Lobbying for Wild Animals



The High-Level Panel of Experts Report 2020

On Sunday the 2nd of May 2021, Minister of Environment, Barbara Creecy, released the High-Level Panel of Expert’s Report, which contains recommendations in relation to policies and regulations on the hunting, trade, captive keeping, management and handling of elephants, lions, leopards, and rhinos in South Africa.  

After the EMS Foundation/Ban Animal Trading publication of The Extinction Business: South Africa’s Lion Bone Trade in July 2018 was sent to the Parliamentary Portfolio Committee on Environmental Affairs (PPCEA),  the Committee took the decision to hold a Colloquium on Captive Lion Breeding for Hunting in South Africa: harming or promoting the conservation image of the country on the 21st  and 22nd August 2018. Presentations to the Committee were made by animal protection organisations and the breeding and trophy hunting industries. On the 8th November 2018 the Committee’s Report was tabled and it clearly stated that the captive lion breeding and hunting industry did not contribute to the conservation of lions and that the industry was damaging South Africa’s conservation and tourism reputation. The Portfolio Committee instructed that the Department initiate a review of policy and legislation in order to stop the captive lion industry. 

To this end, on the 25th February 2019, the Minister gazette the Notice of intention to appoint a high-level panel for review of policies on matters related to management of elephant, lion, leopard, etc. On the 10th October 2019 Minister Creecy gazette the establishmentof the High Level Panel.  A report by this Panel was submitted to the Minister in December 2020, the report was accepted by Cabinet in March 2021.  

On Sunday 2nd May 2021 Minister Creecy announced that: “the Panel envisages secured, restored, and rewilded natural landscapes with thriving populations of elephant, lion, rhino and leopard as indicators for a vibrant, responsible, inclusive, transformed and sustainable wildlife sector”. Minister Creecy, in an interview with Stephen Grootes on SAFM on the 4th May, also said that South Africa is moving away from from domestication and agricultutrisation of wild animals –  a practice that has brought us into conservation, environmental and tourism disrepute internationally. 


In our statement, today,  the EMS Foundation concentrates on one of the recommendations of the High-Level Panel“The ending of certain inhumane and irresponsible practices that greatly harm the reputation of South Africa and position of South Africa as a leader in conservation. 

The captive lion industry poses risks to the sustainability of wild lion conservation resulting from the negative impact on ecotourism which funds lion conservation and conservation more broadly. The panel recommends that South Africa does not captive breed lions, keep lions in captivity, or use captive lions or their derivatives commercially.”

Minister Creecy has requested that the Department of Fisheries, Forestry and Environment (DFFE) action this recommendation to ensure that the necessary consultation for implementation is conducted.

The EMS Foundation has been actively lobbying government on this issue since its inception in 2014. On the 27th of March 2020, the High-Level Panel of Experts, publicly requested written submissions to be made in respect of the management, breeding, hunting, trade, handling and related matters of elephant, lion, leopard, and rhino. On the 15th June 2020 the EMS Foundation and Animal Law Reform South Africa made a submission to the panel of experts, as did sixty-nine other organizations and individuals.  

On the 6th of October the EMS Foundation and Animal Law Reform South Africa made oral submissions and answered questions from the High Level Panel of Experts with a number of other organizations.

Further written questions were communicated to the EMS Foundation and Animal Law Reform South Africa on the 20th of October and these were extensively answered on the 2nd November 2020. 

A Basic Framework for the Resolution of Issues Relating to the Commercial Captive Breeding of Lions and Other Big Cats in South Africa 

The captive bred lion industry was originally exposed and highlighted in 1997 by the Cook Report.  Three successive environmental Ministers in South Africa made undertakings to investigate the industry, these include Dr Pallo Jordan, Mr Valli Moosa and Mr Marthinus van Schalkwyk.  While this industry continued to expand it has continued to attract worldwide, negative attention and criticism. 

In November 2020, the EMS Foundation, Humane Society International-Africa and Blood Lions submitted to the High Level Panel a basic framework for the resolution of issues relating to the commercial captive breeding of lions and other big cats in South Africa. 

These are the key points, in relation to this issue, that the EMS Foundation and Animal Law Reform made in October 2020 to the High Level Panel, these are some of the examples of immediate actions that can be taken by the South African government:

  • Announce that no new permits to keep captive lions will be issued and that existing permits will not be renewed.
  • Amend the conditions in the existing permits to protect the welfare of captive lions.
  • Amend the conditions in the existing permits to require the sterilization of all captive lions.
  • Set a zero quota for the export of lion bones in terms of CITES in order to remove the financial incentive to circumvent the law. Allowing the industry to continue to kill lions for the trade in lion’s bones as a means of limiting the number of lions while government is closing down the industry should NOT be considered as this will be endorsing criminality and supporting the illegal wildlife trade. Research has clearly shown that the legal trade of lion bones is part of the illegal trade.
  • Conduct an independent forensic audit of all lions and big cats in captive breeding facilities and the industry as a whole.
  • Develop a comprehensive national plan for dealing with the current captive lion population in a way that is humane and promotes both the conservation of the species as a whole as well as the well-being of those animals as far as possible. It should be done in such a way that regulates people to create infrastructure for true sanctuaries, repurposes jobs and reskills workers. Government must collaborate with animal welfare and protection organizations, civil society and other stakeholders who have the skills to deal with animal welfare matters and repercussions. 


Following on from the High-Level Panel of Experts Report, and in relation to the captive lion industry, the EMS Foundation cautiously welcomes the Minister’s statement that: “the breeding, petting and hunting of captive lions and the trade in their “derivatives” is something that the government does not want.” The government has been saying that it does not want this industry since 2018, when Parliament endorsed the Portfolio Committee on Environment report calling for the closure of the industry and the end to the lion bone trade.

Notwithstanding the need to follow procedural processes and the actual adoption of policy outlawing it, what we need to see is action. We are therefore urging the Minister to take swift, corrective, and practical steps so that this abhorrent industry is closed down once and for all and with no loopholes.

If this is not done as soon as possible it may have massive welfare implications for the many of thousands of lions held in captivity in South Africa who could in the interim by inhumanely treated and killed for their bones.  It could also mean a rise in the illegal bone trade.

We are also very concerned about the other big cats, particularly tigers, in the captive industry. Minister Creecy needs to include them in her Plan of Action.

For enquiries contact: Michele Pickover, Director EMS Foundation michele@emsfoundation.org.za https://emsfoundation.org.za

IMAGE CREDIT: The South African Police Service

© 2021 EMS Foundation. All rights reserved





22ND APRIL 2021

Tigers (Panthera tigris tigris) are included in Appendix I of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), which assembles 183 Parties, including South Africa.

On several occasions since early 2016 we had been asking your Department (DFFE) if it knew the number of Asian tigers in South Africa and if they monitor and audit the facilities in South Africa that keep Asian Big Cats. They continuously and consistently replied that they do not have any information as tigers are ‘exotics’ and therefore not their responsibility. This despite the fact that they are CITES Appendix I animals.

In 2016 CITES Decision 17.229 forewarned the Parties that the Secretariat was going to conduct a review of the number of facilities keeping Asian big cats in captivity in the territories of Parties and the number of Asian big cats kept in these facilities; and to review legal and illegal trade in Asian big cats from or through such facilities to identify any facilities which may be of concern.

On the 16th February 2018 we became aware that the CITES Secretariat has issued a Notification to the Parties to seek such information from the Parties, we emailed your department on the same day asking if they had this information available and the reply was, “we will be communicating with Secretariat on how we will deal with this matter as you can appreciate that there are 9 Provinces in South Africa and we have to coordinate the information”. On the 28th February 2018, together with Ban Animal Trading, we sent a letter to the CITES Secretariat in relation to Decision 17.229. Appended to our 2018 letter to CITES was a non-exhaustive list of 66 facilities/individuals keeping tigers in South Africa that we were able to trace as a result of internet searches and on-site investigations.

According to DFFE, in response to an EMS Foundation Promotion of Access to Information Act (PAIA) request1 there are 72 facilities/individuals keeping 451 Asian big cats in captivity.2 

This information has not been independently verified. Nonetheless, it is clear that South Africa is allowing intensive operations breeding tigers on a commercial scale.

The increasing trade in tigers and tiger parts is part of the unsustainable growth in the legal global wildlife trade. The The commercial flow of captive-bred tigers is largely driven by the increasing demand for live tigers and tiger parts and derivatives from Asia. This demand is therefore one of the most important factors for the current high levels of tiger poaching, captive breeding, and trafficking. Any trade in captive-bred specimens from South Africa is having an indirect but significant impact on tiger species whose populations are already depleted. In addition, allowing such trade obstructs global anti-poaching and trafficking endeavours.






South Africa bears the enormous responsibility of being the custodian of ninety percent of the world’s southern black and white rhino population. 

Yesterday the Department of Environment, Forestry and Fisheries (DEFF) published a graphic stating  that during 2020, 394 rhinos were poached for their horn in South Africa. This is apparently 33% less than the 594 rhinos that were killed in 2019, and furthermore it marks the sixth year that rhino poaching has continued to decrease in South Africa. 

Minister Barbara Creecy stated: “While the extraordinary circumstances surrounding the battle to beat the COVID_19 pandemic contributed in part to the decrease in rhino poaching in 2020, the role of rangers and security personnel who remained at their posts, and the additional steps taken by the government to effectively deal with these and related offences, also played a significant role.”

There is no mention or published graphic, however, stating that from 2011 there has been a 67% decrease in the number of white rhino, from an estimated 10 621 rhino to an estimated 3529 rhino. 

According to DEFF there were an estimated 415 black rhino in 2013 and now there are an estimated 268 black rhino, a 35% decrease in numbers.  

The confirmation of the decimation of the wild rhino population, was published, for the first time in many years, and is available in the South African National Parks Annual Report 2019/2020. 



Kataza can stay in the Cape Province, has this been considered?


Mr. Mqabuko Moyo Ndukwana Chief Executive Officer
Cape of Good Hope SPCA


Dear Sir,

In the absence of an official enquiry the EMS Foundation would like to continue to raise important questions about how humans are failing to successfully manage the baboon population in Cape Town.

The steady growth of human settlements and development has led to escalating interaction between humans and baboons on South Africa’s Cape Peninsula. Baboons, whose natural habitat is under endless threat and is increasingly diminishing, are being forced into residential areas where there is a ready availability of food discarded inappropriately by humans.

For the record, the EMS Foundation is not in agreement with the baboon management protocols which include paintballing, firing bare bangers, the inappropriate relocation, permanent captivity of male baboons or the killing of baboons. “On average for management purposes, we kill about seven baboons a year – habitual raiders – it is a danger to the public to have them in urban areas” -Julia Wood, Biodiversity manager for the City of Cape Town. Cape Town ratepayers have been paying fourteen million rand a year for the services of a baboon management company.

Human Wildlife Solutions, employed for many years to manage baboons in Cape Town, state on their website that they have worked very closely with the SPCA as part of the baboon management project, to quote their exact words “preventing and mitigating cruelty to baboons on the Cape Peninsula.”

According to the Cape of Good Hope Society for the Prevention of Cruelty to Animals website, the CoGH SPCA is committed to the credo that wild animals belong in the wild.

In 2017 the City of Cape Town extended it’s agreement with the CoGH SPCA to the value of nine million rand. The agreement means that the SPCA supports Law Enforcement with the impoundment of stray animals or animals involved in attacks and homes them for the prescribed impoundment periods. It is interesting to note that despite the contractual agreement, during the height of the so-called Kataza debacle, Kataza was captured and taken to the Westlake Conservation Centre, which is owned by the City of Cape Town. The CoGH SPCA and their appointed wildlife vet Gina Du Toit were denied access to the property, obstructing them from the execution of their duties. On the 10th September 2020 the CoGH SPCA issued a statement to say that: “Our only alternative is to obtain a court order in terms of the Animal Protection Act to gain access to the property so that a veterinary assessment can take place tomorrow.” There was no follow-up statement in this regard.

On the 23rd October 2020 the CoGH SPCA released the following statement regarding Kataza: “The CoGH SPCA has spent an extensive period of time monitoring the integration, movements and behaviour of SK11/Kataza since we were notified of his relocation to Tokai. We hoped he would integrate and be able to live out his natural life on the Peninsula but we are now concerned about his wellbeing and welfare, and that of other animals and the public in general. For this reason, we approached the City of Cape Town on the 21st October 2020 with a proposal to capture SK11/Kataza and relocate him to the Riverside Wildlife Rehabilitation Centre in Limpopo. All costs associated with the relocation process will be borne by the CoGH SPCA on receipt of approval from CapeNature.”

On the 12th January 2021 the SPCA once again submitted an application to CapeNature for a permit to capture and translocate Kataza to a centre in Limpopo. Is the SPCA aware that it is unlikely that Kataza will be released back into the wild?

On what basis has the CoGH SPCA made the decision to relocate Kataza to Riverside in Limpopo? Have other rehabilitation centres or sanctuaries – particularly those in the Eastern Cape – been considered? What assurance has the CoGH SPCA been given by Riverside that Kataza will be released back into the wild? The EMS Foundation is particularly concerned because CapeNature’s Dr Baard has indicated to us in writing that CapeNature will only provide a permit for permanent captivity and/or euthanasia and definitely NOT for rehabilitation and release.

We would very much like an answer to these questions as a matter of urgency.

The SPCA has apparently threatened legal action against the City of Cape Town if “the Kataza debacle” is repeated. “We will not relocate a baboon like this again, we have it made it clear to the City that this is the last time”. Is it fair to say that despite a fourteen million rand a year cost to the ratepayers of Cape Town the baboon management company has failed at their task of mitigating human interaction with wild baboons?

The City of Cape Town has not made any visible attempt to control the poor waste control in the urban areas closet to the baboons shrinking natural habitat. The EMS Foundation has filmed the areas in Kommetjie most often visited by the baboons and have failed to find any effective waste control.

We continue to question the methods of deterrence as well as poor enforcement of regulations to make urban areas less attractive to baboons. HWS failed to stop the baboon from “breaking the line” and raiding in the Kommetjie village. It seems that the new service provider has not been successful either.

Surely, after more than a decade of repeating the same mistakes we cannot possibly expect a different result.

We look forward to your urgent response.

The EMS Foundation 

IMAGE CREDIT Rob Tarr Photography

© 2021 EMS Foundation. All rights reserved






According to their own statement, on the 12th of January 2021, the Cape of Good Hope SPCA submitted an application to CapeNature for a permit to capture, transport and relocate Kataza/SK11 from the Western Cape to Limpopo.  Receipt of such application was not confirmed to the EMS Foundation on the same day by Dr Ernst Baard, Executive Director of Conservations Operations, CapeNature.  

Furthermore, according to media reports, this application was made after a meeting was held between members of the City of Cape Town Municipality and the Cape of Good Hope SPCA on the 5th of January 2021;  where it was discussed that Kataza/SK11 had not reintegrated with the Slangkop troop of baboons in the Kommetjie area. 

In August 2020, Kataza/SK11 was forcibly removed from his Slangkop troop in Kommetjie and relocated to the urban area of Tokai, and despite his own best efforts to return to Kommetjie he was forced to live in the highly populated area of Tokai for a period of over eighty  days. 

The reasons given for the relocation of Kataza/SK11 from his troop included the suggestion that he was a “raiding” baboon, that he was leading a splinter group of baboons to “raid” and that he was weakening the gene pool. 

The rapid rate of urbanization and development in Cape Town specifically, but also elsewhere in the Western Cape, is negatively affecting and placing extensive pressure on ecosystems, nature and wildlife. 

The forced removal of Kataza/SK11 from Kommetije to Tokai not only placed his life at risk but exposed him even further to humans.  Day to day sightings of Kataza/SK11 during this time period indicate quite clearly that he adapted to  being fed by humans and food inappropritately discarded by humans.  

A successful court application by a concerned member of the public, Ryno Engelbrecht, saw Kataza finally returned to his natal troop in Kommetjie but unfortunately Kataza/SK11 has not reintegrated with his natal troop and the behaviours he acquired in Tokai as a result of human interference has continued.

There is great local and international concern for Kataza/SK11, particularly  because, in relation to indigenous primates, specifically baboons, the Western Cape has, over decades, made a number of very  poor decisions.   The EMS Foundation believes that the general public should be kept apprised of the facts in a transparent and open way. 

Alarmingly CapeNature does not support relocation and rehabilitation of wild animals. Dr Baard, the Executive Director: Conservation Operations, CapeNature, has confirmed that “conservation agencies in South Africa use IUCN Red List Assessments and various Guidelines in their exercising of their mandates”. According to the IUCN Guideline on Reintroductions and other Conservation Translocations, “given the risks (to the individual(s)) and risk mitigation, we do not support translocation(s). The alternative would be placement in permanent captivity or euthanasia. For CapeNature this is a standard and we will continue implementing these”.

It is therefore logical  that if CapeNature issues a permit it will be for Kataza to be removed from the Western Cape and into PERMANENT captivity. 

The EMS Foundation believes that baboons on the Cape Peninsula, as they are key to the health of the fragile and dying ecosystem in the Western Cape, need to be protected and a concerted effort made to increase their numbers. Yet, it seems that baboons are being targeted for permanent removal by all the government agencies, including CapeNature and SanParks.  

All the letters we have written to the Western Cape government remain unanswered. Once again, the EMS Foundation calls for an official enquiry relating to the questionable decisions taken in the Western Cape with regard to baboon management.

AMENDMENT: Ernst Baard has contacted the EMS Foundation to confirm receipt of the aforementioned application from the Cape of Good Hope SPCA.

Image Credit: Kataza NCC Environmental Services

© 2021 EMS Foundation. All rights reserved




EMS Foundation

PO Box 3018, Honeydew 2040
South Africa
168-304 NPO

Contact Us


Get Involved

Interested in becoming a Supporter, Partner or Sponsor or want to find out other ways to get involved? Find out more