1990’s arms deal where he is accused of accepting 783 illegal payments. 

Did the present South African government examine every aspect of this controversial deal in light of the before they approved the license’s second renewal period in July 2020? 

State Capture commission of inquiry highlighted the abuse of political power in South Africa.  We have been shown that you do not have to be a politician to hold political power you can influence political developments by buying politicians. 




In July of 2018 the EMS Foundation and Ban Animal Trading published a Report called the Extinction Business – South Africa’s Lion Bone Trade. In 2017 the South African Minister of Environmental Affairs, Edna Molewa, controversially and in the face of vociferous opposition and robust argument against this trade, set the annual export quota at 800 lion skeletons per year. Even more alarmingly, Molewa, without stakeholder participation, took the incomprehensible decision to almost double the quota in 2018 to 1500 skeletons.

The EMS Foundation and Ban Animal Trading gathered extensive information whilst investigating South Africa’s big cat industry and South Africa’s Lion Bone Trade which resulted in this Report.

The evidence in this report was used, amongst other, in a South African High Court matter detailed below.

In the Matter Between the NSPCA and the Minister of Environmental Affairs, The South African Predator Association, the MEC Department of Economic Development, Environment and Tourism, MEC Department of Economic Development, Environment, Conservation and Tourism North West Province, MEC Department of Agriculture and Rural Development Gauteng Province and the MEC Economic Development, Tourism and Environmental Affairs Free State Province Case Number: 86515/17


Page 239 – 415

©The EMS Foundation 2021. All Rights Reserved.





The guardians of the singular, largest group of wild rhino in the world announced the long awaited number of rhino in their care, the figures confirmed a devastating loss of life. 

Using a sample block counting method, 50% of the total Kruger National Park was surveyed. The resulting estimated number of rhino was published in the SANParks 2019-2020 Annual Report

The number of rhinos illegally killed annually in the national parks of South Africa  realistically reflects the minimum number of deceased rhino.  There is a certain amount of difficulty in detecting or finding the remains of every deceased rhino in the dense African bush.  The accuracy of the published information is also reliant upon the data handed in and collated by authorities.  

The very low number of remaining rhino in the Kruger National Park is indicative of  the illegal killing of rhino for their horns by often unknown attackers since 2008.  Hundreds of rhino were also sold to locally based trophy hunters, canned lion hunters, to international trophy hunters, to international zoos and to rhino breeders. 

In addition, the EMS Foundation’s retrospective report Where Have All the Rhino Gone includes familiar names of people involved in the game breeding industry, ex policemen and veterinarians who have been arrested and charged with wildlife crimes over the past two decades.  This information demonstrates that the illegal killing of rhino in South Africa for their horn has not only been carried out by anonymous individuals. 

The research revealed the disappointing reality that Howard Buffett, the American philanthropist and businessman, was not able to complete his R255 million grant to the Kruger National Park to assist with the prevention of the illegal killing of rhino due to a poor internal work ethic. 

In a statement made by SANParks board on the 20th of February 2012 they confirmed that they had received an inquiry from the office of the Public Protector in Nelspruit. A number of companies contracted to the Kruger National Park were alleged to be owned by family, friends or associates of senior officials in the Kruger National Park. 

Whilst the EMS Foundation was unable to substantiate the aforementioned allegation, we were, however able confirm that a company contracted to the Kruger National Park and to SANParks from 2002-2016 was directly linked to Jacob Zuma. 

Over the past two decades the survival of the rhino living in the Kruger National Park has had everything stacked against them including questionable, critical management  decisions, the possible involvement of corrupt politicians, the direct involvement of wildlife veterinarians, members of the South African police servicesSANParks employees which has directly or indirectly led to their deaths. 

IMAGE CREDIT: Gurcharan Roopra


©The EMS Foundation 2021. All Rights Reserved.




Elephants Killed for Trophies in the Kruger National Park System, South Africa

The EMS Foundation has confirmed, via an access to information request to the Limpopo government (LEDET), that in 2020 four male elephants were killed for trophies in an open system with the Kruger National Park – the Balule Reserve. In addition, in 2020, one male elephant was also trophy hunted in the Maremani Nature Reserve, which belongs to the Danish Aage V. Jensen Foundation – https://avjcf.org.                                       

Trophy Hunting VS Ubuntu

Trophy hunting is the killing of wild animals for recreation with the purpose of collecting trophies such as horns, antlers, skulls, skins, tusks or teeth for display. Trophy hunting, like poaching, artificially selects the biggest and strongest animals (largest tusks and thickest manes), weakening populations’ genetic health and variation. Therefore, while revenue may be forthcoming in the short term from such extraction, the longer-term effects are that population growth dynamics are negatively affected.

The incentives that drive trophy hunting (selecting the strongest) are fundamentally at odds with the conservation imperative (preserving the strongest). Beyond the negative ecological effects, the practice remains rooted in colonial modes of extraction. Some also argue that trophy hunting is reinforcing deep apartheid era social and racial inequalities in Africa because organised hunting of endangered wildlife mostly benefits wealthy white landowners while exploiting black workers by paying them pitiful wages. 

Trophy hunting is in stark contradiction with African value systems such as Ubuntu (where harmony, connectedness and respect extend beyond human relationships to the whole living world) and notions of communal commitment to the protection of animals. As Dr Mucha Mkono noted in her article: Neo-colonialism and greed: Africans views on trophy hunting in social media, while a hunter might have a permit to hunt and shoot an animal, if the community and environment suffer it is considered that the principles of Ubuntu have been violated. Furthermore, she says that: “Ubuntu, being grounded in an attitude of caring and compassion, does not excuse gratuitous violence towards individual animals.”  

Balule Private Nature Reserve and the Killing of Elephants

Elephants are irreplaceable ecosystem engineers and their removal negatively impacts ecosystem integrity and biodiversity preservation.  Trophy hunters justify targeting older bull elephants on the grounds they are “redundant”. But, a recent study shows that old male elephants play a key role leading all-male groups. Also, when trophy hunters eliminate older bulls, they destroy elephant family integrity (through trauma and removal of the discipline and knowledge transfer functions executed by patriarchs) and force matriarchs to mate with younger bulls they would otherwise not have selected, thereby skewing reproduction patterns.   

Pre-Covid-19, approximately 950 000 people visited the world-renowned Kruger National Park (KNP) every year. With an annual budget of close to 1 billion ZAR 80% of this conservation income is self-generated through its thriving tourism activities within these wild, natural and protected spaces. 

A classic example of entrenched white privilege is the Associated Private Nature Reserves (APNR) in South Africa, bordering the KNP. The six private reserves each comprise a number of different private owners and farms. By 1996, these reserves had almost no elephants left as they had been hunted to near extinction. The fences were dropped in 1993 – before the end of apartheid – on the premise of creating ‘ecological unity’ between the APNR and the KNP itself. Commercial hunting, in the 1996 agreement, was not mentioned at all. Animals under public custodianship (KNP) now move freely between the APNR and the KNP. Far from creating ecological unity, however, they are treated as res nullius (nobody’s property) in the APNR and are hunted. The APNR allows the commercial trophy hunting of a number of animals, including elephants, lions and buffalos. These animals are part of the country’s national heritage but are permitted to be shot by foreign trophy hunters for the benefit of a small number of wealthy white landowners. How much money actually accrues to local communities remains unknown due to a lack of transparency in the industry. 

Balule Private Game Reserve is located along the banks of the Olifants River between Phalaborwa and Hoedspruit in the Limpopo Province. Balule shares an un-fenced border with the KNP and is one of the APNRs. According to various websites there are twenty-six unique options from budget to luxury accommodation available. 

The ecological benefits of sharing an open system with the KNP has made Balule a popular ecotourism destination and protection efforts have ensured that the wildlife population includes an abundance of lion, elephant, buffalo, leopard and black rhino. 

Trophy hunting is permitted in Balule Private Nature Reserve despite what this article states. 

The Portfolio Committee on Environmental Affairs raised concerns regarding the law governing hunting in the Kruger National Park and about contractual arrangements between the Kruger National Park and the Association of Private Nature Reserves in September 2018.

Unfortunately, over the past three years a number of trophy hunts in Balule have provided very negative media attention. On the 28th of November 2018 Balule issued a statement:

“We wish to express deep regret that visitors to the reserve had to endure a harrowing and traumatising incident in which an elephant was shot by hunters near the lodge that visitors were staying at.  We apologize profusely and unreservedly to those affected.

Based on witness accounts gathered to date, this incident seems not to comply with the sustainable utilisation model of ethical hunting in accordance with the hunting protocol that governs all reserves within the Associated Private Nature Reserves to which Balule and hence Maseke are bound.”

The incident took place on the 23rd November, a young elephant bull was shot 13 times in front of our eye-witnesses standing on a viewing deck overlooking Balule’s Maseke Game Reserve where the hunt took place. The eye witnesses disputed the findings of the investigation

In August of the same year, again in Balule, a collared male elephant aged between 20 and 30 years with tusks of 30 pounds each was shot and killed illegally.  Mpumalanga Tourism and Parks Authority laid criminal charges against the culprit. Frikkie Kotze pleaded guilty to the charges and was fined five years in prison or R50 000.00 both suspended for five years.  He had to pay Elephants Alive R35000.00 to replace the collar.   The hunting party consisted of Kotze, the professional hunter and outfitter JJ Horn, the client and his wife. 

The reason that this hunt was illegal was because the permit for this hunt was issued by the Limpopo Department of Economic Development, Environment and Tourism known as LEDET, whose mission it is to create and facilitate the development of a competitive economy, sustainable environment and tourism growth, the elephant was killed in the Mpumalanga Province.

The elephant was collared and part of an ongoing research project by Elephants Alive!  The chairperson of Balule Nature Reserve, Sharon Haussmann, stated that she was determined to stamp out illegal activities and actions that breach accepted protocol. 

Balule Private Nature Reserve was in the global headline news once more when in 2019 the People for the Ethical Treatment  of Animals PETA published the facts about Aaron Raby who killed an elephant on the 5th December 2019 there.  The elephant suffered a cruel, needlessly prolonged and inarguably painful death. 

Hunting of iconic wild animals in the APNR’s has a negative effect on South Africa’s conservation reputation, on eco-tourism and on Brand South Africa.  The problem with simplistic analyses supporting hunting is that they fail to recognise that trophy hunting and non-consumptive ecotourism are increasingly mutually exclusive. Moreover, the training and so-called qualifications of professional hunters is of an extremely low standard with provincial legislation accepts a training certificate from a 10-day course as the minimum standard.

The EMS Foundation believes that an immediate moratorium on trophy hunting in the APNR reserves should be imposed while: 

  1. policy is being developed
  2. a review and feasibility of the agreement between SANParks and the APNR and all relevant protocols is undertaken and the public given an opportunity to participate meaningfully in all these processes. 

©The EMS Foundation 2021. All Rights Reserved.



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