Submission on the Global Guidance on the Sustainable Management of Wildlife Applicable to Multiple Species and Multiple Practices

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The EMS Foundation welcomes the opportunity to comment on the Draft Global Guidance on the Sustainable Management of Wildlife Applicable to Multiple Species and Multiple Practices.

The EMS Foundation is a South African social justice organisation working to alleviate suffering, advance equity and protect the interests of vulnerable groups, including wild animals. Our work is grounded in the principles of equity, access, diversity, participation and rights, and we advocate for approaches that recognise the intrinsic value of non-human life alongside ecological integrity and social justice.

We commend the Secretariat and contributing bodies for the inclusive and consultative process reflected in the draft. The guidance makes important advances, particularly in recognising participation, safeguards, knowledge systems and equity.

However, we remain concerned that, in its current form, the guidance does not go far enough in establishing clear normative limits. The concept of “sustainable wildlife management” remains insufficiently defined and risks being interpreted in ways that legitimise ecologically harmful, ethically problematic and socially unjust practices.

Drawing on our experience in South Africa, where wildlife governance is often shaped by highly commercialised and contested uses, we have observed that the absence of clear thresholds, precautionary safeguards and ethical considerations can enable:

• the normalisation of harmful and extractive practices;
• the concentration of benefits among elites;
• disproportionate burdens on rural communities; and
• the continued exclusion of animal welfare and wellbeing from policy frameworks.

In this context, our submission—attached in the prescribed template—proposes a number of key areas for strengthening, including:

• Explicit recognition that certain forms of wildlife use may be incompatible with biodiversity conservation and justice;
• A stronger and operationalised precautionary approach, prioritising restraint where risks and uncertainties exist;
• The inclusion of animal welfare and wild animal wellbeing as a core consideration;
• Clear limits on the use of economic benefit-sharing to justify harmful practices;
• Stronger safeguards against commercialisation risks, including corruption, elite capture and perverse incentives;
• The establishment of minimum standards and independent verification for sustainability claims; and
• Greater emphasis on non-extractive approaches, restoration and coexistence where appropriate.

We emphasise that guidance of this nature must not only support improved processes, but also clearly define the boundaries of acceptable practice. Without such clarity, there is a significant risk that the concept of “sustainable use” will continue to be used to justify outcomes that undermine both biodiversity and justice.

If strengthened accordingly, this guidance has the potential to contribute meaningfully to a more ethical, ecologically grounded and socially just approach to wildlife governance globally.

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