The EMS Foundation has been informed that rare wild caught Namibian desert adapted elephants, as part of a clearly commercial transaction, were transported from the containment area on the GoHuntNamibia Safari property located in Gobabis in Namibia and loaded onto a Fly Pro Moldovan Cargo charter plane last night (4th March 2022), at Hosea Kutako International Airport for two captive destinations in the UAE – likely the Al Ain Zoo−a member of the European Association of Zoos and Aquaria (EAZA)−and Sharjah Safari. The flight landed at Sharjah at five am local time.

It goes without question that there are serious welfare and ethical concerns related to the capture, restraint, trade and captivity of elephants. Elephant ethologists, behaviourists and scientists are clear – elephants do not belong in captivity. 

Even the African Elephant Specialist Group of the IUCN Species Survival Commission (IUCN/SSN AfESG) does not support the removal of wild African elephants for captive use. In an official statement they clarified, “Believing there to be no direct benefit for in situ conservation of African elephants, the African Elephant Specialist Group of the IUCN Species Survival Commission does not endorse the removal of African elephants from the wild for any captive use.”

Legal Opinion obtained by the EMS Foundation, found that it would not be lawful for the Namibia CITES Management Authority to issue an export permit under either Appendix I or Appendix II of CITES, nor for a country outside of the range states for Loxodonta Africana to issue an import permit, particularly because Appendix II does not apply to the export and the available evidence indicates that exporting the Namibian wild caught elephants to an ex situ programme cannot meet the requirements of Article III for trade in Appendix I species, particularly the non-detriment criterion.

In a statement, the Namibian authorities confirmed that they had captured wild elephants which were sold on auction in 2021. They confirmed that some of these elephants will be exported to a foreign country. “We are signatories to CITES and we are aware of the international statues, the international law that governs CITES member states.  Our law does not allow an animal to be exported to a country where we know the environment is not conducive for this animal.” 

A number of urgent complaints and letters of concern have been sent by the NGO sector to CITES, and the Namibian and UAE authorities about the cruel capture, confinement and trade of wild elephants for captivity purposes. For example:

  • In December 2020 PREN members highlighted their concerns relating to the proposals to offer live elephants for commercial sale captured from regions of Namibia. 
  • On World Elephant Day on the 12th August 2021, PREN members questioned whether the live wild elephants mentioned in official statements would be sold internationally or whether they were captured for purposes of in situ conservation purposes and whether any of the captured elephants would be held in captivity. 
  • On the 21st September 2021, PREN members urgently directed communications to the CITES Secretary General, to the CITES Legal Affairs and Compliance officer, the Chief of the CITES Science Unit of the Secretariat, the Chair of the CITES Standing Committee and the Chair of the CITES Animals Committee.
  • On the 27th of October 2021, PREN members urgently requested that the CITES Secretariat approach the Namibian government urging the government to comply with CITES regulations and provisions. 
  • On the 18th of February 2022 18th of February 2022 PREN members urgently requested that the Acting Director Biodiversity Department CITES UAE, Namibian CITES Authority, CITES Secretary General, CITES Legal and Compliance Officer, Chair of the CITES Standing Committee and the Chair of the CITES Animals Committee halt the export of the wild caught Namibian elephants and ensure that they are returned to the wild as soon as possible.  

Shamefully, and indicative of the lack of accountability and transparency, there has been no official response to any of these letters from the CITES Secretariat, the UAE or Namibia. 


The EMS Foundation takes note of the inclusion of the wild caught Namibian elephant subject matter on agenda item number 50 at the CITES Standing Committee 74th meeting in Lyon which will be held from the 7th to the 11th of March 2022.  At the very least we demand that the CITES Standing Committee take a clear position on the capture of wild elephants in Namibia. 

Amongst many other matters that require careful consideration, the CITES Standing Committee will the discuss the issue which is listed as agenda item 50, the legal opinion on CITES rules on exports of live African elephants from Namibia submitted by Burkina Faso. The published findings of this legal opinion are as follows: 

  1. Namibia’s elephant population is listed in CITES Appendix II, subject to annotation 2. The annotation clearly states that it allows trade in live elephants from Namibia exclusively for in situ conservation programmes, but by inference not to other locations or for any other purpose. 
  2. Any previous or future export of live wild-caught elephants from Namibia to a destination outside the natural range of the species therefore does not comply with the provisions of CITES. 
  3. The last paragraph of annotation 2 does not apply to live wild-caught specimens and any interpretation implying that live elephants may be exported from Namibia to ex situ locations is contrary to the Convention and the fundamental principles of interpretation of treaties. Given that Namibia’s elephant population is listed in CITES Appendix II, which is subject to a legally binding restriction on live trade, in force since 2003, limiting such trade to in situ conservation programmes only, exports of live wild-caught elephants from Namibia should only be permissible to destinations within the natural range of the species”

As a member of the Species Survival Network (SSN)the EMS Foundation also supports the SSN input on Issue 50 – the definition of the term ‘appropriate and acceptable destinations’ (Report of AC SC74 Doc.). 


The CITES Parties and the CITES Secretariat, despite flagrant non-compliance and numerous communications from the NGO sector as well as legal opinions provided to them from recognised legal firms in Switzerland and South Africa have failed to act or address the capture and sale of wild elephants into captivity. The consequence of this is that a number of elephants have suffered immensely and the CITES parties involved in these commercial transactions are allowed to continue with impunity.  

Furthermore, CITES ignored the African Elephant Specialist Group of the IUCN Species Survival Commission who does not endorse the removal of African elephants from the wild for any captive use. 

The Species Survival Network has published a rejection of Namibia’s use of Article III of the Convention re: its exports of live African elephants to non-range States.

The export of live wild-caught elephants should only be permissible to destinations within the natural range state of the species, i.e. for bona Vida in situ conservation reasons.

The UAE was suspended once before from CITES and should be suspended again. The glaring question is: will CITES Parties do the right thing and enforce their own Treaty.

Images: Previous export of African elephants from Africa to the UAE Credit: Facebook

©The EMS Foundation 2022. All Rights Reserved.





Sunday 13th February 2022

On the 4th of January 2021, the Pro Elephant Network publicly expressed their concerns with regard to the tender notice published on the 3rd December 2020        by the state owned New Era Namibian newspaper from the Ministry of Environment, Forestry and Tourism.

The tender notice was for the sale of 170 wild elephants from four commercial breeding areas in the north of Namibia.  PREN urged the Namibian government to withdraw the tender notice and offered expert assistance with identifying and implementing solutions for human wildlife conflict, drought mitigation and perceived concerns of overpopulation of elephants in Namibia. 

On the 11th August 2021, the Ministry of Environment, Forestry and Tourism in Namibia announced that 57 elephants of the 170 which were put on tender in December 2020 were sold.  They confirmed that 42 elephants will be exported from Namibia.

By October 2021, some members of PREN received reliable information that indicated that the selection and capture of the elephants had taken place and that the elephants were being held in quarantine in preparation for export.  The information suggested that a South African wildlife broker was involved in the process.  The information further alleged that the wild caught elephants were destined for captive locations in the United Arab Emirates.

The EMS Foundation obtained a Legal Opinion which stated that it would not be lawful for the Namibian CITES Management Authority to issue an export permit under either Appendix I or Appendix II of CITES and that, similarly, it would not be lawful for a country outside of the range states for Loxodonta Africana to issue an import permit. 

On the 12th of February 2022, John Grobler, a well-known and internationally published, Namibian investigative journalist was arrested and charged with trespassing under Ordinance 3 of 1962.  According to John Grobler, he was arrested for allegedly flying a drone over a farm in Gobabis in Namibia, owned by GoHunt Namibia Safaris owner, Gerrie Odendaal, where 23 wild, captured elephants with two new born calves, are allegedly being held. 

The EMS Foundation is concerned at the lack of transparency by the Namibian government.  The EMS Foundation fails to understand why the processes of the capture, of the quarantine and the export and import of these elephants has not been transparent if no laws have been broken. 

The EMS Foundation cannot possibly condone the heavy-handed approach of the Namibian government towards John Grobler.  

The capture of free roaming wild elephants is a matter of national interest, general public concern and importance.  This is a subject of legitimate global news interest.  This is an example where an individual has intervened by taking a public interest action and attempted to disclose questionable behaviour by others. 

Image Credit: Ariadne van Zandbergen (Desert Elephant with young crossing, the Huab River)

©The EMS Foundation 2022. All Rights Reserved.








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.




The EMS Foundation and Ban Animal Trading, authors of the investigative report called the Breaking Point Report: Uncovering South Africa’s Shameful Live Wildlife Trade with China, the second in the Extinction Business series, have expressed their disappointment at the inadequate official response from the Minister of Forestry, Fisheries and the Environment in an open communication.

The Report published in 2020, highlighted the fundamental problems which are systemic in nature and relate to overarching policy issues. At the time, the authors welcomed the Minister’s commitment to investigating the serious issues raised in the Report.

The matter of the Report related to South Africa’s legal wildlife trade with China, at the time of the publication in the Minister committed to investigate the serious issues raised in the Report, within a three-month period and committed to: strengthening the permitting system, greater transparency within governmental systems and access to information. The Minister also acknowledged that civil society has a role to play in holding government to account and therefore government should be transparent.


Image Credit: Smaragda Louw / South African Rhino in Chinese Zoo

©The EMS Foundation 2021. All Rights Reserved.







Dinokeng Game Reserve is a 21000 hectare wildlife reserve in the Gauteng province, South Africa. It was officially opened on the 22nd September 2011 by the Gauteng Provincial Government to promote ecotourism and job creation involving more than 170 landowners. The government owns 4000 hectares of the reserve.  Dinokeng is situated one hour from Johannesburg and whilst it sounds idyllic the reserve is situated next to densely populated impoverished town called Hammanskraal.


The NGO Elephants Rhinos and People conducted a survey on 94 of the internal landowner fences and the perimeter fence at Dinokeng.  The results of this survey concluded that the requirements recommended in the National Elephants Norms and Standards were not fulfilled. 

In 2014 it was reported that Dinokeng Game Reserve did not have sufficient funds to maintain the permitter fence. 

On the 17th of April 2017 it was reported that a herd of elephants had escaped from Dinokeng Game Reserve. 

Dinokeng’s Elephant Management Plan 2018 states that all the aforementioned fences would be upgraded in 2022 in order to adequately fence their elephant population.  Dinokeng Game Enterprises Chairman Etienne Toerien confirmed that much of the fencing within the property was not up to standard, leaving elephants to break through properties inside Dinokeng. 


Dinokeng Game Reserve is a small reserve with an extremely high density of human activity.  In light of the fact that so many elephants have been killed at Dinokeng, we have to question their expertise and experience with regard to managing elephants.  It is quite evident that they do not understand the complexities of elephant behaviour or herd social dynamics.

A media report in 2018 revealed that Elephants, Rhinos and People had withdrawn their elephant monitoring services from Dinokeng. This is after the management of Dinokeng had applied for two Damage-Causing Animal permits to have two elephant bulls killed. A representative of ERP stated that the landowners on Dinokeng were hindering proper elephant management.

Three elephants have already been killed at Dinokeng Game Reserve.  In November 2016 a young bull elephant was shot without the required approval.  A young female elephant was also illegally shot leaving her injured, she was then misidentified by Dinokeng vet Dr Jacques O’Dell during a collaring an immobilisation process which eventually killed her. A bull elephant known as Hot Stuff was killed using a Damage Causing Animal permit. 

On the 5th August 2019 the Elephant Specialist Advisory Group  issued a statement with regard to the acquisition of eleven elephants by the Dinokeng Game Reserve in Gauteng. The scientific experts representing ESAG placed on record that they did not support the introduction of the proposal to introduce these elephants until such a time as the Dinokeng Management proved that they can adequately manage and monitor their existing elephants, maintain their fences to the required standard.


The management at Dinokeng Game Reserve failed to engage with elephant experts with regard to their management of the elephants.  

A notice was sent to the Dinokeng Game Reserve landowners stating that the matriarch elephant at Dinokeng is going to be killed today, 2nd December 2021. 

The Gauteng Department of Agriculture and Rural Development confirmed that they have issued a permit to kill the Matriarch and that it has not been rescinded. 

The planned killing of this elephant who apparently also has a young calf is likely to be challenged as it is also likely that it is in contravention of the Norms and Standards for Management of Elephants in South Africa.

Image Credit :

©The EMS Foundation 2021. All Rights Reserved.



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