1st April 2022

Excerpt from this Report:


The full history of the contentious trade deal involving wild elephants caught in Namibia and exported to the United Arab Emirates into a life of captivity is well documented in the previously published Report by the EMS Foundation.

One the 4th of March 2022, the World Association of Zoos and Aquariums published their position statement on the import of wild Namibian elephants from Namibia to Al Ain Zoo. They stated that they were not able to determine if all the requirements of WAZA’s Code of Ethics have been met.

The European Associations of Zoos and Aquaria have published their official opinion regarding the aforementioned trade of wild-caught elephants. The EAZA Elephant Taxon Advsiory Group who oversees the African elephant EEP has repeatedly and clearly informed Al Ain Zoo that no import of wild caught elephants was either necessary or desirable.

It is, however impossible to believe that all EAZA executives were unaware of this particular acquisition of wild elephants. The close associations between EAZA and the Al Ain Zoo and Sharjah Safari Park, are highlighted in this document. Tim Husband stated clearly that elephants were being procured from Namibia for export to the United Arab Emirates in 2017.

Furthermore, the designing, planning and building of the aforementioned elephant exhibitions took place in the UAE over several years at a cost of millions of dollars and these projects would not have gone unnoticed. Questions must have been raised about where the African elephants were being procured and imported from.

At the CITES 74th Standing Committee Meeting held on the 9th of March 2022, Namibia’s interpretation of CITES regulations pertaining to exporting elephants out of their range states was discussed at length under agenda item number 50.

Once again CITES inconsistency in the treatment of the export of live wild elephants listed under Appendix I or Appendix II has been highlighted and is a matter of concern. Senegal, Burkina Faso, Kenya, Congo, Israel and the United Kingdom representatives to mention but a few, do not agree with Namibia’s interpretation of exports of live African elephants to a non-range state.

This matter was not concluded and will be taken up at CITES CoP19 which will held in Panama in November 2022.

However, in the meantime Namibia has suggested that there are 20 remaining wild elephants that apparently were sold on auction in 2021 who will be captured once the permits are concluded.

Image Credit:

©The EMS Foundation 2022. All Rights Reserved.






“Captive elephants lack the very foundation of elephant life.” Dr Keith Lindsay

Based on the body of overwhelming scientific evidence, South Africa took the commendable decision in 2008 to ban the capture of elephants from the wild for the purposes of captivity and trade under the terms of the National Norms and Standards for the Management of Elephants in South Africa (2008). The International Union for Conservation of Nature’s Species Survival Commission African Elephant Specialist Group opposes the removal of African elephants from the wild for any captive use. This position was reaffirmed at the group’s meeting in Pretoria, South Africa in July 2019.

On 6 September 2019, elephant specialists from around Africa and the world participated in an Indaba in South Africa, ‘Taking Elephants out of the Room’, to scrutinize the science, policy and welfare issues related to elephants in captivity. The overwhelming conclusion of the Captive Elephant Indaba was that no elephants should be placed in captivity and elephants currently in captivity should be rewilded.

Trading in Elephants is unconscionable and fails to recognise the sheer intelligence, sentience and complex social structures of Elephants.

Elephants are among the most social animals on the planet and keeping them in captivity and zoos is contrary to their nature and welfare. In captivity these Namibian elephants will have no agency. They have been removed from their context and will be forced to live unnatural, isolated, sad and denigrated lives.

Image Credit: Gerrie Odendaal / Conservation Namibia

©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.




Victims of the Wildlife Trade Living in Solitary Confinement 

Aaron Gekoski, an award-winning wildlife environmental photojournalist, published haunting images of Bau Noi in 2018.  

He has spent years documenting animals in captivity and is the founder and lead investigator at Raise the Red Flag, a global campaign to end cruelty in the Wildlife Tourism industry. 

Bau Noi, is a female gorilla, she has lived at Pata Zoo which is located on the top floors of a shopping mall in Bangkok since 1988.

Human evolutionary studies have indicated that humans and gorillas share ninety-eight percent identical genetic similarities. 

The gorilla genome is particularly important for our understanding of human evolution, because it tells us about the crucial time when we were diverging from our closest living relatives, the chimpanzees.

A team of scientists have concluded that gorillas have hierarchical societies similar to those of humans. Gorillas spend most of their time in dense forests, travel great distances to a new home locations on a daily basis. 

Dr Robin Morrison, a zoologist at the University of Cambridge in the United Kingdom, gained intimate views of gorilla and their social connections during a five year study in the Nouabale-Ndoki National Park in the Republic of Congo.  

She confirmed that there were family units nested inside larger social units in patterns strikingly similar to modern human societies.  Individual gorillas spent time not only with their immediate families but also with an average of thirteen extended family members. Furthermore that each gorilla interacted with thirty-nine other gorillas to whom they were not related.

During the last few years the physical environment of primates in captivity has become a subject of considerable interest.  Gorillas seem to be extremely sensitive to environmental conditions.  

Zoos cannot provide the amount of space gorillas have in the wild, gorillas roam for large distances.  Zoos do not provide natural habitats and this is particularly true of the Paka Zoo in Bangkok. 

The well-being of gorillas is dependent on their environment, Bau Noi lives in unnatural surroundings on her own this could mean that she might have developed physical health problems or anxiety, depression and even psychosis. 

Bau Noi was captured from the wild, the United Nations Special Rapporteur on torture in 2011 concluded that solitary confinement for humans beyond fifteen days constituted cruel and inhumane punishment.

If scientific research has revealed the breadth of human genetic, emotional and cognitive kinship with gorillas, chimpanzees, bonobos and orangutans we must conclude that the lack of contact, the sensory deprivation must had have severe impacts on Bau Noi’s well-being during her solitary confinement in Paka Zoo. 

Primatologists and conservations who have devoted their lives to studying the great apes in order to protect their rapidly vanishing populations in the wild have expressed the opinion that apes should not be confined to zoos and that there is no good evidence that captive apes are having any positive effect on their wild relatives. 

Over the past few years public awareness of the sentient and sensitive nature of high-level mammals, like gorillas, chimps, elephants, orcas and dolphins has led to the demise of Ringling Brothers, the removal of orcas and dolphins from public exhibition, laws preventing the use of bull hooks to control elephants and the freeing of Kaavan, the elephant from the Marghazar Zoo in Islamabad. 

Animal rights activists have asked Thailand’s Department of National Parks, Wildlife and Plant Conservation to remove Bua Noi from the zoo and for the closure of the Pata Zoo.  

Marc Bekoff a behavioural ecologist and professor at the University of Colorado argues that an animal’s life in captivity is a shadow of their experience in the wild.  

PETA’s investigation shows that the animals at the zoo are locked in dark, barren concrete cages and that they are offered no enrichment and little mental stimulation or physical exercise. PETA has offered to transfer all the animals to a sanctuary

Free the Wild is an international charity they endeavour to stop the suffering of wild animals in captivity and ultimately find a way to release them into sanctuaries or better equipped zoos.  Their current mission is to free all the primates at Pata Zoo.

The EMS Foundation is currently completing two investigations into the legal wildlife trade as part of the a series called the Extinction Business.  Three reports have already been published illustrating how zoos and private individuals around the world are supplied legally with wildlife such as elephants, lions, cheetahs, primates and giraffes.  

These wild animals are kept as pets or as part of displays are suffering and living in misery, many are physically and psychologically damaged.  We believe, that it is time to reconsider keeping wild animals in captivity, this is an outdated practise of a less enlightened era. 

Image Credit: Aaron Gekoski at Pata Zoo, Bangkok

Image Credit: Dr Robin Morrison, Nouabale Ndoki National Park

© 2020 EMS Foundation. All rights reserved





“Although exotic pets are technically alive, in terms of conservation they might as well be dead. Removed from nature, they no longer play any meaningful role for their species or ecosystem.”

– Rachel Love Nuwer


Ban Animal Trading (BAT) and the EMS Foundation (EMS) have, over a number of years, been collecting information, doing fieldwork, undertaking research and analysing data on South Africa’s international and so-called ‘legal’ trade in live wild animals.

This report― ‘Plundered: South Africa’s cold-blooded international reptile trade’―is the third in The Extinction Business Series. The two previous reports examined South Africa’s lion bone trade1 and South Africa’s live wildlife trade with China. Both reports discuss in full how loopholes and ineffectual controls in the permit system, which includes CITES, are enabling international laundering and smuggling of live wildlife. The same applies to the global trade in live reptiles and amphibians, which is discussed below.

The international trade in the majority of reptiles, amphibians and arachnids is mostly unregulated, often unlawful and a growing industry in South Africa. Data on the trade in these species is unreliable and insufficient, because most countries do not keep records or compile data unless the species is listed on the CITES Appendices. Even then the data is incomplete. One reason for this is that, unlike so-called charismatic species such as lions, elephants, tigers and primates―perceived to have higher intrinsic value―reptiles, including species such as snakes, lizards, turtles, tortoises, alligators and crocodiles are, in terms of public perception, and often because of the negative stereotypes attached to them, considered less desirable creatures, lack the charismatic appeal of anthropomorphic species and consequently they are afforded less attention.

Reptiles also lack the repertoire of facial expressions and vocalizations that would alert keepers to their pain and distress. A sick, hurt, or chronically stressed reptile will suffer in silence. The suffering will often be far more prolonged than that experienced by mammals, due to reptiles’ slow metabolic rate. Blood loss and the healing of injuries are both relatively slow, as are the consequent risk of infection and further complications. Reptiles are among the most inhumanely treated animals in the pet trade. Because they often are cheap and easily replaceable, dealers, captive breeders, and retailers factor huge mortality into their operating costs.



Plundered: South Africa’s Cold-Blooded International Reptile Trade is Part 3 in the Ban Animal Trading an EMS Foundation, The Extinction Business Investigative Report Series. The purpose of this Series is to examine South Africa’s international wildlife trade.
South Africa’s Lion Bone Trade (2018) was Part 1 of the Series and can be found here: bone-trade.pdf &

Breaking Point: Uncovering South Africa’s Shameful Live Wildlife Trade with China (June 2020) was Part 2 of the Series and can be found here: &

The mention of any individual, company, organisation, or other entity in this report does not imply the violation of any law or international agreement, and should not be construed as such.

© 2020 Ban Animal Trading and EMS Foundation. All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means without permission in writing.



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