In the beginning of 2020, Sanlih E-Television Group's SET Studio Park became the largest shareholder of Wanpi World Safari Zoo, the largest private zoo in southern Taiwan. Immediately after, it initiated ambitious plans to introduce 18 giraffes, white rhinos, antelopes, zebras and other wild animals from Africa, trying to make a profit off of captive animals. Animal protection groups previously held a press conference on June 21 to present evidence showing that Wanpi World Safari Zoo is an extremely poor animal exhibition venue. The animal enclosures are horrendous. Professional veterinary care is lacking. The animals at Wanpi World Safari Zoo are suffering from physical and mental torture.

On July 7, animal protection groups once again held a press conference and invited Dr. Fred Bercovitch to serve as our international wildlife conservation expert. Dr. Bercovitch is the former executive director of Save the Giraffes Foundation, the co-author of the IUCN Giraffe Assessment Report, and the chief giraffe expert representative at CITE’s 18th Conference of the Parties (CoP18).[1]

TSPCA, EAST and TAEA presented four major evidences collected from cross-border investigations, calling on Sanlih E-Television Group to correct course before it is too late, to rethink its role and management policy as a modern zoo, and to refrain from becoming a culprit of "dirty" international wildlife trade that threatens wildlife conservation in Africa. The animal protection community also calls on the Forestry Bureau of the Council of Agriculture to withdraw the permit it has issued to Wanpi World Safari Zoo for importing the wild animals. The Forestry Bureau must not be misled by the lopsided documents provided by the two involved parties. Otherwise, Taiwan will wade into a huge controversy that can be detrimental to Taiwan's international reputation in wildlife conservation.

1. Giraffes are categorized as「Vulnerable (VU)」by IUCN and are also included in CITES APPENDIX II. Giraffes are undergoing a silent extinction. Importing and keeping giraffes captive does not aid conservation.

At the end of 2016, giraffes were listed to the Vulnerable category on the IUCN Red List of Threatened Species. Studies have shown that the wild giraffe population has plummeted by almost 40% over the last 30 years.[2] According to the IUCN classification, there are nine subspecies of giraffes, four of which are classified as "endangered" or "critically endangered." Experts point out that with this declining population, giraffes are heading into a "silent extinction."[3][4]

Furthermore in 2019, giraffes were officially listed in CITES Appendix II, which means that the species is not necessarily threatened with extinction, but trade must be controlled in order to avoid utilization incompatible with their survival. This also means giraffe conservation requires urgent attention and which is why the international community is stepping up its efforts to protect the giraffe species through trade control.

1. Kodolfan Giraffe (Giraffa camelopardalis ssp.antiquorum): Critically Endangered (CR)

2. Nubian Giraffe (Giraffa camelopardalis ssp.camelopardalis): Critically Endangered (CR)

3. Reticulated Giraffe (Giraffa camelopardalis ssp.reticulata): Endangered (EN)

4. Maasai Giraffe (Giraffa camelopardalis ssp.tippelskirchi): Endangered (EN)

5. Rhodesian Giraffe (Giraffa camelopardalis ssp.thornicrofti): Vulnerable (VU)

6. West African Giraffe (Giraffa camelopardalis ssp.peralta): Vulnerable (VU)

7. Rothschild Giraffe (Giraffa camelopardalis ssp.rothschildi): Near Threatened (NT)

8. Angola Giraffe (Giraffa camelopardalis ssp.angolensis): no danger (LC)

9. South African Giraffe (Giraffa camelopardalis ssp.giraffa): not assessed

IUCN conservation status of the 9 subspecies of Giraffa camelopardalis (giraffes)

2. Is the Forestry Bureau Misguided by Eswatini wildlife traders? Or is it confused about CITES regulations? The Forestry Bureau's hasty approval of Sanlih's import permit runs the risk of proliferating illegal wildlife trade.

CITES COP18 passed a resolution with overwhelming support to list giraffe in CITES Appendix II. However, Eswatini filed a "reservation", meaning that it does not want to adhere to giraffe-related regulations in CITES. The COA Forestry Bureau and the MOEA Bureau of Foreign Trade stated at the press conference on June 21: "Regarding the giraffe import application of Sanlih E-Television Group, because both Eswatini and Taiwan are not parties to the CITES convention, this is a transaction between non-parties. Moreover, since Eswatini filed a "reservation", both government authorities hold that "Eswatini's giraffe population does not fall under the prerogative of CITES."

Connie Chiang, Executive Director of the TAIWAN SPCA, responds as follows: Although Taiwan is not a formal CITES delegate because of international politics, Taiwan fully complies with the CITES provisions (as stated on Taiwanese government websites) and pro-actively participates in international wildlife conservation. Though Eswatini is the only country with diplomatic relations with Taiwan in Africa, it does not mean that Taiwan has to compromise its principle when it comes to matters with Eswatini. Taiwan of course is obliged to comply with CITES requirements regarding giraffe trade. Furthermore, all giraffes are listed in CITES Appendix II. Some countries, including Eswatini, were in favor of the motion for “split-listing” giraffe subspecies, but this motion was completely denied at COP18. Therefore, CITES appendix II does not exclude any giraffe population from any country.

Furthermore, in accordance with Clause 3 of Article 15 and Article 23 of CITES, because Eswatini filed a "reservation" against the listing of giraffe in Appendix II, "until such reservation is withdrawn the Party shall be treated as a State not a Party to the present Convention with respect to trade in the species concerned." Therefore, as far as the trade of the giraffe species is concerned, it is not wrong to state that Eswatini is not a party of CITES.  But this does not mean that giraffes from Eswatini are not CITES Appendix II species. Also important to note, CITES 9.5 (Rev. COP16) stipulates that concerning the trade of Appendix II species between a party state and "a state that is not a party to CITES", the importing country is still required to ask the exporting country to provide "Non-Detriment Findings" and "Legal Acquisition Findings" documents to prove that the animals to be exported are not from illegal capture and will not pose a threat to the wild population. Regretfully, Taiwan's Forestry Bureau, the central conservation scientific authority, simply issued the permit without asking for any of the aforementioned information.

3. Without knowing the real source and basic information of the animals, how could the competent authority agree to the import permit? What is the giraffe subspecies that Sanlih E-Television Group intend to import? Can you ensure that the imported animals were not obtained from kidnapping, smuggling and trafficking of wild giraffes ?

The giraffes Sanlih E-Television is set to import is from Eswatini, where there are no native species of giraffes. According to the 2013 Giraffe Conservation Foundation survey, there have only ever been Angolan giraffes and South African giraffes in the country and they were all imported from neighboring countries and then bred in captivity.[5]

Animal protection groups have inquired about the giraffe subspecies that Sanlih E-Television Group intends to import, but we found that even the Forestry Bureau does not know the answer. According to Sanlih E-Television Group's official statement however, they plan to import reticulated giraffes (Giraffa camelopardalis ssp.reticulata), which is a subspecies native to Kenya, Somalia, and Ethiopia, and are listed as "Endangered" by IUCN.

Animal protection groups further consulted with Humane Society International (HSI) in South Africa and talked with a director who is familiar with local animal trade. According to their knowledge, Eswatini does not have any reticulated giraffes. Moreover, according to the CITES trade database, since 2019 after the giraffe listing in CITES Appendix II, there have been no records showing reticulated giraffe exports to Eswatini from their native countries (Kenya, Somalia, and Ethiopia). Therefore, concerning these 18 giraffes that Sanlih E-Television Group intend to import through one single purchase, where are these giraffes originally from? Were these animals caught from the wild and traded illegally? If our government fails to obtain legal, reliable documents to prove that reticulated giraffes were legally imported to Eswatini and then successfully bred between 2013 to 2019, then the real source of these giraffes is very concerning and likely to be linked with the illegal capture and trade of wildlife.

According to CITES Trade Database, there has not been any record of reticulated giraffes exportation to Eswatini from Somalia, Ethiopia or Kenya since 2019.

Animal protection organizations reviewed the Forestry Bureau’s "Application for Export and Import of Live Wild Animals and Products of Protected Wild Animals" and found that importers do not need to fill in critical information about the animals being imported, including the subspecies, age, and sex of the animals. But there are nine giraffe subspecies, each with different countries of origin, different conservation statuses, and each facing different threats in the wild. If our government cannot obtain the correct and fundamental information of these giraffes, how do we ensure that this trade deal will not endanger the wild population of this giraffe subspecies? If it is true that Wanpi World Safari Zoo is bringing into Taiwan endangered reticulated giraffes, this will cause a serious threat to the wild population. As the central government authority responsible for animal conservation, the Forestry Bureau must shoulder full responsibility.

According to Dr. Fred Bercovitch, a wildlife conservation biologist with over 20-years of experience studying giraffes in African countries and the co-author of the IUCN Giraffe Assessment Report, the reticulated giraffe is a subspecies native to the hot and arid climate of Northeast Africa. Taiwan intends to import endangered reticulated giraffes from Eswatini, a country that is not the natural habitat for giraffes but sells giraffes abroad for profit. This is not only detrimental to the conservation of giraffe species but is also extremely appalling and inhumane, an act that we must condemn.

Dr. Bercovitch further questioned:

1. Why and how were these giraffes brought to Eswatini? Was it an ex-situ conservation effort to protect the endangered species? If this is for conservation, why is Eswatini selling them to other countries now? Are these animals being kept in different private reserves in Eswatini for tourism or hunting purposes? Or are they meant for breeding and sale for economic gain? Or do they have any unknown disease?
2. The Taiwanese government must not only have a clear grasp of the age/sex composition of the 18 giraffes destined for Taiwan, but must also clearly understand the makeup of the original/founding population. Do these 18 giraffes account for 100% or 50% of the founding population, or what proportion are we talking about? This affects wild populations and conservation. If the government and Wanpi Zoo do not know clearly the age/sex of the animals, they will not be able to safeguard the welfare of these giraffes. For example, are any of the animals adult males? Which could lead to serious fighting within the group in a captive setting.

Giraffe expert, Fred Bercovitch stated that all 9 subspecies of giraffes are listed in CITES Appendix II. Sanlih E-Television and the Taiwanese government are obliged to acquire legal documents for importation in order to certify the legalisation of animal sources and the conservation of wildlife population.

4. Sanlih E-Television Group's deal with the "devil"? Animals are being imported from a controversial facility – Big Game Parks.

Through cross-border investigations, animal protection groups found out that the source of these 18 giraffes, rhinos, antelopes and other wild animals is likely from Big Game Parks, a wild animal park that the king and royal family of Eswatini have outsourced to a man named Ted Reilly and his family for management. The areas in Big Game Park include one national park and three game reserves, all privately managed by the Ted Reilly family.

Chen Yumin, deputy chief executive of EAST, points out: The Ted Reilly family has close ties with the royal family of Eswatini, which delegated the powers of the country's hunting law, CITES management, science and law enforcement all to this family. Therefore, any wildlife trade carried out by Big Game Parks involves the scenario where the player is also acting as the referee. They can issue relevant statutory certification documents to sell wildlife for profit without oversight, and this is how it has always been making profits through wildlife trade.

The conservation strategies led by the Ted Reilly family have been criticized by international conservation experts and animal protection groups. The Reilly family supports the trade of ivory and rhino horn and trophy hunting. Moreover, in 2003 the family threatened to slaughter "surplus" African elephants so that it could sell 11 African elephants to the United States. In 2015, the Reilly family used the same tactic, it once again sold 17 African elephants (originally 18, but one died of illness before departure) to US zoos, despite the fact that there were fewer than 35 elephants left in Eswatini at the time. Today, Big Game Parks is using the same old trick, wearing the hats of both "conservation" and "wild animal management" to sell wild animals to Sanlih E-Television Group for profit. Animal protection groups solemnly urges the government and Sanlih E-Television Group to step on the brakes and stop dealing with the "devil".

・Instead of purchasing endangered giraffes from Africa, Sanlih E-Television Group should invest the NT$180 million dollars on research, rescue and rehabilitation of Taiwan’s native wildlife species.


Chen Yumin, deputy chief executive of EAST, on behalf of the alliance, also states: If Sanlih E-Television Group spends NT$180 million dollars on importing the giraffes, it may threaten the wild giraffe population and harm animal welfare. Without fully understanding the real source of these animals and then putting them through long-distance transportation, these animals face high mortality risks. Instead, this amount of money will be better spent on donations to conservation agencies and organizations in Taiwan for wildlife research, rescue, rehabilitation, and education.

"The roles and functions of modern zoos are constantly being challenged and questioned. A zoo that really cares about conservation and education is a zoo that prides itself on "negative captivity," said Yumin Chen.  Sanlih E-Television Group purchased these giraffes to make money, but there are many different ways to make a profit, instead of simply relying on collecting all kinds of exotic and cute animals and keeping them in captivity. There is great potential for Wanpi Zoo to refine and upgrade its business strategy and to support the protection of native wildlife species. The zoo can still be open to the public and provide visitors with paid tours showcasing rescue and rehabilitation efforts that are more educational and meaningful.


The animal protection community makes the following appeals:

  1. Sanlih E-Television Group and the Taiwanese government should correct course before it is too late by withdrawing the import permit of the 18 giraffes and also revoke other import permit applications of wild animals.
  2. Government agencies should fully implement relevant CITES regulations and guidelines; for the import and export of species listed in the CITES Appendixes, relevant reviews should be conducted with regards to biodiversity and conservation.
  3. Both the central and local animal protection authorities should request Wanpi World Safari Zoo to immediately improve the appalling captive environments in the zoo and improve its veterinary care for animals.

Global Petition: Call for the Taiwanese government and Sanlih to stop the import of 18 giraffes!   http://chng.it/VpVPW8DCfG

Media links: https://bit.ly/3hnenO0

Press contact:

Chen Yumin, Deputy Chief Executive of EAST +886-910-150-908/ +886-2-2236-9735

eastfree@east.org.tw


Connie Chiang, Executive Director of Taiwan SPCA +886-953-850-303/ +886-2-2738-2130

connie.chiang@spca.org.tw



[1] Wildlife Conservation Biologist/Former Executive Director of Save the Giraffes Foundation- Fred Bercovitch.

-Co-author of the IUCN Red List Assessment for giraffes, participated in compiling all the information that is contained in the assessment.

-The first author on the Thornicroft's giraffe assessment.

-Was the 'giraffe expert' who provided the conservation science background at COP18 for listing giraffes on Appendix II.

-Studied animals in the wild and in zoos for over 40 years. Studied giraffes for about 20 years, including research in Zambia, South Africa, and Tanzania, and have also studied baboons in Kenya, elephants in Botswana, and koalas in Australia.

-Have published over 150 peer-reviewed scientific papers.

[2] 2016 IUCN Giraffe Assessment Report|https://reurl.cc/yEKYkD6

[3] IUCN Red List|https://www.iucnredlist.org/species/9194/136266699

Giraffe Conservation Foundation|https://giraffeconservation.org/giraffe-conservation-status/

[4] IUCN SSC Giraffe and Okapi Specialist Group|https://www.iucn.org/news/secretariat/201612/new-bird-species-and-giraffe-under-threat-–-iucn-red-list

[5] Country Profile-Kingdom of Swaziland-Giraffe Conservation Status Report|https://giraffeconservation.org/wp-content/uploads/2016/03/Swaziland-Profile.pdf

Appendix 1:

The Controversial Background of Big Game Parks and Ted Reilly

 

  1. Big Game Parks Introduction

Big Game Parks (noted as B.G.P. below) is a privately-owned wildlife park in Eswatini. It includes 3 wildlife parks (Mlilwane Wildlife Sanctuary, Mkhaya Game Reserve, KaMsholo Bushveld Safari) and 1 national park (Hlane Royal National Park.) All four parks provide the public with tourism and accommodation services. The wildlife in these parks include zebras, all kinds of antelopes, black rhinos, white rhinos, elephants, lions and giraffes.

The executive director of B.G.P. - Ted Reilly, has very close relationship with Eswatini royalty. He was the designated manager of Hlane Royal National Park since 1967 and in 1998 the Game Act, CITES and all international conventions on wildlife were delegated to B.G.P. by Royal Warrant1 which made him “the CITES management, scientific and enforcement authority in Eswatini2.”

 

  1. Ted Reilly’s Perspectives on Wildlife Conservation
  • Live animal and carcass sales

On the B.G.P. official website it mentions that apart from tourism, they also remove wild animals in the parks for live sale, meat or carcass sale. “We prefer to place and translocate animals alive to expand the kingdom’s wildlife estate, but what cannot be placed alive, we harvest3.” B.G.P. has been making a profit off of selling wildlife instead of relocating the animals to other sanctuaries or national parks when needed. Conservation groups around the world have shown concerns on this matter.

 

  • B.G.P.’s cooperation with U.S. zoos for “conservation and rescue” purposes, causing the suffering of wild elephants

The 11 orphan elephants that were sold to San Diego and Lowrey Zoo in the U.S. from B.G.P. in 2003 marked the first time any wild African elephant had been captured and sent to the U.S. since more than a decade.

In 2015, B.G.P. again sold 18 elephants to U.S. zoos and animal protection groups across the world were outraged. Despite the controversy, B.G.P. and the US zoos carried on with their trade and sent 17 wild African elephants (1 died before transport) to 3 zoos in the U.S., Dallas Zoo, the Sedwick County Zoo in Wichita, Kansas and the Henry Doorly Zoo, in Omaha, Nebraska. Room for Rhinos, which is a partner organization between the zoos and Swaziland (Eswatini now) officials, oversaw the project4.

Both sides of the trade claimed that they were trading the animals in the name of conservation, but this couldn’t be further from the truth. Room for Rhinos claimed that due to the rising number of elephants in 2 of the 3 reserves managed by B.G.P., they were causing a great burden on the environment which had already been severely affected by drought. They argued that the vegetation the elephants consumed affected the endangered rhinos in the area negatively6. In order to solve the problem, Ted Reilly decided that the number of elephants had to decrease and relocating the elephants to other regions in Africa was simply “unfeasible.” He claimed that if they couldn’t find a suitable place for the elephants, they’d have to be culled. Soon after, U.S. zoos stepped in offering to ‘rescue’ the elephants.

In response to this, the Eswatini National Trust Commission (a parastatal of the Ministry of Tourism and Environmental Affairs which oversees four of the country’s seven reserves) noted, “There is space and food for elephants in other reserve areas of Swaziland (Eswatini now), but we were never alerted of the export5.” This shows that Ted Reilly has not tried to keep wild animals in their natural habitats and has chosen to ignore the harm that will be caused to the elephants during transportation and a life in captivity. His decisions are simply about financial gain!

A South African non-profit group, Ban Animal Trading South Africa states, “It is Ban Animal Trading’s view that Big Game Parks, a so-called private, non-profit trust in Swaziland (managed by Ted Reilly) that manages the wildlife in that country, is nothing more than a breeding farm for zoos. Eleven elephants were sold by Big Game Parks to U.S. zoos in 2003. What has Big Game Parks, and specifically Ted Reilly done since 2003 to make sure that there would not be an overpopulation of elephants in the areas he manages, at no cost to the Swaziland government? Not much, it seems, because the cozy relationship between Big Game Park and U.S. zoos means that there will always be some money to be made from ‘surplus’ animals who are kept in small enclosures, are allowed to breed and are then sold for destroying the habitat because there is not enough space for them to roam freely2.

 

  • Supports Legal Trading of Rhino Horns and Ivory

CITES has banned the ivory and rhino horn trade since 1989 and 1977. Ted Reilly however is actively trying to promote the legalization of ivory and rhino horn trading. At the 17th and 18th CITES meeting, Ted Reilly filed motions to try to legalize international white rhino horn and ivory trading, but the motions failed to pass. The proposal also stated, “Big Game Parks, the CITES Management Authority in Swaziland, will be the sole seller and horn will be sold directly to a small number of licensed retailers6.” Important to remember, Ted Reilly is both the player and the referee when it comes to wildlife sales, management and oversight in Eswatini.

Ted Reilly once said in an interview, “African rhinos belong to Africa, they are supposed to be beneficial to the country7.” He criticized the current procedure of burning illegally obtained rhino horns and ivory. He thinks they should be sold and the money used to fund conservation; how and if the money will be used is also highly questionable. He also believes that rhinos should be farmed for their horns.

Lifting the ban of international trade on rhino horns not only gives rhino breeders and poachers a chance to make even more profit, but also opens up a way for neighboring countries such as, South Africa, Namibia, to get involved in the rhino horn trade. Once this considerable amount of rhino horns and ivory enters the market, it will most likely increase the demand for rhino horns in Asia. This will create an even bigger threat for wildlife and therefore will be detrimental to wildlife conservation.

 

  • Support of Private Ownership of Wildlife and Trophy Hunting

Ted Reilly claims that he doesn’t like killing wildlife, especially for entertainment or sports and he will never allow any hunting in B.G.P., but he also agrees that the need for hunting should be fulfilled. He strongly agrees that once somebody owns the rhinos, them shooting the animals should not be interfered. Even if the rhinos are endangered.

Ted Reilly claims that private ownership of wildlife is the best way to conserve the animals. It will force the owners to manage their animals thoroughly and eventually expand the natural habitats. He also thinks that it is key to be financially independent while working on conservation. If it involves making a profit through hunting then it should certainly be valid8.

Ted Reilly also encourages the private ownership of wildlife in South Africa as he believes this will effectively bring up the numbers of endangered animals. However, all the perspectives he holds do not take into account the welfare of the wild animals. Will the animals actually live in an enriched environment that mimics their natural habitats or will they be trapped in enclosures that are barren and small? Animals are not just a mere number, their housing, breeding, transportation and trading purposes are important factors to assess and consider. Ted Reilly is merely using his authorized position to make a profit in trading endangered species and not for the conservation of the animals.

 

 

References:

  1. https://reurl.cc/W3Oxbk  Big Game Parks – 50 Years of Conservation in Swaziland (2014)
  2. https://reurl.cc/Q9aRY0 THE SWAZI ELEPHANTS:COMMERCIAL TRADING IN ANIMALS IS NOT CONSERVATION – Ban Animal Trading South Africa (2015)
  3. https://reurl.cc/EnQNla About Big Game Parks – B.G.P. official website
  4. https://reurl.cc/4aNrNV African Elephants On Their Way to U.S. Zoos, Despite Protests – Jani Hall, National Geographic (2016)
  5. https://reurl.cc/j8rj7M Swaziland elephant export ignores alternatives– news 24, South Africa (2015)
  6. https://reurl.cc/ZGNdg6 Swaziland - thinking the unthinkable to save rhinos by legalizing trade in horn – Professor Keith Somerville, ICWS Senior Research Fellow (2016)
  7. https://reurl.cc/2rQAOX Legal rhino horn and ivory trade should benefit Africa, says Swaziland government – Karl Mathiesen, The Guardian (2016)
  8. https://reurl.cc/ZGNe1W Swaziland showing Africa how to save rhinos– Interview with Ted Reilly – Scott Ramsay (2014)