������

Spanning over an area of eight square kilometres, the recently opened Sharjah Safari Park in the United Arab Emirates claims to be the world’s largest safari outside Africa. With space for 50,000 animals of 120 species from across the continent, it to “simulate the real regions of Africa” in the Arabian desert.

The park’s elephant enclosure, entitled the ‘Niger Valley’, is large by zoo standards, with an opulent waterfall and pool, but barren of any kind of vegetation one would expect to find in a savannah. There are no fences to be seen, but artificial rock formations demarcate the park boundaries.

The Niger Valley is home to 13 wild African elephants, who huddle together under the shade of large umbrellas, their only respite from the glaring sun and up to 50 degree Celsius heat typical of UAE summers.

These elephants are part of a larger group of wild elephants that were exported from Namibia to the UAE in March of this year. Initially captured from their natural habitat in the northwestern Kamanjab constituency of Namibia in early September 2021, they spent six months in quarantine captivity.

The elephants were then heavily sedated before being loaded into shipping containers, onto a plane, and transferred to their final destinations: the Sharjah Safari Park and Abu Dhabi’s Al-Ain Zoo. The first of the two state-owned facilities is an initiative of the Environment and Protected Areas Authority () in 2017 by the ruler of Sharjah, Sheikh Sultan bin Mohammed Al Qasimi. As for the Al-Ain Zoo, it was in 1968 by the late Sheikh Zayed, the founder of the UAE.��

Both facilities are said to be part of the UAE’s larger wildlife conservation efforts, and the arrival of the Namibian wild elephants is supposedly part of this project. In reality, the sale served primarily commercial purposes under a cover of conservation, and violated international guidelines that discourage the removal of wildlife from their natural habitat.��

At the time of publication, there are a confirmed 13 elephants in the Sharjah Safari Park and eight to nine elephants are thought to be in the Al-Ain Zoo. While the elephants in Sharjah were on display for the public, those in Al-Ain have not been seen by ������ (TNA), and remain enclosed in a large hangar, likely only to be exhibited in the beginning of 2023. In late August, when ������ visited the Al-Ain Zoo for the second time in a few months, an Emirati tourist guide put the number of elephants at nine. He had never seen them though, and was convinced that they had come from Zambia.��

Wildlife trafficking is considered to be the fourth most lucrative illicit trade in the world, an estimated USD 15 billion annually. Technically, this is not supposed to be a wildlife trafficking story, but that of an African government selling tuskers to Emirati zoos. The export echoes a wildlife trafficking story though, when looking at the involvement of shadowy intermediaries, the violation of international conventions on endangered species, the mistreatment of the elephants, and the lack of long-term benefits for conservation or the communities affected by their presence.

Namibia: A for-profit conservation model

Namibia is often presented as a country with exceptional wildlife conservation management policies to be replicated across the African continent, but has recently relaxed rules relating to the hunting and sale of wild animals.��

Now, the southern African nation is one of the leading proponents of the ‘sustainable utilisation of wildlife’. The government’s conservation model supports commercial trade of wild animals and products derived from them. Namibia, along with other countries in southern Africa, has been a long-time of legalising the ivory trade.

“Wildlife must have a commercial value in order for it to be protected. They are firm believers in commercialising wildlife,” said Adam Cruise, an investigative environmental journalist who has conducted extensive research on Namibia’s elephants.��

On 3 December 2020, the Namibian government announced an auction to sell��170 'problem' elephants, with offers needed by 29 January 2021. It was organised on short notice, announced only in a government publication, and took place over the main holiday period. In the tender, the Ministry stated the requirements that entire family groups must be captured together using qualified professionals, following all international guidelines.

"The old saying that guides the official approach to the country’s conservation agenda is: 'If it pays, it stays'"

On 15 February 2022, the ministry officially that 57 of the 170 elephants had been sold to successful bidders, 37 of which had already been paid for and captured, including the 22 that were destined for the UAE.��The remaining 20 auctioned elephants were still roaming free, pending payment in full and the issuance of related export permits. They were expecting to generate N$5.9 million (USD 326,000) from the sale in total.��

Intermediaries pocketed most of the profits though. According to , South African game farmer Gerrie Odendaal - whose name was confirmed to be among the successful bidders by the Namibian government - paid 3.3 million Namibian dollars (USD 183,000) for the capture of 22 gentle giants, and went on to sell an indeterminate of elephants (with two of them being born while in quarantine) for N$17.17��million (USD 950,000) to another South African dealer, Elske Burger. She then proceeded to handle the export to the Emirati zoos. Elske Burger declined to comment by the time of publication.

The whole deal was reportedly worth around N$50 million (USD 2.76��million). Speaking to ������ on condition of anonymity, another South African wildlife dealer described the amount as “feasible” for that number of elephants.��

Burger was also involved in the sale of Zimbabwean elephants to the Dubai Safari Park in 2018, according to released by the Zimbabwean government.

Too many unruly elephants or a water problem?

According to official government figures as of 2019, Namibia has an elephant population of 24,000. However, conservationists and wildlife experts believe that the real number is considerably lower.����

In response to questions submitted in December 2018 by Namibian journalist John Grobler, one of the authors of this investigation, the Ministry of Environment, Forestry and Tourism’s (MEFT) Deputy Director for Natural Resource Management Colgar Sikopo stated that Namibia’s elephant population has grown from the 1995 count of 7,000 to 16,000 by 2004, and then 24,000 in 2019.��

He said that the population “is growing at about 3.3% per year”. But these numbers don’t work out. A 3.3% compound growth for 24 years, starting from the 1995 total, would have produced an elephant population of around 15,000.��

In reality, the numbers that Sikopo quoted represent an implausibly high annual population growth of 5.3%, close to the theoretical maximum for African elephants of 7%. Elephants in Namibia have experienced ever increasing human encroachment into their habitat and a once in a generation drought – not the ideal conditions of heavy rainfall and peace from human disturbance.

In fact, in the that the 7% number comes from, rain is cited as one of the biggest indicators of high population growth. The validity of the reported Namibian population numbers are further brought into question when you consider that for the 1995 to 2004 period they show a per annum growth of 9.6%.

"According to official government figures as of 2019, Namibia has an elephant population of 24,000. However, conservationists and wildlife experts believe that the real number is considerably lower"

Compare these numbers to what has been seen in Kenya, where officials boast about having had great success cracking down on poaching and increasing their elephant stock. It saw a 21% jump in seven years, from the peak of . This represents a 2.76% year on year growth, just half of Namibia’s claimed growth.

In addition, Namibia is well known for its small and unique population of what are considered ‘desert-adapted’ elephants roaming the ephemeral river systems in the Kunene region of Namibia, in which Kamanjab is located.

Explaining the reasoning that informed the decision to remove the elephants from the Kamanjab region, Chief Public Relations Officer for the MEFT Romeo Muyunda explained to ������: “We calculate in terms of the carrying capacity of the area against the current population that is there. The reason why the specific areas, Kamanjab included, were selected is because there is too many elephants there.”

However, in recent years studies have shown that the ‘desert-adapted’ elephant population of this region has been in due to severe droughts as well as hunting and conservation mismanagement.

It is believed that the elephants sold to the Emirates come from this population, though there is argument over whether or not they are from the “true desert population”. Given the small numbers of surviving desert-adapted elephants, the export could threaten the group’s existence.����

The Namibian government asserts that the motivation behind the sale of their wild elephants is because of the increase in dangerous interactions between humans and elephant populations across the country, what is referred to as human-elephant conflict (HEC).��

Specifically, they claim that in the four areas that the elephants were taken from, droughts have driven elephants into farmland areas in search of water, damaging infrastructure and crops and posing a threat to local farmers.

“With an estimated 180 freehold farms affected by elephants, infrastructure damages could come to N$9 million (USD 498,000) using a conservative estimate of N$ 50,000 per farmer per year,” Gail Thomson, a consultant with Namibia’s Chamber of Environment.

Last June, Gerardo Martinez, head of elephants at Sharjah Safari Park, Dubai This Week TV programme that the elephants were causing “a lot of conflicts in the villages where they lived” and that the Emirati safari park stepped in to “save” them.

Further comparison with Kenya posed questions on the validity of HEC as the motivating factor behind the sale. Kenya has more elephants and much more people in a smaller area, and while they do experience difficulties with wildlife management, they have not resorted to removing elephants from the country. Namibia, on the other hand, is one of the least densely populated countries in the world. Kenya also does not allow for trophy hunting, whereas Namibia does.

[Table compiled by drawing on a combination of government and UN data].

Conservationists and wildlife experts have also challenged the Namibian government’s claims of increased HEC, and believe that it is being used as the cover story for a financially-motivated sale.

“The reality is that HEC is a complete fabrication that the Namibian government uses to justify these translocations,” said Cruise. He explained that the term itself can be misleading: ‘conflict’ implies there’s danger or threat to human life, when in reality interactions with elephants are rarely ever aggressive or dangerous, and the damage is almost always confined to crops or property.

The claimed HEC ‘hotspots’ are in fact commercial farming areas that have expanded in recent years, crossing into elephant corridors.

In cases like these, of the Convention on the International Trade in Endangered Species (CITES), the only major international treaty on wildlife trade to which Namibia and the UAE are both signatories, say that the elephant groups causing trouble should be relocated within the country or at least the southern African region, and that wild areas or private reserves should be their final destination in order to keep the elephants as close to their home habitat as possible, known as in-situ conservation.

"Given the small numbers of surviving desert-adapted elephants, the export could threaten the group’s existence"

Relocations within the region would have been sufficient to address HEC, and the other 15 elephants that have already been captured were relocated within Namibia. In the case of the UAE-bound elephants, Thomson said that local relocations would have been the ministry’s first choice.

“Although it wasn't a requirement, they had a strong preference to keep them in the country, if there had been a lot of tenders,” she said, but the requirement to take whole elephant herds the number of buyers able to comply with the terms.

However, ������ was told that several offers had been made to the ministry to relocate the elephants within Namibia. Rob Roy Ramey and Laura Macalister Brown, US researchers heading the Namibian Desert Elephant Conservation project, have studied this population for decades. When the ministry launched the auction, they submitted a proposal to relocate the Kamanjab ‘problem’ population to enhance the gene pool of the Hoarusib population further in the west. But they never heard back from the ministry.

������ also spoke with an NGO that had contacted the Namibian authorities at the time of the announcement of the auction, and offered to assist with logistics and securing funding to translocate the elephants to areas of Namibia where populations had declined. A draft of the proposal was also shown to ������. These offers were also not taken up.

When asked about NGOs offering to relocate the elephants, the ministry’s PR officer Muyunda explained that the offers had come in too late: “When there’s a public tender out we expect people to give offers regarding the public tender … Any other alternative solution that anybody is giving outside the tender will not be considered.” He then asked: “Why do they wait until government takes a decision to auction?...Issues of Human Wildlife Conflict are continuing at the moment as we speak.”

In late July ������ visited the communal farming areas of Kamanjab to speak to farmers and other members of the community about their experiences with HEC and whether or not they wanted the elephants to be removed.

Over the 32 interviews conducted, there were points that came up time and time again: the farmers do have a water problem, but HEC is just one factor rather than the main cause; they aren’t getting enough help from the government; people are only injured by elephants when they behave aggressively towards them to start with; they don’t want the elephants to go away, for sentimental reasons but also because their presence attracts tourists.

The last ten years of drought were extremely tough for people in the region, including Aaron Ikurua, a farmer from Driehoek Opstal whose cattle all perished. He is now instead forced to only keep goats, which drink less water but bring in less money.

The elephants have also been struggling throughout the drought years and are drawn to pools of fresh water, such as the large open top concrete cisterns – known locally as dams – that farmers pump water into. Often elephants will come and drink from the dams and leave without causing any damage, though this is still a problem as it forces farmers like Ikurua to use up more of their already scarce diesel: “So the little diesel you are buying for the goat [to pump water] the elephant is coming and drink the dam out.”

Things are then made worse when the elephants have calves with them that are unable to reach over the wall and drink from the dam: “The older ones just puts their trunks in and drinks, but once they are with younger ones and can’t reach then they will pull out the pipe,” said Michael Nowoteb from Farm Driehoek Pos Een.��

Nowoteb’s farm has a government waterpoint that had been damaged by elephants the night before ������’s visit. Just like every other time this happened, he had to repair it himself and reportedly received no financial aid from the government: “We haven’t received any assistance from anyone. Imagine damage like that for 20 years.”

Lidia Brummer is co-owner of Huab Valley Lodge, where she runs wildlife spotting trips for tourists. Elephants are their main attraction.

“If we have water points for them, where they can drink and refresh, I doubt if we are really going to have conflicts,” she said.

"'We are not against the elephants here, as long as we got support from somebody, the conservation or the government or somebody. But we are on our own.'"

Despite the problems that elephants cause, all of the farmers interviewed by ������ – bar one exception – did not want to see them removed. Instead they wanted the government to do more on the ground to help them.

��“We are not against the elephants here, as long as we got support from somebody, the conservation or the government or somebody. But we are on our own,” said Aaron Ikurua.

Farm Ruspoort, run by the ǁUirab��family, was the only place where ������ encountered a fully anti-elephant sentiment. Salonika ǁUiras��said that elephants had broken their water tank a few years ago, and that they’ve repeatedly raided her vegetable garden. ǁUiras��has a complaint not shared by other farmers: she claims that their cattle herders refuse to stay out at night because they are scared of elephants, which means that they then lose livestock to predators.

The cattle herders’ fear of elephants at night is understandable; even Michael Nowoteb, who has lived with elephants his whole life, admitted that he finds it “really scary” when the large noisy creatures come near his home after dark.��

However, incidents in which locals are badly injured or killed are extremely rare and seem to be the result of people acting aggressively and trying to chase elephants away. “If you learn nice with them, you stay together, no problems,” said Adam Bahono, a guide at the local Himba Village.

A portion of the money made from Namibia’s wildlife goes into the Game Products Trust Fund (GPTF), so that it can then be spent on helping people in game areas live with wildlife. According to a MEFT statement released on 15 February this year, N$4.4mn (USD 243,400) from these elephant sales has already been paid into the GPTF.��

However, many of the farmers that ������ heard from say that they currently don’t receive any help from the government and have never heard of the GPTF. In the end, just 10% of the total USD 2.76��million reportedly paid for the elephants would have gone back to the Namibian government.

An alternative way for the people in the region to profit from the elephants is through tourism. Lidia Brummer, from the Huab Valley Lodge, said that it would be a “very sad day” if the elephants were to disappear from the region, and would greatly impact tourism.

She also highlighted that elephants had stopped crossing into the lodge, with only one sighting of elephant tracks in three months. Brummer referred to human encroachment as the reason why elephants have become more nocturnal. Capture operations are likely to further discourage their appearance in the daylight.

Aaron Ikurua also spoke about how important it is that the elephants stay so that people from Europe continue to visit, adding that, “We like them, they are a beautiful animal, we are blessed to have elephants here in Namibia.”

��

Emirati zoos adamant on importing wild-caught elephants

The Sharjah Safari Park officially opened its doors in February 2022. However, plans and preparations to import wild African elephants go back at least a decade, long before the Namibian government announced its intention to auction.

In May 2021, ������ spoke to a prominent UK-based zoo operator, who said that many years ago, he had had a conversation with an Emirati colleague in Sharjah in which he was told that a very large hangar was being built to house elephants. The most obvious location for this would have been the Sharjah Safari Park.

Sharjah’s EPAA the expansion of a conservation park into the current safari in June 2016. Taking into account the planning stage and the fact that Sharjah only has African species in its collection, they likely had to plan the sourcing of the pachyderms three or four years before starting construction of the elephant compound.

Asked whether the UAE would have considered the impact of this import on the Namibian ecosystem, the former CEO of an Emirati safari park told ������ that “the UAE authorities would have turned a blind eye to the status of the elephant population in Namibia, passing the responsibility to the zoos themselves to do any background check.”

As for Al-Ain, the zoo had interest in acquiring elephants as early as 2010. Official plans for African elephants date back to July though, when construction began on the zoo’s AED 93 million (USD 25 million) elephant safari project, which promises a feeding experience that is “unique to the GCC area”.

The beginning of construction of elephant housing facilities in both Sharjah and Al-Ain long before the Namibian government announced its plans to sell the elephants suggest that the UAE’s demand for African elephants was already high.

������ sought a right to reply from all of Mona al-Shamsi, the head of CITES at the Emirati ministry of environment and water; Hessa al-Shamsi, the director of EPAA communications department in Sharjah; Hana Saif al-Suwaidi, the EPAA chairman; the Sharjah Government Media Bureau; Ghanim Mubarak al-Hajeri, the Director General of Al Ain Zoo; Jane Budd, the head of veterinary services at EPAA; Mariam Bint Mohammad al-Mheiri, the minister of climate change and environment; and Daniel O’Loughlin, the head of education at Sharjah Safari.��

As ������ is banned in the UAE, it sought their comment through independent journalists working on this investigation. Nevertheless, none of the concerned parties was available to comment by the time of publication.

The owner of Maguari-One Zoo, the company contracted to design the Sharjah Safari Park, is Dutch national , who is also the former head of the . Koen Brouwer’s design included the ‘Niger Valley’ elephant enclosure in the park. He was not available to comment by the time of publication.��

Al Ain Zoo is accredited by EAZA, while the Sharjah Safari Park was reportedly hoping to become a member.��

, another Dutch zookeeper, was involved in the decision-making process, according to multiple sources. He is operations manager at the EPAA-managed Breeding Centre for Endangered Arabian Wildlife (). Vercammen is also an . He was not available to comment on his alleged role by the time of publication.��

EAZA Director of Communications David Williams-Mitchell told ������ that the association “is made up of institutions, not individuals, and we have no mandate to investigate the actions of people who work for our Members unless their actions are clearly taken on behalf of that Member”.��

While planning the acquisition of African elephants, the Emirati safar parks ignored the warnings of established zoo associations like EAZA and sidelined them in the decision making process.

"For Emirati rulers, the tourism-driven African theme of their wildlife parks apparently mattered more than the success of breeding programmes. And for this, the Emirati zoos were willing to pay a high price"

Arne Lawrenz, the EAZA ex-situ Programme (EEP) coordinator for elephants, told ������ that, around 2019, he had been approached by Mark Craig, the former Al-Ain Zoo Life Science Director, and that he had made “absolutely clear that there are no imports [from Africa] with a breeding programme”. Lawrenz explained that EAZA had imported African elephants in the past but the breeding programmes had not been successful. Mark Craig was not available to comment by the time of publication.

Unlike the African pachyderms, Asian elephants had been doing really well in EAZA facilities, according to the EEP coordinator, to the extent that they had to stop breeding to avoid overpopulation. Lawrenz informally proposed to Craig and Vercammen the transfer of Asian elephants to the Emirati zoos but was told that they wanted to have Africans only.��

For Emirati rulers, the tourism-driven African theme of their wildlife parks apparently mattered more than the success of breeding programmes. And for this, the Emirati zoos were willing to pay a high price. Lawrenz described the “philosophy” of the Emirati zoos as “I got the money, I want to have it. I don't care if that works.” The outcome was a lucrative deal finalised through middlemen rather than a non-commercial exchange between zoos.��

It was also clear from the beginning that the Emirati zoos were interested in obtaining large families of tuskers as soon as possible and were unlikely to source them from a breeding programme.

“They asked for huge families. And we don’t have huge families at the moment within the breeding programme. So we said we have some older females, we might have some bachelor groups available. But that takes time, [...] you have to [...] get on a waiting list... But they just wanted to have elephants and they had built everything in advance,” said Lawrenz. He complained about the Al-Ain Zoo having been elusive in the run-up to the import and said he had learned about it as a fait accompli.��

EAZA did not agree to share with ������ copies of the two internal complaints filed by Dr. Lawrenz with regards to the Al-Ain Zoo. After months of back and forth with EAZA officials, during which ������ kept sharing information and questioning the role of the European association’s members in this sale, EAZA decided to the Al-Ain Zoo’s membership on the 15th of September.

Its statement said the import of the Namibian elephants implied “multiple breaches” of EAZA rules. It further cited lack of transparency and the decision to go ahead with the import in spite of EAZA’s opposition as reasons for ending the membership of the Emirati zoo.��

Membership will be officially terminated by the end of this year but the Al-Ain facility has the right to appeal. Further measures against EAZA members might be announced in the association’s annual meeting scheduled to be held on September 30.��

In violation of international treaties

In August of 2019, 184 CITES members voted on a resolution to end the export of live African elephants. Namibia the resolution, but it passed anyway with a two-thirds majority. One year later, to the surprise of many, Namibia’s MEFT announced its plans to capture and auction 170 wild elephants.

This was not particularly out of character for Namibia: it had previously sold wild elephants to Mexico and Cuba. Zimbabwe leads the region’s pro-trade agenda with to captivity in China over a seven-year period. However, these trades were made before the 2019 decision that these transactions were not and could not be in the animals’ best interest.

All species covered by CITES are listed in three appendices corresponding to the level of protection needed, with Appendix I being the most endangered. Due to the bigger size and stability of the population, Namibian elephants are listed under meaning that they are, “not necessarily threatened with extinction, but in which trade must be controlled in order to avoid utilisation incompatible with their survival.” Despite the threat of extinction faced by Namibia’s desert-adapted elephants, no official distinction is made.

Appendix II allows for the trade of wildlife, but the amendment passed in 2019 explicitly bars the export of elephants from Namibia, Botswana, Zimbabwe, and South Africa to any country where the elephants are not naturally occurring, except in the case where there is an explicit conservation benefit.��

"While all parties involved claim that the trade was legal and done with the wellbeing of the elephants in mind, international guidelines were clearly flouted, and involved parties were likely aware of this"

Elephant populations are not present in the UAE, and under these terms, it would be extremely difficult to justify that the export of wild elephants to captivity in zoos would provide a conservation benefit.��

To get around these regulations, the parties involved exploited a loophole, upgrading the elephants from Appendix II to Appendix I, a move that is permissible given that Appendix I should afford the elephants more protections.

Appendix I prohibits the trade of listed species for commercial purposes. However, in a highly controversial issue within the convention’s policies, zoos and safari parks are considered ‘primarily’ non-commercial sites, and the transaction is therefore not prohibited. This is considered one of the biggest loopholes in CITES, which has a troubled reputation among conservationists, and has drawn widespread .

At the Sharjah Safari Park, , which include a luxury vehicle and private guided tour, go for AED��275 (USD 75). The Al Ain Zoo offers an even more lucrative experience; a costs AED��1,050 (USD 286). In the four months after its opening, Sharjah Safari Park had already 35,000 visitors.

In addition, under CITES regulations, before any trade can be issued, both the exporting and importing countries must produce a non-detriment finding, a conclusion by the country’s Scientific Authority that the proposed trade will not negatively impact the survival of the species.��

In the case of the 22 wild elephants, no non-detriment findings have been made public from either Namibia or the UAE, as these would have certainly triggered scientific challenges of the conclusions reached.��

Several animal welfare and conservation groups have independently sought legal opinions regarding whether the wild elephant sale was illegal under CITES provisions, which are binding for member states.

������ obtained a copy of an opinion submitted by Cullinan & Associates, an environmental law firm, on behalf of EMS Foundation, a South African animal welfare group. Lawyers came to the conclusion that, given that the elephants likely came from the desert-adapted population, both Namibia and the UAE, “could not reasonably be satisfied that the proposed export of such a large number of animals would not be detrimental to the survival of the species.”

The legal opinion therefore concluded: “We do not believe that it would be lawful for the Namibia CITES Management Authority to issue an export permit under either Appendix I or Appendix II of CITES. Similarly, we do not believe it would be lawful for a country outside of the range of states for Loxodonta Africana [i.e. African elephants] to issue an import permit.”

Another legal opinion to CITES for consideration in March concludes that, “any previous or future export of live wild-caught elephants from Namibia to a destination outside the natural range of the species … does not comply with the provisions of CITES.”��

In response to this investigation, CITES spokesperson David Whitbourn asserted that, “the [CITES] Standing Committee considered the issue and did not feel that there was sufficient evidence of non-compliance…for it to take action.”

The 19th meeting of the Conference of the Parties (CoP) to CITES is scheduled to take place in Panama City in November, and regulations governing wild elephant trade are on the .

While all parties involved claim that the trade was legal and done with the wellbeing of the elephants in mind, international guidelines were clearly flouted, and involved parties were likely aware of this.

“If this whole transaction was ostensibly legal as Namibia and the UAE claim, then why was the whole thing very clandestine? It was done under this cloud of secrecy… clearly something was done that they knew wasn’t quite right,” said Cruise, the environmental investigative journalist.

"'If this whole transaction was ostensibly legal as Namibia and the UAE claim, then why was the whole thing very clandestine?'"

Split up families and succumbed calves?

In the Namibian ministry’s original tender, it specified that successful bidders would have to capture an “entire herd as per lot size and not leave infants/juveniles behind”. Government officials and pro-trade conservationists place great emphasis on this requirement as an indicator of the importance of animal welfare during the process.��

“That requirement was an ethical one. The ministry didn’t want small elephants being taken and shipped to zoos, they wanted whole herds being taken at once,” said Thomson, the consultant with the Namibian government.��

Thomson said that the likelihood of a member of a family unit being left behind was “very very small” since elephants of a herd tend to bunch together when threatened.��

Cruise, however, contested this and explained that even though elephants group together, “there's always a very good chance that they forgot a few of them…that they left a few behind.”��

At least one member of the herd was reportedly left behind. The owner of a farm, next to where the group was captured, told ������ that a large bull was left there alone because it could not fit in the transport container. There have been no reports on the condition or well being of this abandoned bull.

Gerrie Odendaal, in an , spoke about a young elephant among the group that “seems to be an orphan,” as it “does not associate closely with any of the adult females.” He assumes that this must mean that its mother had been “killed some time” before the capture. However, he gives no reason why he came to this conclusion, as opposed to having missed the mother in the capture operation, separating it from its calf. This would have contravened the rules of the tender.

Rudie Van Vuuren, a conservationist who relocated the other 15 auctioned elephants within Namibia, explained to ������ that when he had captured his elephants, his team had done lots of scouting work to determine family groups.��

Once they had captured the elephants, they took blood from each to do DNA testing and determine family relations. Van Vuuren said that the blood work was given to the MEFT. However, when speaking with ������, the MEFT’s Muyunda could not recall the existence of any DNA records.

What is known is that the UAE-bound group of 22 elephants were captured in Kamanjab and taken in trucks on an eight hour overnight trip to Odendaal’s quarantine facility. From there, the number of elephants being transported becomes difficult to confirm.

������ has heard from multiple industry sources that there are rumours about what happened to the at Odendaal’s facility: Several sources believe that they died after being subjected to powerful sedatives during transportation, or that they were separated from their mothers during the transfer and then rejected upon reuniting.��

If they were born in captivity, Cruise believes it would have been extremely irresponsible to transport them at such a young age, and that the chances of them dying would be “almost certain”.��

Muyunda, when asked about these calves, could only confirm that “none were left behind.”

If calves or heavily pregnant cows were flown, this would most likely be in contravention to the CITES transportation rules: the advice for carriers guidelines that “pregnant animals, or animals that are still dependent on their mother” are not fit to fly.��

As is often the case though, CITES regulations provide for “exceptions”, including for females of species that are “pregnant for most of their lives and it is, therefore, not practicable to avoid shipping them when they are in this condition”. This might be exploited as a loophole, given that African elephants’ gestation period lasts for 22 months and they usually every four years.

CITES guidelines for non-air transport, which would apply to the elephants captured by Odendaal and transferred to his paddock, are more stringent though. “A pregnant female for whom 90% or more of the expected gestation period has already passed” is not considered fit for transport.

CITES is also clearly opposed to sedation, whose “side-effects are still not fully known and, furthermore, animals that are in a lethargic state are very vulnerable to injury if violent movement of the aircraft, ship, lorry or train is experienced”.

Exceptions are allowed, but “a qualified veterinarian should normally accompany the animal.” Neither the Namibian nor the Emirati authorities provided any evidence as to whether a veterinarian had accompanied the elephants.

In an interview with Gail Thomson, Odendaal he was in “constant contact” with vets while the elephants were “in his care.” However there is no mention of precisely when his care ended. ��������attempted to contact both Odendaal and the vet who had been reportedly present during the capture, to verify if a vet had accompanied the animals while they were flown to the UAE, but received no response.

CITES spokesperson David Whitbourn did not respond to queries on the potential violation of the aforementioned transport guidelines and deferred discussions on the elephant trade to the CoP meeting scheduled in November.��

"'To enclose an elephant in anything beyond its natural range is total cruelty'"

International action needed

When ������ visited the Al Ain Zoo in late August, the facility was empty with very few visitors. Under the scorching heat the zoo had come to resemble a desert, covered in sandy hills. There are wells that are filled with water every morning, but by late afternoon they appear to have dried up.

Driving around in the air conditioned SUV, stopping to feed carrots to ostriches and giraffes, the animals - antelopes, zebras, rhinos, and lions - appeared to be panting, congregating and hiding from the heat under the shade. Once they are on display, these are the conditions the Namibian wild elephants will encounter.��

“To enclose an elephant in anything beyond its natural range is total cruelty, especially if it has grown up in the wild,” said Cruise.

One of the most concerning elements of this deal is that it points to a growing demand in the UAE for wild animals, taking them from their natural habitat and putting them in captivity, not for conservation as they claim, but for personal and public pleasure and status, as well as a willingness to meet this demand from certain nations home to African elephants. The Sharjah Safari Park alone can host up to 50,000 African animals.��

This deal likely is one of several before it, and unless the inadequacy of international regulations and oversight mechanisms is addressed, it's likely there are many more to come.��

EAZA’s decision to end the membership of the Al-Ain Zoo was a step in the right direction, but the road ahead is still fraught with loopholes and complicit institutions. International spotlights are now on CITES to adopt more stringent measures in their summit in November.������

Matteo Mazzoleni contributed to this investigation.