6 Medlaurst Close Claobhana,
GU24 8PA t*44)7788 4040940
Via email and post: email@example.com
Palais des Nations
Avenue de la Paix 8-14 1211
Genève 10 Switzerland
21 February 2020 Dear Sir/ Madam,
Complaint: Import of 18 Chimpanzees from South Africa to China in breach of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (the Convention)
We act for Karl Ammann, renowned wildlife photographer and film maker. We are writing to you by way of complaint in relation to breaches of the Convention by China, as a contracting party, involving the importation of 18 chimpanzees.
We ask that the Secretariat immediately investigate and take action to prevent this illegal trade, in recommending the suspension of all trade in chimpanzees involving China until safeguards are in place. We are instructed that a further chimpanzee transfer is expected from South Africa to China within the next one to two months.
There is a history of unlawful imports of chimpanzees into China, as illustrated by investigations carried out by our client, for example evidenced in a 2016 documentary film.
The complaint is made on the following Grounds:
- The chimpanzees do not meet the definition of ‘bred in captivity’
- Destination not suitably equipped to house and care for the chimpanzees
- The chimpanzees are to be used for primarily commercial purposes
- No finding that the import of the chimpanzees will not be detrimental to the survival of the species
- If the chimpanzees were bred in captivity it was for commercial purposes and therefore requirements under Appendix II were not met
- Chimpanzees were flown contrary to CITES transport rules
The facts are as follows:
In August 2019 eighteen (18) chimpanzees were imported into China front South Africa to a zoo facility entitled ‘Beijing Wild Animal Park’ (also known as ‘Beijing Wildlife Park’ according to Google Maps, and media reports). The zoo is registered under the company name: ‘Beijing Green Landscape Zoo,’ and understood to belong to ‘Beijing Tourism Group Co. ltd,’ which in turn belongs to the Government.
Undercover investigations have revealed concern as to the suitability of the housing and care of the chimpanzees, as set out at Ground 2 below; as well as details surrounding profits that the zoo expects to make, as set out at Ground 3, below.
The import permit and the export permit both used the Purpose Code Z and the Source Code C. This means the alleged sourcing of the chimpanzees was ‘animal bred in captivity in accordance with Resolution Conf 10.16 (Rev.) …exported under the provisions of Article VII, paragraph 5’ [Resolution Conf. 12.3 (Rev. CoP17)]; and the alleged intended end use was for a zoo. We challenge the use of both of these codes.
We attach and exhibit copies of the permit documentation sourced front an official in South Africa (annexed at pages I to 6), also summarized below:
A one page document signed off on 3 July 2019, with an expiry date of 2 January 2020, and entitled: ‘export permit/ certificate’ (annexed at page 1). This document lists the importer as ‘ Beijing Green Landscape Zoo’ (China), and the exporter as ‘Snake & Animal Park’ (South Africa). The permit refers to 18 live chimpanzees as Appendix I species; and specifies Purpose Code Z, and Source Code C.