To be published as HC 1740-iii

House of COMMONS



Environmental Audit Committee

Wildlife Crime

Wednesday 18 April 2012

Grace Ge Gabriel

Richard Crompton

Evidence heard in Public Questions 159 - 203



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Oral Evidence

Taken before the Environmental Audit Committee

on Wednesday 18 April 2012

Members present:

Joan Walley (Chair)

Peter Aldous

Richard Benyon

Neil Carmichael

Martin Caton

Katy Clark

Zac Goldsmith

Mark Lazarowicz

Caroline Lucas

Ian Murray

Sheryll Murray

Caroline Nokes

Mr Mark Spencer

Paul Uppal

Dr Alan Whitehead

Simon Wright


Examination of Witness

Witness: Grace Ge Gabriel, Asia Regional Director, International Fund for Animal Welfare, gave evidence.

Q159 Chair: Thank you very much indeed for coming along this afternoon, Grace. I think we have quite a few detailed questions that we want to get through, and we are also expecting a vote in the House of Commons at 3.50pm, so for your convenience and that of the following panel, we shall have our eyes on trying to finish by 3.50pm. That perhaps just might be helpful to everybody here.

We would just like to go straight into the questions. In the evidence we have already taken we have heard that a key factor in the decline of the tiger, rhinoceros and elephant in the wild is increased demand for wildlife products in China. We want to have the benefit of your experience as to how much China is the main source of demand for such products, how much we perhaps need to understand that aspect of it, and how much priority our Committee report should give to that. It would be very helpful if you could elaborate on that for us, please.

Grace Ge Gabriel: Thank you very much. The use of tigers and rhinos in medicine and the use of rhino horn and ivory for decorative carvings is a tradition in China. The ingrained belief in traditional medicine is shared by many countries in the Asia region. China led the way in becoming the economic powerhouse in the region, and this economic growth created a class of extremely wealthy consumers. Much of the new wealth created in that region was created in a quick and dirty way. In fact, some of the people with that wealth may have made their money from smuggling different kinds of contraband, ranging from cigarettes and drugs to timber to weapons, and now they are engaging in wildlife; the rarer the endangered species, the higher the price. This is the situation currently in China. The economic growth and the conveniences afforded by the internet trade, technological advances and the ease of transportation with connecting flights between Asia and Africa and anywhere else in the world are giving the illegal trade an easy way to conduct business in China. Also, I would like to point out that there is a lack of awareness about the conservation of many of these species because of that ingrained belief in their use in medicine and in carvings.

Q160 Chair: That is interesting. Given what you refer to as the centuriesold tradition and the wealth that now exists, which is encouraging greater takeup of carvings, is there much of a difference between what is carved and what is used for ornamentation as opposed to what is actually consumed when looking at the overall problem of trade in endangered species?

Grace Ge Gabriel: Are you talking about ivory or rhino horn or what?

Chair: Particularly in terms of ivory.

Grace Ge Gabriel: Okay. Ivory is mostly only used for decorations. They are carved for ornamental use, and one of the trends we are seeing is an increasing demand for elephant ivory. Some of the wildlife species that were traditionally used in traditional medicine are now collectibles, antiques. They are promoted as investment. This is a very dangerous trend. The demographics of people who consume wildlife products for traditional medicine as opposed to the people who consume it for ornamental art, to collect it and stockpile it as investment, are different.

I want to give you an example of trade. One of the auction newsletters that I have seen cited an increase in this investment trend in ivory and rhino horn. The auction records in 2011 show that 2,750 pieces of rhino horn carving were sold in mainland China, total sale price US$18 million, which was an increase of 90% and 111% respectively.

Chair: That is huge.

Grace Ge Gabriel: The pieces and the total sale price. This is huge.

Chair: It is huge.

Grace Ge Gabriel: This is only in the last two years.

Q161 Chair: You talked just now about education. Do you think that there is awareness among those who are using their wealth to buy these products of the damage and danger to endangered species?

Grace Ge Gabriel: There are two types of people involved. One is incidentally engaging in the trade and they may not know, and the other people are the hardcore criminals who are getting high profit margins from this illegal trade. In fact, IFAW did a poll in China where we found seven out of 10 people do not even know ivory comes from dead elephants. In Chinese, ivory-xiang ya-is translated as elephant teeth, so people think teeth can fall out naturally. We developed a public awareness campaign basically using this concept, reminding people that babies having teeth should be a joyous occasion for the mother. However, for elephant families having teeth means slaughter, it means killing, destroying families and hundreds of thousands of elephants. I think these types of public awareness campaigns, pulling on people’s heart strings, are making an impact. For instance, the PSA that we produced is currently being adopted into an animal welfare curriculum for schools from elementary school to universities, and also that PSA was adopted in Chinese college entrance exams. But that type of PSA can affect the hearts and minds of people who did not know and who happen to buy a piece of ivory, but now they do know. That includes some ivory carvers who wrote to us and said they will not carve now that they know the facts.

But there are people in China, the class with extreme wealth, who did not make that wealth the right way, the correct way, and those are the type of people who may have connections with criminal syndicates. They have power, they have connections. They often have anonymity, and they may order ivory, large shipments of ivory, from Africa on the internet or via the phone. They are conducting this illegal trade and hiding behind it.

Another very important factor in this rising demand is that in the past few years ivory prices in China, in Chinese money, which is RMB, have tripled; in the past six years since CITES approved the oneoff sale, the stockpile sale to China, the ivory price in China has tripled. During the same six years the Chinese yuan gained value against US dollar. That means that if the Chinese buy ivory anywhere else in the world, they have to buy it in US dollars. For the Chinese, that makes buying ivory anywhere else in the world cheaper and the profit margin on that ivory, once it is smuggled into China and sold on the market-it is very easily sold illegally on the market because it is covered by the legal trade-is huge. That is a great incentive for people who are engaging in this illegal trade.

Q162 Chair: You mentioned the legal trade, and it would be helpful to the Committee to know whether or not trade in ivory, tiger bone and rhino horn is legal or illegal. We sense that it is not quite straightforward; it is not quite black and white. Could you elaborate on that for us, please?

Grace Ge Gabriel: Tigers and rhinos are both listed on CITES Appendix I, and their international commercial trade has been banned for many years. There is legislation in all of the tiger range countries in Asia to ban domestic tiger trade. In China, it is the same. In 1993, China’s State Council banned tiger bone and rhino horn from use in traditional medicine and basically banned its domestic trade. China has a wildlife protection law that covers hunting and poaching tigers in the wild but it does not cover trade. The State Council banned tiger bone and rhino horn trade, but China has a wildlife policy which states that it basically encourages and promotes captive breeding of tigers or captive breeding of any species, including endangered species, for the trade of their parts. This creates a big conflict within China’s policy. On the one hand there is a trade ban, but on the other the policy allowed many business men to breed tigers; for instance, thousands of them were bred on these tiger farms solely for the trade of their parts and derivatives. Because of that very confusion, that trade stimulates demand and fuels poaching of tigers in the wild. This trade has created so much concern within CITES that CITES parties at its Conference of Parties in 2007 made a decision that specifically stated that countries should not breed tigers for the trade of their parts and derivatives.

Q163 Chair: That is helpful, thank you. Finally from me, how effective is wildlife crime enforcement in China?

Grace Ge Gabriel: The wildlife enforcement-effective enforcement-has to be aided by clear policies and laws. As I stated, unclear laws and policies send the wrong message to the public and create enforcement difficulties. In terms of legal versus illegal, it is very murky for a consumer, for instance. On the one hand, they thought tiger bone is banned but, on the other hand, they can buy tiger bone products on these farms. That is confusing. For elephant ivory, CITES had allowed the stockpile sale of ivory. Basically, China imported 62 tonnes of ivory in 2008 from this stockpile sale, so China has a legal ivory market. All these are creating enforcement difficulties, because even law enforcement officers could not distinguish what is legal from illegal, whether this tiger bone comes from the wild or has it come from a farm.

Also, in fact, there are some law enforcement actions China has taken that demonstrated that a trade ban can be effective. For instance, China now has an online population of 500 million people. Five hundred million people are online and some of China’s websites, ecommerce websites, are bigger than eBay. The users of those ecommerce websites are bigger than eBay. The Chinese Government has worked with NGOs and online websites to ban trade in many of these endangered species. Currently, China’s largest online website, taobao.com, which means treasure hunt, has trade to do with tiger bone, rhino horn, elephant ivory, bear bile, turtle shell, pangolins and shark fin. We have seen websites that have the ban are a lot more effective in controlling the trade. For instance, in January this year in one of the online monitorings, we monitored Taobao and many other wildlife ecommerce and collection websites. At most we found 200 sites that have the trade ban-some had zero, no wildlife-but the sites without the ban reached 12,000 listings of endangered species.

Chair: Mark Spencer is just going to probe a little bit more on CITES.

Q164 Mr Spencer: It has been suggested that South-east Asia has been stripped of wildlife by the legal trade meeting the demand of exotic pets, if you like, in Europe and Japan. Could you compare the impact of the legal trade and illegal trade.

Grace Ge Gabriel: When it is legal trade perhaps it is possible to obtain records of it, but there is no way of knowing the size of the illegal trade. But what we are seeing is the impact of both this legal and illegal trade. One of our concerns is that legal trade provides a smokescreen for illegal trade to be conducted.

Q165 Mr Spencer: What sort of volumes are we talking about in terms of the number of animals that are being transported across to Europe and Japan? Have we any idea of the volume?

Grace Ge Gabriel: I don’t have the figure specifically, but we can probably obtain these figures from the CITES website, for instance. However, there is no way of knowing the size of the illegal trade.

If I may, let me cite one example-a guy named Anson Wong. He is probably the world’s most wellknown reptile trader, and he is a kingpin, actually a wildlife criminal. He has a legitimate business in Malaysia selling reptiles, legal reptile trade, all over the world. However, using his business connections and permits, he has been repeatedly found engaging in illegal trade. His most recent arrest and conviction in Malaysia was after he attempted to smuggle reptiles, 95 boa constrictors and vipers and turtles, through Kuala Lumpur Airport to Jakarta in Indonesia. Just incidentally, the lock on his suitcase broke, and all his wildlife contraband spread out on the conveyor belt. That is how he was arrested and convicted. But this criminal unfortunately only served 17 months of his fiveyear sentence, and he is walking free. That shows that these type of people are able to go free because they have power, money and connections.

Q166 Mr Spencer: How effective is CITES? If an animal suddenly becomes fashionable in another part of the world, how reactive is it to dealing with that sort of demand? Can it react in time to protect that species?

Grace Ge Gabriel: It depends a lot on the country where the animal comes from and also on the country where the demand for this animal is. For instance, the turtle trade has been one of the leading trades in Asia and, in fact, China proposed over 20 species of turtles to be listed on CITES. If this trade volume reaches unsustainable levels, it is up to the countries, based on signs, to raise the alarm and bring these species to the attention of the international community for their protection.

Q167 Mr Spencer: Of course, at the moment there is a list of animals that cannot be traded. I wonder if you think whether that is the wrong way round, whether we should actually have a list of animals that can be traded so that the list does not have to react because if the animal is not on that list, it cannot be traded.

Grace Ge Gabriel: Well, unfortunately, we are in the situation now where we have to react and react quickly. Many of the species that are listed-33,000 species listed on CITES, for instance-because they were heavily traded in international trade. They are listed to protect them from extinction; we have to control that international trade.

Q168 Mr Spencer: You mentioned you have to react. Whether that reaction is quick enough is, I suppose, the core of the issue.

Grace Ge Gabriel: Of the species that are currently on CITES, I think there was only one species that became extinct after it was listed on the Appendices, which was Spix’s Macaw. But other than that, the species that got listed on CITES have not disappeared yet, and we hope that that will remain that way.

Q169 Paul Uppal: We are speaking to you because we have looked at the whole issue of tiger farming, and you spoke about this in terms of the decision in 2007 specifically, the CITES decision, about the whole idea of farming tigers and keeping them captive. It seems a bit of a crazy concept, really. This is perhaps a difficult thing to think about, but given the tiger population at the moment of between 3,000 and 4,000, do you think that perhaps, thinking outside the box, tiger farming may be the least worst option that we can consider in terms of the demand that is driving this trade and the pressure it is putting on the tiger population? I know it is a difficult thing, but what is your take on that?

Grace Ge Gabriel: Well, farming tigers for the trade of their parts stimulates demand and fuels poaching of tigers in the wild. If we do not care that the remaining 3,000 to 4,000 tigers go extinct in the wild, yes, what you are saying may be okay, but can we accept that? I do not think we can as an international community. This species is a charismatic species that has been the king of the jungle I think for Asians-I think for Africans probably the lion is the king of the jungle, but for Asians tiger is the king of the jungle. They keep the ecosystem in check by being the king of the jungle. I have worked on tiger issues a lot and I have seen the tiger farms as well. The way they are doing it means-and being Chinese, I know it-it costs a lot more to raise tigers in a farm. It costs thousands of dollars to raise a tiger to maturity for the trade, but it costs very little to kill a tiger in India or Thailand. With this discrepancy, it will always be cheaper to sell tiger from the wild.

Also, I know that when Chinese consumers want to consume tigers or any other endangered species for medicine, they want it from the wild. I have research to prove that, too. If you allow farmed tiger to be traded, again it confuses consumers, it creates law enforcement difficulties and it stimulates demand. The fact is that the use of tiger bone and rhino horn have been banned by the Chinese Government and that demand has reduced since the ban. There was a survey done in 2006 visiting 523 traditional pharmacies in 12 cities in China, and only 11 shops said they have tiger bone to fill a prescription that has tiger bone as an ingredient. Only two shops were able to really produce tiger bone. The official traditional Chinese medicine community has stopped using tiger bone for the past nearly 20 years, and tiger bone was removed from official pharmacopeia. It is also removed from TCM college curriculum, and the demand is being reduced. However, what we are seeing is these farms stimulate that dying demand in China.

Q170 Paul Uppal: I just want to reassure you, Grace, that I have a very strong emotional attachment to tigers as well. I know you spoke about that as well. I was just asking a very awkward question. You just touched on the issue of the conditions. What sort of conditions are these tigers kept in?

Grace Ge Gabriel: China does not have animal welfare legislation, so there is no law to prevent the abuse and cruelty to animals once they are in people’s hands. Many of these tiger farms actually also run as safari parks, as zoos and circuses, so they have circus performances in the parks. Because there is no law and no welfare standards, animals are deprived of the opportunity to follow their natural behaviour. Tigers are solitary animals, but they are housed in large groups together and in barren enclosures. If there are trees, the tree trunks are covered with metal so that tigers will not claw on the bark. Also, to get tourists to pay for tiger food, many of these parks run a show called live feeding. They basically ask tourists to buy livestock, chicken or cow, to feed the animal. In order to attract tourists to buy livestock to feed tigers, they actually let tigers go hungry. They are so starved that they will go into the enclosure for that prey species. Also, to entertain visitors, animals are trained to perform circus acts, such as tigers jumping through fire rings or bears riding on a bicycle. I have seen tigers have teeth and claws pulled and chained to the ground for people to climb on their back to take pictures with them.

Q171 Paul Uppal: I remember there was a piece, I think it was in the Mail, a few years ago-I cannot remember-which described how livestock was actually just thrown into the pen for tigers. Do you think there is anything we can do to highlight the matter, particularly some of the conditions? I have only seen coverage in dribs and drabs in the media. Do you think we as a Committee could do more to focus on that by highlighting those conditions?

Grace Ge Gabriel: Other countries, and Chinese citizens, should ask China to introduce animal welfare legislation to prevent cruelty to animals. In fact, this effort has already been started in China. A few years ago, IFAW and RSPCA helped China’s Academy of Social Sciences in a research project and drafted the first version of China’s anticruelty legislation, but what we need is Chinese citizens realising the cruelty and abuse of animals and not tolerating that, and then voicing their opinion to China’s legislature in asking China to put that anticruelty law into the legislative plan. That is what we are trying to do.

Q172 Chair: Do you think our Committee could help you in any way in that?

Grace Ge Gabriel: Perhaps I can help draft something in written form for the Committee to consider.

Chair: If you wanted to submit anything further, we would be very happy to receive it.

Q173 Martin Caton: You just gave a very positive report about how legislation in China had reduced the use of tiger bone products in the pharmacies in China. Do you have any idea of what proportion of illegally trafficked wildlife products in Asia is still for traditional Chinese medicine?

Grace Ge Gabriel: Yes, traditional Chinese medicine is composed of three types of ingredients: plants, minerals and animals. In fact, animal ingredient in traditional pharmacopeia constitutes only 3% and that includes wildlife and also domestic animals. It is not a very big ingredient. Also, TCM use of wildlife or animals is really based on availability. Three thousand years ago when there was no other type of medicine, a doctor may have used a tiger bone to treat rheumatism or he found that a rhino horn ground up could reduce fever, but all these illnesses and diseases have alternative treatments now. Also, when these products become unavailable, TCM practitioners are already shifting to some of the alternatives themselves. They have to just out of necessity

Q174 Martin Caton: So the market actually directs them to find alternative substitutes. Do you as animal welfare campaigners need to try to persuade the practitioners to find alternatives?

Grace Ge Gabriel: We did and we have funded alternative research for TCM practitioners. We have also done surveys of TCM, what type of ingredients they are using to replace other products. In fact, one of the pieces of research that was done-IFAW funded the research, but it was done together with Middlesex University, Kew Gardens and Defra in the UK, and a report should be available in English-was looking at plant substitutes for tiger bone, rhino horn and bear bile.

To answer your question, one of our concerns is that while we see the demand for TCM use of wildlife is reducing, the other demand for even some of the products that were traditionally used for TCM are now being promoted as an investment, including rhino horn. We are seeing the auction prices of rhino horn-these are all carvings. For instance, last year Hong Kong Customs seized 33 rhino horns, the whole rhino horn. If they are going into China, they are not going into medicine; they are going into carved artefacts and collectibles for investment.

Q175 Dr Whitehead: On that subject, we heard evidence a little while ago that rhino horn in particular, and indeed other wildlife products, are literally becoming stockpiled as their scarcity value increases, presumably, therefore, with a view to not just investment but speculation for release in the market at a future date as scarcity increases. Do you have any evidence of that from your researches and findings?

Grace Ge Gabriel: We are monitoring the physical markets, which include auction markets, collections, shops, galleries, and we are also looking at online wildlife trade. Indeed, in the last few years we have seen an increasing amount of rhino horn carvings. The price that I just mentioned, the 2,750 pieces of rhino horn in trade and the price increase of 111%, these are all indications of people, in fact, buying rhino horn for investment. Another piece of data: one of the auction newsletters actually claimed that due to the rising demand of rhino horn and ivory carvings, an investment bank in China has established an investment fund focusing on the trade of rhino horn and elephant ivory. I only saw this auction newsletter in March, so we have not looked deeper into this investment fund, but this type of investment and the promotion of the product as investment continues to raise its value. As its value rises, more people want to buy it and probably hold it, waiting for the species to be extinct and what the price will then be-they have cornered the market. This is the kind of fear that we have for many of these species, for rhinos and elephant ivory.

Q176 Dr Whitehead: We talked about the use of rhino horn and other products in traditional Chinese medicine, but we have also heard of more recent upsurges in beliefs of the efficacy of various products, particularly rhino horn as a cure for cancer in Vietnam. Is your understanding that that belief is gaining currency, and what efforts have been made to tackle that particular rumour/belief through outreach programmes, education and so on?

Grace Ge Gabriel: Well, as far as we know it is a rumour. All of the NGOs that work in the region could not find the origin of the rumour. But I believe the ingrained belief about rhino horn use in traditional medicine runs deep in many of the cultures in Asia, so it is not surprising that somebody would come up with that rumour. It could be somebody trying to jack up the price using that rumour. In fact, Vietnam lost its last Javan rhino last year, only last year. Now wildlife crime syndicates are buying up rhino horn from around the world. Just recently I heard that South Africa, for instance, lost 448 rhinos last year versus 333 in 2010. Up until today, this year, 171 rhinos have already been killed in South Africa and most of them in Kruger National Park. One of our other fears is another rumour that South Africa is going to propose to legalise rhino horn trade. If elephant ivory trade is any indication, legalising rhino horn trade is going to spell disaster for this species.

Chair: Final question to Zac, and we do have one eye on the clock now, Zac.

Q177 Zac Goldsmith: Yes, okay, I am going to be very quick. You mentioned earlier the ecommerce sites that have removed these things from their inventory. Has that led to a noticeable and measurable reduction in that sector or not?

Grace Ge Gabriel: Yes, it did. When taobao.com banned these products, we then repeatedly checked the websites, and we have seen a significant reduction.

Q178 Zac Goldsmith: I am sorry to rush you. Are there signs that the other sites, the other big competitors, have been encouraged to do the same and is there any pressure being applied by consumers or campaign groups?

Grace Ge Gabriel: Yes. In addition to the e-commerce sites, currently about seven or eight big collection websites have banned wildlife products. Just last month, China’s largest search engine, baidu.com, which has many forums-they call them bars, but they are like forums-banned and completely removed 13 forums that are selling wildlife products. They removed more than 30,000 listings.

Q179 Zac Goldsmith: On the UK Government and its potential role, we provide some funding to Interpol initiatives and a couple of examples we have here are Project Predator, which targets the illegal trade of tiger products, and Project Wisdom, which targets the illegal trade in ivory and rhino horn. Can you tell us, first of all, how effective you think that those two and other Interpol schemes are in the big scheme of things?

Grace Ge Gabriel: Interpol operations can be very effective. Interpol is able to mobilise law enforcement agencies in countries beyond just the wildlife departments in fighting wildlife crime in a collaborative way. By doing so, it elevates the priority level for wildlife conservation in that country. The recent Operation Worthy, which was mentioned in the Panorama programme, was actually funded by IFAW. It was organised in 14 African countries targeting illegal ivory trade and it is sending a strong message to the consumers around the world that wildlife crime is not tolerated. It is also collecting very good intelligence on the illegal crime. Also, one of Interpol’s projects called EcoMessage is helping to collect intelligence on wildlife criminals. When information on wildlife criminals is entered into the database it can be compared to see if those individuals have linkages with other crimes, which is very important.

Q180 Zac Goldsmith: I think this is the final question, and I am lucky enough to have it, but it would be useful to hear from you, as a sort of final statement really, what the British Government can do most usefully. What are the most effective things the British Government can do, addressing all the concerns that we have heard about today in addition to our financial support for various Interpol schemes? What would be your message to the British Government? Where are we lacking and where should we be more bullish? What should we do?

Grace Ge Gabriel: I think strengthening laws and regulations to control wildlife trade on the internet is one of the things, because it is so global now. The demand may be in China, but the buying could be here, could be happening in the UK. We are seeing some of the auctions happening in the EU are selling wildlife and the products are bought by consumers in Asia. Also, we would really like the UK to take a leadership role in opposing any ivory stockpile sale or the sale of any endangered species for which the demand is rising. It is very, very dangerous when this floodgate is opened. One other ask is to make those who commit wildlife crime pay. We really need to make wildlife criminals feel that their business is a high-risk, low-profit business. Currently, it is a highprofit, lowrisk business.

Chair: On that point, Grace, I think you have brought a great deal of both clarity and compassion to the session we have had this afternoon. We must move on, but may I thank you and we look forward to receiving the further written evidence that you referred to. Thank you very much indeed.

Grace Ge Gabriel: Thank you very much.

Examination of Witness

Witness: Richard Crompton, former Wildlife Crime Lead, Association of Chief Police Officers, gave evidence.

Q181 Chair: Mr Crompton, thank you very much indeed. I think you have just sat in and listened to the earlier session, so we will perhaps carry on where we have just left off, if we may. To begin, thank you not only for the written evidence that you have submitted to us and for the work that you have done in your role as lead officer, but for coming back from retirement to give evidence today. What I hope is that it perhaps might make you a little bit more lucid in perhaps pointers for the future and lessons that can be learned.

Richard Crompton: Of course.

Chair: I think that the evidence that we are getting gives us the feel that we are at a bit of a critical time in terms of what the future direction of policy is going to be and, more importantly, what manner of resources are going to be committed and how those resources are going to be balanced between the various parts, if you like, of cross-cutting work between Defra and the Home Office. I think we would just welcome you to start us off in this second part of our inquiry, which will end at 3.50pm I have to say, by perhaps giving us a feel of how much Governments of the day, the previous Government and this Government, have committed the amount of resource that is needed to deal with all aspects of this, including the work with Interpol as well.

Richard Crompton: Okay, that is a huge question. I will try to do my best. I became the ACPO lead for wildlife crime about three years ago. Before that I had absolutely no connection with this world at all, so I am talking from my experience over the past three years.

In terms of Government support, and in terms of interest among members of the Government, both the current Government and the previous Government expressed very great interest. Bluntly, there is a huge amount of public interest in this area, so perhaps that is not surprising. But the subject of wildlife crime, the breadth of wildlife crime, is huge. We have just been hearing from your previous witness about perhaps the most serious end in terms of conservation and some of the most, I suppose, eyecatching examples of wildlife crime as well, but there is another end of the spectrum, which is the day-to-day work perhaps of force wildlife crime officers, which is frequently as much about welfare issues as it is do with conservation. I think different Governments and possibly different individuals in Governments have had more or less interest in those various aspects of wildlife crime.

In terms of practical support, however, both the previous Government and this Government through funding from the Home Office and from Defra have been supportive. For what is I have to say a very small amount of money in general terms-

Q182 Chair: Should it have been a bigger amount of money?

Richard Crompton: I don’t suppose you would find any chief or ex-chief who said, "No, don’t give me any more money". Most certainly I could have done with twice the amount of money that was given to wildlife crime. But I have to say that for a relatively small amount of money both British policing and the Government and other partners got a fair amount of bang for their bucks because the money was spent on the National Wildlife Crime Unit, which has been instrumental, I think, over the past few years in really raising the profile of wildlife crime, the importance of wildlife crime, in British policing and coordinating work, much in the way that your previous witness was talking about internationally, across the forces of the UK and actually to a significant extent playing a coordinating role internationally as well; so, for a relatively small amount of money, it was quite a big return.

Q183 Chair: Has there been a change of emphasis since the Coalition Government came in, would you say, or not particularly?

Richard Crompton: I think possibly the answer is yes, if I can express it in these terms. The money has stayed the same, so we have no more or no less money. The level of interest has stayed roughly the same, but I think the most significant change certainly that I saw in the early days of the new Government was expressed in the Coalition Agreement. I was very taken aback and very pleased to see that wildlife crime was specifically mentioned within that agreement as a priority issue for the border element, as it was then expressed as, of the National Crime Agency that is currently in its inception. I think to have it registered at the national strategic level signalled a significant change in policy direction. I think it has to be said that my understanding of that particular level of interest relates understandably to the illegal trade in endangered species, as opposed to some of the other welfare aspects of wildlife crime that I have referred to.

Q184 Caroline Nokes: The Committee has received some quite interesting written evidence, and certainly as a constituency MP in a rural area I have also had reports from local farmers about wildlife crime that has been both unintentional, people disturbing ground-nesting raptors, disturbing spawning grounds for salmon, but also the intentional, where they is illegal hare-coursing and poaching. The written evidence to us has been that although police forces have been enthusiastic and good to respond, they have not necessarily had the right equipment or training to deal with specific aspects of wildlife crime. In your view, does the average police officer have the right equipment, and have they had enough training to address some of these issues?

Richard Crompton: Can we talk about training first of all, and then perhaps get on to equipment? No doubt we will talk further about legislation at some point today, but wildlife crime legislation is a labyrinth of fairly old legislation and very complex legislation, and the truthful answer to your question is the average cop out there has a rudimentary understanding of that at best, probably based upon a half an hour or an hour’s lecture that was given many years ago in a classroom somewhere during their initial training. However, the fact that virtually every force in the country has wildlife crime officers who receive very significant levels of additional training helps to address that. So, for example, if a police officer was called to whatever, just a run-of-the-mill incident in a force area today, they would have at the other end of the phone, the other end of a radio, possibly on their way out to assist them, somebody who was trained and experienced to give them perhaps the extra advice that they would need.

I can certainly envisage maybe your constituents being frustrated by that from time to time perhaps, because of the time it has taken to bring these people together or something of that nature, but I think it would be probably unrealistic-well, undoubtedly unrealistic-to expect every police officer in the country to have the sort of knowledge of wildlife crime procedure, legislation and so on that the specialists have, but that is a model that you see in many other aspects of policing as well, where specialists assist generalists with their additional knowledge.

In terms of equipment, I am not quite sure what-

Caroline Nokes: The specific point made in terms of equipment was that if you are dealing with poachers, is the best solution to send a bunch of coppers in hi-vis jackets after them?

Richard Crompton: Right. We did suffer from hare-coursing in Lincolnshire, and what was frequently said to me was, "Why aren’t they all in 4x4s so they can chase people across muddy fields?" and what have you, and to a certain extent of course forces do have that equipment, but it is limited. In terms of hi-vis jackets for hare-coursers and what have you, without getting into the detail of how you would deal with that sort of incident, routinely what happens in a force where there is a problem with hare-coursing, which absolutely I understand is of huge concern to farmers and people in rural communities, is that there will be some sort of force-wide operation in place to get officers to the scene, but also to put officers on checkpoints around the county to try to identify, stop and arrest perpetrators of that crime as they move away from the often quite isolated areas where the crime is being committed. But it is the age-old problem of-and I will use Lincolnshire as an example, because it is a good example in relation to hare-coursing-a massive county with not enough officers to be spread liberally across that county, so they have to use them at strategic points to enable us to do anything about that sort of crime. I can understand why a farmer would perhaps expect to see people turn up in a van and a dozen people pour out five minutes after they have phoned. Sometimes that is just not possible, I am afraid.

Chair: Okay, we must move on. Simon Wright.

Q185 Simon Wright: Thank you. We heard evidence that certainly in some parts of the country, wildlife crime officers are increasingly taking on more general policing duties, rather than focusing on wildlife crime full-time. I wonder whether you believe that this is the most sensible use of specialised resource.

Richard Crompton: First of all, I wouldn’t agree that there is evidence to show that that is happening at what I would consider to be a disturbing level. Two or three years ago, I have to admit I did anticipate that we would see a reduction in the number of wildlife crime officers. I am glad to say that to date we have not seen that reduction. In some forces, we have seen some reductions, but in fact, in other forces, we have seen an increase in the number of specialist officers put to that purpose, and it has basically evened out across the country. What has happened, and I think this is a positive, good move, is that wildlife crime officers are increasingly being seen as wildlife/environmental crime officers, so perhaps they will be dealing with the Environment Agency in relation to fly-tipping, illegal dumping of waste and that sort of thing. They are wildlife crime/rural crime officers more generally. To link it back to the question about hare-coursing, your average hare-courser will also be your average rural criminal as well; the two things are different sides of the same coin, so it does make operational sense for officers to look at it through that lens rather than just the wildlife crime lens.

Q186 Simon Wright: What about the attitudes of senior police officers not directly involved in wildlife crime themselves, and the allocation of scarce resources towards wildlife crime? Is that one of the motivating factors behind different forces taking a different approach to the numbers of officers they allocate for these tasks?

Richard Crompton: It is, I think, one of the crucial questions, and if I have been able to achieve anything over the past few years, I think it has been to shift that general opinion of wildlife crime as being a bit of a niche area. In the past, the feeling was, "We would love to do something more about it, but when we are dealing with all these other more important things in relation to policing, we have to make decisions and prioritise our resources and wildlife crime is going to suffer as a result". What we have been able to demonstrate increasingly over the past few years is the linkage between wildlife crime and other aspects of what you might call more conventional or mainstream crime, quite frequently serious and organised crime, again reflecting your previous witness’s comments.

Some wildlife crime, by definition, is absolutely serious and organised. The potential financial gain is huge. It is organised on a professional basis and as has been said, wildlife is a commodity, and that commodity could be drugs, it could be cigarettes, it could be people. It just happens to be wildlife, because there is a significant return. That has been demonstrated more clearly. At the other end of the spectrum, we have people who perhaps engage in badger-baiting, that sort of crime, and the profile of those individuals quite often fits the profile of fairly serious criminals, so they will be carrying out all sorts of crime, not always, but frequently in rural areas, whether that is the theft of high-value plants and machinery from farms, theft of diesel, that sort of thing. They will frequently fit the profile and be the team who go out and do a bit of badger-baiting on their day off.

Q187 Simon Wright: A quick question. I wonder whether you had any thoughts on the risks and opportunities posed by the introduction of elected Police and Crime Commissioners, and what in the run-up to November you would like to hear from candidates for those positions?

Richard Crompton: It is a pretty broad question; I had better be specific in my answer. In relation to wildlife crime, I suppose both-

Chair: Just in relation to wildlife crime.

Richard Crompton: Yes, absolutely. There are some potential advantages, but also a risk as well, depending on different factors, I suppose. I think in some areas, an astute candidate would probably be talking to their rural communities, finding out that things like hare-coursing and so on are a real local concern and having something to say about that in their campaign, and picking up on what I consider to be a real depth of public concern more generally about wildlife crime. However, on the other side, there is, I think, a risk that both Police and Crime Commissioners, and also Chief Constables in the years to come, have to make increasingly difficult decisions about how to spend their money, prioritising different things. Some tough decisions will have to be made, and there is a risk, undoubtedly, that the resources that are put to wildlife crime could be put at risk as a result.

Simon Wright: Thank you.

Chair: We must move on now.

Q188 Paul Uppal: I will try to be very brief. I just want to give you a bit of power here in terms of resource allocation. I am sorry, I know we have discussed this already in previous questions, but in terms of where you think the line is on this, we spoke about specialism versus a generic raising of awareness, and you highlighted that issue. You also mentioned we get a pretty good bang for our buck here. In your perception, do you have any particular view in terms of where the line should be drawn in the balance in this? I mean allocation specifically more in terms of equipment, awareness or just your view on that; a generic sort of view.

Richard Crompton: Okay. I think we are on the right trajectory in terms of addressing wildlife crime. Things are done more professionally today perhaps than they have ever been, and that is as a result of the changes that we have heard about in part of the evidence that has been submitted. One of the areas where undoubtedly there is a rich seam of intelligence about criminal activity that we are largely unaware of is of course in relation to internet-related criminality, and we have been on the cusp of being able to appoint a member of staff to explore that area for us. I think that is one of the areas where we do have to make some significant strides, but there is an additional risk that comes with that. We are already at a point where our ability to action intelligence is very constrained because the resources that are available to us, and I would not want us to or would not want policing and the partners involved to get into a position where we were able to harvest huge amounts of additional intelligence through the internet or other sources if we were not in a position to prioritise and action that intelligence through operations to bring people to justice.

Q189 Paul Uppal: The Wildlife Crime Unit seems to get a lot of kudos, particularly in terms of the Wildlife Crime Intelligence Unit, which it replaced in 2006. Any particular reason for that, do you think?

Richard Crompton: It was before my time, and I am purely going on anecdotal evidence. The previous unit was part of what was then NCIS, the National Crime Intelligence Service, and the decision was taken to create a stand-alone unit at the same time by my predecessor in the ACPO position, Richard Brunstrom. Many of the partners were engaged in both funding the unit and in setting priorities for enforcement activity by police and other enforcers right across the country. A number of things have happened over the past few years that have developed an extremely strong partnership, the Partnership Against Wildlife Crime, PAW, that you will have read about, together with a stand-alone National Wildlife Crime Unit, which although it is very small and at some levels quite poorly resourced, has nonetheless been able to become the focal point, absolutely focusing upon wildlife crime as opposed to perhaps a very small unit in a much bigger organisation that perhaps was not able to give that same degree of focus and attention. That would be my suspicion, I think.

Q190 Paul Uppal: A final brief point. We have had this development of the Royal Society for the Protection of Animals providing funding for the Met. What is your particular view on that?

Richard Crompton: My particular view-I cannot say it is an ACPO view; I suspect there isn’t an ACPO view at the moment on this-is that I am fully in favour of it. I think that we are rapidly entering into an environment where we will have to be more creative about seeking funds from elsewhere. The bottom line for me, the thing that has to be in place if we are going to exploit that sort of external funding, comes with the governance. In other words, there will always be a suspicion that people will buy your resource to do what is number one of their priorities, as opposed to what it should be. So as long as the governance and the protocol is in place, then I think we should be moving into that sort of partnership.

Paul Uppal: Fine. You have answered the next bit. That is fine.

Q191 Caroline Lucas: You touched a moment ago on the importance of the National Wildlife Crime Unit being a stand-alone unit.

Richard Crompton: Yes.

Caroline Lucas: I know ACPO’s position is that it should remain that way, but would there not be an argument that if wildlife crime were included within the remit of the proposed National Crime Agency, you might get more long-term resources on a more stable basis going forward?

Richard Crompton: I absolutely agree, and I have to say that my initial thought a couple of years ago was, "Great. This is a way of creating a long-term sustainable unit by making it part of the new agency". However, on reflection, while I think that would potentially have a very positive impact in terms of the high-end conservation, serious and organised crime aspects of this area, I am afraid the attention given by the National Crime Agency to the plight of bats or freshwater pearl mussels inevitably would be quite low, and I would understand it. So my concern would be if you put the unit wholly into the National Crime Agency, it would lose its ability to look at the whole rich breadth of wildlife crime. If that happened, we would very, very quickly lose the support of many of the partners that are instrumental in our work at the moment, and I think we would also lose the support of Defra as well, who are of course very focused upon some of those other areas. So my own view at the moment, and the official view at the moment, is that we would see a future with the unit remaining separate. However, there would have to be developed-and I am sure this can happen pretty easily-some very clear tasking and co-ordinating linkages into the National Crime Agency, who would of course then be a very, very significant additional enforcement resource, well over and above that which we can call upon at the moment.

Q192 Caroline Lucas: Thank you. It seems to be my role is to be playing devil’s advocate a little bit. Just to press you a bit further on that, we have heard that organised international criminal gangs are profiting from wildlife crime.

Richard Crompton: Yes.

Q193 Caroline Lucas: Is it most effective to investigate such wildlife crime in isolation rather than considering it as part of serious and organised crime, and if it were part of the wider Crime Agency, would that not enable you to do that?

Richard Crompton: Again, I do agree with you. I think that frequently, whether it is today or next year’s world, it can be possible-or it is possible, rather-to get into the ribs of serious and organised criminals by addressing their wildlife crime criminality, as opposed to perhaps some other aspects that are more difficult, on the face of it, to address. So I think there is a tactic that is used and should be used in the future to address serious criminality through that avenue, and I think that is possible, but I would still have the same concerns that I have already expressed about putting the unit into the NCA in its entirety.

Caroline Lucas: That answer answers my next question as well.

Q194 Dr Whitehead: When we reported last time in 2004 on wildlife crime, we put a recommendation forward that what is now the National Wildlife Crime Unit should maintain a central, national database, which would record all the incidents of wildlife crime. At the time that was a pretty practical and uncontroversial recommendation, but it has not been implemented. Why is that so, in your view?

Richard Crompton: Yes. I can understand that, and on that level of course it sounds perfectly straightforward, but it takes us into the world of what are and are not recordable offences. At the moment, the national crime recording arrangements do not make the majority of wildlife crimes recordable offences. Now, if we could just pause on that for a moment, it is a matter for Government, basically through the Home Office, to say what is and what is not a recordable offence, and of course the Home Office officials work with policing to agree those things.

When the NWCU came into existence in 2006, shortly after that-sorry about the acronyms-the National Standard for Incident Recording, NSIR, was introduced, and that is the standard that we have used since in the Wildlife Crime Unit to populate the database, basically. That has taken us much further forward than we were a few years ago, so we do have a national database. It does contain a huge amount of data now in relation to incidents relating to wildlife crime, but it would be incorrect for me to say that it was a totally accurate reflection of wildlife crime across the country for a number of reasons. First, an incident is not necessarily a crime; second, it really is a constant battle in the unit to ensure the accurate submission of regular data from all forces. They are not obliged to do it; they sometimes have to have their arms twisted to do it, to be frank. There are always one or two forces at any one time who are not submitting that data.

So although we have come far further forward in this, it is not reflecting perhaps the vision that you had in 2004. There is a dilemma at the heart of that, because of course the Government could say, "Every wildlife crime is going to be recordable. We will have this ability therefore to press a button and find out exactly how many wildlife crime offences are reported, exactly how many in relation to bats, to raptors, to badgers and so on". The ACPO position, and I have to say also the Home Office position, is that we should not do that, and the dilemma relates to the additional bureaucracy that that will bring to the piece. For every additional crime that is made recordable, there is an additional level of bureaucracy that goes with it, and strategically across the wider environment, there has been an effort to reduce the number of recordable categories of crime as opposed to increase it. I think that has played into the whole history of that particular recommendation, but we are further forward today than we were then.

Q195 Dr Whitehead: Does that mean in terms of, shall we say, the interrogatability of any database that although crimes are recorded on a much better basis than was previously the case, nevertheless they may shunt into other areas in a way that is not retrievable?

Richard Crompton: Yes. To be specific, the proportion of wildlife crime offences that merit a Home Office code that can be searched against largely relate to the CITES offences, the illegal trade in endangered species offences, but they are given the sort of general code. The words have escaped me, I am afraid, but there is a general code for everything else basically, and it fits into that. So even there, we don’t have a specific code for CITES-related offences. I know the Metropolitan Police-and I suspect you will hear evidence from them at some time-have argued that there should be a specific code for CITES-related offences in order that we can be exact about the level of offending in that nature, and I think that is probably very wise. The alternative argument that I understand from the Home Office is, "Well, the figures are very, very small, so they would not be statistically helpful anyway".

Dr Whitehead: Presumably that itself would not be a great increase in bureaucracy, whatever one may think about it.

Richard Crompton: Well, we are dealing with a relatively few number of offences in that so, no, it would not be huge.

Chair: Okay, we have three further questions that we want to get in before the votes, from Martin Caton and then from Neil Carmichael.

Q196 Martin Caton: In response to Caroline Nokes’ question, you described current wildlife crime legislation as "elaborate". We know the Law Commission is currently undertaking a review of wildlife law and is supposed to report in February next year. Do you think the various pieces of legislation on wildlife crime should be consolidated into a single Act?

Richard Crompton: Yes, I do. Very briefly, the reason for that is expressed in your question, really, and we have talked about the difficulties that the average police officer will face in making sense of this. Things have been amended and amended and amended again over the years, and replaced and replaced again by different sorts of regulation. I think it is timely now and we will work with the Law Commission to recodify that, and I think that will work to everybody’s advantage.

Q197 Martin Caton: Thank you very much. Your ACPO written evidence mentioned the introduction of the concept of vicarious liability for offences involving raptor persecution in Scotland and suggested it might be useful to be applied in England and Wales. Would this concept help to overcome the difficulty of securing evidence of raptor persecution?

Richard Crompton: I think the evidence says that we should monitor it and look at it with great interest, because it may be something that will be helpful in England to address the raptor persecution problem. I have spoken to both police officers and to the judiciary in Scotland, and they will all say at the moment, anecdotally, there seems to be a very positive impact of that new aspect of legislation, but they would also say that it is too early to say whether there is going to be a real impact. My gut feeling as a consequence of those discussions is that it would be helpful to raise the degree of responsibility to the most appropriate level among those who are involved in the persecution of raptors.

Q198 Martin Caton: We took evidence from a representative of the gamekeepers, and he has certainly been concerned that law-abiding gamekeepers might suffer from this.

Richard Crompton: Yes, and again, I have worked and others now work with the Gamekeepers Association on this, and I know there are different views. I would say that any gamekeeper who is not in the business of illegally persecuting raptors would have absolutely nothing to fear from that particular piece of legislation.

Martin Caton: Thank you very much.

Q199 Neil Carmichael: Hello there. I was wondering if Natural England, the Environment Agency and the Border Agency were using their civil enforcement powers in a sufficient and robust way and what your thoughts were.

Richard Crompton: First of all, to be fair and even-handed, I know that Natural England have fairly recently launched some prosecutions using their powers in that respect, but I think the answer-and from your question, I suspect you know it already-is that there has not been a huge take-up of those new powers. I suspect almost certainly that comes down not to a lack of will, but to a lack of resources and perhaps different priorities, and an expectation that if it is enforcement, then it should more often than not be done by policing anyway. So I don’t think there has been a huge take-up. I would love to see a situation where there was a greater take-up of those powers. I have to say, I do understand the difficulties that those agencies face.

Q200 Neil Carmichael: Just on that, is there a sort of clear line of differentiation between the role of the police and those three agencies?

Richard Crompton: Well, yes, in the sense that I think with all three we have protocols in place in terms of the way we work with them.

Q201 Neil Carmichael: This next question is not a plea for equality, but a plea for less crime. But it has been brought to our attention that most, if not all, of the people who are committing wildlife crime here at least are men. Is that something that you have found? Is that evidence correct?

Richard Crompton: I think bearing it in mind that we have noted that the intelligence picture and the real picture about wildlife crime is still incomplete, it is virtually without exception that wildlife crime offenders that I am aware of are, I am afraid, all men.

Q202 Neil Carmichael: So do the Partnership for Action Against Wildlife Crime outreach programmes take that point into consideration when they are reflecting on selecting a target audience? Do they take that fact, that basically it is men, into account?

Richard Crompton: Yes, in the sense that the partnership has a very significant educational arm to what it does, and of course we will target the most appropriate groups, whether they are people who are potentially offending or going to be offenders, or whether they are groups of people who might have some sort of influence over those offenders or potential offenders. So it is not quite so straightforward as saying, "Well, it just has to be targeted against men".

Q203 Neil Carmichael: Okay. Last but not least, since we have two minutes to go, is there anything that you would have done differently?

Richard Crompton: Taken a different portfolio. Crumbs-done differently? It has been a massive privilege to have had this portfolio, and I really have enjoyed the work. I would have loved to have raised the profile even more, but my objectives when I took it on was to keep the current level of enforcing at the unit and in each of the forces, and that has been achieved. I think just to extend that question very slightly and quickly, for the future, I would hope that my successor, Stuart Hyde, chief in Cumbria, would be able firstly to keep the resources, and secondly, be more proactive and aggressive really in terms of using the intelligence that we do get, because there is a huge amount of intelligence that is received that is not actioned, some work has to be done on that. Again picking up on a previous question, I think there are emerging strategies to get additional funding and additional resource through developing partnerships with others who perhaps have not been part of the funding stream in the past.

Neil Carmichael: Thank you.

Chair: I think we are bang on time; there we must end it.

Richard Crompton: Thank you very much.

Chair: Thank you very much indeed, Mr Crompton. This is an important inquiry to us, and we very much hope that the expertise that you have brought to the table today can still be used for this work in the future, so thank you very much indeed.

Richard Crompton: Thank you very much indeed.

Prepared 25th April 2012